In conjunction with the clear design in the 1988 Plans, the SR 88-11 traffic study states that the <br />application proposes to construct Crescent Avenue along the north of the Property in order to <br />build "the second driveway to provide truck access to the rear of the site." (Ex. 14, at 5.) <br />The existence of this 1988 access point was also confirmed in the August 15, <br />2000, final site review plans (SR 00-13) for the adjacent property to the east: <br />SR 00-13 Landscape Plan <br />f. <br />-7/ <br />r\ ~ <br />I <br />Although not articulated, it is likely that LSL's theory is premised on the fact that <br />there is currently a small planting bed across this access. But, as recognized by the City and <br />adjacent lot owner, the SR 00-13 final plans and other documents in the SR 00-13 land use file <br />indisputably show that the planter box was constructed without preauthorization by WinCo or <br />the City, and in contradiction of the approved plans. 15 (And instead of having it removed, the <br />Property's previous occupant simply drove its delivery trucks over the obstruction. Id.) <br />Regardless, the existence of the planter box is immaterial. This Application concerns <br />is The history and lack of consequence of this planter box is discussed at length in WinCo's August 3, 2020, letter; <br />Exhibit 7, at pp 5-11, Exhibit 8 (historic satellite photos). <br />Page 17 - WinCo Foods, LLC's Response to Appellants' Statements of Alleged Errors <br />MILLER NASH GRAHAM & DUNN LLP <br />ATTORNEYS AT LAW 4816-6071-2143.6 <br />TELEPHONE: 503.224.5858 <br />3400 U.S. BANCORP TOR'ER <br />I11 S.W FIFTH AVENUE <br />P ORTLAND. OREGON 97204 <br />