Loading...
HomeMy WebLinkAbout2025 - Findings - #PA-T3-2024-00010THE CITY OF ASHLAND BEFORE THE CITY COUNCIL April 15, 2025 IN THE MATTER OF PLANNING ACTION #PA-T3-2024-00010 A REQUEST FOR ANNEXATION AND ZONE CHANGE FOR A 4.8-ACRE PROPERTY, ALONG WITH ADJACENT RIGHT-OF-WAY (ROW), FOR THE PROPERTY LOCATED AT 300 CLAY STREET AND A REQUEST FOR OUTLINE PLAN APPROVAL FOR A PERFORMANCE STANDARDS OPTION (PSO) SUBDIVISION, AS WELL AS A LIMITED ACTIVITIES WRPZ PERMIT. OWNER: BENTELLA LLC APPLICANT: ROGUE PLANNING & DEVELOPMENT SERVICES RECITALS: FINDINGS, CONCLUSIONS, AND ORDERS. 1) The subject property is Tax lot #1100 of Assessor Map 39-1E-11-CB and is addressed as 300 Clay Street. The property is 4.8 acres and slopes gently to the north. A comprehensive physical description of the property and its location are included in the Planning Commission Findings dated March 11, 2025 attached hereto, and for brevity are not repeated here. 2) The application is for a request for annexation and approval of outline plan for a Performance Standard Option (PSO) subdivision, a limited activities and uses permit for the WRPZ, and a tree removal permit to remove four non -hazard trees. The applicant provided detailed responses to all applicable approval criteria in the form of findings of fact, a trip generation assessment and TPR findings, legal description and survey of the property, and civil engineering plans. These application materials are on file at the Department of Community Development and by their reference are incorporated herein as if set out in full. 3) The Land Use Ordinance states that: "all annexations shall be processed under the Type III procedure." Type III planning actions are reviewed by the Planning Commission, which makes a recommendation to the City Council. The Council makes final decisions on legislative proposals through the enactment of an ordinance. 4) The relevant approval criteria include Annexation at AMC 18.5.8.050, Outline Plan at AMC 18.3.9.040.A.3, a WRPZ Limited Activities and Uses Permit at AMC 18.3.11.060.D, and Tree Removal Permit for a tree that is not a hazard at AMC 18.5.7.040.B.2. These are set out in full in the Planning Commission Findings referenced above, and for brevity are not repeated here. 5) The Planning Commission, following proper public notice, held a public hearing on February 11, 2025. Testimony was received, and exhibits were presented. The Planning Commission deliberated and approved the application subject to conditions of approval. On March 11, PA-T3-2024-00010 April 15, 2025 Page 1 2025, the Planning Commission adopted findings, conclusions and orders addressing the relevant approval criteria and conditions of approval. a. The application included a requested exception to the standard at AMC 18.5.8.050.G.3 that requires that "the affordable units shall be comparable in bedroom mix with the market -rate units in the development." b. Instead of approving the requested exception as presented, the Planning Commission approved the application with the following condition: "That the final plan submittal shall identify a mix of bedrooms for the affordable units comparable to the bedroom mix of the market -rate units and include necessary deed restrictions to ensure compliance." 6) The City Council, following proper public notice, held a public hearing on April 1, 2025. Testimony was received, and exhibits were presented by both Staff and the applicant. The City Council deliberated and approved the application including the requested exception to the standard at AMC 18.5.8.050.G.3 requiring compatibility of bedroom mix between the affordable and market rate units. Now, therefore, the City Council of the City of Ashland finds, concludes, and recommends as follows: SECTION 1. EXHIBITS For the purposes of reference to these Findings, the attached index of exhibits, data, and testimony will be used. Staff Exhibits lettered with an "S" Proponent's Exhibits, lettered with a "P" Opponent's Exhibits, lettered with an "O" Hearing Minutes, Notices, and Miscellaneous Exhibits lettered with an "M" SECTION 2. CONCLUSORY FINDINGS OF FACT 2.1 The City Council notes that chapter 18 of the Ashland Municipal Code (AMC) is the City's Land Use Ordinance (LUO). The LUO regulates the development pattern envisioned by the Comprehensive Plan and encourages efficient use of land resources among other goals. 2.2 The City Council finds that it has received all information necessary to render a decision based on the application materials itself, the February 11th Staff Report, the March 11th Planning Commission Findings of Fact, the public testimony received, and the testimony from both staff and the applicant at the public hearings. 2.3 The City Council finds that the proposal for Annexation meets all applicable approval criteria described in AMC 18.5.8.050. These are addressed in the attached Planning Commission Findings and the City Council adopts them as their own with the following exception: 2.3.1 The City Council notes that the standard at AMC 18.5.8.050.G.3 requires that "The PA-T3-2024-00010 April 15, 2025 Page 2 affordable units shall be comparable in bedroom mix with the market rate units in the development" and that the applicant is requesting an exception to this standard. 2.3.2 The City Council notes that AMC 18.5.8.050.G.6 provides that "Exceptions to the requirements of subsections I8.5. 8.0_50. G. 2 through 18.5.8.050. G. 5, above, nlay be approved by the City Council upon consideration" of three different situations. The second of those is that "That the alternative phasing proposal not meeting subsection 18.5.8.050. G. 4 provided by the applicant provides adequate assurance that the affordable housing units will be provided in a timely fashion." 2.3.3 The City Council notes that the phasing schedule requirements of AMC 18.5.8.050.G.4 requires "That 50 percent of the affordable units shall have been issued building permits prior to issuance of a certificate of occupancy for the last of the first 50 percent of the oral ket rate units." and that "Prior to issuance of a building permit for the final ten percent of the market rate units, the final 50 percent of the affordable units shall have been issued certificates of occupancy." 2.3.4 The City Council finds that a thorough review of the application materials confirms that the proposed phasing of the affordable housing, ensuring its completion prior to any market -rate units, provides adequate assurance that the development of a needed housing type and will be "provided in a timely fashion." The City Council concludes that the requested exception is beneficial to the community and finds that the approval criterion for the exception is met based on the proposed phasing. 2.4 The City Council fords that the proposal for Outline Plan of a Performance Standard Option (PSO) subdivision meets all applicable criteria for described in AMC 18.3.9.040.A.3. These are addressed in the attached Planning Commission Findings and the City Council adopts them as their own. 2.5 The City Council finds that the proposal for a Limited Activities and Uses Permit in the Water Resource Protection Zone (WRPZ) meets all of the applicable criteria described in AMC 18.5.5.050. These are addressed in the attached Planning Commission Findings and the City Council adopts them as their own. 2.6 The City Council finds that the request to remove four "Trees that [are] not a hazard" meets all of the applicable criteria described in AMC 18.5.7.040.B.2. These are addressed in the attached Planning Commission Findings and the City Council adopts them as their own. 2.7 The City Council notes that following proper public notice, a public hearing was held on April 1, 2025, where testimony was received, and exhibits were presented. 2.8 Following the close of the public hearing the City Council deliberated and voted (5-0) in favor of the following motion: "I move to approve the first reading of Ordinance No. 3259, an ordinance annexing property and withdrawing an annexed area from Jackson County Fire District No. 5, and direct staff to prepare findings for Planning Action #PA-T3- 2024-00010 reflecting the approval of the applicant's requested exception to the PA-T3-2024-00010 April 15, 2025 Page 3 bedroom mix standard under AMC 18.5.8.050.G.3, while incorporating the remainder of the Planning Commission's March 11, 2025, recommended conditions of approval, and to return for second reading on April 15, 2025. SECTION 3. DECISION 3.1 Based on the record of the Public Hearings on this matter, the City Council approves the application for annexation, outline plan approval, limited activities and uses permit for the VWZ and a tree removal permit to remove four non -hazard trees. 3.2 In addition to the findings set out above, the City Council hereby adopts the Planning Commission March 11, 2025 Findings of Fact and conditions of approval as the City Council's own, with the specific excluding section 2.4.7.1 and condition of approval #2d. A copy of these findings is attached hereto including explicit strikethrough of sections 2.4.7.1 and condition of approval #2d. 1_rl� AtA,� qlIvA5- City C uncil Approval Date PA-T3-2024-00010 April 15, 2025 Page 4 THE CITY OF ASHLAND BEFORE THE PLANNING COMMISSION March 11, 2025 IN THE MATTER OF PLANNING ACTION #PA-T3-2024-00010 A REQUEST FOR ANNEXATION AND ZONE CHANGE FOR A 4.8-ACRE PROPERTY, ALONG WITH ADJACENT RIGHT-OF-WAY (ROW), FOR THE PROPERTY LOCATED AT 300 CLAY STREET AND A REQUEST FOR OUTLINE PLAN APPROVAL FOR A PERFORMANCE STANDARDS OPTION (PSO) SUBDIVISION, AS WELL AS A LIMITED ACTIVITIES WRPZ PERMIT. OWNER: BENTELLA LLC APPLICANT: ROGUE PLANNING & DEVELOPMENT SERVICES RECITALS: FINDINGS, CONCLUSIONS, AND ORDERS. 1) The subject property is Tax lot #1100 of Assessor Map 39-1E-11-CB and is addressed as 300 Clay Street. The property is 4.8 acres and slopes gently to the north. The property has 330- feet of frontage along Clay Street which is fully improved to city standards. Engle Street terminates on both the north and south side of the property. 2) The subject property is located on the east side of Clay Street, with "East Village Subdivision" (formally known as `Bud's Dairy") to the north, and the "Snowberry Brook" development to the south. To the east of the subject property is the rear of a mobile home park that fronts Tolman Creek Road. The property is within the UGB and is adjacent to the City Limits on the north, east and south sides. 3) The adopted Wetland Resource Protection Zone (WRPZ) maps indicate wetlands in two locations; however, the application materials include a wetland delineation, reviewed and approved by the Department of State Lands (DSL), which determined that there is only a single identified wetland that is 0.0096 acres. The application materials propose a twenty - foot buffer around the identified wetland to be dedicated as open space. 4) The application is a request for annexation and outline plan approval for a Performance Standard Option (PSO) subdivision. The applicant provided detailed responses to all applicable approval criteria in the form of fmdings of fact, a trip generation assessment and TPR findings, legal description and survey of the property, landscaping and civil engineering plans, and conceptual building design for future Site Design Review. These materials are on file at the Department of Community Development and by their reference are incorporated herein as if set out in full. a. The proposed PSO subdivision includes a total of 25-lots for residential development, 21 of them are proposed for single family residential (SFR) PA-T3-2024-00010 March 11, 2025 Page 1 development, four lots proposed with four-plex townhomes, and four additional lots to be dedicated as open space area. The SFR lots may be developed with either Accessory Residential Units (ARU) or duplexes as permissible by House Bill 2001. b. The 16 dwellings in the fourplexes plus the 21 SFR lots sums to a proposed density of 37 dwelling units. c. The application also includes a limited activities permit for public utilities within the Water Resource Protection Zone (WRPZ). d. The application also includes a request to remove four non -hazard trees. 5) Annexations require that at least 25% of the base density be affordable housing. In the present application there are eight affordable housing units proposed at 80% area median income (AMI) to meet this requirement. 6) The Land Use Ordinance states that: "all annexations shall be processed under the Type III procedure." Type III planning actions are legislative decisions by definition, and are reviewed by the Planning Commission, which makes a recommendation to the City Council. The Council makes final decisions on legislative proposals through the enactment of an ordinance. 7) The criteria of approval for Annexation are described in AMC 18.5.8.050 as follows: An application for an annexation may be approved if the proposal meets the applicable criteria in subsections A through [ below. The approval authority may, in approving the application, impose conditions of approval consistent with the applicable criteria and standards, and grant exceptions and variances to the criteria and standards in this section in accordance with subsection il. A. The annexed area is within the City's Urban Growth Boundary. B. The annexation proposal is consistent with the Comprehensive Plan designations applicable to the annexed area, including any applicable adopted neighborhood, master, or area plan, and is an allowed use within the proposed zoning. C. The annexed area is contiguous with the City limits. D. Adequate City facilities for the provision of water to the annexed area as determined by the Public Works Department; the transport of sewage from the annexed area to an approved waste water treatment facility as determined by the Public Works Department; the provision of electricity to the annexed area as determined by the Electric Department; urban storm drainage as determined by the Public Works Department can and will be provided from the annexed area. Unless the City has declared a moratorium based upon a shortage of water, sewer, or electricity, it is recognized that adequate capacity exists system -wide for these facilities. All required public facility improvements shall be constructed and installed in accordance with subsection 18.4.6.030.A. E. Adequate transportation can and will be provided to serve the annexed area. For the purposes of this section, "adequate transportation" for annexations consists of vehicular, bicycle, pedestrian, and transit transportation meeting the following standards: 1. For vehicular transportation a minimum 22-foot-wide paved access exists, or can and will be constructed, providing access to the annexed area from the nearest fully improved collector or arterial street. All streets bordering on the annexed area shall be improved, at a minimum, to an applicable City half -street standard. The approval authority may, after assessing the impact of the development, require the full improvement of streets bordering on the annexed area. All streets located within annexed areas shall be fully improved to City standards unless exception criteria apply. Where future street PA-T3-2024-00010 March 11, 2025 Page 2 dedications are indicated on the Street Dedication Map or required by the City, provisions shall be made for the dedication and improvement of these streets and included with the application for annexation. 2. For bicycle transportation, safe and accessible bicycle facilities according to the safety analysis and standards of the governing jurisdiction of the facility or street (e.g., City of Ashland, Jackson County, Oregon Department of Transportation) exist, or can and will be constructed. Should the annexed area border an arterial street, bike lanes shall be constructed along the arterial street frontage of the annexed area. Likely bicycle destinations within a quarter of a mile from the annexed area shall be determined and the approval authority may require the construction of bicycle lanes or multiuse paths connecting the annexed area to the likely bicycle destinations after assessing the impact of the development proposed concurrently with the annexation. 3. For pedestrian transportation, safe and accessible pedestrian facilities according to the safety analysis and standards of the governing jurisdiction of the facility or street (e.g., City of Ashland, Jackson County, Oregon Department of Transportation) exist, or can and will be constructed. Full sidewalk improvements shall be provided on one side of all streets bordering on the proposed annexed area. Sidewalks shall be provided as required by ordinance on all streets within the annexed area. Where the annexed area is within a quarter of a mile of an existing sidewalk system or a location with demonstrated significant pedestrian activity, the approval authority may require sidewalks, walkways or multiuse paths to be constructed and connect to either or both the existing system and locations with significant pedestrian activity. 4. For transit transportation, should transit service be available to the annexed area, or be likely to be extended to the annexed area in the future based on information from the local public transit provider, the approval authority may require construction of transit facilities, such as bus shelters and bus turnout lanes. 5. Timing of Transportation Improvements. All required transportation improvements shall be constructed and installed in accordance with subsection 18.4.6.030.A. F. For all residential annexations, a plan shall be provided demonstrating that the development of the annexed area will ultimately occur at a minimum density of 90 percent of the base density for the zone, unless reductions in the total number of units are necessary to accommodate significant natural features, topography, access limitations, or similar physical constraints. The owner or owners of the annexed area shall sign an agreement, to be recorded with the County Clerk after approval of the annexation, ensuring that future development will occur in accord with the minimum density indicated in the development plan. For purposes of computing maximum density, portions of the annexed area containing unbuildable lots, parcels, or portions of the annexed area such as existing streets and associated rights -of -way, railroad facilities and property, wetlands, floodplain corridor lands, slopes greater than 35 percent, or land area dedicated as a public park, shall not be included. G. Except as provided in subsection t18. 5 .G.7, below, annexations with a density or potential density of four residential units or greater and involving residential zoned lands, or commercial, employment or industrial lands with a Residential Overlay (R-Overlay) shall meet the following requirements: 1. The total number of affordable units provided to qualifying buyers, or to qualifying renters, shall be equal to or exceed 25 percent of the base density as calculated using the unit equivalency values set forth herein. The base density of the annexed area for the purpose of calculating the total number of affordable units in this section shall exclude any unbuildable lots, parcels, or portions of the annexed area such as existing streets and associated rights -of -way, railroad facilities and property, wetlands, floodplain corridor lands, water resource areas, slopes greater than 35 percent, or land area dedicated as a public park. a. Ownership units restricted to households earning at or below 120 percent of the area median income shall have an equivalency value of 0.75 unit. PA-T3-2024-00010 March 11. 2025 Page 3 b. Ownership units restricted to households earning at or below 100 percent of the area median income shall have an equivalency value of 1.0 unit. c. Ownership or rental units restricted to households earning at or below 80 percent of the area median income shall have an equivalency value of 1.25 unit. 2. As an alternative to providing affordable units per section 18.5.8.050.G.1, above, the applicant may provide title to a sufficient amount of buildable land for development complying with subsection 18.5.8.050.G., above, through transfer to a non-profit (IRC 501(3)(c)) affordable housing developer or public corporation created under ORS 456.055 to 56.235. a. The land to be transferred shall be located within the project meeting the standards set forth in sections 18.5.8.050.G.5 and r18.5.8.050.G.6. b. All needed public facilities shall be extended to the area or areas proposed for transfer. c. Prior to commencement of the project, title to the land shall be transferred to the City, an affordable housing developer which must either be a unit of government, a non-profit 501(c)(3) organization, or a public corporation created under ORS 456.056 to 456 235. d. The land to be transferred shall be deed restricted to comply with Ashland's affordable housing program requirements. e. Transfer of title of buildable land in accordance with this subsection shall exempt the project from the development schedule requirements set forth in subsection '18.5.8.050.G.4. 3. The affordable units shall be comparable in bedroom mix with the market rate units in the development. a. The number of bedrooms per dwelling unit in the affordable units within the residential development shall be in equal proportion to the number of bedrooms per dwelling unit in the market rate units within the residential development. This provision is not intended to require the same floor area in affordable units as compared to market rate units. The minimum square footage of each affordable unit shall comply with the minimum required floor area based as set forth in Table 18.5.8.050.G.3, or as established by the U.S. Department of Housing and Urban Development (HUD) for dwelling units developed under the HOME program. 4. A development schedule shall be provided that demonstrates that the affordable housing units per subsection 18.5.8.050.G shall be developed, and made available for occupancy, as follows: a. That 50 percent of the affordable units shall have been issued building permits prior to issuance of a certificate of occupancy for the last of the first 50 percent of the market rate units. b. Prior to issuance of a building permit for the final ten percent of the market rate units, the final 50 percent of the affordable units shall have been issued certificates of occupancy. 5. That affordable housing units shall be constructed using comparable building materials and include equivalent amenities as the market rate units. a. The exterior appearance of the affordable units in any residential development shall be visually compatible with the market rate units in the development. External building materials and finishes shall be substantially the same in type and quality for affordable units as for market rate units. b. Affordable units may differ from market rate units with regard to floor area, interior finishes and materials, and housing type; provided, that the affordable housing units are provided with comparable features to the market rate units, and PA-T3-2024-00010 March 11. 2025 Page 4 shall have generally comparable improvements related to energy efficiency, including plumbing, insulation, windows, appliances, and heating and cooling systems. 6. Exceptions to the requirements of subsections 18.5.8.050.G.2through 18.5.8.050.G.5, above, may be approved by the City Council upon consideration of one or more of the following: a. That an alternative land dedication as proposed would accomplish additional benefits for the City, consistent with the purposes of this chapter, than would development meeting the on -site dedication requirement of subsection 118.5.8.050.G.2. b. That the alternativeQhasing proposal not meeting subsection 118.5.8.050.G.4 provided by the applicant provides adequate assurance that the affordable housing units will be provided in a timely fashion. c. That the materials and amenities applied to the affordable units within the development, that are not equivalent to the market rate units per subsection 18.5.8.050.G.5, are necessary due to local, state, or federal affordable housing standards or financing limitations. 7. The total number of affordable units described in this subsection shall be determined by rounding up fractional answers to the nearest whole unit. A deed restriction or similar legal instrument shall be used to guarantee compliance with affordable criteria for a period of not less than 60 years for units qualified as affordable rental housing, or 30 years for units qualified as affordable for -purchase housing. H. One or more of the following standards are met: 1. The annexation proposal shall meet the requirements of subsection 18.5.8.050.B, above. 2. A current or probable danger to public health exists within the proposed area for annexation due to lack of full City sanitary sewer or water services in accordance with the criteria in ORS chapter 222 or successor state statute. 3. Existing development in the proposed area for annexation has inadequate water or sanitary sewer service, or the service will become inadequate within one year. 4. The proposed area for annexation has existing City water or sanitary sewer service extended, connected, and in use, and a signed consent to annexation agreement has been filed and accepted by the City. 5. The proposed area for annexation is an island surrounded by lands within the City limits. 1. Exceptions and Variances to the Annexation Approval Criteria and Standards. The approval authority may approve exceptions to and variances from the approval criteria and standards in this section using the criteria in section 18.4.6.020.B.1, Exceptions to the Street Design Standards, or chapter 18.5.5, Variances. 8) The criteria of approval for Outline Plan of a PSO subdivision are described in AJIC 18.3.9.040.A.3 as follows: 3. Approval Criteria for Outline Plan. The Planning Commission shall approve the outline plan when it finds all of the following criteria have been met: A. the development meets all applicable ordinance requirements of the city. B. adequate key city facilities can be provided including water, sewer, paved access to and through the development, electricity, urban storm drainage, police and fire protection, and adequate transportation; and that the development will not cause a city facility to operate beyond capacity. PA-T3-2024-00010 March 11.2025 Page 5 C. the existing and natural features of the land; such as wetlands, floodplain corridors, ponds, large trees, rock outcroppings, etc., have been identified in the plan of the development and significant features have been included in the common open space, common areas. and unbuildable areas. D. the development of the land will not prevent adjacent land from being developed for the uses shown in the comprehensive plan. E. there are adequate provisions for the maintenance of common open space and common areas, if required or provided, and that if developments are done in phases that the early phases have the same or higher ratio of amenities as proposed in the entire project. F. the proposed density meets the base and bonus density standards established under this chapter. G. the development complies with the street standards. H. the proposed development meets the common open space standards established under section 18.4.4.070. Common open space requirements may be satisfied by public open space in accordance with section 18.4.4.070 if approved by the city of Ashland. 9) The criteria of approval for a WRPZ Limited Activities and Uses Permit are described in AMC 18.3.11.060.D as follows: D. Limited Activities and Uses Permit. All limited activities and uses described in section 18.3.11.060 shall be subject to a Type I procedure in section 18.5.1.050. An application for a limited activities and uses permit shall be approved if the proposal meets all of the following criteria: 1. All activities shall be located as far away from streams and wetlands as practicable, designed to minimize intrusion into the Water Resource Protection Zone and disturb as little of the surface area of the Water Resource Protection Zone as practicable. 2. The proposed activity shall be designed, located and constructed to minimize excavation, grading, area of impervious surfaces, loss of native vegetation, erosion, and other adverse impacts on water resources. 3. On stream beds or banks within the bank -full stage, in wetlands, and on slopes of 25 percent or greater in a Water Resource Protection Zone, excavation, grading, installation of impervious surfaces, and removal of native vegetation shall be avoided except where no practicable alternative exists, or where necessary to construct public facilities or to ensure slope stability. 4. Water, storm drain, and sewer systems shall be designed, located and constructed to avoid exposure to floodwaters, and to avoid accidental discharges to streams and wetlands. 5. Stream channel repair and enhancement, riparian habitat restoration and enhancement, and wetland restoration and enhancement will be restored through the implementation of a mitigation plan prepared in accordance with the standards and requirements in section 18.3.11.110, Mitigation Requirements. 6. Long-term conservation, management and maintenance of the Water Resource Protection Zone shall be ensured through preparation and recordation of a management plan as described in subsection 18.3.11.110.C, except a management plan is not required for residentially zoned lots occupied only by a single-family dwelling and accessory structures. 10) The criteria of approval for a Tree Removal Permit for a non -hazardous tree are described in AMC 18.5.7.040.B.2 as follows: 2. Tree That is Not a Hazard. A Tree Removal Permit for a tree that is not a hazard shall be granted if the approval authority finds that the application meets all of the following criteria, or can PA-T3-2024-00010 March 11. 2025 Page 6 be made to conform through the imposition of conditions. a. The tree is proposed for removal in order to permit the application to be consistent with other applicable Land Use Ordinance requirements and standards, including but not limited to applicable Site Development and Design Standards in part 18.4 and Physical and Environmental Constraints in part 18.3.10. b. Removal of the tree will not have a significant negative impact on erosion, soil stability, flow of surface waters, protection of adjacent trees, or existing windbreaks. c. Removal of the tree will not have a significant negative impact on the tree densities, sizes, canopies, and species diversity within 200 feet of the subject property. The City shall grant an exception to this criterion when alternatives to the tree removal have been considered and no reasonable alternative exists to allow the property to be used as permitted in the zone. d. Nothing in this section shall require that the residential density to be reduced below the permitted density allowed by the zone. In making this determination, the City may consider alternative site plans or placement of structures of alternate landscaping designs that would lessen the impact on trees, so long as the alternatives continue to comply with the other provisions of this ordinance. e. The City shall require the applicant to mitigate for the removal of each tree granted approval pursuant to section 18.5.7.050. Such mitigation requirements shall be a condition of approval of the permit. 11) The Planning Commission, following proper public notice, held a public hearing on February 11, 2025. 12) Testimony was received, and exhibits were presented. The Planning Commission deliberated and approved the application subject to conditions of approval. Now, therefore, the Planning Commission of the City of Ashland fmds, concludes, and recommends as follows: SECTION 1. EXHIBITS For the purposes of reference to these Findings, the attached index of exhibits, data, and testimony will be used. Staff Exhibits lettered with an "S" Proponent's Exhibits, lettered with a "P" Opponent's Exhibits, lettered with an "O" Hearing Minutes, Notices, and Miscellaneous Exhibits lettered with an "M" SECTION 2. CONCLUSORY FINDINGS OF FACT 2.1 The Planning Commission notes that chapter 18 of the Ashland Municipal Code (AMC) is the City's Land Use Ordinance (LUO). The LUO regulates the development pattern envisioned by the Comprehensive Plan and encourages efficient use of land resources among other goals. The Planning Commission notes that when considering the decision to approve or deny an application the Planning Commission considers the application materials against the relevant approval criteria in the LUO. PA-T3-2024-00010 March 11, 2025 Page 7 2.2 The Planning Commission finds that it has received all information necessary to render a decision based on the application itself, the February 1 l' Staff Report, the applicant's testimony, the exhibits received, and public testimony received at the public hearing. 2.3 The Planning Commission notes that the application was deemed complete and that the notice for the public hearing was both posted on, January 6 (20 days prior to the February 111 Meeting) at the frontage of the subject property, as well as the street stubs on the north and south side of the property. Notice was also mailed to all property owners within 200-feet of the subject property. 2.4 The Planning Commission finds that the proposal for Annexation meets all applicable approval criteria described in AMC 18.5.8.050 and detailed below. 2.4.1 The first approval criterion for annexation is that "The annexed area is within the Cin,'s Urban Growth Boundary (UGB)." The Planning Commission notes that the UGB runs along the north side of East Main in this portion of town which is approximately 0.2 miles to the north. The Planning Commission concludes that the property is within the UGB and finds that this approval criterion has been met. 2.4.2 The second approval criterion for annexation is that "The annexation proposal is consistent with the Comprehensive Plan designations applicable to the annexed area." The Planning Commission notes that the comprehensive plan designation of the property is suburban residential, and the property does not yet have an assigned zone. The application requests a zone change to R-1-3.5 which is appropriate for the comprehensive plan designation of suburban residential. The Planning Commission notes that the table at AMC 18.3.9.050 provides the residential density for a PSO subdivision, and that for the R-1-3.5 zone it specifies a residential density of 7.2 dwelling unit per acre. The Planning Commission notes that the subject property is 4.8 acres and concludes that the allowed base density for the subject property is 34.56. (4.8 x 7.2 = 34.56). The Planning Commission notes that the present proposal leverages an affordable housing density bonus to exceed the base density for a total of 37 dwellings. The Planning Commission notes that AMC 18.3.9.050.B.3 provides a density bonus of two units for each affordable housing unit provided up to maximum bonus of 35-percent, this would allow for up to an additional 12 units over the based density. The proposed 37 dwellings utilize only 3 of the available bonus units for a calculated bonus of 8.7%, which is well below the 35 percent available. The Planning Commission concludes that the proposed 37 dwellings are within the allowed base and bonus density standards and find that the proposed density of residential development, including the proposed affordable housing, is consistent with the Comprehensive Plan Designation. The Planning Commission concludes that based on the proposed number of dwellings, the size of the property, and the requested zoning, and finds that this approval criterion has been met. 2.4.3. The third approval criterion for annexation is that "The annexed area is contiguous with the Cih' limits." The Planning Commission notes that the subject property is shown on the map below. The Planning Commission notes that the map is from the City Geographic Information System (GIS) and has a yellow and grey dashed PA-T3-2024-00010 March 11, 2025 Page 8 line that indicates the city limits. The Planning Commission note that the subject property is contiguous with the City limits to the north, south, and east and finds that this approval criterion has been met. 239 241 DOLLAHHOL wv U4 ;2P ZZ24Q._ 2.4.4 The fourth approval criterion for annexation is that "Adequate City facilities for the provision of water to the anne-xed area as determined by the Public Works Department; the transport of sewage from the annexed area to an approved waste water treatment facility as determined by the Public Works Department; the provision of electricitv to the annexed area as determined by the Electric Department; zrrban storm drainage as determined by the Public Works Department can and will be provided from the annexed area." The Planning Commission notes that the application indicates that the property is served by all city utilities and that the Public Works Department has confirmed that there are no concerns regarding the capacity of any City facilities. The Planning Commission notes that Clay Street contains an eight -inch water main, eight - inch sewer main, and an 18" storm water main, that Engle Street has eight -inch water mains at both the north and south of the property as well as an eight -inch sewer main and a ten -inch sewer main at the north stub of Engle Street. The Planning Commission notes that due to the nature of gravity systems and the topography of the site no sewer or storm is needed on the southern stub of Engle Street. The Planning Commission notes that the application includes a complete set of plans for the proposed civil improvements prepared by Powell Engineering & Consulting which provide complete details on street improvements including curb, gutter, planter strip and sidewalk as well as a protected bike lane all designed to meet city standards. The Planning Commission concludes that based on the existing and proposed improvements that this approval criterion is met. 2.4.5 The fifth approval criterion for annexation is that "Adequate transportation can and will be provided to serve the annexed area. For the purposes of this section, "adequate transportation "for annexations consists of vehicular, bicycle, pedestrian, and transit transportation." The Planning Commission notes that the LUO requires a PA-T3-2024-00010 March 11, 2025 Page 9 minimum 22-foot-wide paved access and for both bicycle and pedestrian facilities be safe and accessible pursuant to the governing jurisdiction. The Planning Commission notes that the application material includes a trip generation assessment and Transportation Planning Rule (TPR) findings prepared by Southern Oregon Transportation and Engineering. These materials detail the expected trip generation of the proposed development and show that the proposed development is below the requirements for a complete Traffic Impact Analysis (TIA) as the development is expected to only generate 30 weekday peak hour trips where the threshold for a TIA is 50 newly generated vehicle trips. The Planning Commission notes that the proposed development includes the creation of new local neighborhood roads connecting Engle Street, as well as a new neighborhood street connecting to Clay Street and that all proposed public facilities are to be constructed to City of Ashland Standards. The Planning Commission notes that all proposed roads meet or exceed the 22-foot wide paved width. The Planning Commission finds, based on the fact that all proposed transportation facilities are to be built to the City Standards, and that those standards were created to provide adequate safe and accessible transportation that this approval criterion is met. 2.4.6 The sixth approval criteria for annexation is that "For all residential annexations, a plan shall be provided demonstrating that the development of the annexed area will ultimately occur at a minimum density of 90 percent of the base density for the gone, unless reductions in the total number of units are necessary to accommodate significant natural features, topography, access limitations, or similar physical constraints." The Planning Commission notes, as stated above, that the subject property is 4.8 acres and has an allowed base density of 7.2 dwellings per acre for a calculated base density of —34 (4.8 x 7.2 = 34.56). The Planning Commission notes that 90% of the calculate base density is —32 dwelling units. (34.56 x 0.9 = 31.1). The Planning Commission notes that the proposed density for the subdivision is 37 dwellings which exceeds the minimum requirement of 32 dwellings and therefore find that the approval criterion is met. 2.4.7 The seventh approval criteria for annexation is that "annexations with a density or potential density of four residential units or greater and involving residential coned lands ... The total number of affordable units provided to qual fving buyers, or to qual Ong renters, shall be equal to or exceed 25 percent of the base density as calculated using the unit equivalency values set forth herein." The Planning Commission notes that the applicant proposes affordable housing restricted to households earning at or below 80 percent of the area median income (AMI), and that such units each have an equivalency value of 1.25 unit. The Planning Commission notes that AMC 18.5.8.050.G.I provides that "The base density of the annexed area for the purpose of calculating the total number of affordable units in this section shall exclude any unbuildable area including wetlands." Additionally, AMC 18.5.8.050.G.7 provides that "The total number of affordable units described in this subsection shall be determined by rounding up fractional answers to the nearest whole unit." As discussed above the wetland delineation determined that the area of the wetland is 0.0096 acres. Therefore, for the purpose of calculating the total number of affordable units we calculate the density excluding the PA-T3-2024-00010 March 11, 2025 Page 10 wetland area, as follows: 4.8 acres - 0.0096 acres = 4.79 acres x 7.2 dwelling units per acer = 34.49 dwelling units x 0.25 = 8.6 — 9 affordable dwelling units. The Planning Commission reaffirms that affordable units designated for households earning 80% AMI or less have an equivalent value of 1.25 per AMC 18.5.8.050G. l.c. To determine the required number of 80% AMI units needed to satisfy the affordable housing requirement, the total required affordable units —in this case, nine —is divided by 1.25 (the equivalency value). Calculation: 9 affordable units _ 1.25 = 7.2, which rounds up to 8 units. Therefore, providing eight units at 80% AMI fulfills the requirement for nine affordable units. Based on this calculation, the Planning Commission concludes that the approval criterion is met. s ON NNONA. r. 4 r .. 2.4.8 The eighth approval criterion for annexation requires at least one of five standards to be met. The fast of these standards is * that "The anne-xation proposal shall meet the requirements of subsection 18.5.8.050.B, above." The referenced section is the second approval criteria which states, "that the proposal is consistent with the Comprehensive Plan designations" and was discussed in section 2.4.2 above. The Planning Commission notes again that the proposal is consistent with the Comprehensive Plan and finds that since the second approval criterion was satisfied that this approval criterion has also been * The other four options are for the situations where the annexation would be allowed even if the development is not consistent with the Comprehensive plan: 2. A current or probable danger to public health exists within the proposed area for annexation due to lack of full City sanitary sewer or water services in accordance with the criteria in ORS chapter 222 or successor state statute. 3. Existing development in the proposed area for annexation has inadequate water or sanitary sewer service, or the service will become inadequate within one year. 4. The proposed area for annexation has existing City water or sanitary sewer service extended, connected, and in use, and a signed consent to annexation agreement has been filed and accepted by the City. 5. The proposed area for annexation is an island surrounded by lands within the City limits. PA-T3-2024-00010 March 11, 2025 Page 11 met. 2.4.9 The ninth and final approval criteria for annexation relates to requested exceptions. The only exception requested, which was discussed above, was an exception to AMC 18.5.8.050.G.3, which requires the affordable units to have a comparable bedroom mix with the market rate units. The Planning Commission made findings that there was insufficient evidence in the record to support such an exception and included a condition of approval to ensure that the standard is met at final plan approval. With the denial of the exception The Planning Commission finds that this approval criterion is met. 2.4.10 Finally, the Land Use Ordinance requires that "the applicant for the annexation shall also declare which procedure under ORS chapter 222 the applicant proposes that the Council use, and supply evidence that the approval through this procedure is likely" (AMC 18.5.8.070). The application states that the annexation procedure outlined in ORS 222.125 should be utilized for the annexation and goes on to say that "This procedure allows for annexation without the need for an election when all landowners in the proposed territory, as well as a majority of the electors, consent in writing. The applicant is the sole owner and can provide written consent within the annexation territory." Based on the fact that there is a single property is proposed for annexation, the Planning Commission finds that this standard is met. The Planning Commission concludes based on the above that all applicable approval criteria for annexation approval have been satisfied. 2.5 The Planning Commission finds that the proposal for Outline Plan of a Performance Standard Option (PSO) subdivision meets all applicable criteria for described in AMC 18.3.9.040.A.3 and detailed below. 2.5.1 The first approval criterion for Outline Plan approval is that "The development meets all applicable ordinance requirements of the City." The Planning Commission notes that this is an all -encompassing criterion and that it has considered which City Ordinances are applicable. The Planning Commission notes that for the purposes of resolving this criterion we rely on the entirety of the record including the applicant's submittal, and the Staff Report, and testimony provided. The Planning Commission notes that with the findings that are set out below, and the adopted conditions of approval that the proposal will meet all applicable ordinance requirements and finds that this criterion of approval is satisfied. 2.5.2 The second approval criterion for Outline Plan approval is that "Adequate key City facilities can be provided including water, sewer, paved access to and through the development, electricity, urban storm drainage, police and fire protection, and adequate transportation; and that the development will not cause a City facility to operate beyond capacity." The Planning Commission notes that city facilities were discussed at length in the fourth approval criterion for annexation and restate them for the record here. The Planning Commission notes that the application indicates that the property is served by all city utilities and that the Public Works Department has confirmed that there are no concerns regarding the capacity of any City facilities. The Planning Commission notes PA-T3-2024-00010 March 11, 2025 Page 12 that Clay Street contains an eight -inch water main, eight -inch sewer main, and an 18" storm water main, that Engle Street has eight -inch water mains at both the north and south of the property as well as an eight -inch sewer main and a ten -inch sewer main at the north stub of Engle Street. The Planning Commission notes that due to the nature of gravity systems and the topography of the site no sewer or storm is needed on the southern stub of Engle Street. The Planning Commission notes that the application includes a complete set of plans for the proposed civil improvements prepared by Powell Engineering & Consulting which provide complete details on street improvements including curb, gutter, planter strip and sidewalk as well as a protected bike lane all designed to meet city standards. The Planning Commission concludes that based on the existing and proposed improvements that this approval criterion is met. 2.5.3 The third criterion for approval of an Outline Plan is that "Ae existing and natural features of the land; such as wetlands, floodplain corridors, ponds, large trees, rock outcroppings, etc., have been identified in the plan of the development and significant features have been inchided in the open space, common areas, and inibi ildable areas." The Planning Commission notes that aside from the proposed tree removals, which are discussed below, that the only other natural feature to address is the delineated wetland. The Planning Commission notes that the wetland along with a twenty -foot buffer is proposed to be in a lot dedicated to open space. The Planning Commission notes that there are no other natural features to address and find that this approval criteria is satisfied. 2.5.4 The fourth criterion for approval of an Outline Plan is that "The development of the land will not prevent adjacent land from being developed for the uses shown in the Comprehensive Plan." The Planning Commission notes that to the west is Clay Street, and that the surrounding property is fully developed, with "East Village" Subdivision to the north, the "Snowberry Brook" development to the south and to the east is the rear of a mobile home park that fronts Tolman Creek Road. The Planning Commission notes that there is no adjacent vacant land and that with the foregoing find that this approval criterion is met. 2.5.5 The fifth criterion for approval of an Outline Plan is that is that "There are adequate provisions for the maintenance of open space and common areas, if required or provided, and that if developments are done in phases that the early phases have the same or higher ratio of amenities as proposed in the entire project." The Planning Commission notes that the draft HOA governing instruments have obligations for the maintenance of the open space and other common amenities. The Planning Commission finds that there are adequate provisions for the maintenance of the open space and common areas and finds that this criterion of approval is satisfied. 2.5.6 The sixth criterion for approval of an Outline Plan is that is that "Ae proposed density meets the base and bonus densitv standards established under this chapter." The Planning Commission notes that density was discussed in the second approval criterion of annexation and restate those findings again here. The Planning Commission notes that the table at AMC 18.3.9.050 provides the residential density for a PSO subdivision, and that for the R-1-3.5 zone it specifies a residential density of 7.2 dwelling unit per acre. The Planning Commission notes that the subject property is 4.8 acres and concludes that the PA-T3-2024-00010 March 11, 2025 Page 13 allowed density for the subject property is 34.56. (4.8 x 7.2 = 34.56). The Planning Commission notes that the present proposal leverages affordable housing density bonus to exceed the base density for a total of 37 dwellings. The Planning Commission notes that AMC 18.3.9.050.B.3 provides a density bonus of two units for each affordable housing unit provided up to maximum bonus of 35-percent, this would allow for up to an additional 12 units over the based density. The proposed 37 dwellings utilize only 3 of the available bonus units for calculated bonus of 8.7%, which is well below the 35 percent available. The Planning Commission concludes that the proposed 37 dwellings are within the allowed base and bonus density standards and finds that this criterion of approval is satisfied. 2.5.7 The seventh Outline Plan approval criterion is that "The development complies with the Street Standards." The Planning Commission notes that transportation facilities were discussed at length in the fifth approval criterion for annexation and restate them for the record here. The proposed development includes the creation of new local neighborhood roads connecting Engle Street, as well as a new neighborhood street connecting to Clay Street and that all proposed public facilities are proposed to be constructed to City of Ashland Standards. The Planning Commission notes that the application includes detailed civil engineering plans including street cross sections showing a 47' ROW, 22' paved width including seven -foot planter strip and five-foot sidewalk which meets the standards shown in Figure 18.4.6.040.G.4.b. 'Neighborhood Street, Parking One Side.' The Planning Commission notes that there are two locations on the preliminary plat and civil site plans that show only 46' feet of proposed ROW dedication. A condition of approval is included below that will require the revised civil plans at Final Plan approval to indicate 47' of ROW dedication. The Planning Commission finds that with the included condition of approval below that all proposed transportation facilities are built to the City Standards that this approval criterion is met. 2.5.8 The final criterion for approval of an Outline Plan is that is that "The proposed development meets the connnon open space standards established under section 18.4.4.070. Common open space requirements mm be satisfied by public open space in accordance with section 18.4.4.070 if approved by the Citv of Ashland" The Performance Standards Option Chapter requires that at least eight percent of the total lot area be provided in common open space for developments with a base density of ten units or greater. The Planning Commission notes that the proposed subdivision includes four open space areas totaling 16,102 square feet. The requirement for minimum open space for a PSO subdivision is five percent of total lot area for developments with a base density of 10 units or more. The subject property is 209,088 square feet in size, five percent of that is 10,454 square feet. Based on the calculation above the applicant is providing a total of 7.7% in open space which exceeds the required minimum and find that this approval criterion is met. The Planning Commission concludes based on the above and finds that all applicable approval criteria for Outline Plan subdivision approval have been satisfied. 2.6 The Planning Commission finds that the proposal for a Water Resource Protection Zone (WRPZ) Limited Activities and Uses Permit meets all of the applicable criteria described in AMC PA-T3-2024-00010 March 11, 2025 Page 14 18.5.5.050 and as detailed below. As explained above the property has locally identified wetlands from the City's Local Wetland Inventory (LWI). The Planning Commission notes that the application states that based on the area of the wetland, the wetland is not a Significant Wetland, but a small, 418.76 square foot (.0096 acre) wetland area, as such they propose a twenty -foot buffer around this 419 square foot area. The Planning Commission notes that among the listed "limited activities and uses" that are allowed in the WRPZ area is the installation of public and private storm water treatment facilities. The application states that "The proposed stormwater lateral dispersal trench is a permitted use within the Water Resource Protection Zone. The utility is outside of the wetland area and is proposed at the outer edge of the 20 foot wetland buffer gone. ", and that "The areas of disturbance will be reseeded with a native grass mix that is appropriate for planting in the wetland buffer gone." The Planning Commission notes that all disturbance activities shall be as far away from the wetland as practicable. The Planning Commission further notes that the proposed storm water infrastructure is at the edge of the buffer area and concludes that the nature of the storm water system requires that it be within some proximity to the wetland. The Planning Commission notes that the proposal has been designed to minimize the excavation area, that the wetland is located on HOA open space, and that the long- term conservation will be ensured through the HOA management documents. The Planning Commission concludes based on the forgoing that the proposed storm water facility meets all the required approval criteria. 2.7 The approval criteria for "Tree that is not a hazard" first require that "Tire tree is proposed for removal in order to permit the application to be consistent with other applicable Land Use Ordinance requirements and standards." The Planning Commission note that the application includes a request to remove four trees. The application describes the removals as follows: "There are three deciduous trees that have a DBH of 12-inches or more that are proposed for removal and one tree conifer tree greater than 16 inches DBH. These trees are within the area of the public streets, the alley and within the building envelope area of the development area of the lots. The tree removal is necessitated by the construction of public streets, an alley and residential dwellings." (Applicant findings p. 46). The Planning Commission notes that to approve the removal of a non -hazard tree it needs to be shown that "The tree is proposed for removal in order to permit the application to be consistent with other applicable Land Use Ordinance requirements and standards." The Planning Commission notes that the location of these trees being within the proposed street dedication and building envelopes, the proposed removals are found to meet the standards. The Planning Commission notes that the applicant will be required to mitigate for the removal of each tree and further notes that preliminary landscape plan, shows that the number of trees to be planted far exceeds the four that are required to mitigate these proposed removals. The Planning Commission find, based on the forgoing, that the applicable approval criteria are met. 2.8 The Planning Commission notes that following proper public notice, a public hearing was held on February 11, 2025, where testimony was received, and exhibits were presented. 2.8.1 The Planning Commission deliberated, and a motion was made to recommend approval to the City Council. The recommendation to approve the application was subject to the conditions of approval in the Staff Report along with added condition of approval: ""That the final plan submittal shall identify a mLc of bedrooms for the affordable units PA-T3-2024-00010 March 11, 2025 Page 15 comparable to the bedroom mix of the market rate units and include necessary deed restrictions to ensure compliance." 2.9 The Planning Commission notes that the record includes the applicant's submittal, the Staff Report, as well as the testimony received at the public hearing, each of these by their reference are incorporated herein as if set out in full. 2.9.1 The Planning Commission finds that there is substantial evidence in the record to make findings that each of the criteria of approval for annexation and Outline Plan have been met. SECTION 3. DECISION 3.1 Based on the record of the Public Hearings on this matter, the Planning Commission concludes that the request Annexation and Outline Plan Approval is supported by evidence contained within the whole record and forwards a recommendation of approval to City Council including the conditions of approval below. The conditions of approval are below: 1) That all proposals of the applicant shall be conditions of approval unless otherwise specifically modified herein. 2) That the applicant applies for final plan approval pursuant to AMC 18.3.9.040.B within 18 months of this outline plan approval. The application for Final Plan approval will be required to include the following: a. That the revised civil and site plans that are to be submitted with Final Plan approval indicate 47' of ROW for both Engle and Street and Caldera Lane. b. Provide CC&R's for review that include sufficient maintenance for the private drive and all common area amenities. c. That pursuant to AMC 13.24.010.0 that the applicant shall consult with the Public Works Director for approval of the proposed street name of Caldera Lane. d— That the-, final plan sub-n—A-ittall shapil identify a -m-ix- of h-e-d-F-A-A-Has ftf-�- th-t-A -Aff-49-r-d-a4h-l-e- 3) That permits shall be obtained from the Ashland Public Works Department prior to any additional work in the public right of way. 4) That a final survey plat shall be submitted within 12 months of Final Plan approval and approved by the City of Ashland within 18 months of this approval. Prior to submittal of the final subdivision survey plat for signature: a. All easements including but not limited to public and private utilities, public pedestrian and public bicycle access, drainage, irrigation, and fire apparatus access shall be indicated on the final subdivision plat submittal for review by the Planning, Engineering, Building and Fire Departments. PA-T3-2024-00010 March 11, 2025 Page 16 b. Subdivision infrastructure improvements including but not limited to utilities, driveways, streets and common area improvements shall be completed according to approved plans, inspected and approved. Electric services shall be installed underground to serve all lots, inspected and approved. The final electric service plan shall be reviewed and approved by the Ashland Electric, Building, Planning and Engineering Divisions prior to installation. d. That the sanitary sewer laterals and water services including connection with meters at the street shall be installed to serve all lots within the applicable phase, inspected and approved. 5) That a final Fire Prevention and Control Plan addressing the General Fuel Modification Area requirements in AMC 18.3.10.100.A.2 of the Ashland Land Use Ordinance shall be provided prior to bringing combustible materials onto the property, and any new landscaping proposed shall comply with these standards and shall not include plants listed on the Prohibited Flammable Plant List per Resolution 2018-028. 6) That the building permit submittals shall include the following: a. Identification of all easements, including but not limited to any public and private utility easements, mutual access easements, and fire apparatus access easements. b. For Lots #1-16 & 25 Solar setback calculations demonstrating that all units comply with Solar Setback Standard A in the formula [(Height —6) / (0.445 + Slope) = Required Solar Setback] and elevations or cross section drawings clearly identifying the highest shadow producing point(s) and the height(s) from natural grade. c. For Lots #17-24 Demonstrate compliance with the approved solar setback showing that any shadows cast do not exceed five feet above the finished floor elevation of the main level of a house on the respective lots to their north, assuming the affected house is built six feet from the shared property line. d. Final lot coverage calculations demonstrating how lot coverage is to comply with the applicable coverage allowances of the R-1-3.5 zoning district. Lot coverage includes all building footprints, driveways, parking areas and other circulation areas, and any other areas other than natural landscaping. e. That storm water from all new impervious surfaces and runoff associated with peak rainfalls must be collected on site and channeled to the City storm water collection system through the curb or gutter at a public street, a public storm pipe, an approved public drainage way, or through an approved alternative in accordance with Ashland Building Division policy BD-PP-0029. On -site collection systems shall be detailed on the building permit submittals. /s/ Lisa Verner 3/11/2025 Planning Commission Approval Date PA-T3-2024-00010 March 11, 2025 Page 17