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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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nonconforming use or conditional use code sections, where the right to conduct a use can be lost <br />in certain circumstances. But as explained above, the site review code has no impact on the uses <br />allowed on a site. It cannot authorize or restrict a use. At most, the circumstances of a new or <br />altered use might trigger the need for a new site review, McPhillps Farm, 2012 WL at *9, which <br />is clearly not the case here. <br />LSL also fails to identify a code provision or provide any other basis for why <br />WinCo is required to update the Property outside of the modifications proposed in the <br />Application. In fact, even the development standards applicable to the proposed structures <br />underlying the request for the site review plan modification are not pertinent at this time because <br />the Application does not authorize the improvements; it only alters the 1988 Plans to allow <br />WinCo to subsequently apply for development permits. <br />F. The Director Correctly Found That a Traffic Impact Analysis Is Not <br />Required for WinCo's Proposed Remodel. <br />In its fourth and final argument, LSL states that the City should have required a <br />traffic impact analysis to be submitted with WinCo's application for the modification of the <br />1988 Plans. (LSL Appeal at 7.) <br />This is incorrect. A TIA is only required when proposed "developmenti24 will <br />generate substantial traffic, i.e., "100 or more vehicle trips during any peak hour." It cannot be <br />reasonably argued-and no one has-that the "development" actually at issue in the Application <br />will generate meaningful levels of new traffic. As the City properly found, the reconfiguration <br />and there would be no need to submit to a new site review. EC 9.8430(1) (site review only required for <br />development of vacant property or the expansion of existing building footprint by 20 percent or more). <br />24 EC 9.0500 (development includes "building alterations or additions, site improvements, or a change in use"). <br />Page 30 - 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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