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Commercial Self-Storage Facilities and Ord. 2187 Minor Modification Approval Criteria for Off-Street Parking Reduction
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Summary and Background Information: Commercial Self-Storage Facilities:
Over the last few years, staff has received several inquiries regarding development of self-storage facilities in commercial zone districts. The proposed facilities have been all or mostly indoor-access, climate-controlled, multi-story types of facilities with exterior appearances similar to office buildings or multi-family residential buildings. Currently, the Land Development Code (LDC) only allows self-storage facilities (mini-storage) in industrial zone districts. The purpose of this study session is to explore the possibility of expanding self-storage facilities to be allowed in the C-3 zone district subject to additional potential design standards. This change would not impact most PUDs in the Northern Range, though they could opt to amend their zoning to allow this use as well. As this is a study session only, no public comment or voting will be required Monday evening.
Based on the number of inquiries, staff has researched 16 other jurisdictions to compare how Commerce City regulates self-storage facilities, and found 11 allow self-storage in at least one commercial zone district, while 5 prohibit such facilities in commercial zone districts. Of those that allow self-storage facilities in commercial zone districts, some require an enhanced level of design (such as minimum 2-story structure, restrictions on outdoor access to units, or limiting proximity to highly-visible corridors). Several adjacent jurisdictions have allowed the commercial-style facilities to be built, including Denver (Stapleton), Thornton, and Aurora.
Some of the potential benefits for allowing self-storage facilities in commercial areas include:
• Supporting residential and commercial growth. Typical users of mini-storage include households in transition due to moving, marriage, divorce, estate management, etc.; home occupations, such as pharmaceutical representatives and direct sales; businesses storing excess inventory and supplies, such as real estate signs, stock, files, and equipment; and sports leagues with seasonal equipment like balls, goals, and protective gear.
• Locating on under-used or difficult to develop sites. Self-storage has a relatively low impact for the building size since most of it is warehouse space, so it can fit on sites that would otherwise be undeveloped due to access, utility, or similar constraints. Traffic generation is typically not a concern, the demand for restrooms is limited to the office space, and lack of need for interior finishes keeps construction costs low. Allowing difficult properties to develop also adds more to the property tax base than leaving them vacant.
• Allowing people to reclaim garages. Many people with garages tend to use them for storage rather than for parking. Providing easily accessible storage units near residential areas allows people to clear the garage space for parking vehicles or to store items that otherwise might be stored outdoors, such as a lawnmower, creating an unsightly appearance and potential code violations.
Some concerns with allowing self-storage facilities in commercial areas include:
• Taking up land that could be used for higher-priority commercial uses. Economic Development staff typically seeks commercial users who create good paying jobs and generate activity in the area to support other businesses. Self-storage facilities typically only need a few employees to manage the office and sometimes provide security at night. Tenants generally do not regularly access their storage units, resulting in few trips and lower activity than a use like a retail store or a restaurant.
• Large structures may feel out of place. While design standards can help encourage a more pedestrian-scale feeling rather than a monolithic block, self-storage structures themselves are still larger than many other commercial buildings. Even those with a higher-quality appearance are typically multiple stories, which may be out of place with adjacent surrounding development.
• Repurposing buildings for other uses. In the event that a self-storage facility closes, the opportunities for the building to house other types of uses may be limited given the size and design. Additionally, parking requirements for storage is typically lower than other commercial uses because most people only rarely need to access their units, and provided parking may not be adequate to convert to other types of uses.
To mitigate the potential concerns and maximize the potential benefits of allowing self-storage facilities in commercial areas, staff has created a list of potential supplemental regulations, including use standards and design standards:
1. Use Standards: The following standards shall apply to mini storage facilities located in commercial zone districts:
a. Storage units shall only be used for the storage of goods and/or property. Storage units shall not be used for activities such as:
i. Residences, offices, workshops, studios, hobby, or rehearsal areas;
ii. Manufacturing, fabrication, or processing of goods, service or repair of vehicles, engines, appliances, or other electrical equipment, or any other industrial activity;
iii. Conducting retail sales of any kind including garage or estate sales or auctions or to conduct any other commercial activity;
iv. Storage of flammable, perishable, or hazardous materials or the keeping of animals.
b. Accessory use such as the rental of trucks, trailers, or moving equipment, the installation of trailer hitches, or the sale of boxes or packing materials are allowed only if they are otherwise permitted in the zone in which the facility is located, and shall meet all applicable use and development standards.
c. Outdoor storage is prohibited, including outdoor storage of boats, RVs, vehicles, and storage in outdoor storage pods or shipping containers.
d. A night watchman, resident caretaker, or 24-hour security guard is allowed but not required.
e. Hours of operation shall be limited to the hours from 6 am to 10 pm. Business activities and tenant access to storage units are not permitted from 10 pm to 6 am.
2. Design Standards: For mini storage facilities located in commercial zone districts, the following additional standards shall apply in addition to the development standards generally required for all new commercial development in Article VII regarding entrances, materials, landscaping, parking, etc.:
a. Mini storage facilities are permitted only within multi-story structures designed to emulate multi-family residential or office buildings. The building must be designed in such a way as to allow
b. The site on which a mini storage facility is located shall not have frontage along an arterial street.
c. All individual storage units shall gain access from the interior of the building. The primary facility loading bays, docks, or doors shall not be visible from any adjacent residential property or from a public or private right-of-way.
d. All fencing shall consist of wrought iron or similar types of decorative fencing materials. Chain link fences are prohibited.
e. Colors shall compliment the natural characteristics of the site and surrounding development, and shall not be used to attract attention to the facility (i.e. no red roofs, orange doors, etc.).
A study session was held with Planning Commission on February 5, where they were generally supportive of allowing such facilities in the C-3 zone district and offered some additional suggestions for the design and use standards, shown below:
• Specify that using units as gathering spaces (such as for poker games, garage bands, or parties) is prohibited;
• Allow access until at least 12 am to accommodate people who may not be able to take time off to move, if all loading functions are indoors so as to prevent outdoor noise from moving trucks backing up;
• Require a minimum percentage of glazing/windows on building facades to ensure a more commercial appearance and make it easier for the building to be repurposed in the future;
• Prohibit perimeter security fencing of any style because it detracts from the commercial appearance desired.
To summarize, there are two main questions for which staff seeks input from the City Council: should we consider updating the LDC to allow self-storage facilities in the C-3 zone district, subject to additional use and design standards; and are the proposed design standards adequate to create a desirable type of development for such facilities? As a reminder, the study session is for discussion and feedback only, and no vote or formal action needs to be taken at this time. If Council opts to pursue code amendments, they are tentatively scheduled for public hearings with Planning Commission in April and with City Council in May for formal adoption.
Ordinance 2187 - Minor Modification Approval Criteria for Off-Street Parking Reduction:
This ordinance was part of the 2018 Minor LDC Amendments package. It was recommended for approval by Planning Commission on November 7, 2018, and approved on first reading by City Council on November 19, 2018. At the second reading on December 17, 2018, it was referred to a study session for additional information.
Minor Modifications are an administrative process which grants the ability to make small changes (typically up to 20%) to minimum or maximum standards within the LDC for specific properties and developments facing unique situations. This process is similar to a variance, but with less potential variability and no public hearing required before the Board of Adjustments for approval. It is intended to be business-friendly by allowing a small amount of administrative flexibility during the development review process.
The City’s parking regulations are based on the land use and building square footage. For example, office uses require a minimum of 1 parking space for every 300 square feet of building area, while restaurants require a minimum of 1 parking space for every 100 square feet of building area. These calculations determine the minimum amount of parking which must be present in order to approve new development plans. The LDC allows an applicant to have to 150% of the minimum parking requirement by right; parking under 100% or above 150% of the minimum requires a Minor Modification or a Variance. To continue using restaurants as an example, a 5,000 square foot restaurant would require a minimum of 50 parking spaces (1 per 100 square feet). They would be allowed to have up to 75 parking spaces by right (150% of the minimum 50). To approve a number of parking spaces either below 50 or above 75, a Minor Modification or Variance would be needed, depending on how much of a deviation from the minimum is being requested.
There are four types of Minor Modifications related to parking: one allows a parking increase up to 200% of the minimum required (100 spaces in the restaurant example), and three allow a parking reduction under specific situations, including shared parking between compatible uses and a regulatory incentive program for large-scale office developments, mixed-use developments, and development within an Activity Center as identified in the Comprehensive Plan. Ordinance 2187 deals specifically with the remaining allowable situation for parking reductions: a hardship reduction.
Currently, all five approval criteria must be met in order to approve a hardship reduction. These require that the development be for non-residential uses, or housing for the elderly or disabled; that there be a severe site constraint that makes complying with the minimum parking requirements impractical; that the traffic patterns associated with the proposed use be atypical in nature; that the operations of the proposed use are such that there is reduced demand for parking; and that sufficient evidence be submitted (typically a parking study) that demonstrates that less parking is warranted. The proposed amendment reduces the number of approval criteria which must be met from all five to just the first (non-residential use) and one additional criteria. This amendment is in response to increasing development activity in the core city, particularly with redevelopment of existing sites and infill development of vacant lots, which often have site constraints such as existing access and utility locations. Greater flexibility in how parking is handled allows for prioritizing architecture, site layout, and landscaping to enhance the overall function and aesthetic of new developments.
The purpose of this study session is to answer any questions that City Council may have and relay additional information regarding the proposed amendment to alleviate any concerns. No voting will occur on Monday night. There are three options for Council to consider at that time: approve the amendment as proposed; approve the amendment with changes, such as the total number of approval criteria which must be met; or the amendment can be denied and the existing code language will remain in effect. If Council provides feedback to incorporate into the ordinance, or does not seek to change the ordinance as currently written, it will be brought back to Council at a future date for action.
Staff Responsible (Department Head): Chris Cramer
Staff Member Presenting: Caitlin Long
Financial Impact: N/A
Funding Source: N/A
Staff Recommendation: N/A; Study session is for feedback only.