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Applicant’s Appeal Response
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Applicant’s Appeal Response
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Last modified
10/26/2020 4:01:27 PM
Creation date
10/23/2020 3:14:32 PM
Metadata
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Template:
PDD_Planning_Development
File Type
MDA
File Year
20
File Sequence Number
5
Application Name
Winco
Document Type
Public Comments
Document_Date
10/21/2020
External View
Yes
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Again, it must be noted that the proper comparison is not between the occupant's <br />prior development and use of the Property, but the full extent of the use and development <br />possible under the original and modified plans. Appellants offer no explanation for why the <br />proposed bottle redemption center would be a significant change from the large range of <br />buildings and operations of a greenhouse/lawn and garden center allowed under the 1988 Plans. <br />For example, the currently allowed greenhouse and garden/lawn area could be the exact same <br />size and intensity of use as the planned bottle redemption center, or even far larger and busier. <br />C. The Director Properly Rejected Appellants' Theory That the 1988 Plans <br />Converted Supermarkets Into a Nonconforming Use on the Property. <br />Appellants likely recognize that their arguments have no chance of success unless <br />they can manufacture a theory as to why the outright allowed use "supermarket" is not actually <br />an allowed use on the Property. To this end, LSL argues that a supermarket is not a permitted <br />use on the Property because it has not been authorized by a site review approval and because the <br />1988 site review (SR 88-11) only approved a "shopping center." Both are clearly incorrect. <br />First, site reviews do not authorize, or otherwise control, the allowed uses on a <br />property. The site review code only addresses the development already allowed on the site "as a <br />means to maintain or improve the character, integrity, and harmonious development of an area, <br />address potential environmental impacts, and to provide a safe, stable, efficient, and attractive <br />on-site environment." EC 9.8425. Thus, the site review process evaluates proposed "site review <br />plans" for compliance with criteria concerning protection of natural features, tree preservation, <br />parking, and transportation systems, as well as whether "[t]he site review plan's general design <br />and character is reasonably compatible with surrounding properties, as it relates to building <br />locations, bulk and height, noise, glare and odors." EC 9.8440. <br />Page 26 - 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 />
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