In summary, the City should not be pressing for the right to apply the TIA standards in the <br />future. These are the kinds of standards that are anathema to the Needed Housing Statute, aside <br />from being off the table under the Goalposts Statute. <br />Dated: July 22, 2016. <br />Respectfully submitted, <br />ogee ~ ua w <br />Bill Kloos <br />Attorney for Applicant <br />Enclosure <br />APPLICANT'S FINAL ARGUMENT - Page 7 <br />Cathedral Park (CU 02-4) Record July 2016 <br />