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HomeMy WebLinkAbout1. PLN-19-00039 11040 LakewoodDATE: MAY 1, 2019 TO: PLANNING COMMISSION SUBMITTED BY: ALDO E. SCHINDLER, DIRECTOR OF COMMUNITY DEVELOPMENT REVIEWED BY: CRYSTAL LANDAVAZO, CITY PLANNER PREPARED BY: MADALYN WELCH, ASSISTANT PLANNER SUBJECT: PLN-19-00039 (SPECIAL EVENT PERMIT) – A REQUEST TO OPERATE A CARNIVAL FOR FOUR (4) CONSECUTIVE DAYS (MAY 24, 25, 26 AND 27, 2019), IN CONJUNCTION WITH DOWNEY HIGH SCHOOL FOOTBALL BOOSTER CLUB LOCATION: 11040 BROOKSHIRE AVENUE ZONING: R-2 (TWO-FAMILY RESIDENTIAL) AND R-3 (MULTIPLE- FAMILY RESIDENTIAL) REPORT SUMMARY Downey High School Football Booster Club is requesting the approval of a Special Event Permit that would allow them to conduct a carnival in the school parking lot on May 24, 25, 26 and 27, 2019. Pursuant to Code Section 9420.04(c), special events involving over five hundred (500) people shall require approval from the Planning Commission. Based on the analysis contained in this report, staff recommends that the Planning Commission adopt the following resolution: A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF DOWNEY APPROVING SPECIAL EVENT PERMIT (PLN-19-00039), A REQUEST TO PERMIT THE OPERATION OF A CARNIVAL FOR FOUR CONSECUTIVE DAYS (MAY 24, 25, 26 AND 27, 2019), IN CONJUNCTION WITH THE DOWNEY HIGH SCHOOL FOOTBALL BOOSTER CLUB, ON PROPERTY LOCATED AT 11040 BROOKSHIRE AVENUE, ZONED R-2 (TWO-FAMILY RESIDENTIAL) AND R-3 (MULTI-FAMILY RESIDENTIAL) BACKGROUND This is the eighth consecutive year that a temporary carnival will be held in the City of Downey for fundraising purposes. The carnival was held at Columbus High School last year, however, the carnival was previously held at Downey High School for six consecutive years. The school campus occupies 42 acres and is located on the northeast corner of Brookshire Avenue and Firestone Boulevard. The proposed use will specifically encompass the school’s 2.57 acre parking lot in the southwest corner of the property. The subject site is zoned R-2 (Two-Family Residential) PC Agenda Page 1 and R-3 (Multi-Family Residential). The surrounding uses include single-family residential and apartment buildings to the north, single-family residential and office buildings to the east, the Downey Civic Center is to the west across Brookshire Avenue, and retail uses to the south across Firestone Boulevard. On March 7, 2019, Mary Laurer and Ismael Chavez submitted a Special Event Permit (PLN-19- 00039) application on behalf of Downey High School Football Booster Club, requesting the Planning Commission’s approval to conduct a four-day carnival on the parking lot of the school. Due to missing information, the application was deemed incomplete and was re-submitted on April 1, 2019. On April 8, 2019, staff completed the review of the application and deemed it complete. Brookshire Avenue and Firestone Boulevard Street View of Downey High School On April 18, 2019, staff mailed notice of the pending public hearing to all property owners within 500 feet of the subject site and the notice was also published in the Downey Patriot. DISCUSSION As previously stated, this will be the eighth year for the carnival and in past years, parking and trash has been a concern for residents living on Marbel Avenue, just east of the subject site. A solution to this issue was conditioned in 2017 to close off Marbel Avenue to any non-residents and have a Downey Police Officer monitoring the closure of this street. Staff has applied this same condition to minimize potential impacts to proximity to the carnival. The current proposal follows the same preparation and operation used in prior years. Carnival activities include a Ferris wheel, super slide, large rides, kid rides, fun house, games and food sales. The proposed carnival hours will be as follows: •Friday, May 24, 2019, from 5:00 p.m. to 11:00 p.m. •Saturday, May 25, 2019, from 1:00 p.m. to 11:00 p.m. •Sunday, May 26, 2019, from 1:00 p.m. to 11:00 p.m. •Monday, May 27, 2019, from 1:00 p.m. to 10:00 p.m. Set up of the carnival will occur no sooner than 4:00 p.m. on Wednesday, May 22nd, prior to the beginning of the carnival. All carnival activity will be located in the southwest Downey High School parking lot, which is surrounded by an eight-foot tall wrought iron fence. The carnival site is located PC Agenda Page 2 approximately 628 feet from residential properties on the east (Marbel Avenue) and 1,216 feet from residential properties to the north (5th Street). Removal and clean-up of all carnival apparatus (rides and large equipment) will be on Tuesday, May 28, 2019, the day following the conclusion of the event. Staff is recommending Conditions of Approval to ensure the clean-up area be extended to also include the sidewalks and public areas adjacent to the carnival site. The Ferris wheel will be located on the southwest corner of the subject parking lot. The large rides and the super slide will be on the south side of the parking lot, along Firestone Boulevard. The children’s area with smaller rides will be located just north of the large rides in the center of the parking lot. Food booths will be located on the northern area of the parking lot adjacent to the 20’ fire lane near the school buildings. The fun house will be east of the large and small rides. Similar to the events from prior years, the Applicant is expecting 2,000-3,000 people to attend the proposed carnival throughout the duration of the event. To ensure litter generated by the carnival does not impact surrounding residences, a condition has been placed to confirm that trash receptacles will be placed throughout the site. There will also be portable restrooms placed on both east and west ends of the carnival area. Generator equipment will be placed abutting Firestone Boulevard and to the furthest extent possible away from residential property lines, as done in prior years. There will be 200 parking spaces, including 10 accessible spaces, available on the northern parking lot near the tennis facility and 150 parking spaces, including 4 accessible spaces, available at the east of the school near the baseball fields on 3rd Street. Therefore, there will be a total of 350 on-site parking spaces for patrons. The carnival will have three (3) pedestrian access points; one along Brookshire Avenue near the school buildings on the west; another access point will be from Firestone Boulevard at the southeast corner, for those parking at the baseball field parking lot, an entrance to the site at the northeast corner of the carnival. There is a walkway along the south border of the campus connecting the parking lot to this carnival entrance. The applicant will be using three (3) Downey Police officers for carnival security. Two (2) officers will be on site between 5:00 p.m. and 11:00 p.m. and one (1) officer will be located at the closure of Marbel Avenue during all carnival operating hours. A condition has been placed to also require six (6) security guards present at all times during carnival hours, provided by the Applicant. DEVELOPMENT REVIEW COMMITTEE The request was reviewed by the Development Review Committee on March 21, 2019. The Downey Police Department provided the condition that includes two (2) Downey Police Officers from 5:00 p.m.-11:00 p.m. of the event, six (6) security guards on site during all hours of the event and one (1) Downey Police Officer at Marbel Avenue during all hours of the event. Also, the Fire Department stated that permits are required for the proposed rides and tents. The Public Works Department identified that trash receptacles are required throughout the carnival area for trash generated from the event. Conditions of approval have been included in the attached Resolution to address these comments and concerns. ENVIRONMENTAL ANALYSIS Staff has reviewed the proposed use for compliance with the California Environmental Quality Act (CEQA). Upon completion of this review, staff determined that this request is categorically exempt from CEQA, pursuant to Guideline Section No. 15304 (Class 4, Minor Alterations to Land). Categorical Exemptions are projects, which have been determined not to have a significant effect on the environment and have been exempted from the requirements of CEQA. PC Agenda Page 3 Class 4 exemptions include temporary uses, such as a carnival, that will have no permanent effect on the environment. FINDINGS Pursuant to the requirements of the Municipal Code, staff recommends that the Planning Commission make the following findings to approve the request: A.That the proposed activity or use will be consistent with the objectives, policies, and general land uses and programs specified in the City’s General Plan. It is staff’s opinion that the project is consistent with all applicable objectives, policies, and programs specified in the City’s General Plan. In addition, the project’s fundraising efforts help achieve various long term goals. Specifically, the following policies are promoted by the Special Event Permit: Program 7.4.1.4 – Support efforts to raise funds for local school districts and other groups involved with providing educational facilities for residents. Program 1.1.5.3 – Promote recreation and entertainment uses that serve needs of the public. In as much as the proposed carnival is a fundraising event for Downey High School Football Program, the event is open to the public, and includes games and rides for attendees to enjoy. The proposed special event is consistent with the aforementioned General Plan program. B.That the proposed activity or use is consistent with other provisions of Article IX of the Downey Municipal Code. Downey High School is located within the R-2 (Two-Family Residential) and R-3 (Multiple-Family Residential) zone, which allows religious organizations and private schools. Operation of a carnival will not alter the use of the site or create a need to deviate from any section of the Downey Municipal Code. Section 9420.20 of the Downey Municipal Code permits special outdoor events in residential zones, subject to the general requirements stated in that Code Section. The proposed event satisfies those requirements. C.That the proposed activity or use will not result in conditions or circumstances contrary to the public health, safety, and general welfare. The temporary event will occur on the south parking lot of the school property. The applicant will maintain 200 parking spaces at the north parking lot and 150 parking spaces at the baseball field, with a total of 14 accessible parking spaces. The school will provide restroom facilities on the east and west corner of the proposed area for the event to accommodate visitors. Also, conditions of approval are incorporated to address any concerns related to the permitted hours of event, parking, noise, security, trash receptacle requirements, restroom, and site clean-up. Approving the special event, governed by the attached conditions of approval, will not result in conditions contrary to the public health, safety and general welfare. PC Agenda Page 4 CORRESPONDENCE As of the date that this report was printed, staff has not received any correspondence regarding this matter. CONCLUSION Based on the analysis contained herein, and the previous years of the festival operating without incident, staff is concluding this event can be a benefit to the community as encouraged through General Plan policies. Furthermore, staff concludes that all of the required findings can be made in a positive manner. Therefore, staff recommends that the Planning Commission adopt a resolution approving the Special Event Permit (PLN-18-00150), subject to the conditions of approval as stated in Exhibit A of the Planning Commission Resolution. EXHIBITS A.Maps B.Draft Resolution C.Carnival Layout PC Agenda Page 5 Exhibit ‘A’ Vicinity Map PC Agenda Page 6 Zoning Map SUBJECT PROPERTY PC Agenda Page 7 Aerial Map Carnival Location Event Parking Event Parking Marbel Ave Closed Off PC Agenda Page 8 RESOLUTION NO. 19- A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF DOWNEY APPROVING SPECIAL EVENT PERMIT (PLN-19-00039), A REQUEST TO PERMIT THE OPERATION OF A CARNIVAL FOR FOUR CONSECUTIVE DAYS (MAY 24, 25, 26 AND 27, 2019), IN CONJUNCTION WITH THE DOWNEY HIGH SCHOOL FOOTBALL BOOSTER CLUB, ON PROPERTY LOCATED AT 11040 BROOKSHIRE AVENUE, ZONED R-2 (TWO-FAMILY RESIDENTIAL) AND R-3 (MULTI-FAMILY RESIDENTIAL) THE PLANNING COMMISSION OF THE CITY OF DOWNEY DOES RESOLVE AS FOLLOWS: SECTION 1. The Planning Commission of the City of Downey does hereby find, determine and declare that: A.An application was filed by Mary Laurer and Ismael Chavez (hereinafter "Applicant") on March 7, 2019, requesting approval of a Special Event Permit to allow the operation of an outdoor carnival, on property at 11040 Brookshire Avenue (Downey High School) Downey, California (hereinafter "Subject Site"), zoned R-2 (Two-family residential) and R-3 (Multi-Family Residential); due to missing information, the application was deemed incomplete and, B.On April 1, 2019, the application was re-submitted, and the project was deemed complete on April 8, 2019; and, C.On April 18, 2019, notice of the pending public hearing was sent to all Downey property owners within 500 feet of the subject site and the notice was published in the Downey Patriot; and, D.The Planning Commission held a duly noticed public hearing on May 1, 2019, and after fully considering all oral and written testimony, facts, and opinions offered at the aforesaid public hearing adopted this resolution. SECTION 2. The Planning Commission further finds, determines and declares the environmental impact of the proposed development has been reviewed and has been found to be in compliance with the California Environmental Quality Act (CEQA) and is categorically exempt from CEQA, pursuant to Guideline Section No. 15304 (Class 4, Minor Alterations to Land). Categorical Exemptions are projects, which have been determined not to have a significant effect on the environment and have been exempted from the requirements of CEQA. Class 4 exemptions include temporary uses, such as a carnival, that will have no permanent effect on the environment. SECTION 3. Having considered all of the oral and written evidence presented to it at said public hearings, the Planning Commission further finds, determines and declares that: A.The proposed activity or use is consistent with the objectives, policies, and general land uses and programs specified in the City’s General Plan. The project is consistent with all applicable objectives, policies, and programs specified in the City’s General Plan. In addition, the project’s fundraising efforts help achieve various long term goals. Specifically, the following policies are promoted by the Special Event Permit: Program 7.4.1.4 – Support efforts to raise funds for local school districts and other groups involved with providing educational facilities for PC Agenda Page 9 residents. Program 1.1.5.3 – Promote recreation and entertainment uses that serve needs of the public. In as much as the proposed carnival is a fundraising event for Downey High School Football Program, the event is open to the public, and includes games and rides for attendees to enjoy. The proposed special event is consistent with the aforementioned General Plan program. B.The proposed activity or use is consistent with other provisions of Article IX of the Downey Municipal Code. Downey High School is located within the R-2 (Two- Family Residential) and R-3 (Multiple-Family Residential) zone, which allows religious organizations and private schools. Operation of a carnival will not alter the use of the site or create a need to deviate from any section of the Downey Municipal Code. Section 9420.20 of the Downey Municipal Code permits special outdoor events in residential zones, subject to the general requirements stated in that Code Section. The proposed event satisfies those requirements. C.The proposed activity or use does not result in conditions or circumstances contrary to the public health, safety, and general welfare. The temporary event will occur on the south parking lot of the school property. The applicant will maintain 200 parking spaces at the north parking lot and 150 parking spaces at the baseball field, with a total of 14 accessible parking spaces. The school will provide restroom facilities on the east and west corner of the proposed area for the event to accommodate visitors. Also, conditions of approval are incorporated to address any concerns related to the permitted hours of event, parking, noise, security, trash receptacle requirements, restroom, and site clean-up. Approving the special event, governed by the attached conditions of approval, will not result in conditions contrary to the public health, safety and general welfare. SECTION 4. Based upon the findings set forth in Sections 1 through 3 of this Resolution, the Planning Commission of the City of Downey hereby approves the Special Event Permit (PLN-19-00039), subject to the Conditions of Approval attached hereto as Exhibit B, which are necessary to preserve the health, safety and general welfare of the community and enable the Planning Commission to make the findings set forth in the previous sections. The conditions are fair and reasonable for the accomplishment of these purposes. PC Agenda Page 10 SECTION 5. The Secretary shall certify the adoption of this Resolution. PASSED, APPROVED AND ADOPTED this 1st day of May, 2019. _________________________ Steven Dominguez, Chairman City Planning Commission I HEREBY CERTIFY that the foregoing is a true copy of a Resolution adopted by the Planning Commission of the City of Downey at a regular meeting thereof held on the 17th day of April, 2019, by the following vote, to wit: AYES: COMMISSIONERS: NOES: COMMISSIONERS: ABSENT: COMMISSIONERS: ABSTAIN: COMMISSIONERS: _________________________ Mary Cavanagh, Secretary City Planning Commission PC Agenda Page 11 PLN-19-00150 (SPECIAL EVENT PERMIT) EXHIBIT A - CONDITIONS PLANNING 1.This approval of this Special Event Permit allows Downey High School Football Booster Club to host a four-day carnival (May 24, 25, 26, and 27, 2019) on the southern parking lot of Downey High School, which consists of food booths, game booths, a fun house, a super slide, large mechanical rides and small rides located at 11040 Brookshire Avenue. 2.Carnival hours of operation shall be limited to: •Friday, May 24, 2019, from 5:00 p.m. to 11:00 p.m. •Saturday, May 25, 2019, from 1:00 p.m. to 11:00 p.m. •Sunday, May 26, 2019, from 1:00 p.m. to 11:00 p.m. •Monday, May 27, 2019, from 1:00 p.m. to 10:00 p.m. 3.The owner/applicant agrees, as a condition of approval of this resolution, to indemnify, defend and hold harmless, at Applicant's expense, City and City's agents, officers and employees from and against any claim, action or proceeding commenced within the time period provided in Government Code Section 66499.37 to attack, review, set aside, void or annul the approval of this resolution, to challenge the determination made by City under the California Environmental Quality Act or to challenge the reasonableness, legality or validity of any condition attached hereto. City shall promptly notify Applicant of any such claim, action or proceeding to which City receives notice, and City will cooperate fully with Applicant in the defense thereof. Applicant shall reimburse the City for any court costs and attorney's fees that the City may be required to pay as a result of any such claim, action or proceeding. City may, in its sole discretion, participate in the defense of any such claim, action or proceeding, but such participation shall not relieve Applicant of the obligations of this condition. 4.The City Planner is authorized to make minor modifications to the approved preliminary plans or any of the conditions if such modifications shall achieve substantially the same results as would strict compliance with said plans and conditions. 5.Approval of this Special Event Permit shall not be construed to mean any waiver of applicable and appropriate zoning regulations, or any Federal, State, County, and City laws and regulations. Unless otherwise expressly specified, all other requirements of the City of Downey Municipal Code shall apply. 6.The approved activities for the special event shall consist of food booths, game booths, a Ferris wheel, a fun house, a super slide, large mechanical rides and small rides. 7.Marbel Avenue shall be closed to vehicles during all carnival hours for any non-resident of that street. As well as, one (1) of the three (3) required Police Officers shall monitor this street during all carnival hours. 8.Complete restoration of the site, which includes removal of all tables and chairs, booths, trash receptacles, portable restrooms, electrical equipment, mechanical rides, and garbage on site and the surrounding proximity of the high school shall be completed no later than 11:59 p.m. on Tuesday, May 28, 2019. PC Agenda Page 12 9.All public sidewalks immediately surrounding the carnival site must be monitored and removed of litter throughout the event and at time of final site restoration. 10.Site configuration and operations must remain in substantial conformance with the approved site plan. Modifications to the approved site plan must be approved by the City Planner. 11.All carnival activities shall cease by 10:00 p.m. on Monday, May 27, 2019. 12.Set-up shall begin no sooner than 4:00 p.m. on Wednesday, May 22, 2019. 13.No amplified music or live entertainment will be permitted during the four-day carnival. 14.All necessary lighting shall be directed away from nearby residential uses. 15.All speakers associated with rides and games must be positioned to direct noise away from nearby residential uses. 16.The sale and consumption of alcoholic beverages shall be prohibited at all times. 17.Any necessary Health Department approvals required for the sale of food shall be obtained no later than May 23, 2019. Appropriate documentation reflecting approval must be submitted to the City Planner by the same day. 18.The Applicant shall obtain all permits required by the City of Downey Building and Safety Division, Police Department and Fire Department for mechanical rides, electrical connections, or other activities associated with the event no later than May 23, 2019. Appropriate documentation reflecting approval must be submitted to the City Planner by the same day. 19.Signs advertising the event are not allowed outside of the proximity of the subject property. In addition, hand held signs shall not be utilized on public or private property to advertise the event. BUILDING AND SAFETY 20.Temporary structures that cover an area greater than 120 square feet and used for the gathering of 10 or more persons require permits. The construction documents shall include a site plan indicating the location of the temporary structure and information delineating the means of egress and the occupant load. The temporary structure shall be located in accordance with the requirements of California Building Code Table 602 based on the fire-resistance rating of the exterior walls proposed type of construction (10 feet minimum from property line based on Type VB). 21.Temporary structures or facility shall meet the requirements of Chapter 11B of the California Building Code. Site plan shall include a site accessibility plan identifying exterior routes of travel and detailing running slope, cross slope, width, pedestrian ramp, curb ramps, handrails, signage and truncated domes. Path of travel shall be provided from the public right of way and accessible parking to building or facility. The design PC Agenda Page 13 professional shall ensure that the site accessibility plan is compliance with the latest Federal and State regulations. PUBLIC WORKS 22.The owner/applicant shall obtain all necessary plan approvals and permits. 23.The facility must provide trash receptacles (refuse/recycles) for the proper disposal of food items and trash generated from the event. 24.The owner/applicant shall comply with the National Pollutant Discharge Elimination System (NPDES) requirements of the Federal Clean Water Act; and Ordinance 1142 of the Downey Municipal Code (DMC). Watering down parking lot for maintenance purposes shall be prohibited at all times. 25.Parking lot maintenance by hosing down method shall be prohibited FIRE DEPARTMENT 26.Obtain a special event permit from City of Downey Fire Department. Permit shall be obtained through the Fire Prevention Bureau no later Thursday, May 16th. 27.Event set-up including all rides, booths, generator, tents, fire protection, electrical, etc. shall be complete, in place, and ready for inspection by noon (12pm) on Friday, May 24th. Both carnival ride operator and event permit holder (Downey HS Football Boosters) shall be present and available for the fire inspection [Note: If inspection is conducted after hours (or on the weekend) an additional inspection fee (4 hour minimum) will be applied as per city fee schedule]. 28.W ith permit application, submit a detailed plot plan/map as to clearly indicate type of rides, generator location, tents, fire lane width, cooking booths, type of cooking (e.g. BBQ, frying, etc.) 29.Each amusement ride shall display the required State registration (identification & rating plate). At time of permit application, submit list of rides with their corresponding current annual permit to operate. 30.All amusement rides shall be permitted with State of California DIR-DOSH. All amusement rides shall comply with the requirements of CCR Title 8 – General Safety Orders, and the CA Labor Code. 31.Crowd managers shall be required for an event involving the gathering of more than 1,000 persons. Please provide information as to anticipated crowd size. Crowd managers shall be established at ratio of one crowd manager for every 250 persons and their duties to include: conduct inspections to identify fire hazards, verify permit compliance, direct and assist event attendees in evacuation during an emergency, assist emergency response personnel where requested [CA Fire Code §403.12.3; 403.12.3.1; 403.12.3.3] 32.If the event shall require a crowd manager(s), then an IAP (Incident Action Plan) or Emergency Action Plan (EAP) shall be required for emergency planning purposes. 33.Fire apparatus access (e.g. fire lane) of 20-feet shall be maintained accessible at all PC Agenda Page 14 times. A 26 ft. fire access lane shall be provided to any elevated ride(s) (e.g. Ferris Wheel) as to accommodate an aerial ladder truck [CA Fire Code §503.2.1; D105.2] 34. Tents, canopies, and membrane structures having an area in excess of 400 square feet; or tents open on all sides having a size of 700 square feet or more; or aggregate area of multiple tents placed side by side without a fire break clearance of 12 feet and exceeding 700 square feet shall require a separate tent permit [CA Fire Code 3103.2]. 35. Tents shall comply with CA Fire Code, CA Code of Regulations, and State Fire Marshal for flame resistance standards of fabric [CA Fire Code § 3104.3; 3104.4; CCR Title 19 Division 1, §315(d); §335(a)] 36. Tents shall not be located within 20 feet of parked vehicles, open flame or heating devices, combustion engines, and buildings [CA Fire Code § 3104.7] 37. Generators shall not be located within 10 feet of lot (property line) and 20 feet of tents/membrane structures [CA Fire Code § 3104.19]. An approved barrier (e.g. fencing) shall be provided around generator. 38. State Fire Marshal (SFM) “tagged” 4A-20BC rated extinguisher shall be provide at the generator as per NFPA 10 and CA Fire Code §906 39. No cooking shall be conducted inside tents or canopies; cooking and heating equipment shall not be located within 10 feet of combustible materials [CA Fire Code § 3104.15.3] 40. The Applicant shall provide fire extinguishers on the subject property in accordance with California Fire Code. Areas where deep frying cooking operations are occurring shall be provided with a K-class fire extinguisher. POLICE DEPARTMENT 41. The applicant must provide licensed security guards on-site during the duration of the event, including three (3) Downey Police Department Officers and six (6) security guards. One (1) of the Downey Police Officers will monitor Marbel Avenue during all carnival hours. Two (2) Police Officers will be on-site of the event from 5:00 p.m. to 11:00 p.m. Within ten days of the approval of PLN-19-00039, the applicant shall obtain Downey Police Department approval of a security plan for the carnival and provide a map of the security locations. 42. The applicant shall submit a security plan that includes provisions to address traffic control on Firestone Blvd at Marbel Ave, Brookshire Ave at the school’s north parking lot, and Lakewood Blvd at Third St. Said traffic control measures shall be subject to the approval of the Director of Public Works. 43. Within seven (7) days of the approval of PLN-19-00039, the applicant shall obtain Downey Police Department approval of a security plan for the carnival and provide a map of the security locations. 44. Carnival security officers shall be easily identifiable in brightly colored security shirts. The security shirts shall not resemble the color of Downey Police officers; they shall not be blue or black. END OF CONDITIONS PC Agenda Page 15 PC Agenda Page 16