February 9, 2021 Appeal Statement TIA 21-2 and ARA 21-14 P a g e | 3 <br />Gillespie’s statement erroneously claimed that “[t]he applicant has submitted Traffic Impact <br />Analysis in conformance with the standards for Traffic Impact Analysis. In fact, an examination <br />of the July Applications unequivocally demonstrates that the submitted TIA was missing <br />numerous required elements of the report. (See October 29, 2021, email from Paul Conte to <br />Mike McKerrow enumerating over a dozen missing elements.) <br />In an email to Paul Conte on November 3, 2021, Mike McKerrow stated: <br />“This means that Scott Gillespie’s information is part of the record but informal <br />completeness comments anticipated soon from public works staff and a future referral will <br />be the focus of the decision maker.” (Emphasis added.) <br />“While the paper copies of the October 25th information had the first two pages of the <br />applications filled out, the digital copies did not. This will be shared with the applicant as <br />part of the current informal completeness review, * * *.” (Emphasis added.) <br />There is no legal process that is an “informal completeness review,” and the requirement <br />for a statutory completeness requires written notification to the applicant that becomes <br />part of the record. No such written notification exists, and there was no reliable <br />“completeness review” after the notice to the applicant on August 27, 2021. <br />August 27, 2021 – The applicant was notified that the July Applications were complete. <br />August 31, 2021 – An erroneous Public Notice was mailed. <br />August 31, 2021 – According to the City’s “Events” web page, “Send Referrals.” However, no <br />document is posted for that event. <br />September 2, 2021 – A corrected Public Notice was mailed. <br />September 16, 2021 – Applicant submitted a written request for a “hold/extension” for 60 days <br />for the MAC applications. <br />October 8, 2021 – Mike McKerrow stated in an email to Paul Conte that: “Some time ago the <br />applicant indicated they plan to submit new materials about the middle of October.” (Emphasis <br />added.) <br />October 26, 2021 – “New” applications were submitted (the “October Applications”) were <br />submitted. The October Applications for the first time made the substantial change to remove <br />the proposed residential development that had been included in the June and July Applications. <br />The October Applications comprised one 341-page document that included the same subject <br />materials as the July Applications and the August 16, 2021, “internal and queuing” study. The <br />document included application forms that were totally blank, except for the two signature <br />pages that still falsely listed Wells Fargo as the property owner.