Narrative Justification

1 | P a g e 
 
Morton Rock Kappa, LLC 
7520 E. Edgemont Ave 
Scottsdale, AZ 85257 
408-504-6959 
 
 
Narrative Addendum – MZO Section 11-73-3 
 
La Jolla Villas 
1500 E. Dana Avenue 
Mesa, Arizona 
Application No. BOA26-00502 
 
I. 
Response to Planning Comment No. 4 – SCIP Findings 
This Narrative Addendum is submitted in response to Planning Comment No. 4 
requesting documentation addressing the findings required for a Substantial 
Conformance Improvement Permit ("SCIP") under Mesa Zoning Ordinance 
("MZO") Section 11-73-3. 
 
This application seeks reapproval of a previously approved SCIP and 
associated site plan after the prior approvals expired. The current owner 
purchased the property after the expiration of those approvals. The proposed 
development, site layout, and improvements remain substantially consistent with 
the previously approved plans and continue to satisfy the findings required under 
MZO Section 11-73-3. The Applicant respectfully submits the following findings 
in support of the requested SCIP.  
 
II. 
A. The Entire Development Site Will Be Brought into Substantial 
Conformance 
The proposed project will bring the overall development site into substantially 
greater conformance with the Mesa Zoning Ordinance through improvements to 
both the existing development and the proposed new construction. 
The project includes, among other improvements: 
• Construction of eight new multifamily residential units.  
• Replacement of the existing unmarked gravel parking area with a paved 
parking lot meeting current design standards.  
• Installation of accessible parking, covered parking, bicycle parking, 
pedestrian walkways, landscaping, perimeter screening, drainage 
improvements, retention facilities, lighting, and upgraded site infrastructure.

2 | P a g e 
 
Collectively, these improvements substantially increase the site's compliance with 
current development standards while preserving the existing residential use and 
improving the overall quality of the property.  
III. 
A.1 No Demolition or Reconstruction of Existing Buildings 
Approval of the SCIP does not require demolition or reconstruction of the existing 
apartment buildings in order to achieve substantial conformance. The existing 
residential buildings remain in place while the site is substantially improved 
through new construction and site improvements. Only an old garage and patio 
cover identified on the approved plans are to be removed to improve compliance. 
IV. 
A.2 No Cessation of an Existing Conforming Use 
The existing multifamily residential use will remain in continuous operation. The 
proposed improvements do not eliminate or preclude any lawful existing or 
permitted use of the property. Instead, the project enhances and expands the 
existing residential development. 
V. 
A.3 No Creation of New Non-Conforming Conditions 
The proposed project does not create any new non-conforming conditions. Rather, 
it substantially reduces existing site deficiencies by improving parking, circulation, 
landscaping, drainage, open space, pedestrian access, screening, and other site 
improvements while preserving only those existing non-conforming conditions that 
cannot reasonably be corrected without demolition of existing buildings. 
 
VI. 
B. Compatibility with Adjacent Properties and Neighborhood 
The proposed improvements are fully compatible with the surrounding 
neighborhood and will enhance the overall appearance and function of the 
property. 
The project provides: 
• Modern multifamily residential architecture consistent with the surrounding 
area.  
• New landscaping and perimeter screening.  
• Improved parking and circulation.  
• Enhanced pedestrian connectivity.  
• Upgraded utilities, drainage, lighting, and other site improvements.  
These improvements significantly improve the existing property and will not be 
detrimental to adjacent properties or the surrounding neighborhood. Instead, the 
project modernizes an underutilized site, enhances neighborhood aesthetics, and 
provides additional quality housing while maintaining the existing residential 
character of the area.

3 | P a g e 
 
VII. Conclusion 
The Applicant respectfully submits that the proposed development satisfies each of 
the findings required by Mesa Zoning Ordinance Section 11-73-3 for approval of 
a Substantial Conformance Improvement Permit. The proposed project brings the 
property into substantially greater conformance with current zoning standards 
without requiring demolition of existing buildings, and without interrupting the 
existing lawful residential use. The proposed improvements further result in a 
development that is compatible with and beneficial to the surrounding 
neighborhood. 
Accordingly, the Applicant respectfully requests approval of the requested 
Substantial Conformance Improvement Permit (SCIP). 
 
Best regards, 
 
Albert Penilla 
Morton Rock Kappa, LLC 
Officer of Owner