Applicant’s Appeal Response - Laserfiche WebLink

of the loading dock and placement of a bottle redemption center could not possibly generate anywhere close to 100 trips during any peak hour. (Decision at 13.) In response, appellants repeat their argument that the opening of the WinCo store is a "change in use" and the switch from a department store to a supermarket is "development" that will generate significantly more traffic. But, as explained several times above, it could not be clearer that department stores and supermarkets are in the same use category. As reinforcement of this point, below is the entire relevant section of the pertinent use table: Table 9.2160 Commercial Zone Land Uses and Permit Requirements C-1 C-2 C-3 GO Trade (Retail and Wholesale) Agricultural Machinery Rental/Sales/Service C Appliance Sales/Service P P Bicycle Rental/Sales/Service P(l) P P Boat and Watercraft Sales/Service P C Book Store P(1) P P Building Materials and Supplies Computer Store P(1) P P Convenience Store P(1) P P P(2) Drug Store (excluding Drug Treatment Centers) P(l) P P Electrical Appliances and Supplies P(1) P P Equipment, Light, Rental/Sales/Service P P Equipment, Heavy, Rental/Sales/Service- includes truck and tractor sales C Fabric Store P P Floor Covering Store P P Furniture and Home Furnishing Stores P P Garden Supply/Nursery P(1) P General Merchandise (includes supermarket and department store) P(1) P P P(2) Hardware/Home Improvement Store P(l) P P Healthcare Equipment and Supplies P P Liquor Store P P Manufactured Dwelling Sales/Service/Repair C Office Equipment and Supplies P P Page 31 - WinCo Foods, LLC's Response to Appellants' Statements of Alleged Errors MILLER NASH GRAHAM & DUNN LLP ATTORNEYS AT LAW 4816-6071-2143.6 TELEPHONE: 503.224.5858 3400 U.S. BANCORP TOR'ER I11 S.W FIFTH AVENUE P ORTLAND. OREGON 97204