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HomeMy WebLinkAboutPC Findings-APPROVED w-Attach LU 18-0034APPROVED: 05/13/2019 LU 18-0034-1975 Page 1 of 7 BEFORE THE PLANNING COMMISSION 1 OF THE 2 CITY OF LAKE OSWEGO 3 4 A REQUEST TO AMEND CHAPTER 50 COMMUN- ) LU 18-0034 – 1975 5 MUNITY DEVELOPMENT CODE OF THE LAKE ) (CITY OF LAKE OSWEGO) 6 OSWEGO CODE FOR THE PURPOSE OF ALLOWING ) FINDINGS, CONCLUSIONS & ORDER 7 SHORT-TERM RENTAL LODGING IN ZONES WHERE ) 8 TRANSIENT LODGING (HOTELS) ARE NOT CUR- ) 9 RENTLY ALLOWED; DELETING “BED & BREAKFAST” ) 10 FROM PARKING TABLE 50.06.002-3. ) 11 12 13 NATURE OF APPLICATION 14 15 The City of Lake Oswego is requesting legislative approval of changes to Chapter 50 Community 16 Development Code of the Lake Oswego Code for the purpose of allowing Short-Term Rental 17 Lodging (STRs) in zones where transient lodging (Hotels) are not currently allowed; and deleting 18 “Bed & Breakfast” from Parking Table 50.06.002-3. 19 20 HEARINGS 21 22 The Planning Commission held a public hearing and considered this application at its meetings 23 on April 22, 2019 and May 13, 2019. The following information was submitted following 24 publication of the March 11 Planning Commission Staff Report or presented to the Commission 25 at its April 22 hearing and added to the record: 26 Exhibit G-1 Letter from Kevin and Nora Semonsen, 03/13/19 27 Exhibit G-2 Email from Steve Unger, 04/01/19 28 Exhibit G-3 Email from Dr. Sharon Buckmaster, 04/10/19 29 Exhibit G-4 Email from Diana Boom, 04/11/19 30 Exhibit G-5 Email from Ana Rose, 04/11/19 31 Exhibit G-6 Email from David Dorr, 04/12/19 32 Exhibit G-7 Email from Todd Schwartz, 04/12/19 33 Exhibit G-8 Email from Shelly Kintzinger, 04/17/18 34 Exhibit G-9 Letter from Mark Rockwell, 04/18/19 35 Exhibit G-10 Letter from Ryan Kovac, 04/18/19 36 Exhibit G-11 Letter from Dianne Cassidy, 04/19/19 37 Exhibit G-12 Letter from Christopher Wojda, 04/19/19 38 Exhibit G-13 Letter from Debi Hertert, 04/22/19 39 Exhibit G-14 Letter from Housing Land Advocates and Fair Housing Council of Oregon, 40 04/22/19 41 42 43 APPROVED: 05/13/2019 LU 18-0034-1975 Page 2 of 7 CRITERIA AND STANDARDS 1 2 A. City of Lake Oswego Comprehensive Plan 3 Community Culture – Civic Engagement, Policies 1, 2, 4 and 5 4 Land Use Planning – Development, Policy A-1(b) and A-1(c) 5 Land Use Administration, Policy D-1 6 Inspiring Spaces and Places – Goal 1, Policy 7 7 Complete Neighborhoods and Housing, Policy B-1, B-4, and C-6 8 Economic Vitality, Policy A-7 9 10 B. City of Lake Oswego Community Development Code 11 LOC 50.07.003.16.a Legislative Decisions Defined 12 LOC 50.07.003.16.c Required Notice to DLCD 13 LOC 50.07.003.16.d Planning Commission Recommendation Required 14 LOC 50.07.003.16.e City Council Review and Decision 15 16 CONCLUSION 17 18 The Planning Commission concludes that the recommended Code Amendments in Attachment 19 2 (dated 05/13/2019) of proposed Ordinance 2815 are in compliance with all applicable criteria. 20 21 FINDINGS AND REASONS 22 23 The Planning Commission (Commission) incorporates the staff report, dated March 11, 2019 24 (with all exhibits attached thereto), supplemented by the further findings and conclusions set 25 forth herein. In the event of any inconsistency between the supplementary matter herein and 26 the staff report, the matter herein controls. 27 28 Following are the supplementary findings and conclusions of this Commission: 29 30 1. The Commission received oral and written testimony (Exhibits G-9, G-10, G-12) opposed 31 to some or all of the following limitations on STRs in the public hearing version of the 32 draft code amendments (Attachment 2 to Ord. 2815, dated March 7, 2019): 120 nights 33 per calendar year, owner on-premises, 25% of floor area, no rental of all bedrooms, and 34 six guests. The testimony argued that some or all of these limits are unnecessary 35 because the existing Home Occupation standard – to which the STR limitations are being 36 added – states the requirement that Home Occupations shall not “alter the residential 37 character of the neighborhood nor infringe upon the right of residents in the vicinity to 38 the peaceful enjoyment of the neighborhood“ [LOC 50.03.004.1.b.ii(1)], and that 39 together with the proposed STR parking requirement and existing non-land use 40 nuisance, fire code, and traffic regulations, are sufficient to control the impacts of STRs 41 and maintain the residential character of neighborhoods. No applicable Comprehensive 42 Plan policy was cited. 43 44 APPROVED: 05/13/2019 LU 18-0034-1975 Page 3 of 7 The Commission notes the Land Use Planning Chapter of the Comprehensive Plan, Policy 1 A-1(b) and (c), states: “Promote compatibility between development and existing and 2 desired neighborhood character; [and] ... Minimize and/or mitigate adverse traffic 3 impacts generated by new development on adjacent neighborhoods.“ 4 5 The Commission finds that the above proposed limitations on STRs — 120 nights per 6 calendar year, requiring a dwelling resident on-premises at night, 25% of floor area, and 7 six guests — and the existing Home Occupation standard of LOC 50.03.004.1.b.ii(1) will 8 minimize traffic, parking and other impacts on neighborhoods and promote 9 compatibility, complying with Policy A-1. 10 11 Under the proposed STR provisions in Attachment 2, the limitations on number of 12 nights, floor area, and number of guests may be adjusted or waived with approval of a 13 conditional use permit. The applicant would be required to meet the conditional use 14 criterion that: “The functional characteristics of the proposed use are such that it can be 15 made to be reasonably compatible with uses in its vicinity” [LOC 50.07.005.3.a.iv], and 16 all other conditional use criteria. The conditional use permit procedure requires 17 neighborhood contact and a public hearing, ensuring public/neighborhood comment on 18 compatibility before a permit is approved that adjusts or waives the STR limitations on 19 number of nights, floor area, and numdber of guests, and authorizes the review body to 20 impose conditions of approval to mitigate any adverse impacts on the neighborhood, 21 including traffic and parking; therefore, Policy A-1 is met for the STR adjustments or 22 waivers. 23 24 The Complete Neighborhoods and Housing Policy C-6 similarly is met to allow STRs with 25 limitations, as the Commission finds that the recommended STR code amendments 26 “Implement[s] home occupation standards to regulate home-based businesses 27 (occupations) to provide business development opportunities while preventing adverse 28 impacts on residential areas.“ 29 30 2. The Commission received oral and written testimony (Exhibit G-11) that STR lodging is a 31 commercial use and therefore conflicts with purposes of the City’s residential zones 32 under LOC Chapter 50 Community Development Code. The testimony argues that 33 allowing STRs is akin to allowing “Auto Repair“ in neighborhoods. Testimony also stated 34 that allowing STRs as a type of commerical use within a residential zone, was a 35 “regulatory taking“ of nearby residences. No applicable Comprehensive Plan policy was 36 cited. 37 38 The criteria for a legislative amendment is to comply with applicable state law, 39 statewide planning goal or administrative rule, and applicable provisions of the 40 comprehensive plan. [LOC 50.07.003.15.b]. The Commission finds the Comprehensive 41 Plan, Complete Neighborhoods and Housing Chapter, Policy C-6, cited in Finding #1, 42 above, accommodates limited commercial uses in residential zones, specifically Home 43 Occupations; in compliance with LOC 50.03.004.1.b.ii; Home Occupation is: “A lawful 44 APPROVED: 05/13/2019 LU 18-0034-1975 Page 4 of 7 use conducted in a residential zone in or on the premises of a dwelling unit, said use 1 being secondary to the use of the dwelling for dwelling purposes.” 2 3 The Commission finds that the STR regulations in proposed LOC 50.03.004.1.b.ii(7) 4 ensure that a lot containing an STR is used primarily for residential purposes – the STR 5 must be secondary to the residential use. The argument that STRs are similar to Auto 6 Repair, and that Auto Repair would not be a permissible use in a residential zone, is not 7 valid because Auto Repair that meets the criteria for a Home Occupation (“does not 8 alter the residential character of the neighborhood nor infringe upon the right of 9 residents in the vicinity to the peaceful enjoyment of the neighborhood... [no] outside 10 storage of goods or material“ [repair is inside a garage], etc.) would be permissible. 11 12 Even if the residential zone purpose provisions were criteria for this legislative 13 amendment, which they are not, allowance of home occupations in the residential zone, 14 including STRs, is not contrary to the purpose of providing lands for single-family 15 development with certain densities per gross acre. LOC 50.02.001.1.b, .2.b, .3.b. The 16 STR home occupation is a type of accessory use within a dwelling and does not displace 17 the opportunity for single-family development with the requisite densities per 18 respective zone. 19 20 The Commission finds that allowing STRs as a home occupation in a dwelling within a 21 residential zone is not a regulatory taking because: (a) the use of a dwelling to include 22 an STR as accessory to the primary residential use is an expansion rather than a 23 limitation of the uses on the subject real property; (b) providing for the opportunity of a 24 neighbor to conduct an STR within their dwelling is not a restriction of use of any other 25 property; (c) home occupations are currently permissible within residential zones, as 26 long as there is no alteration of the residential character of the neighborhood, and the 27 same remains true by allowing STRs as home occupations; and (d) there is no evidence 28 that the neighbor’s conduct of an STR within their dwelling will preclude all (or nearly 29 all) economic use of the real property adjacent to the STR. 30 31 Therefore, the Commission finds that the code may be amended to allow STRs as a 32 home occupation, consistent with the above cited Policy C-6. 33 34 3. The Commission received testimony from Housing Land Advocates and the Fair Housing 35 Council of Oregon (HLA-FHCO) (Exhibit G-14). HLA-FHCO, citing ORS 197.175(2)(a) and 36 Statewide Planning Goal 10, request the Commission defer action on LU 18-0034 until 37 Goal 10 findings can be made and the proposal is evaluated under the City’s Housing 38 Needs Analysis and Buildable Lands Inventory. 39 40 The Commission finds that the applicable Goal 10 policies are contained in the Complete 41 Neighborhoods and Housing Chapter of the Lake Oswego’s State-acknowledged 2013 42 Comprehensive Plan. The Staff Report dated March 11, 2019 addresses the City’s 43 Buildable Lands Inventory and Housing Needs Analysis, as follows: 44 APPROVED: 05/13/2019 LU 18-0034-1975 Page 5 of 7 1 Policy B-1: Provide and maintain zoning and development regulations that allow the 2 opportunity to develop an adequate supply and variety of housing types, and that 3 accommodate the needs of existing and future Lake Oswego residents. 4 5 Findings: The proposed amendments are designed to allow for changes in the market 6 and flexibility in lifestyle choice for residents by allowing STRs under a Social Model 7 (home-sharing) that welcomes guests to the community while maintaining the 8 primary use of dwellings as residential. By allowing STRs as an accessory use subject 9 to Home Occupation (and supplemental standards), the City maintains the ability to 10 meet the needs of existing and future residents. 11 12 The Commission finds that Goal 10 has been addressed and the proposal has no effect 13 on land supply or the City’s ability to meet its housing needs. Specifically, by limiting 14 STRs to only a portion of a Single Family dwelling, or an Accessory Dwelling Unit (ADU), 15 and requiring a primary resident be on the premises during the rental (“home-sharing“), 16 the City maintains its supply of housing and the proposal has no effect on the City’s 17 inventory of buildable lands. The City’s Housing Needs Analysis and Buildable Lands 18 Inventory (2013 Comprehensive Plan, Appendix; Ordinance 2060, Exhibit 4) does not 19 assume any production of ADUs, even though City code allows ADUs and ADUs have 20 been built in Lake Oswego. Further, no empircal evidence has been been provided 21 indicating that housing prices or rental rates (housing affordability) in Lake Oswego 22 would be affected by allowing STRs under the proposed home-sharing model. The 23 Commission did received testimony, albeit anectdotal, that the supplemental household 24 income that STRs may provide can assist homeowners with remaining in their homes, 25 particularly for those on fixed incomes or who have experienced unemployment or 26 similar life changes. 27 28 4. The Commission received testimony separately for and against allowing STRs in 29 dwellings other than those on single family lots. (“Option 2“ STR definition in 30 Attachment 2 to Ord. 2815, dated March 7, 2019). The Commission finds that the STRs 31 should be limited to single-family dwelling lots because lots containing other dwelling 32 types, such as Duplex, Townome, and Multifamily, typically have less site area per 33 dwelling unit than single-family dwelling lots and may not have sufficient space to meet 34 the proposed STR parking requirement. The Commission further finds that resident 35 occupancy in the dwelling where the STR is located assures that the residential 36 character of the dwelling itself, and of the surrounding neighborhood, is maintained, per 37 Policies A-1 and C-6 cited above. The Commission also finds that short-term subletting 38 of multiple dwellings in a multifamily development, with no requirement that a resident 39 reside in the dwelling where the STR is located, could create defacto Hotels, which 40 would be contrary to the above policies to maintain neighborhood character and 41 preventing adverse impacts on residential areas. The Commission notes defacto Hotels 42 would be contrary to the purposes of the residential zone. 43 44 APPROVED: 05/13/2019 LU 18-0034-1975 Page 6 of 7 5. The Commission received oral and written testimony (Exhibits G-4 and G-11) that STRs 1 should not be allowed because the City would not have capacity to enforce the 2 regulations; no applicable Comprehensive Plan policy was cited. The Commission finds 3 that code enforcement is a staffing/resource issue, not a land use issue. Ultimately the 4 City Council must consider the budgetary implications of any new policy and 5 theresources required to enforce new regulations. 6 7 6. The Commission received testimony opining that allowing STRs leads to unsafe buildings 8 and conflicts with handicapped accessibility requirements (Exhibit G-11). No empircal 9 evidence or applicable Comprehensive Plan policy was cited. 10 11 12 The Commisson finds that the issues of building safety and accessibility are regulated 13 through the Building Code (and limiting STRs to lots with single-family dwellings, not 14 commerical or multifamily buildings, the Oregon Residential Structural Speciality Code 15 will be the applicable Building Code for one- and two-family dwellings). The Building 16 Code is set by the State of Oregon and administered by the City Building Official under 17 LOC Chapter 45. The Commission finds that building regulations are not land use 18 regulations and therefore outside its purview. 19 20 7. The Commission received testimony relating to business considerations and limitations 21 in the operation of an STR, e.g, liabilities and insurance, mortgage limitations, taxes, 22 fees, online advertising limitations. The Commission finds that per the criteria for 23 legislative amedments to the Community Development Code, LOC 50.03.007.15.b, the 24 scope of this Commission’s review and recommendations is the land use impacts of the 25 use. Similar to commerical uses and other other types of home occupations within Lake 26 Oswego, business operation considerations, such as how much insurance to have and 27 how to pay taxes on the income from the operation of an STR, is beyond the scope of 28 review and recommendations of amendments to the Community Development Code. 29 30 8. Sunset Provision. The Commission recommends to the Council that, with the exception 31 of the repeal of “bed and breakfast“ from Parking Table 50.03.002-3, the STR code 32 amendments be repealed automatically three years from their effective date unless the 33 Council acts to extend or remove the repeal provision, so that the Planning Commission 34 and City Council can review the effects of STR operations upon the neighboring 35 properties in order to determine if addtional limitations should be imposed, limitations 36 removed, or otherwise modify the STR standards, or to extinguish the opportunity to 37 conduct STRs within dwellings, all to assure that Policies A-1 and C-6 are met. 38 39 40 APPROVED: 05/13/2019 LU 18-0034-1975 Page 7 of 7 ORDER 1 2 IT IS ORDERED BY THE PLANNING COMMISSION of the City of Lake Oswego that: 3 4 1. The Planning Commission recommends that proposed Ordinance 2815, with Attachment 2 5 (05/13/2019) [LU 18-0034] be approved by the City Council. 6 7 I CERTIFY THAT THIS ORDER was presented to and APPROVED by the Planning Commission of 8 the City of Lake Oswego. 9 10 11 DATED this 13th day of May, 2019. 12 13 14 Robert Heape 15 Robert Heape, Chair 16 Planning Commission 17 18 19 ATTEST: 20 21 ADOPTION OF FINDINGS AND ORDER - May 13, 2019 22 23 AYES: Baker, Beckett, Hansen, Heape, Papé 24 NOES: Ward 25 ABSTAIN: None 26 EXCUSED: Puhlman 27 DRAFT: 05/13/19 PC Recommendation LU 18-0034 (Ordinance 2815) ATTACHMENT 2/PAGE 1 OF 6 Amendments shown in bold underline text for additions and strikeouts for deletions. The commentary in text boxes is not part of the code and will be removed before ordinance enactment. LOC 50.10.003 DEFINITIONS // 2. Definition of Terms Short-Term Rental Lodging The offering of one or more bedrooms (and use of any common area) on a lot containing a single-family detached dwelling for transient residential purposes to serve paying guests for periods of 30 days or less. Comment: This definition would make STRs accessory to a Single-Family Residential use and limit STRs to detached single-family dwellings and accessory dwelling units. This would avoid conversion of apartment or condominium buildings into de facto hotels, i.e., where multifamily residential is allowed but hotels are not. In response to the online community survey on the short-term rental issue conducted by the City during June 2018, accessory dwelling units were most often cited as the dwelling type that would be appropriate for STR lodging. Hotel or Motel A building or group of buildings used for transient residential purposes containing rental units which are designed to be used, or which are used, rented or hired out for sleeping purposes, including associated retail uses within the hotel or motel intended to serve paying guests but not including short-term rental dwellings. Comment: The definition of Hotel/Motel (commercial use limited to commercial zones) is amended to set it apart from STR lodging, which this draft proposes to allow as an accessory use to a dwelling. Residence, Primary A dwelling where a person lives most of the time. At a given time, a person does not have more than one primary residence. For purposes of determining whether a dwelling is a primary residence, the City may consider whether the dwelling is the legal residence of an individual for purposes of voting, motor vehicle / driver ATTACHMENT 2 (Ordinance 2815) LU 18-0034 DRAFT: 05/13/19 PC Recommendation LU 18-0034 (Ordinance 2815) ATTACHMENT 2/PAGE 2 OF 6 licensing, income tax calculation, the time the person spent at the residence, and other such factors. Comment: Under the proposed short-term rental regulations [LOC 50.03.004.1.b.ii(7)(e), an individual who makes the dwelling their primary residence would have to be on the premises during specified hours when the unit is rented. LOC 50.03.002 USE TABLE 2. RESIDENTIAL USE TABLE TABLE 50.03.002-1: RESIDENTIAL DISTRICTS USE TABLE P = Permitted Use | Blank = Not Permitted | C = Conditional Use | A = Accessory Use [x] Table notes located at the end of the table Use Category Use Type Residential Use-Specific Standards R- 15 R- 10 R- 7.5 R-6 R-5 R- DD R-W R-3 [3] R-2 R-0 [3] [4] ACCESSORY USES Accessory Uses Community garden A A A A A A A A A A 50.03.003.6.j Home occupation A A A A A A A A A A 50.03.004.1.b.ii Short Term Rental Lodging [5] A/C A/C A/C A/C A/C A/C A/C A/C A/C A/C 50.03.004.1.b.ii ///// Accessory dwelling unit A A A A A A A A A 50.03.004.1.b.vi Notes: [1] Erected on pilings over the water of Oswego Lake. [2] No commercial activity allowed. [3] If lot has multiple zones, e.g., R-0/EC, see LOC 50.02.002.2.e. [4] Site-specific use limitations, see LOC 50.02.002.2.c. [5] May exceed floor area, single transient guest booking, number of overnight stays, and number of transient guests of LOC 50.03.004.1.b.ii(5), and/or (7)(a, b, d) with Conditional Use Approval. Comment: This table allows for use of a portion of permitted dwelling unit in the zone as an accessory use (type of home occupation) and that meets the definition of Short Term Rental Lodging in residential zones. It also designates which Home Occupation standards in LOC 50.03.004.1.b.ii can be exceeded by Conditional Use Permit. DRAFT: 05/13/19 PC Recommendation LU 18-0034 (Ordinance 2815) ATTACHMENT 2/PAGE 3 OF 6 LOC 50.03.004 ACCESSORY STRUCTURES AND USES 1. Accessory Uses // b. Standards for Specific Uses ii. Home Occupation A home occupation may be conducted where allowed by other provisions of this Code if the following conditions are continuously complied with: (1) The use does not alter the residential character of the neighborhood nor infringe upon the right of residents in the vicinity to the peaceful enjoyment of the neighborhood. (2) A current and valid business license is maintained. (3) No employeespersons other than family members who reside at the dwelling may be employed or otherwise work in the home occupation, except persons performing housekeeping, yard maintenance, or other domestic services for the dwelling where the short-term rental lodging occurs. Comment: This would allow employment of housekeeping, yard maintenance, or other domestic employees who may help maintain or operate a STR. (4) No outside storage of goods or materials other than vegetation. (5) No more than 25% of the aggregate floor area on the lot is devoted to nonresidential use; an accessory structure may be used provided the provisions of this subsection are met. Comment: Where a portion of a dwelling is to be used for STR lodging, floor area would be calculated based on the floor area of rented bedrooms, except where lodging is in an accessory dwelling, in which case the total floor area of the ADU would be counted. Where the STR would use more than 25% of aggregate floor area on the lot (a higher intensity use that increases the risk that residential character could be harmed) a conditional use permit is required. Floor Area is the gross building floor area excluding attics, vent shafts, courtyards, garages, allowable projections (e.g., bay window), decks, patios, uncovered exit stairs, and uncovered above-grade driveways. (LOC 50.10.003.2) DRAFT: 05/13/19 PC Recommendation LU 18-0034 (Ordinance 2815) ATTACHMENT 2/PAGE 4 OF 6 (6) Marijuana facilities are prohibited. Comment: Short-term rental lodging in a dwelling is not a “marijuana facility,” so this standard would be automatically met. [Ord. 2689 bans all marijuana facilities in the City, and the voters approved continuation of the ban on Nov. 8, 2016.] (7) Short-term rentals shall meet the following additional standards: (a) No booking or guest stay shall occur for more than one transient lodging at a time on the lot, i.e., one guest may rent multiple bedrooms but two separate guests may not each rent a bedroom for use on the same lot at the same time. (b) The number of guest stays on the lot shall not exceed 120 nights in a calendar year. (c) The number of bedrooms rented at any one time shall not exceed the total number of bedrooms on the lot minus one. (d) The total number of transient guests in the dwelling shall not exceed 6, regardless of the number of bedrooms. (e) An individual who makes the dwelling their primary residence shall be on the premises during the hours of midnight to 6:00 AM when a short-term rental guest is present. Comment: To ensure that the “residential character” and “peaceful enjoyment of the neighborhood” are maintained, an individual who makes the property their primary residence shall be on the premises during specified hours when a renter is present. DRAFT: 05/13/19 PC Recommendation LU 18-0034 (Ordinance 2815) ATTACHMENT 2/PAGE 5 OF 6 (f) No other commercial uses are allowed in conjunction with or accessory to a short-term rental. The short-term rental shall not be marketed for group events such as weddings, classes, or similar events for example. Comment: The intent of “no other commercial uses allowed” is to prohibit marketing of short-term rental properties for weddings and other large group gathering events, as this would be contrary to Home Occupation. The provision does not prohibit a second home occupation in the dwelling if (1) it is not associated with the short term rental lodging, e.g., consulting business; and (2) all other home occupation standards are met, e.g., the consulting business and the short term rental lodging collectively do not exceed the floor area limitation. The provision also does not prohibit someone from having a wedding ceremony in a short-term rental, but the unit cannot be marketed for weddings, parties, etc., or violate any other Home Occupation standard. (g) One on-site parking space shall be provided for up to every two bedrooms rented, in addition to required parking for the dwelling. The short term rental lodging parking areas shall be located to ensure they do not interfere with required parking or maneuvering areas for the dwelling. Comment: Required parking would be verified prior to issuance of a business license; or for applications requiring conditional use approval with the development review application. DRAFT: 05/13/19 PC Recommendation LU 18-0034 (Ordinance 2815) ATTACHMENT 2/PAGE 6 OF 6 50.06.002 PARKING //// 2. STANDARDS FOR APPROVAL a. Vehicle Parking //// TABLE 50.06.002-3: MINIMUM OFF-STREET PARKING SPACE REQUIREMENTS Type of Use Parking Space Required [1] ///// (A) RESIDENTIAL 1. Single-family dwelling and duplex 1 space per dwelling unit 2. Accessory dwelling unit 1 space per unit (in addition to 1 space required for main dwelling unit). See LOC 50.03.004.1.b.vi(1)(a) for siting standard. /// 4. Rooming and boarding house; bed and breakfast 1 space per each guest room plus 1 for owner (B) COMMERCIAL RESIDENTIAL 1. Hotel or motel 1 space per unit //// Comment: The Bed and Breakfast parking standard is deleted to avoid confusing Bed and Breakfast with STR, Hotel, and Restaurant, each having its own parking standard. A STR host could provide meals to their guests only (not marketed as a restaurant), provided they meet County health/food handling requirements, as applicable, and not be a Hotel or Restaurant. The parking requirement for short-term rentals is proposed to be located within the Home Occupation standards, not in the parking table, as is done for other use-specific standards.