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Appeal Materials (2)
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PDT 17-1
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Appeal Materials (2)
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Last modified
5/10/2018 4:01:40 PM
Creation date
5/9/2018 9:09:54 AM
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Template:
PDD_Planning_Development
File Type
PDT
File Year
17
File Sequence Number
1
Application Name
Capital Hill PUD
Document Type
Appeal Materials
Document_Date
5/7/2018
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Yes
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The applicant concurs in all the recommended conditions. <br />The applicant also concurs with the Staff Report conclusion, stated at page 44, that this <br />development proposal is exempt from Geological and Geotechnical Analysis requirements of EC <br />9.6710 for the reason that the site as a whole is on the acknowledged Goal 5 inventory. <br />EC 9.8320(11): The proposed development shall have minimal off-site impacts, including <br />such impacts as traffic, noise, stormwater runoff and environmental quality. <br />1. The operative standard here is "minimal," which is an inherently subjective standard; hence <br />this standard should not be applied under the Needed Housing Statute. <br />2. The Staff Report at 55-56 provides a competent summary of the evidence in the record that <br />supports a finding of "minimal off-site impacts" on the relevant dimensions. The HO should <br />concur with the staff and incorporate those findings. <br />EC 9.8320(12): The proposed development shall be reasonably compatible and <br />harmonious with adjacent and nearby land uses. <br />1. As is the case with the standard above, "reasonably compatible" requires the most subjective <br />value judgment, which is beyond the scope of the Needed Housing Statute allows. <br />2. The Staff Report at 57-58 summarizes the evidence that support a "reasonably compatible" <br />finding by the HO. We recommend that analysis. <br />Conclusion <br />As is evident from the scale and intensity of the opposition, this neighborhood does not want this <br />infill project at this site, even though the City has determined that this site is intended for just this <br />kind of use at about this proposed density. Perhaps the best recommendation we have for <br />approval is the positive and detailed review by the city staff. We hope the HO concurs with the <br />applicant and the city staff and approves the use as proposed to be conditioned. <br />Sincerely, <br />ow x&" <br />Bill Kloos <br />Client <br />Schirmer Satre Group <br />APP C - Final Argument 4.6.2018 <br />
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