Appeal Materials (2) - Laserfiche WebLink

(2) Avoid conversion of natural resource areas designated in the Metropolitan Area General Plan to urban uses when alternative locations on the property are suitable for development as otherwise permitted. b. Proposed buildings, road, and other uses are designed and sited to assure preservation of significant on-site vegetation, topographic features, and other unique and worthwhile natural features, and to prevent soil erosion or flood hazard. 1. Our March 5 Spreadsheet of Standards and Hearing Letter explains why the elements of this standard are not clear and objective and therefore make it inapplicable. 2. The Staff Report at 20 addresses this standard in a competent fashion; we recommend those findings to the HO. 3. This standard was a focus of opposition. The opposition assumes, without any evidence related to this site, that there are rare, sensitive and vulnerable animal species on this site that would be impacted by this development. There is no expert evidence to support this; it is a working assumption by opposition. In addition, opposition is assuming that the code reference to "natural features" encompasses animals. That term is not defined. in the code, as noted in our March 5 Spreadsheet of Standards. That assumption is not consistent with the ordinary meaning of the term "natural features." (b) Tree Preservation. The proposed project shall be designed and sited to preserve significant trees to the greatest degree attainable or feasible, with trees having the following characteristics given the highest priority for preservation: 1. Healthy trees that have a reasonable chance of survival considering the base zone or special area zone designation and other applicable approval criteria; 2. Trees located within vegetated corridors and stands rather than individual isolated trees subject to windthrow; 3. Trees that fulfill a screening function, provide relief from glare, or shade expansive areas of pavement; 4. Trees that provide a buffer between potentially incompatible land uses; 5. Trees located along the perimeter of the lot(s) and within building setback areas; 6. Trees and stands of trees located along ridgelines and within view corridors; 7. Trees with significant habitat value; 8. Trees adjacent to public parks, open space and streets; 9. Trees located along a water feature; 10. Heritage trees. 1. Our March 5 Spreadsheet of Standards and Hearing Letter explains why the elements of this standard are not clear and objective and therefore make it inapplicable. The standard calls for a APP C - Final Argument 4.6.2018