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Page 1: go.boarddocs.com · 2021. 6. 2. · Spring Road Business Owners Spring Road Property Owners June 2, 2021 Page 4 Roberto’s testified that it hosts banquets in existing individual
Page 2: go.boarddocs.com · 2021. 6. 2. · Spring Road Business Owners Spring Road Property Owners June 2, 2021 Page 4 Roberto’s testified that it hosts banquets in existing individual
Page 3: go.boarddocs.com · 2021. 6. 2. · Spring Road Business Owners Spring Road Property Owners June 2, 2021 Page 4 Roberto’s testified that it hosts banquets in existing individual
Page 4: go.boarddocs.com · 2021. 6. 2. · Spring Road Business Owners Spring Road Property Owners June 2, 2021 Page 4 Roberto’s testified that it hosts banquets in existing individual
Page 5: go.boarddocs.com · 2021. 6. 2. · Spring Road Business Owners Spring Road Property Owners June 2, 2021 Page 4 Roberto’s testified that it hosts banquets in existing individual
Page 6: go.boarddocs.com · 2021. 6. 2. · Spring Road Business Owners Spring Road Property Owners June 2, 2021 Page 4 Roberto’s testified that it hosts banquets in existing individual
Page 7: go.boarddocs.com · 2021. 6. 2. · Spring Road Business Owners Spring Road Property Owners June 2, 2021 Page 4 Roberto’s testified that it hosts banquets in existing individual
Page 8: go.boarddocs.com · 2021. 6. 2. · Spring Road Business Owners Spring Road Property Owners June 2, 2021 Page 4 Roberto’s testified that it hosts banquets in existing individual
Page 9: go.boarddocs.com · 2021. 6. 2. · Spring Road Business Owners Spring Road Property Owners June 2, 2021 Page 4 Roberto’s testified that it hosts banquets in existing individual
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Spring Road Business Owners

Spring Road Property Owners

June 2, 2021

Page 2

pizzeria. You likely have similar awareness and you do not count any part of the rundown

building south of Roberto’s as part of the restaurant. This is important background relating to the

two new private parking lots that will serve only Roberto’s while Roberto’s operations

dramatically increase parking demand a few multiples beyond the 58 new spaces.

The bottom line is that residents and some businesses oppose the new private parking

lots. Among their grounds for opposition, the residents stated that Roberto’s intended to utilize

the new parking for new banquet operations that would demand more parking. (Roberto’s no

longer denies that it will be expanding its banquet operations, but it denies being a banquet hall.)

The residents also indicated that the new parking, in combination with the expansion, would

leave the Spring Road Business District burdened with more unanswered parking demand than it

has now—even with 58 new private parking spaces. Roberto’s currently hosts banquet functions

for 25 to over 200 people. With the addition, its banquet capacity will certainly grow. Parking for

banquets leads to longer-duration use of individual spaces (often as long as four hours).

As you read this letter, consider that Tom Borchert and Than Werner analyzed parking in

the past and, between them, found only perceptions of parking shortages. Also, pay attention to

numbers. Applicant relied on average rates in a dense urban setting and on rates based on a very

limited survey pool (only a few parking studies for quality restaurants from the ITE Parking

Manual (5th Edition)). All of the general urban suburban Class 931 and Class 932 ITE data

sheets are enclosed. As we know it, Roberto’s Ristorante comprises the area south of Roberto’s

Pizzeria and west of the dilapidated commercial units that the Moreci family has ignored for

decades. It is a restaurant comprised of no more than 3,300 square feet and it has a bar that we all

know regularly serves more than 14 people. (Scott Day presents the bar as having 14 seats, but

many of us have seen in excess of 40 people in the bar area extending from the current main

entrance to the southernmost interior dining area.) Roberto’s restaurant and pizzeria share a

kitchen that was constructed under circumstances that will be reviewed later but need not be

recited in this letter. Due to the nature of the carryout pizzeria, it is fair to include half of the

1,000 square foot kitchen in the area of each use. The Moreci family testified it has twenty

delivery drivers in a single shift, but the parking and movements for these drivers has not been

considered at hearing or in this correspondence. North of the pizzeria lies 481 Spring which has

an office and storage areas. To the rear of 481 Spring, the Moreci family has proceeded to install

outdoor containers for storage which would not count towards floor area when analyzing parking

or trip generation issues.

With these circumstances in mind, consider that KLOA’s August 18, 2020 trip generation

and parking study noted a 9,700 square foot restaurant facility in Block 2. On April 15, 2021,

after setting aside some of KLOA’s findings, Scott Day argued that the buildings on the

Roberto’s Ristorante property had a footprint of 10,955 square feet (excluding the 1,630 square

foot dining patio currently in use). These figures are so far in excess of the 3,300 square feet for

the restaurant and the 1,725 square feet for the pizzeria that one can only surmise that the nearly

10,000 square foot and nearly 11,000 square foot figures provided by KLOA and Scott Day were

intended to bolster the claim that there was a deficiency in parking that neither Mr. Borchert nor

Mr. Werner found. The City’s own parking consultant initially had problems with the traffic and

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parking study but, after some discussion with City staff and KLOA, no further questions were

raised despite disparities in the presentation of parking demand figures and the glaring omission

of any reference to expanded dining and banquet operations within the restaurant.

The remainder of this correspondence provides details the impact of the now-admitted

banquet expansion on parking and trip generation information. The Zoning & Planning

Commission (often steered by questionable staff analysis) has recommended the project and

Roberto’s admits it is pursuing a 5,130 square foot addition that will eviscerate the public benefit

previously presented to business and residential neighbors. The project will indeed make things

worse for those who desire parking in the Spring Road Business District and, consequently,

doing business and owning property in the Spring Road Business District gets harder.

Concern for Banquet Operations

Roberto’s has banquet operations. Due to the Elmhurst Municipal Code definitions,

Roberto’s eventually realized that it could no longer fight the issue of whether it offers banquets.

It indeed has a banquet menu and cannot deny hosting gatherings that qualify as banquets.

Banquets are different from general restaurant operations because the arrival and departure rates

are more dispersed for restaurants. In the case of banquet operations, patrons will arrive over a

shorter period of time and stay for a longer period of time (two to four hours). Anyone concerned

with parking in the Spring Road Business District should worry about an expansion of banquet

operations and neighbors should already have noticed that when there is an event at Roberto’s,

the 25 to more than 100 attendees of the event stay longer and occupy parking spaces longer.

Everyone notices banquet events when they occur because neighborhood streets are

busier and more vehicles are spread across the Spring Road public parking lot while street spaces

remain occupied longer. KLOA has testified in other matters concerning banquet operations and

stated that banquet vehicle occupancies are, on average, 2.5 occupants per vehicle (Skokie,

2019-49P: Parking Determination, Ateres Ayala Community Center (2020)). The New York

City DOT uses an assumed average vehicle occupancy of 1.8 persons for banquets. The

minimum impact of banquet operations at Roberto’s is as follows:

SIZE ROOM AREA KLOA VEH. NYCDOT VEH. NOTES

25 Any 10 14

50 Any 20 28 South room would use bar area

75 Any 2 rooms 30 42 Assumes no standees (any if so)

100 Any 2 rooms 40 56 Standees if bar dining area used

125 Any 2 rooms 50 69 Standees in both

150 All but patio 60 83

175 All but patio 70 97

200 All but patio 80 111

224 All but patio 90 124 Roberto’s purported occupancy

250 All but patio 100 139 Standees incl. in bar area

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Roberto’s testified that it hosts banquets in existing individual dining rooms and in the dining

area near the bar. Roberto’s testified that doing so is inconvenient and deters hosts from having

their events at the restaurant. Roberto’s has also closed for events. With this history, the

neighbors raised a concern over expansion to allow for the larger banquets and they objected to

the recently-recommended Plan B which includes a 5,130 square foot addition to Roberto’s amid

testimony that Roberto’s requires a larger kitchen and larger banquet dining area (despite

denying efforts to compete with restaurant facilities that are purely banquet halls).

With the 5,130 square foot addition, and absolutely no details presented concerning the

addition or its use, the testimony of the Moreci family and Scott Day can be fairly summarized as

supporting the neighbors’ position that Roberto’s intends to operate banquets in the addition. Not

only will the addition have accessible parking directly adjacent to a distinct entrance on the east

side of Roberto’s, but the kitchen will be enlarged from its suspect current configuration which

arose from construction that seemed to occur under the radar of “ordinary” fire and building code

review. If Roberto’s expands its main dining area by 500 square feet, constructs a singular

distinct dining area for banquets in 30% of the addition and uses no other areas within the

restaurant for banquets, the following vehicle counts are possible:

DINING AREA SQUARE FEET PATRONS KLOA (0.7;2.5) ITE/NYC (.86;1.8)

Restaurant 1930 (3800 Gr) 224 157 vehicles 193 vehicles

Restaurant New 500 50 35 vehicles 43 vehicles

Banquet* 1500 187 75 vehicles 104 vehicles

Patio 470 24 17 vehicles 21 vehicles

456 284 vehicles 361 vehicles

*Friday quality restaurant ITE rate applied to banquets could lead to 161 parking space demand

using slightly-lower-than-current dining patron density.

The above table excludes delivery vehicles and carry-out parking. The table assumes an easterly

expansion of the dining area, a large kitchen expansion, new ADA restrooms, ADA

improvements to the existing restrooms, new storage and a hall and foyer. Roberto’s provided no

interior floor plan. Note that the table continues to rely on a single-story building across the

property. (Even though Roberto’s has had roof issues in the past, and despite suggesting that it

may build a second story, doing so is not deemed likely in light of the expenses involved,

demand, and the lack of parking). Restaurants prefer that 60% of the interior be planned for the

dining and the above table is based on only 40% of the addition being comprised of dining.

The Zoning and Planning Commission partially recognized the concern for banquet

operations and inquired at hearing about the option to use valet parking. On-site valet parking for

Roberto’s is not possible. Spring Road is not capable of hosting a valet parking operation for

Roberto’s due to the use of seven on-street parking spaces for carry-out and the demand for other

on-street spaces. Additionally, even if Roberto’s could host valet operations, the City should

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mandate that no valet parking operation will occur east of the Moreci family buildings (either

vehicle loading or vehicle parking).

Roberto’s Parking Analysis

From the beginning, KLOA estimated parking required for the existing Roberto’s

restaurant without noting any change in use, any addition or any use of the vacant building east

of Roberto’s. Roberto’s and KLOA used a figure of 9,700 square feet in order to calculate trip

generation and parking demand. Scott Day used a building that was 10% larger than KLOA’s

estimate. Scott Day then relied on ITE data for gross floor area before improperly suggesting that

parking was proper under a gross leasable area analysis.

KLOA estimated that 59 parking spaces (59 spaces were not proposed) “will

accommodate up to 70% of the peak parking demand estimated to be generated by Roberto’s

Ristorante.” The estimated demand was 84-85 parking spaces. The restaurant hosts a quality

dining area (technical ITE classification) comprised of 3,300 square feet. Under the Elmhurst

Zoning Ordinance which does not exempt Spring Road from parking requirements, the interior

of the restaurant is required to have 38-39 parking spaces and the patio is required to have

another 9-10 spaces. Since the Moreci family is attempting to extend the parking waivers from

the CBC, CBOC and CBOCR districts, KLOA calculated parking demand based on published

standards from the Institute of Traffic Engineers and Urban Land Institute, but there is no

indication anywhere how it is that it did so other than to misclassify the restaurant. KLOA

believes that Roberto’s necessitates one parking space for every 60 square feet of gross floor

area. 84 spaces at one space for every 60 square feet of gross floor area leads to 5,040 square feet

if the same ratio was applied for the bar and restaurant areas. The carry-out and delivery

operation and restaurant (interior only) comprise slightly more than 5,040 square feet.

The table below summarizes the use, plan and parking progression from January 2021

forward:

Subject January 20 April 20 May 18

Site Parking Demand 84 (8/18/20 KLOA) 84-170 (KLOA) 284-361 (Plan B)

Parking Planned 59 (8/18/20 KLOA)

58 (10/16/20 Spaceco)

56 (1/19/21, Day, at 49)

56 58 (Plan B)

% Parking On Site 67% 35-70% 16%-20%

Banquets No growth mentioned Banquet location a rumor Expand banquet area

Gross Floor Area 5,040 SF 5,040 SF 10,170 SF

Live Entertainment Not mentioned Mischaracterization Undetermined

Scott Day testified under oath that Roberto’s has never had a conditional use permit for live

entertainment. The testimony that Roberto’s has a history of frequent live entertainment remains

uncontested. Yet, as noted below, the City has allowed a backdoor adjustment that escapes

proper hearing review (and was not susceptible to ordinary review by owners and tenants on

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Spring Road) because the Zoning and Planning Commission “forced” an Alternative Plan B on

the applicant that includes a doubling of the size of Roberto’s which eviscerates all the parking

and traffic testimony from KLOA.

As noted earlier, KLOA evaluated a plan that called for 59 parking spaces. (Page 8,

https://go.boarddocs.com/il/coe/Board.nsf/files/BVASWY72D0F5/$file/15%20KLOA%2020-

119%20Spring%20Road%20Business%20District%20Parking%20Evaluation%208-18-

2020%20bsm%20lra.pdf) In stating that these spaces would provide 70% of the peak parking for

Roberto’s, KLOA relied on a peak demand of 84 parking spaces and a ratio of one parking space

for each 60 square feet of gross floor area. The area of the Roberto’s building according to the

assessor is 6,975 square feet, but the building is usable only to the extent of +/-3,260 square feet.

According to the DuPage County GIS, the delivery component of Roberto’s and the restaurant

comprise slightly more than 5,000 square feet. This is consistent with backing out 5,040 square

feet from Page 8 of KLOA’s August 18, 2020 memorandum. On January 20, 2021, Scott Day

reported that 56 parking spaces would provide 61% of the peak parking demand—meaning that

the peak parking demand somehow increased from 84 to 91-92 parking spaces between August

18, 2020 and January 20, 2021. The mystery behind this math likely matters little, but the

conclusion Scott Day presented is critical:

The proposed parking lots will open 56 additional parking spaces for other businesses

within the business district….

(Day Slide Presentation, January 20, 2021, at 49) As argued by neighbors, this assessment was

false at the time. In the same slide, Mr. Day surmised:

The proposed parking lots will reduce the projected deficit in parking available for the

businesses along Spring Road.

Id. The neighbors also asserted that this was false. One page later, Mr. Day asserted that “parking

lots will reduce traffic circulation throughout the area” and “trips generated by Roberto’s are

existing on the roadway network.” Both of these assertions were false at the time.

The neighbors asserted that the analysis was flawed since Roberto’s is a multifacted

operation with significant delivery service, standard dining, bar dining, outdoor dining, banquet

dining and live entertainment with dancing. The neighbors asserted that the traffic report

mischaracterized Roberto’s and the applicant admitted this on April 20, 2021.

On January 20, 2021, Roberto’s presented Spaceco’s December 17, 2020 site plan with

56 parking spaces. There was no indication of the gross floor area of the restaurant or the

carryout and delivery area. There was no indication of the predicted parking demand and no

explanation of how Mr. Day surmised that the 56 parking spaces provided 61% of the parking

needed for Roberto’s. The plan contained no indication that there would be a partial demolition

and a substantial expansion of Roberto’s restaurant.

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As of January 15, 2021, KLOA was still reviewing the project as though 59 spaces were

proposed and 58 were depicted on the site plan—despite Spaceco’s December 17, 2020 plan

which depicts 56 parking spaces. As of January 15, 2021, KLOA stated:

Roberto’s Ristorante has a peak parking demand ranging from 92 to 169 vehicles

depending on the day of the week and on the resource utilized.

(https://go.boarddocs.com/il/coe/Board.nsf/files/BXARBY6B13D7/$file/KLOA%20Response%

20to%20comments.pdf) KLOA lowered its assessment that Roberto’s would provide 70% of its

parking on site to providing between 35% (59/169) and 64% (59/92). Id. In reaching its 61%

conclusion, KLOA used the 56-space plan and the lowest 92-space demand figure. KLOA never

mentioned an expansion of the restaurant or banquet facilities. These remained the circumstances

until April 20, 2021.

The neighbors presented their positions and evidence in February and March, leaving

Scott Day to provide a reply and conclude the presentation portion of the hearing. The hearing

closed on April 20, 2021. During the rebuttal, Scott Day provided what has come to be known as

alternate Plan B. There is no single document known to depict Alternate Plan B other than the

site plan pasted into Scott Day’s memorandum and presentation to the Zoning and Planning

Commission and Alternate Plan B seemingly arises only in the response memorandum. (Pages

25-26, at https://go.boarddocs.com/il/coe/Board.nsf/files/C25RJX6D6527/$file/04-16-

21%20Memo%20regarding%20Robertos%20Conditional%20Use%20Application%20for%20Eg

gleston%20Surface%20Parking%20Lots%20-%20FINAL.pdf) Alternate Plan B depicts 18

parking spaces in the north parking lot and 40 parking spaces in the south lot, or 58 total spaces.

While Alternate Plan B shows a parking increase compared to the plan presented on

January 20, 2021 and subjected to examination in February and March, Alternate Plan B also:

1. Calls for the demolition of 3,800 square feet east of the existing restaurant;

2. Adds 5,130 square feet of new restaurant building area and a new east entrance; and

3. Relocates accessible parking spaces and places an accessible route in a fashion that

indicates a future entrance at the southeast side of the new building.

Zoning and Planning Commission members Uditsky and Pittman specifically noted that

Roberto’s is the greatest demand on parking and the parking lot was a benefit, but their

statements were made in complete disregard of the circumstance that Roberto’s was also

increasing the demand for parking, leaving no benefit to anyone. While these statements might

be understood due to the volume of information and the omission of the Zoning and Planning

Commission in choosing not to focus on Roberto’s use when mandating Plan B, the statements

from a licensed realtor (Kevin Byrnes) are shocking since he is particularly aware that available

parking is a key component of any commercial lease or property transaction.

Indeed, while Mr. Byrnes stated that he studied numerous codes, he apparently missed

that communities typically require 11-16 parking spaces per 1,000 square feet for uses like

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Roberto’s and that this addition would lead to new demand for 86 spaces even under KLOA’s

analysis. Further, he also seems not to have reviewed the ITE manuals for either trip generation

or parking demand. He readily accepts Scott Day’s discussion of Spring Road as a “dense multi-

use urban” area, but the ITE manuals are very clear that Spring Road is not such an area:

In the area designated as dense multi use urban in the parking generation manual is a

fully developed area (or nearly so), with diverse and complementary land uses, good

pedestrian connectivity, and convenient and frequent transit. This area type can be a well-

developed urban area outside a major metropolitan downtown or a moderate size urban

area downtown.

The land-use mix frequently includes office, retail, residential, and often entertainment,

Hotel, and other commercial uses. The residential uses are typically multi family or

single-family on lots no larger than 1/4 acre. The commercial uses often have little or no

setback from the sidewalk. Because the motor vehicle still represents the primary mode

of travel to and from the area, there typically is on-street parking and often public off-

street parking.

The complementary land uses provide the opportunity for short trips within the dence

multi use urban area, made conveniently by walking, biking, or transit. The area is served

by significant transit (either rail or bus) that enables a high level of transit usage to and

from area development.

Compare the above description to the “general urban/suburban” setting described by ITE as

follows:

An area designated as general urban/suburban in the parking generation manual is an area

associated with almost homogeneous vehicle-centered access. Nearly all person trips that

enter or exit a development site are by personal passenger or commercial vehicle.

The area can be fully developed (or nearly so) at low-medium density with a mix of

residential and commercial uses. The commercial land uses are typically concentrated at

intersections or spread along commercial corridors, often surrounded by low density

almost entirely residential development. Most commercial buildings are located behind or

surrounded by parking.

The mixing of land uses is only in terms of their proximity, not in terms of function. A

retail land use may focus on serving a regional clientele or a service land use may target

motorists or passerby vehicle trips for its customers. Even if the land uses are

complementary, a lack of pedestrian, bicycling, and transit facilities or services limit non-

vehicle travel.

Additionally, in catering to Mr. Byrnes, Scott Day also commingled gross floor area and

gross leasable area. This was improper and the attorney’s statements cannot supersede those of

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the traffic professional on the matter who was already left in a hole by the fact that he had to

conduct studies during a pandemic when school was not in session and businesses were not open

or not fully open. The ITE provides the following concerning floor area:

Gross Floor Area (GFA) – the sum of the area of each floor level of a building (expressed

in square feet), including cellars, basements, mezzanines, penthouses, corridors, lobbies,

stores, and offices, that are within the principal outside faces of exterior walls, not

including architectural setbacks or projections. Included are all areas that have floor

surfaces with clear standing head room (6 ft. 6 in. minimum) regardless of their use. With

the exception of buildings containing enclosed malls or atriums, GFA is equal to gross

leasable area and gross rentable area. Occupied gross floor area refers to GFA within the

facility which is currently being utilized. If a ground-level area, or part thereof, within the

principle outside faces of the exterior walls is not enclosed, this floor area is considered

part of the overall GFA of the building. However, unroofed areas and unenclosed roofed-

over spaces, except those contained within the principal outside faces of the exterior

walls, should be excluded from the area calculations. For the purpose of parking

generation calculation, the floor area of all parking garages within the building should not

be included in the GFA of the entire building. The majority of the land uses in Parking

Generation Manual use GFA as an independent variable.

Gross Leasable Area (GLA) – the total floor area designed for tenant occupancy and

exclusive use, including any basement, mezzanines or upper floors, expressed in square

feet and measured from the centerline of joint partitions and from the outside wall faces.

For the purpose of parking generation calculation, the floor area of all parking garages

within the building should not be included within the GLA of the entire building. GLA is

the area for which tenants pay rent; it is the area that produces income for the property

owner. Occupied gross leasable area refers to GLA within the facility which is currently

in use. Leased space that is not in productive use is not considered occupied. In the retail

business, GLA lends itself readily to measurement and comparison and it has been

adopted by the shopping center industry as its standard for statistical comparison.

Accordingly, GLA is used in Parking Generation Manual for shopping centers. For a

specialty retail center, strip center, discount store and freestanding retail facility, GLA

usually equals GFA.

At Page 69 of his April 20, 2021 slide presentation, Scott Day presented Plan B.

(https://go.boarddocs.com/il/coe/Board.nsf/files/C25RJX6D6527/$file/04-16-

21%20Memo%20regarding%20Robertos%20Conditional%20Use%20Application%20for%20Eg

gleston%20Surface%20Parking%20Lots%20-%20FINAL.pdf, at 26)

(https://go.boarddocs.com/il/coe/Board.nsf/files/C29N2E5DBE77/$file/ZPC%20Public%20Hear

ing%20-%20Rebuttal%20-%2004-20-21%20-%20FINAL%20UPDATED.pdf, at 69) On April

20, 2021, while discussing Alternate Plan B, the City Attorney (Andrew Acker) commented: “I

think that the proposal by the applicant is single option, that he totally stated that the original

plan as submitted is what they're seeking. So obviously, you know, unless he changes that, that's

what we're proceeding under.” (Tr. Proc., at 154:20-155:3,

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https://go.boarddocs.com/il/coe/Board.nsf/files/C34NEF5DC118/$file/Transcripts%204.20.21.pd

f) Mr. Acker continued: “I believe that it's the applicant who controls the submission, and the

applicant indicated this evening that that original submission is what they're proceeding under.”

(Id. at 157:18-23) Member Snyder noted that the new alternative needed to be vetted more. (Id.

at 155:12) But the Zoning and Planning Commission only “vetted” Alternative Plan B during the

May 18, 2021 deliberation, fully ignoring that (a) Plan B contained a 5,130 square foot addition,

(b) the new plan called for more new demand on parking, and (c) the plan eviscerates any benefit

to Spring Road properties and businesses and actually burdens them even more. The Chair twice

refused to acknowledge the attorney for the neighbors when he attempted to raise the issue that

more vetting of this plan was required because it was never the subject of studies presented by

the applicant or examination at any public hearing. Indeed, on April 20, 2021, Plan B was not

even part of the application.

Scott Day indicated that the primary plan remained the plan submitted with the

application and openly admitted that Alternate Plan B called for immediate construction of the

5,130 square foot addition. (Id. at 122:18-123:11) Though he presented the plan as one which the

City would “force” upon the applicant, the applicant never amended the plan or the application,

never submitted updated parking and traffic studies and never provided an interior floor plan for

the addition. This glaring problem is exactly what concerned the neighbors who presented

uncontested factual testimony that Roberto’s had live entertainment which requires a conditional

use permit and an amended application. Further, the expansion by 5,130 square feet is exactly the

piecemeal approach that neighbors testified they were concerned about. Called rumors, the

neighbors’ assertion that Roberto’s was pursuing a banquet expansion is now a blunt reality as is

the vastly expanded dining area.

Perhaps the most remarkable circumstance is that Spring Road has been one of those

business districts that is controlled by parking availability which limits the character of

businesses to those that primarily serve the neighborhood and area. The Moreci family has

known for several years that it intended to expand its operations, but it did not do so because

there was not enough parking. Without new parking, the addition was not justified. The Moreci

family then sold you this new parking lot entirely on the false premise that it would benefit

everyone on Spring Road. It denied it was expanding banquet operations and did not address

testimony that the Moreci family has a plan to expand that has long been known. The plan

recommended by the Zoning and Planning Commission (Alternate Plan B) now includes an

expansion that leads to additional parking demand that threatens Spring Road.

Call to Action

The residents adamantly oppose the parking lots. They also believe that the City is

committing gross error in allowing Roberto’s to slip a 5,130 square foot addition into a

proceeding that opened with a feigned commitment by Roberto’s to use the proposed parking to

make up for existing operations that allegedly placed too great a burden on existing parking.

(Compare, however, the Borchert and Werner findings.) The restaurant will more than double in

floor area. Banquets will demand parking spaces for longer durations than a typical or quality

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restaurant. The new parking spaces were admittedly 35%-61 % of what might be required for existing conditions, but the new parking spaces will be a far smaller 16%-20% of the required number of spaces when considering the 5,130 square foot addition.

The Development, Planning and Zoning Committee of the City Council (Alderpersons Polomsky, Mulliner and Bastedo) will consider the matter next. The committee meets the second and fourth Mondays of the month. At the time of this letter, there was no indication from staff that the DP & Z Committee would have the proposed parking lots on the next agenda. As always, your City's leaders are happy to receive your input via meeting participation or direct emails or telephone calls. It is strongly recommended that any business owner or property owner who wishes to address the parking lots and Plan B act immediately to reach their alderperson by telephone or electronic mail. Additionally, please keep an eye on meeting protocols inasmuch as Mayor Levin has, thus far, continued to determine that in-person meetings are not practical or prudent at this time.

In the event you wish to learn more about the long term planning of those organized to fight the Roberto's parking lot development, please contact Grant Dungan at (630) 251-4122.

cc: Hon. Scott Levin, Mayor DP & Z Committee Members John Quigley Scott M. Day, Esq.

Yours very truly,

Mark W. Daniel

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