February 9, 2021 Appeal Statement TIA 21-2 and ARA 21-14 P a g e | 2 <br />unambiguous record upon which the Planning Director’s decision was based would <br />substantially compromise the rights of Jefferson Westside Neighbors members and others. <br />As identified below, the Planning Director made substantial claims without providing any <br />reference to the record. Such claims therefore cannot be treated as based on substantial an d <br />reliable evidence. <br />Summary of Substantial Facts <br />The following provides a partial summary of the events relevant to this appeal, with preliminary <br />notes: <br />June 1, 2021 – The first versions of the MAC Applications (the “June Applications”) were <br />submitted by Wells Fargo, who was listed as the owner. The June Applications proposed <br />development of a 7-ELEVEN, gas pumps, and coffee shop on one lot and housing on a second <br />lot. The June Applications comprised 288 pages, including a 253-page document with the <br />application narrative and TIA data plus a 35-page document with a site plan and other <br />drawings. <br />June 25, 2021 – Michele Wilcox submitted Public Works referral comments regarding the ARA, <br />identifying substantial missing elements that were required for the ARA. Wilcox’s assessment <br />was based on the June Applications, which were entirely replaced and superseded by the <br />applicant. <br />June 29, 2021 – Wells Fargo sold the subject lot to Maj Eugene LLC. <br />July 1, 2021 – The City notified the applicant that the June Applications were incomplete. <br />July 21, 2021 – The second versions of the MAC applications (the “July Applications”) were <br />submitted. These new versions of the applications proposed the same developments as the <br />Original Applications and incorrectly listed Wells Fargo as the owner when the property had <br />been sold to Maj Eugene LLC. The July Applications comprised one 245-page document that <br />included the same subject materials as the June Applications but limited the drawings to a one - <br />page “Site Plan.” <br />August 16, 2021 – The applicant submitted supplemental materials, which comprised a 9-page <br />document “to present a detailed evaluation of internal queuing and circulation * * *.” <br />August 19, 2021 – Scott Gillespie submitted Public Works referral comments regarding the TIA, <br />conditional on further document submission by the applicant. The referral erroneously stated <br />that “[t]he residential component of this project has since been removed from the application.” <br />It was not removed from the applications in the record until the October Applications (below) <br />were submitted. Gillespie’s was based on either the June or July Applications (the comments do <br />not state which), which were both entirely replaced and superseded by the applicant.