Should Montgomery County churches, if located in residential zones, be allowed to operate community commercial kitchens? I blogged the topic in A Community Commercial Kitchen for Takoma Park? but will take on a couple more points, Parking (and other disruption) and Operational requirements.
Brief background: Most residents who have contacted me support the Takoma Park Presbyterian Church’s plan to open a CCK. A zoning change would be needed, however, given the church’s location in an R-60 area, zoned for single-family housing. Churches may open in R-60 and other residential zones; the question is whether they should be newly allowed to operate CCKs.
Several residents expressed concerns to about parking and traffic impact. I don’t see a TPPC community commercial kitchen, or any church CCK, generating more than a couple of vehicle trips per hour, on average. In TPPC’s case, there is a 3-car zone marked with One Hour Parking signs, and other nearby streets require residential parking permits for daytime hours Monday to Friday. CK activity during the work day could not legally take street parking spots from residents. It would, however, affect Takoma Park Child Development Center parents and church visitors.
Other complaints about church-associated behavior relate to existing evening and weekend activities, when a church rents out a hall for events that attract large numbers of people and go on late into the night. Food for these events is brought in; CCKs are unrelated.
Concern two is that fear that a property owner will convert a single-family home into a church and open a commercial kitchen. I do not see significant risk of such conversions, in Takoma Park or elsewhere in the county. They would be uneconomical.
Consider Montgomery County’s licensure and operational requirements for commercial kitchens, wherever located. Excerpting from a page on the county’s Web site —
“Chapter 15, Montgomery County Code, 2004, requires that everyone who prepares, serves, sells, or gives away food to the public have a valid Montgomery County Food Service License. The only exception to this law is for the sale of fresh, whole produce or live crustaceans. At least one individual who has a current Montgomery County Certified Food Service Manager card must be present at all times when food is being prepared…
“All food that is prepared for sale or service to the public must be prepared at a licensed facility. A residential kitchen at a private home or apartment cannot be licensed for commercial use…
“When you make application for your [Montgomery County Food Service ] license, you will be asked to provide information concerning the types of food you intend to prepare, and develop a Hazard Analysis Critical Control Point (HACCP) type food preparation review for typical items on your menu…
“An initial operating inspection will be conducted prior to the issuance of a license, unannounced operational inspections will be conducted each year.”
County Certified Food Service Manager and Food Service Facility license applications are linked from another county Web page along with Maryland state HACCP guidelines, referenced above. They make me wonder if the CCP part (Cyrillic characters that stand for Soviet Socialist Republic) is coincidental.
These licensure, operational, and inspection requirements mean it is impossible to open a legal commercial kitchen casually.
(Someone willing to operate an unlicensed CK will ignore zoning restrictions.) Serious investment is involved, and remember the 5% space limitation on a CK per the proposed ZTA 11-08. A CK in a 2,000 sq.ft. property would be limited to 100 sq.ft., or 10’x10′ and couldn’t also be used for residential food preparation. A CK in 3,000 sq.ft. property would be limited to 150 sqft., or 10’x15′.
I conclude that no serious person is going to attempt to convert a house to a church in order to open a CK.
(No non-serious person will make it through the licensing & inspections.)