Highland Park City


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



TO:               Plan and Design Commission

FROM:              Jaemi Jackson, Planner II             

DATE:              May 7, 2019

RE:              Continuation of the Public Hearing for 1535 Park Avenue West Planned 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. This is a three-part application that includes the following:


  1. Planned Development for a Senior Housing Facility (Case #18-11-PUD-011)
  2. Zoning Map Amendment from I – Light Industrial District to RM1 – Medium-to-High Density Residential District (Case #18-12-REZ-002)
  3. Special Use Permit to allow “Nursing Home Care” as Conditional Use in RM1 District, which permits the Assisted Living and Memory Care Units (Case #18-12-SUP-004)


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. Updated Project Rendering With Flat Roof


Prior Commission Consideration

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.

On April 2, 2019, the applicant presented revised materials, as well as provided additional information. The applicant received feedback and questions from the Commission that addressed the following items:

  1. Consideration to reduce the height of the principal structure.
  2. Inclusionary Housing application summary.
  3. Information about the staffing and operations (total employees, how many employees change at shifts, special care givers, and drop-off/pick-up times for school buses).
  4. Parking utilization.
  5. Summary of how many trees are proposed for removal, replacement, etc.
  6. Additional renderings that show the same seasons for existing and proposed.
  7. Additional information regarding environmental hazards on-site, if any.


Information regarding the previous Public Hearing meetings can be found in the agenda packets linked below:

·         Pre-Application Discussion, November 20, 2018


·         Public Hearing, March 5, 2019


·         Public Hearing, April 2, 2019


It was brought to staff’s attention that Attachment N was not included within the packet. This attachment has been included as part of this report as Attachment O.


Revised materials

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


1. Building Height & Design

Based on discussion and input from the Plan and Design Commission and the public, the applicant revised the building design from the use of pitched roofs to flat roofs. The revised design effectively lowers the height of the principal structure; however, it still requires zoning height relief. In addition, the garages on the east side of the property have also been revised to lower their overall height. Refer to pages 9-21 in Attachment A for the revised elevations.


Table 1. Height


RM1 District



Proposed Height
March 5, 2019

Revised Height

April 2, 2019

Revised Height

May 7, 2019

Requested Relief

Principal Structure

35 ft

39 ft

42.33 ft

38.0 ft

3.0 ft

Accessory Structure

15 ft

16.75 ft

17.91 ft


1.08 ft



2. Inclusionary Housing

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, amendments to Article 21 are currently going through the PDC-led public hearing process, at the direction of City Council, to allow 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 and zoning relief is necessary.


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

1) Provide a portion of the required affordable units on site

2) Pay a fee-in-lieu for the remaining 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.


At the time of this report, the Applicant submitted an Inclusionary Housing Application that will be reviewed by the Housing Commission at its June 5, 2019 meeting. The Inclusionary Housing policy requires 20% of the 75 independent living units (prior to the density bonus[1]) to be allocated as affordable units, or a total of 15 units, per Sec 150.2102 (B). The applicant is requesting a market rate bonus of four (4) units in exchange for providing eight (8) units on-site and a request for seven (7) units fee-in-lieu. This would make the total number of on-site independent living equal 87 units (75 base units + 8 affordable units + 4 bonus units). A summary of the application is included as Attachment B.


3. Staffing & Operations

Allegro, the operator of the proposed development, provided information with regard to staffing and operations of its facilities, based on surveys from 6-8 similar developments (Attachment C).


Third-Party Health Providers

Generally, the facilities have an average of 10 third-party caregivers on-site on weekdays, and 5 on weekends. These third-parties provide a range in services from X-ray, Physical Therapy, Occupational Therapy, Private Duty, Hospice, pet sitting, wound care, blood draws for off-site testing etc. Allegro allows residents to select outside providers for care matters that either exceed the abilities of the facility or are of a unique or one-time need as dictated by their medical advisor.


Staff Changes

Allegro provided a typical staffing model (Attachment D) that shows the total staff by shifts (arriving and leaving) and that will be onsite at one time. While the facility may have up to 42 staff members onsite at a given time, the maximum number of people both leaving and arriving at the facility for work is limited to a maximum of 14 people at 8:00 AM on weekdays. North Shore School District 112 buses picking up students headed to Wayne Thomas School are generally within the vicinity of the project site between 8:07 and 8:14 AM (Attachment E). Drop-off times are generally around 3:00 PM according a District representative.


4. Parking Utilization

Based on a review of 13 communities managed by Allegro, 12.5% of the Assisted Living residents have a personal vehicle and 31.5% of the Independent Living residents have a personal vehicle (Attachment C). These numbers help to support the parking utilization rates presented at the April 4, 2019 Public Hearing. Further, Allegro states that their communities “generally do not have any challenges with sufficient parking at either peak or off-peak periods.” As noted in previous staff reports to the Plan & Design Commission, the proposed development meets all off-parking requirements under Article 8 of the Zoning Code.


5. Trees

The applicant provided a detailed chart that indicates the number of current and proposed trees. See Attachment A, page 42. The numbers below reflect conformance to Article 22 of the Zoning Code (Chapter 150) and Chapter 94 of the Municipal Code.

Table 2. Tree Summary (from Kimley-Horn and Associates)



Current Conditions

Future Conditions



Trees to Remain




Tree to remain

Buffer Trees to Remain




Trees to be removed – good forestry*




Trees to be removed

Protected trees to be removed**



Replacement Canopy Trees




New Trees

Replacement Evergreen Trees


New Canopy Trees


New Evergreen Trees


New Ornamental Trees






* Trees removed for good forestry practices do not require replacement due to undesirable tree species, poor condition, and disease.

** Protected trees to be replaced at a 2:1 ratio. 218 trees required. Due to sizing and siting of trees to allow for proper spacing and healthy growth, 136 replacement trees are proposed. Remaining replacement to be addressed through fee-on-lieu.


6. Additional Renderings

Figure 3. Existing and Proposed View from Park Avenue Traveling West

The applicant submitted additional renderings that illustrate the proposed landscape plan and building design. These renderings show seasonally-appropriate before and after images. The full set of renderings can be found in Attachment A on pages 35-37.


7. Environmental Review

The applicant completed Phase 1 and Phase 2 Environmental Studies. No buried machinery was identified on the site.



The site at 1535 Park Avenue West is located within the Skokie Highway Corridor District of the Master Plan. While the description of the Northwest District in the Neighborhood Strategic Plan seems to indicate the site is within the planning area, master planning area descriptions are general in nature, and supplemented by visual aids to illustrate the exact boundaries. Page 3 of the Neighborhood Strategic Plan for the Northwest District provides an overall map of the City’s planning districts, which shows the project site within the Skokie Highway Corridor District (Attachment F, Page 1). In addition, page 5 illustrates that the site is not included within the Northwest District (Attachment F, Page 2). As such, the site would fall under the policies written under the Skokie Highway Corridor District.



Figure 4. Map of Master Plan Neighborhood Planning District - Subject Site is outlined in Red


Summary of Proposed Zoning Relief

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 revised building design.


Table 3. 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

38 ft

Article 7

Maximum Height., Accessory Structure

15 ft

16.08 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.


It should be noted that the application meets or exceeds the applicable requirements of Chapter 150, outlined in the table below:


Table 4. Zoning Code Compliance

Zoning Code Section



Article 6

Lighting Performance Standards

Meets requirements

Article 5 and Article 7

Area, Bulk, and Density

Meets requirements except for height and side yard setbacks as noted above

Article 8

Off-Street Parking and Loading

Exceeds requirements

Article 22

Landscape Planting and Screening

Meets requirements



Public Testimony

The April 4, 2019 Public Hearing included testimony from 12 members of the public, some of whom submitted material to the Plan and Design Commission. These are included as Attachments G, H, I and J. Following the April 4, 2019 Public hearing, staff received additional input, which are included as Attachments K, L, M and N.



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.


Standards for Review

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

4)      Design Review

a.       Sec. 176.045(D)(2). Design Review Standards for a Certificate of Design Review Approval

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


Staff recommend the Commission direct staff to draft Findings of Fact recommending approval or denial of the request. Findings must be directed for the following elements:


1)      Planned Development

2)      Special Use “Nursing Home Care” facility

3)      Zoning Map Amendment to change the property from I – Light Industry zoning to RM1 – Medium to High Density Multifamily

4)      Design Review Standards for a Certificate of Design Review Approval


The standards for each of these elements of the application are provided in Attachment P.  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] Section 150.2106 allows for a density bonus of one market rate unit for each affordable housing unit that is provided. No density bonuses are provided for payments of fee-in-lieu units.