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HomeMy WebLinkAboutPUBLIC INPUT RECEIVED SEPT 12 2022 WELLINGTON PLAZA ASSOCIATION WELLINGTON PLAZA A.SSOCIA TION 17662 Irvine Blvd,Suite 5,Tustin, CA 92780 September 12, 2022 City of Tustin Planning Commission Community Development Department Members of the City Council 300 Centennial Way Tustin, CA 92750 RE: Conditional Use Permit(CUP) 2022-0009 To the esteemed members of the City of Tustin, and specifically the Planning Commission: Please accept this correspondence from the Wellington Plaza Owners Association Board and the forty owners that comprise the Wellington Plaza Association as our opposition and objection to the granting of Conditional Use Permit ("CUP") 2022-0009 for 535 E. Vt Street, Tustin, California 92780. We are forwarding this correspondence to not only the Planning Commission but also to the Development Department and to the'City Council in order to put on notice all city elements within this decision-malting process regarding our desire to not have this use anywhere within the city of Tustin. The purpose of this letter is to inform all levels of city government of the legitimate and significant concerns of neighboring landowners, residents, business owners and tenants to advise the city on matters of safety, noise, increased crime, and the corresponding diminution in property values if the proposed new use is permitted. Wellington Plaza is a condominium office project located in five separate buildings at 505 to 515 East First Street,Tustin. The Association represents forty (40) individual assessor parcel owners who work in Tustin with many of them living in Tustin. Wellington Plaza is located contiguous to the subject property, 535 East First Street, Tustin. All forty (40) of the owners at Wellington Plaza request that the Commission deny CUP 2022-0009. EXECUTIVE SUMMARY On August 23, 2022, the Planning Commission met to address CUP 2022-0009. The applicant, California Treatment Services, a subsidiary of Acacia Healthcare, a public company traded on the NASDAQ and Atom is Investments, LLC(owner of the building at 535 E. 1st Street,Tustin, CA) requested additional time to respond to staff's questions and their public hearing was rescheduled to September 27, 2022. objections to the CUP were minimal since the City did not properly notify all those located within the required distance from the subject location. In Wellington Plaza only one owner out of 40 received notification. Most residents and businesses affected by the approval of this CUP heard about it by word of mouth and not from the city as they should have. Ifthe residents and businesses in the city are properly noticed we expect a considerable number of objections from the community at large to include residential areas all over Tustin. We expect an outflow of objections from businesses in the Downtown Commercial Core Specific Plan (DCCSP) and elsewhere in Tustin. i 1 WELLINGTON PLAZA ASSOCIATION 1.7662 Irvine Blvd,Suite 5,Tustin, CA 92780 The applicant seeks to operate a methadone treatment clinic in 10,610 sf of space consisting of the second floor at 535 E. 1St Street,Tustin,to provide active drug addicts with either a liquid or pill treatment, either option given to the addict at the time of treatment and in some cases, they are allowed to take their treatment home with them. The applicant is proposing to operate six(6)days a week,while treating close to 1,000 active addicts per week. California Treatment Services is currently operating the same facility at 2101 E. 1St Street, Santa ,Ana, CA. Their lease has not been renewed and therefore they desire to move their operation into Tustin. THE PROPOSED FACILITY IS IN NONCONFORMANCE WITH THE INTENT OF THE DOWNTOWN COMMERCIAL CORE SPECIFIC PLAN (DCCSP) The Executive Summary of the DCCSP reads as follows: "The DCCSP sets a planning and regulatory framework to preserve and enhance the planning area (in which this facility would be located) as a vital, pedestrian-friendly, and attractive commercial core in Tustin. The DCCSP seeks to attract more patrons to support and strengthen businesses in Old Town through shopping, dining, and entertainment opportunities to foster community interaction and pedestrian activity. To bring additional patrons to the planning area, the DCCSP also introduces the opportunity for mixed use residential developments in selected areas, which requires a discretionary approval process to ensure projects are high quality." The key phrase in the Vision Components of the DCCSP is "high quality". Putting 1,000 drug addicts on the streets of the Old Town of Tustin a weekly basis does not represent high quality. This facility slips through the cracks of the intent of the DCCSP by being considered part of a group in the general zoning as a medical clinic for outpatients. This clinic ford rug addicts is put on the same consideration as a dialysis clinic, a heart clinic and any other medical clinics. The plan should differentiate between medical clinics and drug addict clinics. A clinic such as this is so obviously detrimental to the entire community, not just those 300 feet from the property,that it should never even get this far in the decision process. The specific plan should carve out uses such as porn stores, sex stores and methadone drug addict clinics and other uses that shouldn't be allowed under any circumstances within the specific plan. The Planning Commission should deny the request for this CUP since it does not conform to the intent of their own DCCSP and would be a detriment to the entire city of Tustin and specifically the Did Town area. THE CREATION OF A REVOLVING DOOR OF ACTIVE DRUG ADDICTS AND MENTALLY INSTABLE CLIENTS PUTS THE OLD TOWN IN TUSTIN AND ALL RESIDENTS&BUSINESSES WITHIN THAT AREA IN DANGER As articulated above,the Commission's chief responsibilities when evaluating a request such as this are the health, safety,and general welfare of the residents of Tustin,the businesses in Tustin, the children of Tustin, and all the people working anywhere near this property. It is the city's responsibility, no matter which agency, to protect those who are already within the confines of Tustin. That is their sacred duty and to do anything less is gross negligence. The applicant anticipates pushing close to 1,000 active drug addicts through this facility on a six-day week schedule. These are unsupervised active drug addicts that will walk around the Tustin community each and every week. This is not a supervised program. They come to the clinic on their own and they leave the clinic on their own. They are not supervised to and from the clinic. This allows active drug addicts to walk the street of Tustin at will. What could possibly go wrong? This system does not get the addict clean of the substance they are using; it simply substitutes another substance. The clinic substitutes for the drug addicts drug dealer and the addict continues to be an active .addict.. We already have more than WELLINGTON PLAZA ASSOCIATION 17662 Irvine Blvd,Suite 5,Tustin, CA 92780 sufficient of these clinics in Orange County or close by. By a quick count on the internet there are at least 1E such clinics to include several in Long Beach. This is more than enough by any count. No medication that this clinic uses is safe for these addicted addicts. Medications come with a potential for risk of abuse and addiction by the addicts. The success ratio for methadone clinics is not high, in many cases less than 50%. This means after a twelve-month program the active addict is still an addict. That failed group of active addicts will be an even greater burden on the Tustin community. If the city approves this clinic in the location proposed,it will be grossly negligent in its duty to the citizens of Tustin by allowing a potential problem of major proportions to grow and fester within the community. By approving this CUP, the Planning Commission would be placing a huge liability on all the residents and businesses within the DCCSP. If any of these active drug addicts conducts an act of violence or hurts themselves within this area it is highly likely they will sue existing businesses and residents for damages, they inflicted upon themselves. It is not an exaggeration to state that allowing active drug addicts into the area will significantly reduce the quality of life within the area. The Computer Aided Dispatch Report(See Addendum A to this letter) specifically prepared for the current clinic operated by California Treatment Services located at 1101 E. 1St Street, Santa Ana, CA (only a short distance east of the proposed facility) for the period 1/1/2021 — 8/11/2022, the report shows there were.140 incidents related to their clinic in this area. These are only the reported incidents on which the police acted. Many of the incidents were Narcotic Activity; also included were transient disturbance, robbery, silent robbery, commercial burglary, hit and run,transient trespassing, theft from a vehicle, indecent exposure and terrorism. Does the city need to allow any of these criminal acts to take place on the streets of Tustin? Why would the city of Tustin promote criminal activity such as that already associated with this specific clinic in its current location not far from Tustin? in Oceanside they allowed a clinic similar to the one being proposed for Tustin. Oceanside had a huge homeless encampment that came about because a clinic such as this was allowed in the area. It took Oceanside years to clean up the area. Does the city of Tustin really want to take these risks with the health and welfare of those who live and work in Tustin by allowing unsupervised active drug addicts wandering around our streets and neighborhoods? Within the city we already have considerable crime from the homeless community. Our police force is tasked with the burden of trying to control this problem and they are losing the battle. The police are reactionary, acting after the fact, and they do not have a solution to control the problem. Just in the last week alone in Wellington Plaza, at the intersection of 1St Street and Centennial,we have had one man set himself on fire in the trash container area. In another incident three men tied the inside of the trash container doors dosed (essentially locking it) and were doing drugs. Another man was living inside a utility closet and yet another person was living on an elevated trellis balcony that is cosmetic only and surrounds the building, to walk on itis very dangerous and in no way was intended to support a human. This is the homeless activity in one week that we know of in Wellington Plaza exactly next door to 535 E, 1St Street. Females, and all people, working in the area are very nervous and continually on the lookout in this area for homeless trouble. They are very wary of what is already occurring in this area and installing an active addict clinic will only heighten all of our concerns and bring even more criminal activity to the area. With the homeless issue out of control it is hard to imagine why the city of Tustin would bring in an even worse problem of active drug addicts and allow them to wander around our city at will and add criminal activity similar to what they are already causing in Santa Ana on a daily basis. The homeless services system in Tustin is broken and allowing almost 1,00 active drug addicts per week to walk WELLINGTON PLAZA ASSOCIATION 17662 Irvine Blvd, Suite 5,Tustin, CA 92780 unsupervised on our street every week will attract more homeless to the area and will create a humanitarian crisis within our city. This approval will create additional criminal activity that our police are not equipped to handle or resolve. THE PROPOSED FACILITY WILL NEGATIVELY IMPACT NEARBY BUSINESSES BSc RESIDENTS The heading forthis paragraph is only partially true. Actually,approval of this facility will negatively impact all of Tustin, to include all its residents, its businesses, all its restaurants and all of its landowners. 'There are already enough of these types of facilities with Orange County, in fact the parent company already operates two drug related facilities in the County. There is more than sufficient clinics to support this type of issue and we certainly do not need another one,we definitely do not need one anywhere in Tustin. Once this facility is up and operating,we will experience loitering of active drug addicts in the area. Many of them will still be using drugs and they will inflict their addiction on the community. This will place the patrons of local restaurants in harm's way when they have to wade into potentially dangerous situations in order to eat, shop, or take a walk around the neighborhood. This will have the effect of causing people to stay clear of the area and people will refuse to come to restaurants in the neighborhood. The entire service industry in Tustin will be affected. The potential of active drug addicted people, some who are mentally unstable, will create a negative reputation for the area, which will soon cause current individuals in the area to stop coming to the area and will cause existing businesses to lose customers. Tustin promotes itself that people should work where they must, but Tustin wants them to live and play in Tustin, That will no longer be the case. If people are scared to come into an area because the area has become drug infested, businesses will suffer with a drop in sales and may even have to close or move. We are certain the City of Tustin would not want to see that happen in a city that is beautiful and is building our future while honoring our past. If this CUP is approved, it will damage Tustin's future and will certainly not honor our past by putting those of us who have worked hard to help make Tustin a desirable community at risk. Within the immediate vicinity is Columbus Tustin Middle School. Many of-the children have to walk by the proposed clinic on the way to and from school. Does the city really want to accept the liability of exposing children to the existence of active drug addicts on our street among the children trying to get to and from school? There are many residential communities within a few hundred-yards of this proposed facility. To name just a few there is Town Center Apartments,Tustin Plaza Apartments, Pickwick Manor Apartments, and Stonegate Apartments within a stone's throw of the proposed active drug addict clinic. Of the hundreds of businesses within this area,there are dozens of restaurants that rely on the foot traffic in the area. Over time that foot traffic will disappear, and those potential customers will find other restaurants to enjoy. The city approval of an active drug addict clinic in this area will negatively affect the lives of literally thousands of Tustin children, residents, and businesses and for this reason alone should be denied by the Planning Commission. To demonstrate how poorly planned this decision is a spokesperson for the dialysis center on the ground floor of 535 E I"Street(the active addict clinic is proposed to occupy the 2na floor of this building) did not know that this use was being considered for the second floor of the building they are already renting in. The city and the owner of the building had failed to notify them. They stated that they had moved to Tustin from Santa Ana specifically to get away from this same methadone clinic that moved into 2101 E. 15t Street near where the dialysis center used to be located. The dialysis center left.Santa Ana in-order not WELLINGTON PLAZA ASSOCIATION 17662 Irvine Blvd,Suite a,Tustin, CA 92780 to be in the same neighborhood as the methadone clinic. They felt the neighborhood would be negatively impacted. They did not want their dialysis patients mixing every day with active drug addicts. It is bad enough that people have to be subjected to dialysis treatment, but it should not be compounded by active drug addicts surrounding people who are already weakened by their condition. The dialysis treatment center felt that being around active drug addicts would be problematic for their patients. Based on the Santa Ana Police Report(attached as an addendum)regardingthe criminal activity surroundingthat clinic, almost every day,the decision by the dialysis center to move was justified. While we are all sympathetic to the mentally ill and drug addiction, the citizens of Tustin do not believe that this location is appropriate for a drug treatment clinic. There are numerous alternatives in Orange County that are already available to active drug addicted users. Putting an active unsupervised drug addiction clinic in this location will result: in changing the character of the neighborhood and eventually the entire downtown area of Tustin. As such the Planning Commission should deny CUP 2022-0009 because of its negative impact on the area and specifically local business. THIS DRUG TREATMENT CLINIC IS BEING CONSIDERED BECAUSE OF FLAWS IN THE ZONING IN THE DOWNTOWN COMMERCIAL CORE SPECIFIC PLAN This specific plan is flawed. Within its general zoning criteria, it allows for the use of a medical clinic for outpatient only. It does not differentiate between a methadone active drug addict clinic and any other land of clinic. The authors of that plan should have recognized this flaw in their plan and made corrections that slid not allow an active drug addicted clinic as a use under any circumstances. They cannot directly get approval but according to the way the plan is written they can obtain approval through the CUP process. The Planning Commission hands may be tied since they have no discretion but to follow the way the zoning in the specific plan was written. This DCCSP should specifically deny the approval of a drug addict clinic, a methadone clinic, or any clinic that dispenses any medication to active drug addicts or anyone else. To point out how flawed this specific plan is in 2017 a sports physical therapist who had his office on Fl Camino Real for many years, decided he wanted to move into Wellington Plaza. This was a use that was compatible to the specific plan and to the Wellington Plaza CC&R's. This sports therapist had only himself in the office at any time and one patient at a time. The Planning Commission worked on his request for months and finally rejected it stating he impacted the parking in Wellington Plaza. His suite would have been 700 sf and based on his program he and his patient would have been the only two people in the suite at any given time, so they would be using two parking spaces. They strung his request along for so long that he finally gave up and moved to Santa Ana. He was already operating a good business in the city of Tustin, and they rejected him. There are many horror stories regarding perfectly good uses that have been denied or delayed by the Planning Commission. it is hard to imagine how they can now be giving serious consideration to an active drug addict clinic. A clinic that has no business even being considered within the business area of Tustin. This shows the inconsistencies when small business owners with a legitimate quality business are denied by the city while a multi-million-dollar operation is given consideration that should never be forthcoming. This is not simply a technical issue that can be approved or disapproved by the Planning Commission based on the zoning allowed in the DCCSP. A more important aspect of the decision requires the city to use some good judgment in deciding what is right and proper for those who already reside within the city limits and those who work in Tustin and also those who own property within the city. Should the Planning WELLINGTON PLAZA ASSOCIATION 17662 Irvine Blvd,Suite 5,Tustin, CA 92780 Com rnission ignore their responsibilities to the overall current population within Tustin and approve this CUP then they will be guilty of gross negligence as it applies to the existing population already in Tustin. The Planning Commission will be working against the best interests of the community and the city. By allowing these clear flaws to exist in the DCCSP the city has placed the burden on the residents and the business owners of Tustin to step up and point out to the city that what they are considering should never even get this far in the planning process and should be denied. This is a tragedy that this is allowed to happen because the DCCSP has flaws in it that is allowing this type of active addict clinic to be considered. It should be in the same category as porn stores, sex shops, and other uses that should be immediately rejected. The Planning Commission should not have to give any thought, consideration or time to this type of use in our quality city. This type of use should never be considered under any circumstances, and the Planning Commission should deny the CUP. NOTICE The City of Tustin's Municipal Ordinance is constitutionally deficient in terms of its notice period. Further, the actual notice was not received by most of the businesses within 300 feet of the proposed facility,this is a major deficiency in the cities notice procedures, since the same thing happened when they proposed the DCCSP. It almost appears as if the Planning Commission is trying to sneak this CUP approva{ through without the citizens of Tustin ever being aware of it. Hardly anyone within the designated area was noticed as to the hearing. The Tustin city notice system is flawed and needs to be reviewed and fixed so that every business within the control area is notified. In fact,an issue of this magnitude needs to have a greater than 300 feet notification distance since a user such as this active drug addicted addict's clinic affects the entire community, not just the small area of 300 feet surrounding 535 E 11t Street. The burden is on the city to ensure people are properly noticed. It should not be on the citizens of Tustin. The actual notice given to residents and businesses in the designated area failed to comply with both the Municipal Code and the constitutional due process requirements. CONCLUSION Approval of the Conditional Use Permit 2022-0009 presents a serious danger to the health,welfare,safety, morals, comfort and the general well-being of people living within Tustin and residing or working within proximity to this proposed location. As such, the Wellington Plaza Association Board and all forty(40)assessor parcel owners of Wellington Plaza Office'Condominium Association, owners of the property adjacent to the proposed property, unequivocally state that the: CUP 2022-0009 SHOULD BE DENIED IN 17S ENTIRETY. Sincerely, Wellington Plaza Association Board of Directors Dani Webe ian 8. 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