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HomeMy WebLinkAbout2025-08-12_Planning MIN Planning CommissionMinutes Note: Anyone wishing to speak at any Planning Commission meeting is encouraged to do so. If you wish to speak, please rise and, after you have been recognized by the Chair, give your name and complete address for the record. You will then be allowed to speak. Please note the public testimony may be limited by the Chair. August 12, 2025 REGULAR MEETING Minutes I.CALL TO ORDER: Chair Verner called the meeting to order at 7:00 p.m. at the Civic Center Council Chambers, 1175 E. Main Street. Commissioners Present: Staff Present: Lisa Verner Brandon Goldman, Community Development Director Susan MacCracken Jain Derek Severson, Planning Manager John Maher Aaron Anderson, Senior Planner Russell Phillips Michael Sullivan, Executive Assistant Absent Members: Council Liaison: Eric Herron Jeff Dahle (absent) Kerry KenCairn II.ANNOUNCEMENTS 1.Staff Announcements: Community Development Director Brandon Goldman made the following announcements: The City Council will hold a public hearing regarding the annexation of 1511 Highway 99 at their meeting on Tuesday, August 19. The City Council will be reviewing the second reading of ordinances implementing the SOU Masterplan at their next meeting. The Parks Department will hold an open house on August 14 from 5:00 PM to 6:00 PM at the Senior Center to gather feedback on the East Main park project. The Water Treatment plant work on Granite Street is underway, with the culvert crossing currently in process and a temporary pedestrian crossing over Ashland Creek in place. 2.Advisory Committee Liaison Reports – None III. CONSENT AGENDA Approval of Minutes 1.July 22, 2025 Special Meeting Minutes Chair Verner noted that Staff had submitted revised minutes for the July 22, 2025 Special Meeting Page 1 of 4 In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please email planning@ashland.or.us. Notification 72 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to the meeting (28 CFR 35.102-35.104 ADA Title 1). Planning CommissionMinutes which clarified Staff announcements regarding the SOU Masterplan project. Commissioners Phillips/Maher m/s to approve the Consent Agenda as amended by Staff. Voice Vote: All AYES. Motion passed 4-0. IV.PUBLIC FORUM Alison Laughlin/Ms. Laughlin spoke regarding dangerous flooding conditions at Roca Street and Fern Street. V.UNFINISHED BUSINESS A.Approval of revised Findings on remand from City Council for PA-T2-2024-00053, 231 Granite Street Chair Verner explained that the Planning Commission's earlier decision regarding 231 Granite Street had been appealed to the City Council. While the Council upheld the Commission's decision, they requested more robust findings in anticipation of a possible appeal to the Land use Board of Appeals (LUBA.) The revised findings before the Commission included suggested revisions from staff, the applicants, Commissioner Phillips, and Chair Verner (see attachment #1). Chair Verner noted that a question had been raised about section 2.5 of the findings, which contained the statement "the Commission notes that with the proposal one additional home serving a lot with a pre-existing easement will be served from the shared driveway." Staff clarified that this referred to the home proposed in the application, not implying additional future construction. Ex Parte Contact Commissioners Maher and Phillips disclosed site visits. No ex parte contact was disclosed. Decision Chair Verner proposed removing a sentence in the middle of page 6 that stated "The Commission finds that the proposed development reduces adverse impacts, potential hazards, and limits the amount of hillside disturbance," stating that it went beyond what the Commission had directly found. Commissioners Phillips/Maher m/s to approve the amended findings, incorporating revisions from staff and the updated condition 2.5 provided by Chair Verner, and also included removing the sentence "The Commission finds that the proposed development reduces adverse impacts, potential hazards, and limits the amount of hillside disturbance." Roll Call Vote: All AYES. Motion passed 4-0. Page 2 of 4 In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please email planning@ashland.or.us. Notification 72 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to the meeting (28 CFR 35.102-35.104 ADA Title 1). Planning CommissionMinutes VI.TYPE II PUBLIC HEARINGS PLANNING ACTION: PA-T2-2025-00059 SUBJECT PROPERTY: 39-1E-04-AD Tax Lot 8600 OWNER/APPLICANT: PDK Properties LLC DESCRIPTION: A request for Final Plan approval for a 15-lot Performance Standard Option (PSO) subdivision. The Subdivision Outline Plan was approved by the Ashland Planning Commission adopted findings approving PA-T2-2024-00054, on January 14, 2025. The Proposed final plan come before the Planning Commission because a section that was approved as an alley is now proposed to be pedestrian access due to the existing adjacent grade. The application also includes a modification to the previous Site Design Review. COMPREHENSIVE PLAN DESIGNATION: North Mountain l; ZONING: NM-MF; MAP: 39 1E 04 AD; TAX LOTS: 8600 Chair Verner acknowledged public comments received before the meeting but after the packet had been published (see attachment #2). Ex Parte Contact Commissioners Phillips and Verner disclosed site visits. No ex parte contact was disclosed. Staff Presentation Senior Planner Aaron Anderson briefly outlined the project with the following proposed changes to the previously approved plan: altering a vehicle traffic connection to a pedestrian pathway; changing building layouts and elevations; removing underbuilding parking in favor of a small parking area on Julian Court; and lowering building heights. Items addressed were increasing rights-of-way from 47 to 48 feet and additional alleyway dedications. Staff also added Condition #8 regarding new irrigation, and removed a mistakenly included condition related to another planning project (see attachment #3). Questions of Staff Commissioner Phillips requested clarification regarding the walkway's grade; Mr. Anderson confirmed a 15% grade with steps. Mr. Goldman elaborated that improvements in the public right-of-way often exceed ADA standards in the City due to the terrain, while internal sidewalks and the ADA parking space would be subject to ADA accessibility requirements. Applicant Presentation Applicant Mark Knox explained that the civil plans revealed the grade was steeper than initially anticipated, especially at the connection to Patton Lane, resulting in the proposed revisions. The applicant team determined that while a vehicle connection wasn't feasible, a pedestrian connection would align with the North Mountain plan's goal of facilitating pedestrian movement. He noted that the 15% grade was a worst-case scenario, and the addition of steps would likely reduce it to about 12%. He Page 3 of 4 In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please email planning@ashland.or.us. Notification 72 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to the meeting (28 CFR 35.102-35.104 ADA Title 1). Planning CommissionMinutes mentioned that other paths in the development also have similar grades with steps. Applicant Kyle Taylor explained that the requested modifications were refinements from the outline plan. He explained that the team had struggled with the grade on the pedestrian path and needed to drop the buildings to address neighbor concerns about views. This made the parking underneath the buildings unreasonable, so the parking was relocated and the structures rearranged while maintaining the same number of units with similar square footage. He noted that pushing the building frontage on Patton down would make it appear more like a single-story property from the uphill perspective. Questions of the Applicant Chair Verner asked about a market for small units, with the applicant responding to demand focused on affordable and workforce housing. Public Comments Mark Abelle/Mr. Abelle raised concerns regarding wildfire risk and advocated for changes enhancing safety. Chair Verner closed the Public Hearing and Public Record at 7:50 p.m. Deliberation and Decision Commissioner Russell requested clarification on the conditions of approval. Staff confirmed that the original condition #2 had already been removed from the packet prior to distribution, and the new condition regarding irrigation would be added as condition #8. Commissioners Russell/Maher m/s to approve the application consistent with the conditions recommended by staff, with the addition of Condition #8 as proposed by staff. Roll Call Vote: All AYES. Motion passed 4-0. VII.OPEN DISCUSSION The Commission discussed planning its annual retreat, including potential topics, such as wildfire risk and how it pertains to land use, Public Meeting law, and a site visit to projects completed with the previous year. The date of the retreat was not determined. VIII.ADJOURNMENT Meeting adjourned at 8:14 p.m. Submitted by, Michael Sullivan, Executive Assistant Page 4 of 4 In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please email planning@ashland.or.us. Notification 72 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to the meeting (28 CFR 35.102-35.104 ADA Title 1). BEFORE THE PLANNING COMMISSION August 12, 2025 IN THE MATTER OF PLANNING ACTION #PA-T2-2024-00053,) INCLUDING REVIEW ON REMAND PURSUANT TO #PA-APPEAL-2025-) 00021,A PHYSICAL AND ENVIRONMENTAL(P&E) CONSTRAINTS ) REVIEW PERMIT FOR THE CONSTRUCTION OF A NEW SINGLE-) FAMILY RESIDENTIAL HOME ON A VACANT PARCEL AT 231) GRANITE STREET.IN ADDITION TO THE P&EPERMIT, THE ) FINDINGS, DEVELOPMENT REQUIRESA VARIANCE TO FLAG DRIVE) CONCLUSIONS & STANDARDS OF AMC 18.5.3.060.FFOR BOTH MAXIMUM DRIVEWAY ) ORDERS. GRADE AND LENGTH, A TREE REMOVAL PERMIT FOR THE ) REMOVAL OF74 TREES INCLUDING NINE SIGNIFICANT TREES,AND) ANEXCEPTION TO THE DEVELOPMENT STANDARDS FOR HILLSIDE ) LANDS.) ) OWNERS: BRYAN & STEPHANIE DEBOER) APPLICANT: CARLOS DELGADO,ARCHITECT _______________________________________________________________ RECITALS: 1)The subject property is tax lot#1800of Assessor’s Map 39-1E-08-DAand has a site address of231GraniteStreet. 2)The property is zoned Rural Residential (RR-.5) andis 2.182acres in size. 3)The subject property was created prior to the current Physical & Environmental Constraints Ordinance (AMC 18.3.10) and has an average slope ofapproximately27percent. As provided at AMC 18.3.10.090.A.1.a, “Existing parcels without adequate buildable area less than or equal to 35-percent shall be considered buildable for one single-family dwelling and an accessory residential unit or a duplex…” 4)The application proposes the construction of a new single-family residential home which requires a Physical & Environmental (P&E) Constraints Review Permit due to thesite’s topography.The application also requires aVariance to the flag drive standards in AMC 18.5.3.060.F, a Tree Removal Permit to remove 74 trees including nine significant trees, and an Exception to the Development Standards for Hillside Lands. 5)On January 31, 2025,theapplicationwas deemed complete, and in accordance with AMC 18.5.1.050.B.4aNotice of Complete applicationand public meetingwas posted on February 19, 2025 at theentrance of the access easement along Granite Streetin clear view from the public right-of-waythat accesses the subject property. Notice was also mailed to all property owners of record within 200 feet of the subject parcel. 6)The Planning Commission, following proper public notice, held apublic hearing on March 11, 2025. The meeting was conducted in person and electronically via Zoom. Public testimony PA-T2-2024-00053 August 12, 2025 Page 1 was received,and exhibits were presented.Prior to the closing of the public hearing, members of the public requested that the hearing be continued. As provided under ORS 197.767.6.a-e, the Planning Commission voted to close the hearing but leave the public record opento allow for new information from parties of record for seven days (until March 18 at 4:30 p.m.), rebuttal from parties of record for the next seven days (until March 25 at 4:30 p.m.), and for a final seven days, only the applicant could provide their final legal arguments, but not new evidence, in response to all previously submitted information(until April 1 at 4:30 p.m.). The Planning Commission reconvened for deliberation on April 8, 2025at 7:00 p.m.The Chair provided her summation of all conditions of approval recommended by the Staff Advisor, Commissioners and through public comments contained within the whole record.Following deliberations, the Planning Commission approved the application subject to a numberof modified conditions pertaining to the appropriate development of the site. 7)On May 2, 2025, a timely appeal of Planning Action #PA-T2-2024-00053 was filed by appellants Leonard Eisenberg and Kent and Pamela McLaughlin, represented by attorney Zack P. Mittge of Hutchinson Cox. The appeal challenged the Planning Commission’s April 22, 2025 decision to approve a Physical and Environmental Constraints Review Permit, a Variance to the flag drive standards, an Exception to the Development Standards for Hillside Lands, and a Tree Removal Permit for development of a single-family residenceat 231 Granite Street. 8)The City Council held a hearing on July 15, 2025, to consider an appeal (PA-APPEAL-2025- 00021) of the Planning Commission’s approval of PA-T2-2024-00053 for development at 231 Granite Street. Upon review of the 25 assignments of error raised by the appellants, the Council determined that the Planning Commission’s decision was supported by substantial evidence in the record and did not involve legal or procedural errors. As part of its decision, the Council settled the record and excluded untimely written submittals in accordance with AMC 18.5.1.060.I.5. The Council affirmed the Commission’s decision and rejected the appeal, and remanded the matter to the Planning Commission for the sole purpose of amending its April 22, 2025 findings to provide more specificand detailed findings in support of the approval based on the established and settled record. The Council’s Findings dated July 15, 2025, are incorporated into the record of decision. 9)The criteria for approval for a Physical& Environmental (P&E)Constraints Review Permit are described inthe AshlandMunicipal Code (AMC)18.3.10.050which requiresthat all of thefollowing criteria are met: A.Through the application of the development standards of this chapter, the potential impacts to the property and nearby areas have been considered, and adverse impacts have been minimized. B.That the applicant has considered the potential hazards that the development may create and implemented measures to mitigate the potential hazards caused by the development. C.That the applicant has taken all reasonable steps to reduce the adverse impact on the environment. Irreversible actions shall be considered more seriously than reversible actions. The Staff Advisor or Planning Commission shall consider the existing development of the surrounding area, and the maximum development permitted by this ordinance. PA-T2-2024-00053 August 12, 2025 Page 2 10)The criteria for approval for an Exception to the Development Standards for Hillside Lands are described in the Ashland Municipal Code (AMC) 18.3.10.090.H which require that all of the following criteria are met: 1.There is demonstrable difficulty in meeting the specific requirements of this chapter due to a unique or unusual aspect of the site or proposed use of the site. 2.The exception will result in equal or greater protection of the resources protected under this chapter. 3.The exception is the minimum necessary to alleviate the difficulty. 4.The exception is consistent with the stated Purpose and Intent of chapter18.3.10, Physical and Environmental Constraints Overlay, and section18.3.10.090, Development Standards for Hillside Lands. 11)The criteria for approval for a Variance are described in the AshlandMunicipal Code (AMC) 18.5.5.050 which require that all of the following criteria are met 1.The variance is necessary because the subject code provision does not account for special or unique physical circumstances of the subject site, such as topography, natural features, adjacent development, or similar circumstances. A legal lot determination may be sufficient evidence of a hardship for purposes of approving a variance. 2.The variance is the minimum necessary to address the special or unique physical circumstances related to the subject site. 3.The proposal’s benefits will be greater than any negative impacts on the development of the adjacent uses and will further the purpose and intent of this ordinance and the Comprehensive Plan of the City. 4.The need for the variance is not self-imposed by the applicant or property owner. For example, the variance request does not arise as result of a property line adjustment or land division approval previously granted to the applicant. 12)The criteria for approval of a Tree Removal Permit are described in the AshlandMunicipal Code (AMC) 18.5.7.040.B.2 which require that all of the following criteria are met: a.Thetreeis proposed forremovalin 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 part18.4and Physical and Environmental Constraints in part 18.3.10. b.Removalof thetreewill not have a significant negative impact on erosion, soil stability, flow of surface waters, protection of adjacenttrees, or existing windbreaks. c.Removalof thetreewill not have a significant negative impact on thetreedensities, sizes, canopies, and species diversity within 200 feet of the subject property. The City shall grant an exception to this criterion when alternatives to thetree removalhave been considered and no reasonable alternative exists to allow the property to be used as permitted in the zone. PA-T2-2024-00053 August 12, 2025 Page 3 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 landscapingdesigns that would lessen the impact ontrees, 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 theremovalof eachtreegranted approval pursuant to section18.5.7.050. Such mitigation requirements shall be a condition of approval of the permit. 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 MiscellaneousExhibits lettered with an "M" SECTION 2. CONCLUSORY FINDINGS Now, therefore, the Planning Commission of the City of Ashland finds, concludes,and recommends as follows: 2.1The Planning Commission finds that it has received all the informationnecessary to render a decision based on thecompleteapplicationmaterials,staff report, public hearing testimonyand exhibits;and by theirreference each of these are incorporated hereinas if set out in full. 2..2The Planning Commission findsthatAMC Title 18 Land Use regulates the development of land envisioned by the Comprehensive Plan to encourage efficient use of land resources among other goals. The Planning Commission finds that there is substantial evidence in the record to make findings that each of the requestedactions has been shown to meet the relevant approval criteria or to meet those approval criteria through the imposition of certain binding conditions of approval. 2.3.The Planning Commission finds that the purpose of the Hillside Ordinance is to: “Provide for safe, orderly, and beneficial development of districts characterized by diversity of physiographic conditions and significant natural features; to limit alteration of topography and reduce encroachment upon, or alteration of, any natural environment and to provide for sensitive development in areas that are constrained by various natural features.” The Planning Commission finds that the proposed site development does not create soil erosion, sedimentation of lower slopes, slide damage, flooding problems, or severe cutting or scarring. The Commission finds that the intent of the hillside development standards are to encourage a sensitive form of development and to allow for a reasonable use that complements the natural and visual character of the City. PA-T2-2024-00053 August 12, 2025 Page 4 The Planning Commission finds that the proposed development complies with the criteria from AMC 18.3.10.050.A., B., and C., for the Physical and Environmental Constraints Review permit The for the development of hillside lands that include areas of greater than 35 percent. Commission finds that the proposed erosion control and wildfire hazard mitigation measures, including selective tree removal and tree preservation, will allow the hillside development to proceed in compliance with applicable standards for areas with slopes greater than 35 percent. The Planning Commission notes that AMC 18.3.10.090.A.1 generally provides that all development is to occur on lands defined as having a buildable area. Slopes greater than 35 percent are considered to be unbuildable, except that existing parcels without adequate buildable area, less than or equal to 35 percent, shall be considered buildable for one single-family dwelling and an accessory residential unit or a duplex. The Commission finds that the subject parcel was created prior to the adoption of the hillside regulations and the standard AMC 18.3.10.090.A.1. The Commission finds that the subject property does not have adequate building area of less than or equal to 35percent when considering the need to minimize broader disturbance by limiting development of the site to an area as near the existing driveway location as possible while also providing for site access and vehicular circulation. The Commission finds that, consistent with AMC 18.3.10.090.A.3, the portion of the driveway on land greater than 35 percent does not exceed 100 feet in length. The Planning Commission finds that the proposed home and outdoor area havebeen located in the northeast portion of the property to minimize hillside disturbance by limiting cuts and fill for construction. The Commission finds the proposed building design with the approved exception, reduces hillside disturbance through slope-responsive design, and that the height, roof forms, and off-sets reflect the irregular form of the property consistent with the building design standards from AMC 18.3.1.090.E. The Commission finds that through the application of the requirements of the Hillside Ordinance, under the oversight of a geotechnical expert, a civil engineer and a structural engineer, with the implementation of erosion control measures, preservation of a substantial area of the property in a natural state, tree protection/preservation, selected tree removal for site access and implementation of a wildfire fuels management plan, potential adverse impacts have been minimized. The Commission recognizes that development of the 2.18-acre site is focused on in the area nearest the location of the vehicular access easement, therefore retaining the majority of the large property in an undeveloped state. The construction of a single-story residence with a basement reduces the building height and limits visual impacts to adjacent properties. The residence is cut into the hill's slope without the PA-T2-2024-00053 August 12, 2025 Page 5 use of substantial amounts of fill. The Commission finds that the proposed cut slopes are retained and terraced with the terraces planted with erosion control vegetation, and do not exceed the maximum allowed vertical height as allowed in AMC 18.3.10.090.B.4. The Commission finds proposal minimizes slope failure and potential impacts to the subject property or adjacent properties through the implementation of appropriate drainage and retaining wall construction. The proposed development has stepped structural retaining walls to lessen the impact of a structure on the lot through the use of terracing and erosion control plant materials. The Commission finds that the proposed site disturbance is substantially less than allowedper AMC 18.3.10.090.B.3. To ensure the development is balanced with environmental preservation, by limiting excessive grading and modification of hillside slopes, the required percentage of the site to remain undisturbed is 52 percent \[27% average slope + 25% = 52% required to be retained in a natural state\]. The Commission finds that the site grading has been proposed, considering the factors found in AMC 18.10.090.B.8. The area of the proposed patio,pool, and pool deckiswithin an area of excavation for the construction of the residence that will provide a contractor staging area during the construction of the residence. The Commission finds that the pool is a lap pool, proposed in an area where the majority of the existing grade is slopes of less than 25 percent. The Commission finds that pools are discouraged but not prohibited.TheCommission finds that the proposed location of the proposed building pad, the patio area, and the pool are within an area of least slope, closest to the driveway access location, with as much of the remaining lot area as possible retained in the natural state of the original slope. The Commission finds that the proposed development reduces adverse impacts, potential hazards, and limits the amount of hillside disturbance. The Commission finds that there is 18,738 square feet of disturbance proposed on the 94,960 squarefoot lot, which equates to 80 percent (75,969 square feet) of the lot being retained in a natural state.This is substantially greater than the minimum percentage required. The Commission finds that the site is heavily treed, and the plan seeks to reduce fuel loads in the wildfire land overlay adjacent to the construction, while protecting healthy, preservable trees to reduce adverse impactsto the subject property or to adjacent properties.The Commission finds that the proposed development minimizes fire hazard through the implementation of a fire management plan. The Commission finds the proposed tree removal is consistent with AMC 18.3.9.110 requirements for wildfire hazards mitigation plan and an adequate wildfire mitigation zone surrounding the development area. The Commission finds that under the oversight of the city of Ashland Fire Marshal, adequate fire truck apparatus access has been proposed. The proposed paved driveway with pull-outs and adequate turning radius provides adequate fire apparatus access. In addition to the fire apparatus access, there will be residential fire sprinklers, and a nearby private fire hydrant is present within the neighborhood, accessed from the shared, private driveway. An outdoor pool can provide emergency firefighting water outflow. The proposed fire safety measures demonstrate that all PA-T2-2024-00053 August 12, 2025 Page 6 reasonable steps have been taken to reduce adverse impacts on the environment and potential impacts to the property and nearby areas have been considered and impacts minimized. The Planning Commission concludes that the proposal meets all applicable criteria and standards fora Physical & Environmental (P&E) Constraints Review Permit as provided at AMC 18.3.10. The proposed area of development is in the least-steep portion of the lot, near the end of the private drive, and the application has made every effort to minimize the impacts to the site by locating the home as close to the driveway access as possible, in this area of least-steep slopes. The Planning Commission finds that the application includes erosion and sediment control plans as well as a geotechnical report and that by following the recommendations in both, the potential hazards will have been mitigated. The Planning Commission findsthat the landscaping plan and erosion control plan will minimize any adverse impactsthrough the control of storm water drainage upon the subject property and prevention of off-site drainage, with temporary and permanent erosion control measures,and preservation of a substantial amount of trees upon the subject propertyirreversible actions have been considered more seriously than reversible actions, and that the single-family home retains substantially more of the site in its natural state than required by ordinance. 2.4 The Planning Commission notes that the application,as originally submitted,involved two Exceptions to the Development Standards for Hillside Lands. The first of these was to AMC 18.3.10.090.E.2.c requires that downhill building wall heights greater than 20 feet require at least a six-foot step back. The Commission rejects the applicant'sassertion that this standard was limited to the wall face, and that the height measurement considered in the standard did not include the fascia androofing above. As such, while they had proposed an 18-foot 9-inch wall face, with the inclusionof the fascia and roof above, the total height above natural grade was 23- feet 10-inches tall withoutthe requisite setback. The Planning Commission, however, finds that excluding the fascia and roof measurements from the wall height would run counter to the intent of the standard,which seeks to have the structure step back meaningfully with the hillside. The Commission therefore finds that the proposal as presented requires an Exception. In considering this Exception, the Commission notes that the application asserts that the building step backs are minimal to keep the building shorter and closer to parallel with the slope of the lot, without interfering with the ridgeline, explaining that the lot is one long, consistent linear hill with rock outcroppings, and the proposed structure has differentiated it's masses to mimic these smaller masses. The applicantfurther asserts that the design minimizes alteration of the area of natural slope retention and protects thetopographic character and integrity of the hillside lands. The Planning Commission finds that the applicant has demonstrated that the Exception allows for a reasonable use that complements the natural and aestheticcharacter of the city on a challenging site. The Commission finds that there is demonstrable difficulty in meeting the The Commission finds that the proposed design standard for a six-foot step back. development area is located near the driveway access, with a reduced setback on the uphill side of the house due to slopes exceeding 35 percent.The proposed structure is located to minimize hillside disturbance; a larger step back into the hillside would require grading into steeper slopes and disturb a greater area of the property. The Commission finds the PA-T2-2024-00053 August 12, 2025 Page 7 requires structure requestsan exception to the standards in one portion of the structure where the grade is steeper, and the exception does not apply to the entire downhill wall. The Commission finds that the exception is the minimum necessary to alleviate the difficulty. The Commission concludes that in this instance, the Exception is merited subject to a condition that with final grading, the total height of the wall, fascia,and foot above shall not exceed 25 feet. The second Exception requested involved AMC 18.3.10.090.E.2.d, which requires that, "Continuous horizontal building planes shall not exceed a maximum length of 36 feet. Planes longer than 36 feet shall include a minimum offset of six feet." The applicant had initially requestedan Exception to provide only a four-to five-foot offset where six feet was required; however,subsequent to the close of the public hearing, the applicant provided revised designs providing thefull required offset while the record remained open to the submittal of new materials. As such, thePlanning Commission finds that the second Exception is no longer necessary and has included acondition (#9e) below requiring that the building permit drawings reflect the revised design. 2.5The Planning Commission further notes that the application requiresa Varianceto the flag drive standards in AMC 18.5.3.060.F which speaks to the maximum grade and length of flag driveways. AMC 18.5.3.060.F specifically provides that, “Flag drive grades shall not exceed a maximum grade of 15 percent. Variances may be granted for flag drives for grades in excess of 15 percent but no greater than 18 percent; provided, that the cumulative length of such variances across multiple sections ofthe flag drive does not exceed 200 feet. Such variances shall be required to meet all of the criteria for approval in chapter18.5.5Variances.” The Planning Commission finds that the proposed driveway is via an existing shared access easement toutilize an existing long, steep, partially paved private driveway. The proposed drivewayextension to serve the subject property is approximately 197feet in total lengthfrom the terminus of the existing drivewayand has anaverage slope of approximately 24 percent. The Planning Commission finds that the lot configuration, site topography,existing driveway grade and existing naturalfeatures are unique circumstances that prevent meeting the standard. The existing drivewayserving the lot and the adjacent properties to the east exceeds a15 percent grade and is a legal, non-conforming situation. The averageexisting property grade before driveway construction is 27 percent, and there is no feasible area to mitigate the driveway grade withswitchbacks,given the narrow 33.04-foot width of the flagpole portion of the lot configuration and the location of the accesseasementto the property. The Commission finds that noalternative driveway access is available. The Commission further finds that allowing access via the existing easement to this otherwise landlocked parcel for the development of a residential dwelling on an existing legal lot of record utilizing the shared driveway is the minimum necessary to address the unique physical circumstances relatedto accessingthe subject property. The Commission further notes that the proposal has been reviewed by the Fire Marshal, and as proposed the residence will have a fire suppression system to mitigate fire risk, and that the driveway grade and the final driveway design will be reviewed by theFire Marshal for PA-T2-2024-00053 August 12, 2025 Page 8 compliance with all applicable fire codes. To ensure compliance with the requirements for a fire suppression system, driveway grade and turnoutdimensions and location, adequate hydrant pressure, and fuels management, the Commission has included conditions ofapproval ( #10, 11, &12) addressing these criteria. The Commission notes that staff have provided a March 22, 1992,letter from the Planning Director,John McLaughlin,to the record, which discussed access to the subject property in the early 1990s.This letter stated that access from Granite Street would be the "most appropriate" means to accessthe subject property if an access easement were to be acquired. The alternative access consideredat the time, via a driveway from Strawberry Lane, was noted as requiring a Variance to allow formore parcels to takeaccess off a private easement than was allowed. A subsequent August 12,1992 letter from McLaughlin stated, "To summarize the above statements, if an easement isgranted for access to lot 1800 from the existing drive from Granite Street, the City will allow thisas the driveway to this parcel, even though it exceeds the current allowable grades. Further, aminor land partition survey will be required for the parcels to approve the boundary lineadjustment previously made illegally. Once these are complete,parcels 1800 and 1801 becomebuildable parcels, subject to all development requirements of the City regarding drivewaysurfacing and hydrant/sprinkler requirements. " The required partition plat was recorded as P-43-1996 on April 12, 1996. Based on this historical information, the Commission finds that thedriveway grade was recognized as an issue with the lot's creation, that the lot creation predates thecurrent hillside standards, and that the need for a Variance has not been self-imposed by the currentproperty owners nor the applicants. The Commission finds that the driveway's location is determined by the existing private drive andthe lot's flagpole configuration, which extends to the established driveway access. The natural slope within the flagpole area averages 27 percent, making it impossible for the applicant to comply with the standard requirement for a driveway on slopes less than 15 percent for a flag driveway, 18 percent with a variance to the flag driveway standards. The Commission finds the property grades prevent development of a driveway that complies with the maximum grade, and is a unique circumstance that applies to this property and the proposed driveway extension of the existing shared driveway. The Commission finds that, as the proposed building area is situated immediately adjacent to the end of the flag pole along the east property line, it is evident that the proposed building location minimizes the length of the driveway to the greatest extent feasible while still providing necessary vehicular and emergency vehicle access to the property. The Commission finds that the existing driveway accessing the adjacent properties and the subject property leading to the proposed driveway is in excess of 15 percent. The Commission finds the only way to access the legal, developable lot of record is via the existing driveway connecting to the proposed driveway. Because the existing grade and the proposed grade exceed 18 percent, the variance to increase the grade to the proposed approximately 24 percent is the minimum necessary. The Commission finds that the proposal’s benefit of development of a permitted residential dwelling on a residentially zoned, legal lot of record with access via the existing access easement PA-T2-2024-00053 August 12, 2025 Page 9 and the existing shared driveway benefitting the subject property and the adjacent properties furthers the purpose of the land development ordinance which is to encourage the most appropriate and efficient use of the residentially zoned land with a residential home.The Commission finds that the development of residentially zoned property, utilizing a legal access easement and the development of a driveway, will not have a substantial negative impact on the adjacent properties. The Commission finds that thecity of Ashland Fire Marshal has reviewed the proposed driveway grades, turnout locations, and hydrant access and has indicated that the proposal with the fire suppression system provides adequate fire apparatus access and does not substantially increase fire-fighting response times or emergency vehicle access to the adjacent properties. The Commission concludes that the requested flag drive Variance is the minimum necessary deviation to facilitate development of the site while ensuring compliance with safety and accessibility requirements. The Variance criteria are met, as the standard code provisions for maximum driveway grade and length do not account for the unique physical characteristics and topography of the site, which is recognized as a pre-existing legal lot of record. 2.6 The Planning Commission notes that there are 74 tree removals proposed as part of the application, including nine significant trees. The application materials explain that there are hundreds of trees on the property and the adjacent properties and that the design of the project has sought to minimize required tree removals. The application states that those trees identified for removal are being removed because they are" ... within the building envelope/footprint ... within the proposed driveway or within the identified area of disturbance. " The application asserts that, "The tree assessment retains most of the siteslope stabilizing trees ... The property will remain heavily treed following the removal of the small-diameter fuels, the dead trees, and the trees in poor condition. Tree protection zones are included on the tree protection plan, including preservation plans for tree conservation during construction." With that said, the application includes a request for a Tree Removal Permit consistent with the standards from AMC 18.3.10.090.D.5, and AMC 18.5.7.404 to remove 74 trees, including nine significant trees, to develop the site and reduce wildfire fuels in the area of disturbance, with the majority of the property and the majority of the trees preserved as they are outside of the area of proposed development. The Tree Management Advisory Committee (TMAC) reviewed the initial application which identified the removal of 67 trees at their regular monthly meeting. While expressing that the number of trees proposed for removal was substantial, the TMAC recognized that all trees proposed for removal were either within the building envelope or very close to the excavation required for the construction of the proposed site development. The most significant tree near the project, a 36-inch diameter at breast height (d.b.h.) Madrone is partially on an adjacent property, and it initially appeared that the Tree Protection Plan provided adequate protection to its critical root zone. Revised submittals received on March 18, 2025 included several trees that were not originally identified on the tree inventory, including two ten- to 12-inch d.b.h. Madrones on the property line, as well as a revised location for the 36-inch Madrone that is also on or near the property line, but within the access easement, thus necessary to remove. The Planning Commission finds that while the 36-inch d.b.h. Madrone and seven PA-T2-2024-00053 August 12, 2025 Page 10 additional trees that were to be removed were not initially identified in the applicant's submittals; their presence was raised during the hearing, and subsequent to the close of the hearing, they were identified in revised submittals while the record remained open and therefore received due process. The applicant's narrative and final argument submittals made clear that the 36-inch d.b.h. Madrone tree was within the driveway easement, and that its removal was necessary to construct the driveway and to provide access to the property. The Planning Commission concludes that the driveway construction will significantly impact the 36-inch d.b.h. Madrone's root system, and that its removal is necessary in order to provide driveway access to this otherwise landlocked property. The Commission finds that the removal of the trees will not have significant negative impact on erosion, soil stability, protection of adjacent trees or windbreaks. The Commission finds that the trees proposed for removal consists of primarily small-diameter trees within the development area and removed for wildfire fuels reduction and nine significant trees that are within areas of development where a structure, patio, driveway, retaining wall, erosion control vegetation adjacent to the areas disturbed by construction that will not be subject to erosive action due to construction/development. The Commission finds that the removal of the nine significant trees and the smaller diameter trees will not have a significant negative impact on tree densities, sizes, canopies, and species within 200 feet of the subject property. The Commission finds that there are hundreds of trees upon the subject property and within 200 feet of the subject property. There are numerous large-stature madrone trees upon the subject property and on the adjacent ,.tT properties. There are numerous ponderosa pine, Douglas fir, and oak treeshe removal of the nine significant trees and the small diameter trees will not have a significant negative impact on the tree canopies, species, and tree density. The Commission finds that the proposal mitigates for each significant tree proposed for removal and proposes twelve mitigation trees. 2.7The Planning Commission discussed the applicant’s voluntary proposal to provide a public pedestrian access easement across the property along the TID Trail. While such a dedication is not a requirement for the development of a single-family home, the Commission recognized the public benefit of formalizing trail access in this location. As a result, the proposal has been included as Condition of Approval #14, reflecting the applicant’s willingness to dedicate the easement and the Commission’s support for securing long-term public access along the trail corridor. 2.8The Planning Commission notes that after the hearing was closed but while the record remained open, six comments were received from non-parties of record.The Planning Commission finds that because the hearing was closed and the record left open to new submittals only from parties of record who had participated orally or in writing while the hearing was open, these six comments must be excluded from the record and were not considered by the Planning Commission. The Planning Commission further notes that while the record remained open to new submittals, th on March 18Planning staff provided memos to the record responding directly to a number of public comments that had been submitted. Staff responses are adopted here as findings of the PA-T2-2024-00053 August 12, 2025 Page 11 Commission as if set forth in full. 2.9In summary, the applicantshavesubmitted substantial findings addressing allthe relevant approval criteriaand applicable standards for the planning action, the requested Exception and the Variances. The application addresses the unique factorsrequiring the need for the requested Variance due to the site’s topography and the fact that the lot is pre-existing with little to no slopes under 25percent to develop, and much of the lot having 25to 30percent slopes, or greater, along with the requirementto take access via apre-existing easement from Granite Street, which is an existing driveway with aconsiderable slope, greater than the maximum allowed 15percent driveway grade.This driveway location allows for access to an otherwise landlocked property from an existing driveway. 2.10The Commission finds that with the conditions below attached, the proposal satisfies the applicable approval criteria. The Planning Commission finds that the proposal meets all applicable criteria for a Physical & Environmental (P&E) Constraints Review Permit as provided at AMC 18.3.10.050, for an Exception to the Development Standards for Hillside Lands in AMC 18.3.10.090.H,for aVariance as provided at AMC 18.5.5.050, and for a Tree Removal Permit to remove 74 trees, including nine significant trees, as provided at AMC 18.5.7.040. SECTION 3. DECISION 3.1Based on the whole record of the public hearing on this matter, and all materials submitted by staff, the applicant and other participants, the Planning Commission concludes that the applicant's site planning, building design, engineering and landscape planning have adequately addressed the criteria and standards for the approval of a Physical & Environmental (P&E) Constraints Review Permit with an associated Exception to the Development Standards for Hillside Lands to allow a downhill wall height exceeding 20 feet, a Variance to the flag drive standards for maximum grade and length in AMC 18.5.3.060.F, and a Tree Removal Permit to remove a total of 74 trees, including nine significant trees. Therefore, the Planning Commission approves the application, with the attached conditions of approval, noting that this decision is supported by evidence contained within the whole record. 1.Thatallproposalsoftheapplicantbecomeconditionsofapproval. 2.AVerificationPermitshallbeappliedforandapprovedbytheAshlandPlanningDivision priortositework,treeremoval,buildingdemolition,and/orstorageofmaterials.The VerificationPermitistoinspecttheidentificationofthe74treestoberemovedandthe installationoftreeprotectionfencingfortheremainingtreesonandadjacenttothesite.The treeprotectionshallbechainlinkfencingsixfeettallandinstalledinaccordancewith 18.61.200.B. 3.AllrecommendationsoftheTreeManagementAdvisoryCommittee,whereconsistentwith theapplicableordinancesandstandardsandwithfinalapprovaloftheStaffAdvisor,shallbe conditionsofapprovalunlessotherwisemodifiedherein. 4.Priortobuildingpermitissuance: a.Theplanssubmittedforthebuildingpermitshallbeinsubstantialconformancewith thoseapprovedaspartofthisapplication.Iftheplanssubmittedforthebuildingpermit PA-T2-2024-00053 August 12, 2025 Page 12 arenotinsubstantialconformancewiththoseapprovedaspartofthisapplication,an applicationtomodifytheVarianceandPhysicalandEnvironmentalConstraints Reviewpermitapprovalshallbesubmittedandapprovedpriortoissuanceofabuilding permit. b.Identificationofalleasements,includingpublicandprivateutilityeasements,mutual accesseasements,publicpedestrianaccesseasements,andfireapparatusaccess easementsshallbeidentifiedonbuildingpermitplans. c.SolarsetbackcalculationsdemonstratingthatallnewconstructioncomplieswithSolar SetbackStandardAintheformula\[(Height–6)/(0.445+Slope)=RequiredSolar Setback\]andelevationsorcrosssectiondrawingsclearlyidentifyingthehighest shadowproducingpoint(s)andtheheight(s)fromnaturalgradeshallbemet. d.Lotcoveragecalculationsincludingallbuildingfootprints,driveways,parking,and circulationareas.Lotcoverageshallbelimitedtonomorethan20percentasrequired inAMC18.2.5.030.C. e.Stormwaterfromallnewimpervioussurfacesandrunoffassociatedwithpeakrainfalls mustbecollectedonsiteandchanneledtotheCitystormwatercollectionsystem(i.e., curbgutteratpublicstreet,publicstormpipeorpublicdrainageway)orthroughan approvedalternativeinaccordancewithAshlandBuildingDivisionpolicyBD-PP- 0029.On-sitecollectionsystemsshallbedetailedonthebuildingpermitsubmittals. f.ArevisedTreeProtectionPlanconsistentwiththestandardsdescribedin18.4.5be submittedforapprovalbytheStaffAdvisor.Thetreeprotectionfencingshallbe installedaccordingtotheapprovedplanpriortoanysitework,storageofmaterials onsiteorissuanceofthebuildingpermit.Theplanshallidentifythelocationand placementoffencingaroundthedriplinesoftreesidentifiedforpreservation.The amountoffillandgradingwithinthedriplineshallbeminimized.Cutswithinthedrip lineshallbenotedonthetreeprotectionplanandshallbeexecutedbyhandsawand kepttoaminimum.Nofillshallbeplacedaroundthetrunk/crownroot. g.Noconstructionshalloccurwithinthetreeprotectionzoneincludingdumpingor storageofmaterialssuchasbuildingsupplies,soil,waste,equipment,orparked vehicles. h.Alandscapingandirrigationplantoincludeirrigationdetailssatisfyingthe requirementsoftheSiteDesignandUseStandardsWaterConservingLandscaping GuidelinesandPoliciesshallbeprovided. i.Thetreeprotectionandtemporaryerosioncontrolmeasures(i.e.siltfenceandbale barriers)shallbeinstalledaccordingtotheapprovedplanandapprovedbytheStaff Advisorpriortoanysitework,storageofmaterials,issuanceofanexcavationpermit andissuanceofabuildingpermit.Theerosioncontrolmeasuresshallbeinstalledas identifiedintheMarquess&Associates’reportdatedDecember5,2024andas approvedbyPublicWorks. j.Awrittenverificationfromtheprojectgeotechnicalexpertaddressingtheconsistency ofthebuildingpermitsubmittalswiththegeotechnicalreportrecommendations(e.g. PA-T2-2024-00053 August 12, 2025 Page 13 gradingplan,stormdrainageplan,foundationplan,etc.)shallbesubmittedwiththe buildingpermit. k.Applicantshallprovidedocumentationfortheaccesseasement. l.Applicantshallhavetheretainingwalldesignedbytheprojectengineertoconform withAMC18.3.10.090.B. 5.Mitigationtrees,tobeplantedon-site,off-site,orpaymentinlieu,shallbeplantedattherate of1:1ofregulatedtreeremovals. 6.ApreconstructionconferencetoreviewtherequirementsoftheHillsideDevelopmentPermit shallbeheldpriortositework,theissuanceofanexcavationpermitortheissuanceofa buildingpermit,whicheveractionoccursfirst.TheconferenceshallincludethePlanning Department,BuildingDepartment,theprojectengineer,projectgeotechnicalexperts(i.e. Marquess&Associates),landscapeprofessional,arborist(i.e.Canopy)andthegeneral contractor.Theapplicantorapplicant’s’representativeshallcontactthePlanningDepartment toschedulethepreconstructionconference. 7.Thefoundationplansofthehouseshallbestampedbyanengineerorarchitectwith demonstrablegeotechnicaldesignexperienceinaccordancewithAMC18.3.10.090.F. 8.Allmeasuresinstalledforthepurposesoflong-termerosioncontrolandfiremitigation, includingbutnotlimitedtovegetativecover,rockwalls,retainingwallsandlandscapingshall bemaintainedinperpetuityonallareasinaccordancewith18.3.10.090.B.7.a. 9.PriortoCertificateofOccupancy: a.Thelandscapingandirrigationforre-vegetationofcut/fillslopesanderosioncontrol shallbeinstalledinaccordancewiththeapprovedplan.Vegetationshallbeinstalledin suchamannerastobesubstantiallyestablishedwithinoneyearofinstallation. b.Alllandscapinginthenewlandscapedareasshallbeinstalledaccordingtothe approvedplanandtiedintotheonsiteirrigationsystem. c.Marquess&Associatesshallprovideafinalreportindicatingthattheapproved grading,drainageanderosioncontrolmeasureswereinstalledaspertheapproved plans,andthatallscheduledinspectionswereconductedbytheprojectgeotechnical expertperiodicallythroughouttheproject. d.Theflagdriveshallbepavedto12feet,haveaverticalclearanceof13-feet,6-inches andbeabletowithstand44,000lbs.ofpressure.Theflagdriveshallbeconstructedso astopreventsurfacedrainagefromflowingovertheprivatepropertylinesand/or publicwayinaccordancewith18.76.060.B. e.ThehouseshallbeconstructedasshownontheamendedplanssubmittedonMarch12, 2025,withthe6-foothorizontaloffset,perAMC18.3.10.090.E.2. f.Applicantshallprovideasurveyor’smapthatconfirmsthedrivewaygradedoesnot exceed24percentandthatthelengthoftheportionofthedrivewayinexcessof35 percentslopesdoesnotexceed100feet,perAMC18.3.10.090.A.2. PA-T2-2024-00053 August 12, 2025 Page 14 10.RequirementsoftheAshlandFireDepartmentshallbemet,includingthatalladdressingshall beapproved,thatfireapparatusaccessbeprovided,thatafinalapprovaloftheaccessplan (turnouts,etc.)beobtained,thatafiressuppressionsystembeinstalledinthehome,thatanew firehydrantandpumpbeinstalled,ifnecessary,andthatafuelbreakisrequired. 11.Priortobringingcombustiblematerialsonsite,applicantsshallprovidedocumentationoffire hydrantlocationwithin600feetofthesouthwestcornerofthehouseandoftheaccess (easement). 12.AFirePreventionandControlPlanaddressingtheGeneralFuelModificationArea requirementsinAMC18.3.10.100.A.2shallbeprovidedpriortobringingcombustible materialsontotheproperty.Newlandscapingproposedshallcomplywiththesestandardsand shallnotincludeplantslistedontheProhibitedFlammablePlantListperResolution2018- 028. 13.FinalgradingandretainingwallplansshallmeettheterracingrequirementsofAMC 18.3.10.090.B.4.btothesatisfactionoftheStaffAdvisor. 14.Priortoissuanceofbuildingpermitsfortheproposedresidence,applicants/propertyowners shallexecuteanddelivertotheCityaperpetualpublictraileasementinfavoroftheCityof Ashlandalongtheexisting“DitchTrail”,whichgenerallyfollowstheTalentIrrigation District’s(TID)“AshlandCanal”asittraversesthesubjectproperty(TaxLot1800). ApplicantsshallalsoprovideacenterlinelegaldescriptionoftheEasementAreatobe appendedtotheeasementdocumentandreflectinganeasementarea10-feetinwidthandshall includethetraveledportionoftheexistingDitchTrailcrossingtheproperty.Thiscondition wasvoluntarilyofferedbytheapplicants/propertyownersandthispublictraileasementisnot anexactionrequiredbytheCityandisnotsubjecttoconstitutionaltakingsconcernsor nexus/proportionalityanalysis. August 12, 2025 Planning Commission ApprovalDate PA-T2-2024-00053 August 12, 2025 Page 15 Comments on Planning Action: PA-T1-202500268 Subject Property: 39-1E-04-AD Tax Lot 8600 Kestrel Park Phase III August 8, 2025 The proposed development is a present and future threat to this neighborhood and city. In the event of an emergency, such as a residents of our beautiful city could be in extreme wildfire danger. This building project next to the Mountain Meadows Community, is a potential threat to this neighborhood. This neighborhood houses mostly senior residents. Who are walking their dogs slowly down the streets. An increase in street traffic, more moving cars, could be a threat to our neighbors. Wildfire tragedies are beautiful community of Paradise, CA burned in a horrible wildfire. People could not escape the wildfire in their town because the lack of adequate exits for all of the cars. Too many deaths occurred. The Kestrel plan is for very small apartments-it looks like a Motel many as another 17 cars would be added to our area. 2025 Community wildfire protection plan update: Due to climate change our chance (City of Ashland) of being destroyed by a wildfire, is in the top 97% could be destroyed by traffic bottlenecks in the too few evacuation routes. There are too few evacuation paths out of our streets are narrow, and there is overdevelopment. Many of the new developments are high-density, too many people in one dangerous for all. It is time for our City Council to reduce the high-density projects in this city. According to the City funded KLD report 2021: it would take at least 3 hours and 10 minutes to evacuate the city!!!!! Public safety is more important that meeting the financial plans. Sincerely, Lyn Gutierrez 907 Plum Ridge Drive, Ashland, OR (805) 714-3334 Daniel DeRoux dderoux@gmail.com New data and findings place the current dense-building proposal for Kestrel Phase 3 directly at odds with the City of Ashland’s own wildfire studies and expert recommendations. 2025 Draft Wildfire Protection Plan The makes this clear: “It’s imperative that we re-imagine our community and behavior, lest we risk more frequent and more severe losses as the climate continues to change. We have an enormous opportunity right now. We can avoid a serious fire if we plan carefully and begin making needed changes right now.” against increasing density in wildfire-vulnerable The plan specifically advises areasmore likely than 97% of U.S. . It also identifies Ashland as being communities to experience a catastrophic wildfire. Public Safety data shows: traffic bottlenecks, blocked evacuation A 2024 citywide survey ranked routes, and lack of evacuation alternativestop wildfire concern as the (Public Interest Rating 100/100). narrow streets and The third-highest concern (PIR 80) was overdevelopment impeding evacuation . confusion about evacuation Residents and survey respondents also reported procedures and how to interpret emergency messages. foreseeable hazards These are not hypothetical issues—they are supported by the city’s own research and public feedback. CONFLICT WITH CITY’S OWN EXPERT ADVICE The current plan increases density in an area where: 1-Evacuation times are already dangerously limited. 2-Infrastructure cannot handle additional population during an emergency. 3-The City’s own wildfire consultants have recommended reducing, not increasing, density. LIABILITY ISSUES Moving forward without addressing these documented safety risks creates potential legal exposure for the City. While governmental immunity can limit liability, there is precedent for lawsuits and settlements when a municipality: clear, repeated warnings Ignores from experts and the public. foreseeable danger Approves development in the face of . its own safety codes or evacuation plans Fails to enforce . Recommendation: Reduce the number of units at Kestrel Phase 3 to align with wildfire safety best practices, the 2025 Draft Wildfire Protection Plan, and the clear priorities of Ashland’s residents. This is the third time I have testified on this matter—my concerns are shared by hundreds of neighbors who will be directly impacted. The choice before you is whether to follow the City’s own evidence-based guidance, or to take a risk that cannot be undone once the next wildfire comes. Area 6 Area 6