HomeMy WebLinkAboutPLNZAD2024-00793 - 15 S 2400 WPage 1 of 3
September 4, 2024
ADMINISTRATIVE INTERPRETATION
DECISION AND FINDINGS
PLNZAD2024-00793
REQUEST:
This is a request by Garrett Stockton (Arcadis), on behalf of the property owner, Thrifty Rent-A-
Car System LLC (Hertz Car Rental), for an administrative interpretation regarding a proposed use
on property in the TSA-MUEC-C District at approximately 15 S 2400 W (Tax ID#: 15-04-200-
004-0000). Per the submitted application, the use is an Electric Vehicle (EV) Charging Hub,
which will be used to charge EV rentals and will also be open for public use. A determination is
sought because the applicant is inquiring whether the proposed use would be considered
accessory to the car rental service on the property.
DECISION:
The Zoning Administrator finds that the addition of electric charging equipment to an existing
parking space does not constitute a change in land use. The proposed EV Charging Hub would be
part of the provided off-street parking for the site. As such, the proposed equipment is permitted
in the TSA-MUEC-C zoning district.
This interpretation is specific to the proposal as it relates to the Salt Lake City Zoning Ordinance.
Additional requirements associated with the use may be required by other divisions, such as
Building Services, Public Utilities, or the Fire Department.
FINDINGS:
The applicant proposes an EV Charging Hub on the existing parking lot at the Hertz Rental Car
facility. According to the applicant’s narrative, the facility will include 24 charging stalls covered
by canopies, covering a quarter-acre on the southwest corner of the existing parking lot.
The Salt Lake City Code does not have a land use category specific to Electric Vehicle charging or
parking. In the zoning ordinance, the term “electric vehicle” is used in the following sections:
21A.62.040: DEFINITIONS OF TERMS:
VEHICLE, ELECTRIC: A device which is considered a vehicle that uses electricity as its
primary source of power, such as a plug-in electric vehicle or a plug-in hybrid electric
vehicle. An electric vehicle does not include devices that are moved by human power.
21A.44.040: REQUIRED OFF STREET PARKING:
C. Electric Vehicle Parking:
1. Each multi-family use shall provide a minimum of one (1) parking space dedicated
to electric vehicles for every twenty-five (25) parking spaces provided on-site. Electric
vehicle parking spaces shall count toward the minimum required number of parking
spaces.
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In addition to the zoning ordinance, the Salt Lake City Code and the Salt Lake City Policies and
Procedures Manual also refer to electric vehicle charging as infrastructure and parking stalls
(underlines added for emphasis):
Title 12: Vehicles and Traffic
12.56.205: PARKING METERS; NO CHARGE FOR SLC GREEN VEHICLES;
ELECTRIC VEHICLE CHARGING STATIONS:
A. The following definitions shall apply to this section:
ELECTRIC VEHICLE CHARGING STATION: A parking stall equipped with
infrastructure that supplies electric energy for the recharging of electric vehicles.
56-3-6: SUSTAINABLE INFRASTRUCTURE:
C. Electric Charging Infrastructure: For all City owned capital improvement projects,
such as road or parking lot construction or reconstruction, the City shall evaluate
opportunities for the inclusion of electric vehicle (EV) charging infrastructure. At the
minimum, this should include “electric vehicle ready” parking spaces that have
electrical conduit and sufficient electrical capacity for the future use of a minimum
208-240-volt electric vehicle charging station. Where practicable, the project should
also include the installation of electric vehicle charging stations in coordination with
the Sustainability and Public Services departments, which are responsible for citywide
EV planning, grant support, operations, maintenance, and budget.
While this interpretation pertains to zoning, these other sections help inform how such equipment
is characterized by the City. In every case where EV charging is referenced it is referred to as a
“parking stall” or “parking space,” and the associated equipment is referred to as “infrastructure.”
No references exist in the current code distinguishing EV charging as a distinct land use, whether
accessory or primary.
The current zoning ordinance considers certain types of parking as separate, distinct land uses
(e.g., commercial parking, off-site parking, and park & ride lots). Other off-street parking
provided on a property is not considered a separate use, and is regulated by Chapter 21A.44: Off
Street Parking, Mobility and Loading. Section 21A.44.040 includes requirements for standard
parking, EV parking, ADA parking, and bicycle parking. Each of these sets of requirements are
tied to the primary land use of the site and are not considered to be a separate land use on their
own.
Section 21A.04.010 explains the organization of the zoning code, including the types of
regulations. Off-street parking standards are included in Part IV of Title 21A, which is described
as development standards:
21A.04.010: ORGANIZATION OF TITLE:
Development standards control the height, size, location and other particular aspects of
structures and uses on sites intended for development. (…) Development standards for
each zoning district appear in part III of this title. (…) The development standards in
part III of this title are supplemented by additional development standards in part IV
of this title.
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The conversion of standard parking stalls to EV charging stalls is not prohibited by the zoning
ordinance and does not constitute a change in land use. It is merely an allowed modification of a
development and does not require a separate land use designation.
This letter serves as an administrative interpretation, clarifying a specific situation on the subject
property. Staff has not conducted a review of any site plans or building plans for the proposed
canopies or equipment. A full review for compliance with all applicable standards and regulations
will be required prior to the issuance of a building permit. If you have any questions regarding
this interpretation, please contact Andy Hulka at (801) 535-6608 or by email at
andy.hulka@slc.gov.
APPEAL PROCESS:
An applicant or any other person or entity adversely affected by a decision administering or
interpreting this Title may appeal to the Appeals Hearing Officer. Notice of appeal shall be filed
within ten (10) days of the administrative decision. The appeal shall be filed with the Planning
Division and shall specify the decision appealed and the reasons the appellant claims the decision
to be in error. Applications for appeals are located on the Planning Division website at
https://www.slc.gov/planning/applications/ along with information about how to apply and
processing fees.
NOTICE:
Please be advised that a determination finding a particular use to be a permitted use or a
conditional use shall not authorize the establishment of such use nor the development,
construction, reconstruction, alteration, or moving of any building or structure. It shall merely
authorize the preparation, filing, and processing of applications for any approvals and permits
that may be required by the codes and ordinances of the City including, but not limited to, a zoning
certificate, a building permit, and a certificate of occupancy, subdivision approval, and a site plan
approval.
Andy Hulka
Inland Port Principal Planner
CC: Nick Norris, Planning Director
Mayara Lima, Zoning Administrator
Casey Stewart, Planning Manager and Development Review Supervisor
Poplar Grove Community Council
Posted to Web
Attachments:
• Applicant’s Narrative to Administrative Interpretation
Administrative Review Narrative
Project Address: 15 S 2400 W, Salt Lake City, UT
Project Name: Salt Lake EV Hub
Project Number: PLNZAD2024-00793
Project Description:
The proposed development involves establishing an Electric Vehicle (EV) Charging Hub at 15 S 2400
West. This facility will operate 24/7 and will be open to the public without an attendant. The hub will
feature 24 charging stalls: 20 equipped with Tesla V4 Superchargers and 4 with Alpitronic HYC400
chargers. The site will also include 1 van-accessible stall. All charging stalls will be covered by a parking
canopy, which is designed to potentially support solar panels for future installation.
Reason for Administrative Review:
Arcadis/BP seeks administrative interpretation for the proposed EV Charging Hub due to the absence of a
specific definition for EV charging within Salt Lake City's current building and zoning codes. During the
pre-application review meeting on May 13, 2024, the plan reviewers considered categorizing EV charging
as either a gas station or a parking lot—neither of which are permitted uses in the TSA-MUEC-C zone.
The development is planned to utilize 0.25 acres of an existing parking lot at the Hertz Rental facility. The
parcel, measuring 2.6 acres, currently has 2 acres developed, the project would make use of the
southwest corner of the under-utilized parking lot. Hertz is expanding its EV rental fleet, and this charging
hub will directly support their operational needs while alleviating the capital burden associated with
maintaining an expanding EV fleet. Although the facility will be open to the public, it will provide significant
operational benefits to Hertz without requiring them to invest heavily in charging infrastructure.
Proposed Use Classification: Accessory Use
Given that the zoning code does not currently include a classification for EV charging facilities, we
propose that this project be classified as an "Accessory Use." The development will occupy only a small
portion (0.25 acres) of the existing parking lot and will enhance the functionality of an underutilized area.
Additionally, as Hertz has already developed a significant portion of the parcel, the proposed EV Charging
Hub will complement their expanding EV rental operations. Therefore, we believe this project aligns with
the intent of an Accessory Use classification.