LivingStrong Appeal <br />October 12,2020 <br />Page5 <br />The Director’s conclusion, at page 13 para 2, that a TIA is not required is erroneous. The <br />site review modification is for WinCo, and WinCo’sown traffic engineer determined, <br />“The project is projected to generate more than 100 vehicle trips during multiple peak <br />hours, thus warranting a Traffic Impact Analysis.” See page 2 of WinCo’s January 2020 <br />TIA. <br />3.The Director erred by not addressing EC 9.4410 and evaluating the <br />proposed development for compliance withmore restrictive code <br />standards. <br />EC 9.4410 states, <br />“Where the overlay zone, base zone, or special area zone provisions conflict, the more <br />restrictive requirement applies.” <br />The Director’s decisionrests heavily on a determination that the original 1988 Site Review is <br />still in effect and prevents development standards adopted since1988 from being applicable. <br />The Director’s decision ignoresmore restrictive code standardsincludingthose applicable to <br />large scale commercial developments. <br />Even if the Director is correctthat the 1988 Site Review is still in effect, this does not ignore the <br />requirement that new development shall demonstrate compliance with applicable standards in the <br />base zone.In this case, the original 1988 site review approval did not evaluate theproposed <br />development for compliance with numerous standards in the codesince they were not even <br />enacted at the time. <br />4.The Director erred by not finding that the proposed development requires a <br />Traffic Impact Analysis. <br />TheDirector’s decision contains a findingthat,“The proposed site modification to demolish a <br />corner of the building, reconfigure the loading dock, add additional landscaping, and construct <br />a bottle redemption structure does not trigger the need for a Traffic Impact Analysis.” <br />The Director’sfinding is not correct.The SR Modification is for WinCoandincludes both a <br />building alteration and changein use. As stated previously, the TIA submitted by WinCo <br />provides a comparison of the projected traffic for Shopko versus WinCo and concludes thatthe <br />proposed developmentwill generate more than 100 vehicle trips during multiple peak hours. <br />We look forward to the public hearing on thismatter. <br />Sincerely, <br />Bill Kloos <br />Bill Kloos <br /> <br />