4. Finally, to the extent that any of the SHS policies do apply, the Staff Report at 8-15 has gotten <br />it right in its review of each policy and its finding of compliance. <br />We offer the following additional comments with respect to the specific SHS policies addressed <br />in the Staff Report: <br />The policies related to "Development Standards" are prefaces with the directive to <br />"encourage." That limitation makes the policies non-mandatory standards for this <br />decision. <br />The policy to "encourage clustering of open space elements of different developments" is <br />also written in non-mandatory terms. <br />The policy requiring that balancing of "public and private interests" is more subtle than is <br />usually recognized. The City has a keen public interest, as stated in the Goal 10 <br />provisions of the comprehensive plan, in providing housing for the city's growing <br />population. <br />Laurel Hill Plan <br />1. Our March 5 Spreadsheet of Standards identifies three policies that are relevant, but explains <br />why they may not be applied because they are not clear and objective or they do not state a <br />mandatory standard. <br />2. The Staff Report at pages 16-18 addresses the same three Laurel Hill Plan policies and <br />explains why this proposal complies. The Staff Report also address several additional policies - <br />Transportation Policies 1, 2 and 4, and East Laurel Hill Area Policy 6. None of these appear <br />directly applicable to this proposal. To the extent that any of the policies addressed in the Staff <br />Report can be applied, the applicant supports the staff's findings of compliance. <br />3. Opponent Jason Brown quoted Laurel Hill Plan Land Use Policy 1 in support of his complaint <br />that future dwellings would be visible from the Ribbon Trail. The referenced policy relates to <br />residential density and discouraging large apartment complexes. These policies do not relate to <br />views from the Ribbon Trail. <br />EC 9.8320(3) The PUD will provide adequate screening from surrounding properties <br />including, but not limited to, anticipated building locations, bulk, and height. <br />1. Our March 5 Spreadsheet of Standards and Hearing Letter explains the "adequate" standard <br />makes this standard less than clear and objective and therefore not applicable. <br />2. The Staff Report at 18-19 addresses this standard in a competent fashion; we recommend <br />those findings to the HO. <br />APP C - Final Argument 4.6.2018 <br />