Highland Park City


Continuation of Public Hearing #18-11-PUD-011 for a Special Use in the Nature of a Planned Development for a Senior Housing Facility Consisting of 87 Independent Living Units, 55 Assisted Living Units, and 20 Memory Care Units at 1535-1549 Park Avenue West


Department:Community DevelopmentSponsors:
Category:Planned Unit Development



The property at 1535 Park Avenue West, often referred to as the Greenburg Radiology Site, is a 7.48-acre (325,638 SF) parcel located west of US 41. Trammell Crow, a Dallas-based real estate development group, is proposing to construct a senior living facility on the site that includes independent living, assisted living, and memory care. The building program includes 87 independent living units, 55 assisted living units, and 20 memory care units, for a total of 193 beds in 162 suites/units. The building features several dining areas, a swimming pool, and walking paths. The proposal requires rezoning site from a light industrial zoning district to a multi-family zoning district.


Table 1. Project Summary Information

Project Description:

3-story, 193-bed, senior living facility


Planned Development, Special Use Permit, Zoning Map Amendment

Applicant/ Property Owner

Trammel Crow Chicago Development, Inc.

Site Location

1535 Park Avenue West

Current Zoning:

I – Light Industrial

Proposed Zoning

RM1 -  Medium to High Density Residential

Current Use

Vacant Medical Facility

Proposed Use

Multi-family dwelling and Nursing Home Care (Conditional Use in RM1 District)





Figure 2. Project Rendering





The Plan & Design Commission discussed this redevelopment project in a pre-application context at the November 20, 2018 meeting. After revising the plans to address comments from the Commission, the project was reviewed and discussed at the March 5, 2019 Public Hearing. The applicant received feedback and questions from the Commission that addressed the following items:


  1. Latest market study report submitted to staff on March 5, 2019.
  2. Additional information regarding on-site stormwater management and detention. 
  3. Additional information about the retaining wall on the east side of the property.
  4. Delivery schedule.
  5. Facility staffing will be at the facility and how it is consistent/inconsistent with industry standards.
  6. Overflow parking plan for high volume days/events.
  7. Cost of development.
  8. Additional exhibits that address site design and character.  
  9. Additional exhibits that shows landscaping and screening.
  10. Updated public benefit associated with the development.



The applicant submitted revised materials in response to the Plan and Design Commission. These items are discussed below.


1. Market Study

The applicant commissioned a market study for the proposed senior living facility at 1535 Park Avenue West. A market study analyzes the market demand for a specific type of real estate product. The study, prepared by CBRE, concludes that, “there is high demand for senior housing” and “Robust growth for senior demographics is expected over the foreseeable future.” The full report is included as Attachment A. Further, the applicant commissioned an additional market study from Jones Lang LaSalle. This report also concludes that there is sufficient unmet demand to support additional assisted living, memory care, and independent living to support the project. This report is included as Attachment B.


2. Stormwater Management

During the Public Hearing, there were concerns about stormwater management of the site and the potential for flooding. The City of Highland Park reviewed the preliminary engineering drawings submitted as part of the March 5, 2018 Public Hearing and confirmed that the stormwater management system, including compensatory storage and release rates, meet the City code and Lake County Watershed Development Ordinance (WDO) requirements to adequately mitigate potential stormwater runoff.


The applicant provided a Preliminary WDO REPORT, which evaluates the pre-and post-development stormwater requirements of the site to provide compliance with the City of Highland Park and the WDO. The applicant states that the proposed development exceeds the stormwater requirement for compensatory storage, providing more flood plain storage than required. The proposed stormwater detention system will include an additional 7% of stormwater detention and an additional 80% of volume control storage (see Attachment C and Attachment D). The report and updated preliminary engineering plans are included as Attachment E and Attachment F. The Engineering Division will review final drainage and grading plans for the project when they are submitted as part of the final development plan.


3. Retaining Walls

The proposed development includes retaining walls on the east and west of the site. The applicant revised the plans to include a headlight screening fence at the retaining wall. The proposed west side fence is 3’2” in height, and the retaining wall will not exceed 5’4”. The proposed designs are shown below and included in Attachment G.


Figure 4. West and East Retaining Wall Design


4. Delivery Schedule

The applicant provided the following schedule of deliveries and services for the proposed facility, which will be scheduled to avoid peak drive times:

·         Maintenance 1/week

·         Linen provider 1/week

·         Housekeeping 1/month

·         Food in larger truck - 2/week

·         Fresh produce 6 days/week

·         Other deliveries for supplies would be 1/month for Assisted Living and Memory Care


5. Facility staffing

The applicant notes that staffing will be consistent with industry standards. Care staff will be provided based on the care needs of the residents. Care staff hours are scheduled from 7:00 AM – 3:00 PM (8 care staff), 3:00 PM - 11:00 PM (8 care staff), 11:00 PM – 7:00 AM (5 care staff).


6. Overflow Parking Plan

The proposed development includes 190 off-street parking spaces. The applicant estimates that 170 stalls will accommodate all residents and guests at maximum capacity during holidays and special events. Based on utilization of similar facilities the applicant estimates nearly 80 stalls will be available on a regular basis (Table 1).


Table 1. Parking Utilization Estimate

Unit Type/Use

Estimated Utilization Rate

Estimated Parking Need

Independent Living



Assisted Living



Staff Max at Shift Change









(of 190 provided)


7. Cost of Development

The estimated cost of the development is approximately $40 million. In addition, the Commission had questions with regard to the Fiscal Analysis, specifically related to the Building Assessed Value in comparison to previously reported values by staff for multi-family developments (See the March 5, 2019 Plan and Design Commission Staff Report[1] Attachment II for the Fiscal Analysis). In the February 5, 2019 Plan and Design Commission Staff Report[2] regarding industrial land use in the City, staff calculated the average property tax revenue of newer multi-family development in the City at $10.89 per square foot (2017). These numbers were based on the total land area of the development for the purpose of comparing them to the average property tax revenue of industrial areas. The “$35.58 Building AV/sf Bldg” number presented in the Fiscal Analysis is the average Building Assessed Value per square foot of comparable buildings. The numbers are divergent because they are measuring different values.


8. Additional Exhibits - Site Design and Character

The applicant submitted several “existing and proposed views” of the site to better illustrate the design impact to the surrounding area (Attachment H). Also included are night renderings to demonstrate the lightshed of the proposed development. As noted in the March 5, 2019 staff report, the proposed lighting for the project complies with zoning code performance standards of Section 150.605.


Figure 5. Existing and Proposed View from Park Avenue Traveling West

The applicant submitted additional architectural exhibits that demonstrate three build-out scenarios based on the current I – Light Industrial Zoning. The massing study shows a typical grocery store, motor vehicle salesroom and repair business, and a freight and parcel terminal (Attachment I).


8. Additional Exhibits -  Landscaping and Screening

The applicant provided exhibits to better illustrate the proposed landscape plan, which has been revised to add an additional 53 trees for additional screening (Attachment J). The location of the added evergreen and canopy trees are shown in Attachment K. An illustrative Landscape Plan is included as Attachment L. In addition, new section graphics demonstrate the scale of planting and screening (Attachment M).


Figure 6. Section view of Park Avenue West


9. Updated Public Benefit

Section 150.515(B) of the Zoning Code establishes the requirement to provide a public benefit as part of a Planned Development when zoning relief is requested. The proposed public benefits shall be commensurate with all zoning relief requested by the applicant, and proportional to the anticipated impact of the proposed Planned Development on adjacent properties and land uses and on the community at large.


The applicant proposes to increase connectivity and enhance and support the character and vitality of the neighborhood by constructing a new sidewalk on the north side of Park Avenue from the west property line to the east property. In addition, the applicant will work with the City to extend the sidewalk from the east property line across the train tracks.


In consideration of the additional request for zoning relief with regard to Inclusionary Housing (see below), the Applicant proposes an additional public benefit that includes increased stormwater management. As noted above, the applicant proposes to increase the required stormwater detention by an additional 7% of and an additional 80% of volume control storage.



In addition to the feedback provided by the Plan and Design Commission, staff and the applicant have provided additional material regarding the project.



Upon further review of City Code, the applicant has revised their plans based on the City’s definition of average grade, impacting the measured building height. Section 150.202 defines “Grade or Grade Level” as:


The average elevation at the corners of the smallest polygon formed by the intersecting lines of: the minimum required front yard, rear yard, side yard, subdivision setback lines, and steep slope setback lines (excluding established front yard setback lines) on a legal lot of record; and, which polygon is entirely outside of a steep slope zone. If the required yards and subdivision setback lines do not intersect to form "corners" (e.g., as in a circular shaped lot), then grade shall be the average elevation measured in five-foot intervals along the smallest continuous boundary of buildable area formed by required yards, subdivision setback, and steep slope, excluding established front yard setback lines. Grade shall be established prior to any development, demolition, or issuance of a drainage and grading permit or tree removal permit.


Revising the elevations based on the newly calculated average grade increases the overall building height as measured from the average grade, since the site is slightly elevated near the building and lower at the corners at which grade is measured (See Attachment N). It should be noted that the height of the buildings has not increased since presented at the March 5, 2019 public hearing. As such, visual impacts including shadows, are not affected. In addition, the applicant lowered the overall height of the garages by 2 feet, but due to the average grade measurement, the height relief has increased. Height diagrams showing how the average grade changes the measurement of the building height are included as Attachment O.


Table 2. Height

RM1 District



Proposed Height
March 5, 2019

Revised Height

April 2, 2019

Requested Relief

Principal Structure

35 ft

39 ft

42.33 ft

7.33 ft

Accessory Structure

15 ft

16.75 ft

17.91 ft

2.91 ft



FSCI Review

FSCI, a third party consultant specializing in fire, building, and life safety, provided initial review comments to the Applicant in a letter dated February 11, 2019 (included in the March 5, 2019 Public Hearing Packet). The Applicant submitted a response to address the comments, which were again reviewed by FSCI. In a letter dated March 27, 2019 (Attachment P), FSCI recommended the City conditionally approve the development, on the condition that several items meet specific life safety and building code requirements, which are reviewed by staff as part of the building permit process.


Emergency Call Data

To better additional information about the potential for emergency calls to the proposed development, staff has provided data about two existing senior living facilities. The data was provided by the City of Highland Park Fire Department and Police Department. Over the period of a year (from November 29, 2016 to November 29, 2017) the following emergency calls have been made to these two facilities, as shown in the Table 3: Emergency Call Data below. The details for this data are included in this report as Attachment Q.


Table 3. Emergency Call Data

Facility Name

Facility Type



Fire Visits

Police Visits


Avg/ week

# of 911 calls from total


Silverado Senior Living

Assisted Living, Memory Care

1651 Richfield Avenue








Sunrise of Highland Park

Assisted Living, Memory Care

1601 Green Bay Road











The applicant is proposing a total of 87 independent living dwelling units and Article 21 of the Code - Inclusionary Housing applies to only this portion of the project. The applicant requests variation from Article 21 to provide a portion of the required inclusionary units on-site and provide a payment-in-lieu of the remaining required inclusionary units in order to satisfy the balance of the inclusionary housing requirement. The applicant also requests a variation to obtain market rate credit for the units provided on site.  Article 21 requires that all affordable units be provided on-site for a development to realize any market-rate unit bonuses and does not allow both a payment-in-lieu and the provision of on-site units to be used in tandem to fulfill the inclusionary unit requirement.


Although Article 21 of the City Code does not allow the concurrent use of payment-in-lieu and on-site affordable units, amendment to Article 21 is currently going through the PDC led public hearing process, at the direction of City Council, to include this bifurcation along with other proposed amendments to Article 21. However, until the proposed amendments to Article 21 are fully vetted through the public hearing process and are formally adopted by City Council, the current Article 21 ordinance stands in force.


The applicant is requesting a variation from Article 21 to allow them to:

1) Provide some affordable units on site

2) Pay for some affordable units

3) Obtain market rate unit credit for the affordable units provided on site.


If the applicant’s request for variation from Article 21 is granted, the Applicant will work with staff and the Housing Commission to determine the number of affordable units that will be provided on-site and the number that will be payment-in-lieu.




The requested areas of zoning relief for Article 7 have not changed from the March 5, 2019 Public Hearing; however, the degree of height relief has changed based on the newly calculated average grade.



Table 4. Summary of Proposed Zoning Relief

Zoning Code Section




Article 7

Minimum Side Yard, Accessory Structure Setback - East Side Yard

20 ft

3.7 ft

Article 7

Minimum Side Yard, Vehicular Use Area Setback - East Side Yard

20 ft

2.7  ft

Article 7

Maximum Height, Principal Structure

35 ft

42.33 ft

Article 7

Maximum Height., Accessory Structure

15 ft

17.91 ft

Article 21

Inclusionary Housing, On-Site/Fee-in-Lieu Split

100% affordable units on site

1) Provide some affordable units on site

2) Payout some affordable units

3) Obtain market rate unit credit for the affordable units provided on site.




The Public Hearing included testimony from 16 members of the public, some of whom submitted material to the Plan and Design Commission. These are included as Attachments R, S, and T. Following the March 5, 2019 Public hearing, staff received additional input, which are included as Attachments U, V, W, X, Y, Z, and AA.


With regard to public testimony given at the March 5, 2019 Public Hearing and provided thereafter, some statements require clarification in order to eliminate any misinformation about the project:


·         Pubic testimony submitted notes that, “The parking lot will be only 4’ from the property line of the Grange Rd. homeowners.” The parking lot on the west side of the site, the side that abuts property on Grange Road, is located 16’ from the property line and the required setback is 15’.

·         Public testimony at the March 5th meeting indicated that a Fire Department official stated Park Avenue West would require major upgrades. The City of Highland Park Fire Department Chief confirmed to staff that a resident had spoken to the Deputy Fire Chief; however the conversation involved the potential for increased traffic on McCraren Road when the Fire Department responds to calls, but made no mention to any infrastructure upgrades to Park Avenue.

·         Public testimony submitted referenced that the site falls under the Northwest Neighborhood Planning District. Under the City’s Master Plan, the subject property is located within the commercial and industrial-oriented Skokie Highway Corridor District, not the more residential Northwest Neighborhood Planning District.



The redevelopment of the 1535 Park Avenue West property will be processed as a Planned Development, which is a type of Special Use and requires a public hearing process. The Public Hearing is in conjunction with an application for a zoning map amendment and Special Use Permit for a Conditional Use. The Plan and Design Commission shall consider the proposed amendment of the Official Zoning Map prior to consideration of the Planned Development application (Section 15.530(C)). The Exterior design features, including the building design, lighting, landscaping, and signs on the property are subject to design review approval, as well. The Housing Commission will provide input on the inclusionary housing plan.


The applicants are electing to go through the two-stage PUD approval process. This allows PDC and City Council approval of a Preliminary Plan, followed by a Final Plan that is reviewed for substantial compliance with the approved Preliminary Plan. The City Council has final authority in approval of planned developments.



As an application for rezoning from I – Light Industrial to RM1 - Medium to High Density Residential District; a new multifamily development being processed as a Planned Development; and as a Special Use Permit to permit the Nursing Home Care Facility land use as Conditional Use, Findings of Fact for the 1535 Park Avenue West project will include the following standards:

1)      Zoning Map Amendment

a.       Sec. 150.1505. Zoning Amendment Standards

2)      Planned Development

a.       Sec. 150.520. Site Planning Constraints and Design Standards

b.       Sec. 150.1404. Standards for Special Uses

3)      Special Use

a.       Sec. 150.1404. Standards for Special Uses

Design review standards in Chapter 176 “Design Review” will also be applicable. All of these standards are listed as Attachment BB to this report.



Staff recommend that the Plan and Design Commission continue the public hearing, hear public testimony and discuss and deliberate on the proposed planned development at 1535 Park Avenue West.


The Commission can continue the public hearing if more time is needed for testimony or deliberation.  Alternatively, if appropriate, the Commission can direct staff to draft Findings of Fact recommending approval or denial of the request. The Findings will be presented to the Plan & Design Commission at a future meeting for approval, then transmitted to the City Council for final consideration.


[1] http://highlandparkil.iqm2.com/Citizens/Detail_Meeting.aspx?ID=2442

[2] http://highlandparkil.iqm2.com/Citizens/Detail_LegiFile.aspx?Frame=&MeetingID=2440&MediaPosition=&ID=3514&CssClass=