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ATT New Evidence Submitted During First Open Record Period
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ATT New Evidence Submitted During First Open Record Period
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Last modified
6/19/2015 4:11:17 PM
Creation date
6/18/2015 10:30:06 AM
Metadata
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Template:
PDD_Planning_Development
File Type
CU
File Year
14
File Sequence Number
3
Application Name
ATT AT CROSSFIRE
Document Type
Public Comments submitted after hearings official hearing
Document_Date
6/17/2015
External View
Yes
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a <br />r <br />intent as the Hearings official believes on locking the policy then and <br />forever to the definition of C-2 in the land use code. <br />The more obvious way to read this policy is that if the authors and <br />City Council intended to lock the policy to C-2 hand C-1~, they would <br />have simply said sa, This conclusion is supported by the fact that "C-2 <br />Community Commercial" is used explicitly in Policy 2 under the f <br />"Eastern I~esidentialJMixed Use Area" section on page 3-S, when fine <br />authors and Council wanted the policy tied to a zone, they reference <br />the zone explicitly. <br />The Hearings Official's selected references to the use of "C-2 General <br />Commercial" in non-immediate sections of the ~II~NP and a version of <br />code two years earlier than adoption of the wNP don't hold up well <br />under a more thorough examination. <br />The alternative interpretation has equal merit under a "text similarity" <br />analysis; but, more importantly, is more plausible and has a firmer <br />statutory foundation. <br />If the wNP policy referred to "C-2" or "the General Commercial <br />District" there would be no need to look further, but that's not the case <br />here. Statutory construction requires looking at the immediate contexts <br />first, when the text itself isn't sufficient. The WNP itself doesn't clarify <br />the term, and thus the next place to look is other elements of the <br />comprehensive plan, and here we find what we need. There is an <br />obvious correspondence between "general commercial uses" term in <br />the wNP and the "general [commercials activities" term found in the <br />1982 Nletrv Plan at page fIY~-4, <br />while the "general [commercial] activities" term appears under the <br />"Community Commercial Centers" Metro Plan category, it's clear from <br />examples above, that "Community Commercial" was in the minds of <br />the V1~'NP authors as they wrote the "Chambers Street Commercial • <br />Area" section, regardless of whether the authors were correct that this <br />was the C-2 zone title at the time the section was written or adopted. <br />Mast compelling is that the Metro Plan commercial categories form a <br />loose hierarchy, in which "Neighborhood Commercial Facilities" <br />includes the least intensive commercial activities, "Community <br />Commercial Centers" is the next "higher" category in terms of which <br />• ~ commercial activities it includes, and "Major Retail Centers" is at the <br />top of the hierarchy. Policy 1 under the "Chambers Street Commercial • <br />Area" section is clearly intended to encompass the Tower two . ; <br />categories, <br />Appeal Statement ~ 11-3 15 • . August 1b, Zg11 ' <br />• PC Agenda -Page 24 <br />
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