Table 9.2160 Commercial Zone Land Uses and Permit Requirements <br />Plumbing Supplies <br />P <br />P <br />Retail trade when secondary, directly related, and limited <br />to products manufactured, repaired or assembled on the <br />development site <br />P(1) <br />P <br />P <br />Storage Facility, Household/Consumer Goods, enclosed <br />P <br />Specialty Store (an example includes a gift store) <br />P(I0) <br />P(1)(I0) <br />P(10) <br />P(2)(10) <br />Toy and Hobby Store <br />P(1) <br />P <br />P <br />Video Store <br />P(1) <br />P <br />P <br />Because there is not a change in use, the Director correctly found that a traffic <br />impact assessment was not required. <br />V. CONCLUSION <br />The Director's findings and approval for the two minor modifications to the <br />1988 Plans should be uncontroversial. And in fact, it is readily apparent from the appellants' <br />appeal statements and past submissions that the modifications are not really what they oppose. <br />Appellants' arguments opposing the opening of the WinCo supermarket, however, are not only <br />irrelevant but also facially meritless. Because the two modifications requested in the Application <br />easily satisfy the two applicable criteria, WinCo requests that the hearings official affirm the <br />Director's Decision. <br />DATED this 21st day of October, 2020. <br />MILLER NASH GRAHAM & DUNN LLP <br />f~ r <br />Steven G. Liday, OSB No. 075975 <br />Kelly Hossaini, OSB No. 010598 <br />Counsel for WinCo Foods, LLC <br />Page 32 - 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 />