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HomeMy WebLinkAboutMt. Pines - Appellant's Brief APPELLANT'S BRIEF IN OPPOSITION to PLANNING ACTION 2004-105 (MOUNTAIN PINES PROJECT) Randall Hopkins 735 S. Mountain Ave. Ashland, OR 97520 BRIEF IN OPPOSITION TO PLANNING ACTION 2004-105 This planning action ("PA") seeks, among other things, an Exception to Ashland Street Standards which would also allow the project to avoid the City's zoning regulat.ions. Approval would shoe-horn an overly intense developmE~nt into steep hillside and wildfire land with associatE~d dangerous streets that would be beyond the carrying capacity of the area to handle it. The Council is invited to review the presentation of citizens opposed to thePA before the Planning Commission (IIPC"). These begin at 1: 34 of the PC's November melating. There were no citizens speaking in favor of the PA. To sunnnarize, the citizens testified as follows: 1. Andy Stallman: His wife had asked developer to meet with area neighbors, but was turned down on grounds that these meetings "never go well." Concerns of neighbors were never addressed and the PA is NOT the result of cooperative effort. The developer has never contacted many neighbors. Fewer lots would lessens problems with the development. 2. Dr. Phil Phillips: Prospect Street, for which a Street Standa.rd Exception is sought, is a dead end road that already presents access, exiting and parking problems, even with only parking on one side. Adding tremendous load to this street will degrade safety and well being of the area. Proposed paving will narrow the driveable road surface from that which currently exi.sts along the eastern 2/3rds of street. The plan is a Idisastrous recipe' according to this Emergency Room doctor at Ashland Community Hospital. 1 (note- -when Dr. Phillips spoke the proposed plan called for single sided parking on Prospect. The PC later imposed double sided parking on the street, thus grElatly expanding the many problems noted by the Doctor.) 3. Kip Sigetich: Like Andy Stallman said, no prior discussions with Applicant. Outlined severe parking, turning and access problems on Prospect that will be much worse by a development that dumps much mOrE! load onto a Prospect that is to be handicapped hy a Street Standard Exception. Contrasted proposed development with Quail Haven across S. Mountain, a quality development accomplished without removing trees and preserving 'incredible beauty of area.' Fewer lots will greatly relieve t.he problems. 4. Rebecca Reid: Developer tries to pack more homes into arl:!a than is safe. Currently (with one sided parking on much of Prospect), all available spaces art:! routinely used, leaving room for no more parking. Very limited turn around capacity now, so people back out. Prospect is a nightmare already ,and can 't handle more burden, especially from heavy construction vehicles, which would increasle access problems, as well as fire and pedestrian safety hazards. Fewer houses in the development would help. S. Bob Gordon : Lives on Wildwood way, a dead end road with four houses that is similar to Prospect St. Whenever someone has guests that street is blocked and fire trucks couldn't get access. People won't park on S. Mountain because it is too stee!p, but pack into wildwood. In winter, snow sticks at this higher elevation. S. Mountain is alre!ady very, very dangerous with people speeding down the hill, meeting vehicles driving up the hill at a blind dogleg where Prospect meets Moumtain. 2 Gordon has seen accidents in this area alrE~ady. Adding more load is 'asking for lots of difficulty. ' 6. Ed Beutner: 'Alice in Wonderland' interpretations are ))eing used to create 'incredibly dangerous' street. In winter, you can see lots of skidmarks on Mountain. Private drive will be almost blind when it hits Mountain and needs city services. 7. Judy Little: Too many proposed homes for what area can :safely support. S. Mountain is already dangerous :since it is steep, high elevation, and ices up in winter. Has seen vehicles sliding down out of control, backwards. Hard to get up Mountain now when there is parking on both sides of the road. Has seen accidents on Mountain, including vehicles ending up on the sidewalk at the :bottom where Prospect meets Mountain. There is now a home at the other side of this sidewalk. P'eople really speed down Mountain. Lots of pedestrian traffic, walkers and kids on this street. This is a wildfire zone. Need safer proposal that is more in keeping with the neighborhood. 8. Chris Cotton: Family has lived in area for 56 years and was greatly involved in building our community. Sees fire safety problems. Shoving more parking onto S. Mountain is unsafe, as he has seen a ca,r 'totaled' there even on a clear, sunny day'. OVer the years, has seen people going over the sidewalk at the base of Mountain (near Pro'spect) into land that now has a home on it. A recent accident in area hospitalized a bicyclist. His family developed Quail Haven right across the street without removing a single tree and allowing quality open space. Need to build fewer homes in the new project, instead of: shoehorning too many into available space. 3 9. Jeanne Stallman: It is clearly shown that Prospect affords no extra parking and is incapable of handling Lots 2 and 3. Developer willfully shoehorning pJ:"oject to avoid zoning rules. Private drive is designed at maximum grade, with sharp curve going up a hill ,with an 11 foot retaining wall atth'3base in area that ices up. Need fewer homes. Perhaps the most telling comment of allwasprClvided by Chris Cotton, a citizen who speaks with knowledgle of how Ashland has been developed with quality and livability# but who feared that "what would be sad .to see is this (commitment to quality and livability) not continue." Fortunately, in this case, quality and livability can be enhanced and preserved by the simple expedient of enforcing the rules that are available. As noted, it is this project that seeks to avoid the City Street Standards and zoning rules. (NOTE -theCity's Street Standard Handbook ("Handbook") defines the term 'street' to refer to Imore than the paved, curb-to...,.curb roadway,' and to include Ithe sidewalk, parkrow,...on-street parking lanes and motor vehicle travel lanes. I This brief uses that definit.ionin referring to the t~r.m Istreet.') (NOTE - Also, there are separate problems alon9the eastern 2/3s to 3/4ths of Prospect vs. those at the! narrower, dead end western portion where Rebecca Re!id and Kip Sigetich live. The Eastern section will be addressed first. Discussion of the western stub appears at pcLge 16 below. ) 1. Enforcement of the Street Standards minimizes the problems of Prospect Street (eastern 2/3rds). Table 1 of the City of Ashland Street Design Standards states that the standard street right-of-way (ROW) where parking is provided on both sides of a neighborhood street (Prospect) is 50 to 57 feet. See Handbook, p. 20. 4 The current Prospect Street ROW varies between 43.85 feet and 28.745 feet per page 18 of Applicant's Pl~~ning Application. Approximately 15' of the ROW on the nourished is, by agreement of Staff and Applicant, unusable a:s it is too steep. The council is empowered by anyone of several sections of the Code to require the applicant to dedicate added ROW from its property. The Subdivision Design Standards (Sec. 18.80.020B5) provide that: 5. Existing streets. Whenever existing streets adjacent to or within a tract are of inadequatE! width, additional right-of-way SHALL be provided at the time of subdivision.. Sec. 18.82.020, titled STREET DEDICATION REQUIlmD, also provides that U(l)and will be dedicated by a property owner for the construction of a street when...(E) The City may require additional right-of-way on streets which do not meet the Street Standards of Chapter 18.88, Performance Standards Options, or for necessary realignments of intersections or street sections. These do not have to be shown on the official map." Under 18.82.060, such U(d)edication of the future right-of-way for a street or greenway is required prior to final action on a partitioning, Subdivision, or development requiring a planning action. The only exception to this dedication scheme is provided in 18.82.040 (titled STREET DEDICATION WAIVED) which provides that: II (t ) he property owner is not required to dedicate land for the construction of a City street or greenway when it has been proven, to the satisfacti.on of the Planning Commission, that the planned use will not increase IN ANY WAY. the automobile. pedestrian or bicycle traffic generated in the area." Obviously, Applicant's development will increase the traffic on Prospect since: (a) lot 1 will directly access off the street, 5 (b) Prospect will, according to the PC's Findinqs (par. 2.7), be relied upon the provide Ifire apparatus access, on-street parking and pedestrian access' for Lots 2 and 3, and (c) construction vehicles will find Prospect a haven, since it is the only flat portion of land i.n the vicinity. Clearly, the one exception to the rule requiring Applicant to dedicate ROW does not apply. If the City does no more than require a dedication up to the lower 50' ROW standard for double sided parking, then there is enough room to create an improved Prospect that greatly relieves these problems. This is so eVE~n though all parties agree that the northern ROW (appJ:'ox. 15 feet) is unusable. Such improvement, described from south to north, could include: 1. A 5' sidewalk adj acent to Applicants' Prospe:ct lots, as presently intended and required by the St~ldards, 2. A 7' parking bay. This section could be segregated by bumpouts to differentiate the parking area from .the rest of Prospect. This would help satisfy the request listed in the Staff's October 12, 2004 Report, which asked that Prospect be reconfigured to provide more on-street parking for the existing and new residences. The parking bay would also serve to segregate pedestrians using the sidewalk from vehicular use of the street, as a planting strip would do. 3. A paved road way surface of approximately 23 feet. If added dedication brought the ROW to 52 to 54 feet, then the traveled portion of Prospect could be paved to its current width, with no reduction in the currently traveled portion of the road. Parking can be retained on the south side, as presently provided. In other words, instead of eliminating the plaJlting strip, as Applicant seeks to do by Exception, we should keep the 7' planting strip width, but substitute a parking bay instead. 6 This approach more fairly divides burdens among the parties. Applicants' approach requires current homeowners along Prospect not only to sacrifice part of its current width, but to accept the substantial new parking on a street which strains under the burden of single sidE~d parking. The approach suggested above would shift the added parking brought to the area by the subdivision into what is now Applicant's property. The City's Street Handbook (p. 4) says that it is not uncommon for 25% or more of a proposed development's land area to be set aside for required ROW. As presently proposed, only 2.8% of Applicant's land (a 12.5' strip of ROW along S. Mountain) is called to be dedicated. Requiring an added dedication of 6 feet along Prosp1ect will only increase this to 4.9%, or less than a fif.th of what the Handbook says is commonly dedicated. This approach to improving Prospect has never t>een considered, apparently from a belief that the standards prevent you from substituting a parking bay for a planting strip. But. there is not only no such requirement in either the Code or Handbook. Indeed, the Handbook would be violated by accepting such a 'planting strip or nothing' argument. The use of planting strips (called a parkrow) between street and sidewalk is shown on the configuration drawings at page 34 and elsewhere in the Streets Handbook. But page 1 of the Handbook emphasizes that, with respect to these basic street configurations,: "Variations can be made from these basic types to fit the particular site and situation." The Handbook also states that "each street should be individually designed and molded to the particular situation at hand." p. 6. Also, while street design must follow the standards (which would be fulfilled here by requiring a fulle~r ROW dedication under the Standards), they must be "flexible enough to accommodate varying situations" and 'very specific to the particular street at hand." 7 At page 32, the "different configurations" for a neighborhood street (as is Prospect) are described a.s configurations containing "on-street parking OPTIONS." Finally, page 33 of the Handbook provides that two 7' parking lanes are required for parking on both sides and that such " (p)arking may be provided in 7' bays rather than a continuous on-street parking." Construing the Street Standards to prohibit substituting a parking bay for a plant strip within the required standard ROW improperly ignores all these portions of the Handbook that urge and demand flexibility. In sum, requiring Applicant to dedicate ROW up to City's Standard, combined with use of a parking bay configuration in place of a planting strip, adheres to the Handbook's demand to: (a) adhere to the Standards (50-57' ROW), whilE~ (b) using flexibility of design inside the ROW" which will (c) produce a more balanced street that affords safer and equal access by pedestrians, bicyclists and vehicles, all without reducing the amount of roadway available now. It would create a more 'livable, functional street for a neighborhood,' exactly as demanded by the Street Standards Handbook. The Council should and lawfully can require added ROW dedication along Prospect Street. (NOTE - Applicant has only recently purchased "this property. All ordinances and standards ci ted here E!xisted before his purchase. Thus, Applicant has no MeaSUrE! 37 claim. ) 8 2. In contrast, Applicant cannot meet the criteiria for an Exception to the Street Standards. Applicant must meet ALL the criteria for an Exception. It cannot do so: A. There is no demonstrable difficulty in meeting the street standard due to a unique or unusual aspect OF THE SITE. Nothing about this site precludes an additional ROW dedication. As shown below, the only problem for Applicant is that the required dedication will reduce lot sizes below the minimum lot area of the zoning laws. But 'that is just a result of the law, not a lunique or unusual aspect' of the site. B. The SS Exception will not result in equal Ol~ superior transportation facilities and connectivity. Applicants' Exception would shove the additionCiI on- street parking, which the Planning Staff's October report says is necessary along Prospect, out into the currently traveled portion of the street (which, as noted, would actually be paved to a narrower area that presently exists). At the very moment when massive construction vehicles will appear, to be followed by added vehicles of the new neighbors, Prospect will be reduced below its present dimension and clogged with double sided parking. Presently, there is only one sided parking, except at the western stub, where there is no parking allowed at all. The attached photos, testimony at the PC, and testimony to be provided for the City Council, demonstrate just how worse off Prospect will be from the standpoint of access and public safety, if this I improvement' unfolds. The I turnaround' proposed opposite Dr. Phillips house, while nice, does not alter this conclusion. It will look a parking space and invite people to park there. Both your Planning Staff and your Fire Department's represent~ative have warned that Ino parking' signs will be routine!ly ignored. See, 10-12-04 Staff Report, pp. 9-10, and M. Hickman's testimony at 2:45 of the PC's November he!aring. 9 C. The variance is not the minimum necessary to alleviate the difficulty. Even ignoring the issue of ROW dedication and viewing this as 'just' an exception to eliminate a planting strip does not save this PA. Paragraph 2.5 of the PC's Findings concluded "..the sidewalk will be installed at curbside rather than with a planting strip as required by thE~ Street Standards so that the trees on the south sidE~ of the street can be preserved." But, there are no such trees on Lots 1 and 21 Since a street standard exception may only be the minimum necessary to fix the problem, the south side trees only warrant reducing construction along lot 3. They provide no justification for an exception adjacent to Lots 1 and 2. D. The variance is not consistent with the stat.ed purpose and intent of the Performance Standards Options Chapter. This requirement is not and cannot be fulfillecl, since designing Prospect as Applicant desires would: 1. provide a lower quality of life compared to a development built to standard. The current residents along Prospect struggle with difficulty to accommodate the demands placed on their dead end street. They would be forced to accept the massively added demands on the street, though it is not getting any wider and parking would go from one side to two. 2. the Applicant's approach would in no way be_ aesthetically pleasing, since it would cram parking into a narrower space, creating a situation like those shown on the attached photos. It will be ugly. 3. provide for an inefficient land use, by crmmning parking into the formerly traveled portion of a public street, when Applicants' land is available for ROW dedication and the shifting of the development's added parking and traffic burden into a truly widened Prospect, and 10 4. would increase. not decrease. the impact on the natural environment and the neighborhood. The existing neighbors (as well as though buying into the subdivision) will pay the price in terms of difficulty of access and an increasingly unsafe Prospect street. (NOTE - In effect, Applicant is proposing to re~duce Prospect to a single 11 foot I queuing' lane. By the City's Handbook makes clear that the queuing lane concept is used to Ireduce speeds.' But the problem on Prospect has not been, nor will it be speed, it is access, a problem worsened by the use of queuing. with full-up parking on both sides, it will be hard even to find a place to pull over when two vehicles meet in the middle. The queuing option is thus singularly inappropriate for the a street that that narrows as it dead ends.) 3. Requiring compliance with the City's full ROW standard will also allow the City's zoning rules to do their job. A prime purpose of zoning rules is to make surE~ that new development fits in with the carrying capacity of land to be developed and the surrounding neighborhood. The Applicant's proposed subdivision is zoned ]~-1-10, which requires 10,000 SF lots. The Subdivision Design Standards (18.80.02001) provides that subdivision lots SHALL meet the requi.rements of the zone in which the subdivision is located. This Standard provides only three exceptions, none of which are applicable here. Requiring dedication of the standard ROW from Applicant's property (clearly within the City's po~~r and contemplated by the Standards), will reduce the Applicant's Prospect side lots below the 10,000 SF minimum. For example, dedicating an added 6.15 feet, which would increase the east portion of Prospect to a 501 ROW, would reduce Lot 1 from its current claimed 10,074 SF to 9,275 SF (10,074 SF - 130' frontage x 6.15'). This 11 original 10,074 SF number includes the required ROW dedication along S. Mountain (12.5'). If the S. Mountain ROW dedication is also excluded, then Lot 1 is even further removed from compliance. Lot 2 would be 9,575 SF (10,000 SF - 69' frontage x 6.15'). Lot 3, presently exactly 10,000 SF would fall below the minimum area as well. (NOTE - in order to save trees, Appellant does not propose that a parking bay be included at the western end of Prospect adjacent to Lot 3. However, in the future those trees may perish and, given the current access problems there, street changes may be desired. Now is the time to make sure adequate ROW exists now and in th~3 future. ) Allowing the City's zoning regulations to fulfill their function by deleting a Prospect side lot will alleviate all the concerns urged by the development's neighbors. It will ease demands placed not only on Prospect, but on the private drive as well, reducing units accessing that drive from the current 5 to 4 and thus getting closer to the 13 lots per private drive' Standard. This will, in turn, minimizing the Exception needed to accommodate the private drive. There will be fewer vehicles accessing S. Mount.ain, which, as the testimony shows, is itself a problematic and dangerous street. The whole project will better fit into the existing neighborhood and the limitations that the area imposes. In short, the zoning rules will be doing their intended job and assuring a quality development. Applicant claimed at the Planning Commission that any added ROW dedication would not reduce available lot sizes, but that is not what the City Code says. Section 18.20.040 establishes the 1 (m)inimum lot area" for R-1-10 areas as 10,000 square feet. Section 18.08.360 defines Ulot area" to be uexclusive of street right-of-way." 12 There is no exception to this within the Code that is applicable to a neighborhood street like Prospect. l~or can such an exception be imposed now consistent with thE3 Street Standards Handbook, which makes clear that there is a trade off between ROW dedications and land available for development. Page 4 of the handbook explains that: II Currently , it is not uncommon for 25 percent or more of a proposed development's land area to be set aside for required rights-of-way. Using narrower streets can reduce this percentage and free up land for open space, OR MORE INTENSE DEVELOPMENT.' Thus, there is a clear trade off contemplated in the Handbook between ROW Dedication and development intlensi ty . If Applicant's suggestion that ROW dedication is irrelevant to lot size, there could be no tradeoff. But there IS a tradeoff and here it favors less intensity. Nor can the Applicant avoid this result by cast.ing the ROW dedication as an easement. Under the Subdivision Design Standards (18.82.020C), easements are designated for utility lines and water watercourses, or for private ways. with respect to satisfying shortcomings of a public street, however, the Code uses ROW dedication. See, 18.80.20B5 (Uadditional ROW SHALL be provided). Moreover, Applicant's behavior during the course of the planning actions on this subdivision belies its claim that ROW dedication does not deduct from lot area calculation. At every stage, Applicant has taken CSLre to avoid any required dedication along Prospect (or S. Mountain for that matter, as its latest Application sought to use an easement). Applicant originally argued that the required planting strip be sited within the current:ly traveled part of Prospect, which would have reduced the unfortunate inhabitants along Prospect to an even narrower street running down to 18 feet wide. Even now, Applicant casts its requested Exception in terms of innocuously dropping a planting strip inst:ead of what is really needed - an exception to ROW standards. 13 (NOTE - It is very likely that the zoning land area minimums along Prospect are ALREADY violated, as it appears the currently proposed sidewalk extends 1-2 feet into the subdivision. This needs to be professionally confirmed, as this alone would defeat the lots, which are already at the breaking point. Moreover, the turnaround on Lot 3, which would approximate a full ROW dedication at that limited area, also drops that lot below 10,000 SF.) In short, this Council could enforce the Codes and Standards. That, not Applicant's attempt to end run the zoning rules, will help produce the best quality development and neighborhood. 4. Lot 7 also violates zoning rules. Applicant proposes to carve up the existing lot at 769 S. Mountain to provide land for part of the private drive for Lots 4-6. The remainder lot would be Lot 7. When purchased, this lot was well over 10,000 SF. Applicant's proposed adjustments, however, would reduce Lot 7 below the minimum area. The Applicant's Tentative Lot Layout Notes of 1-9-2004 states that the lot is 10,091 SF, which includes a 12.51 ROW dedication along S. Mountain. Again, the Code defines Ilot area' as lexclusive of street right-of-way.' without this ROW dedication, Lot 7 is listed at only 9,026 SF. The dimensions of the Lot 7 shown on the TTL Notes of 1-9-2004 remain the same to date. Thus, Lot 7, as proposed now, would violate the zoning rules, whatever the Council chooses to do on any other issue. Curiously, the Applicant's latest Site Plan makes no mention of the area of Lot 7, either with or without the ROW dedication. 5. Applicant's other lots also violate zoning :~ules. Lots 4, 5 and 6 are flag lots. Under City Standards, the flag portion of those lots may not be included in lot size calculation (although Applicant's most recent Site Plan, filed 10-29-04, includes the flag portion when listing the area for at least Lot 5). 14 On Feb. 25, 2003, in response to Applicant's original PA, the City's Staff acknowledge that: u...the Planning Commission could make the interpretation that the flag drive area is the actual physical location where the drive is pro- posed and deduct this area from the lot." Obviously, if the Planning Commission can make such an interpretation, so can the City Council. This interpretation available to this Council makes sense. The flag pole exclusion seeks to exclude land used for access. Why not use the actual dimensions of the paved access drive for a clearer, more precise measurement? This interpretation, applied to the lots as presently configured, would mean that, at a minimum, the current lots 4 and 6 would be far less than the 10,000 SF minimum. Applicant's Tentative Lot Layout filed 1-9-2004 contained Notes that showed Lot 6 is only 8,988 SF if you exclude the flag portion and the paved drive. Since there is only a tiny portion of the flag portion that is not within the paved drive (approx. 50 sq. feet), deducting just the paved drive alone still puts Lot 6 far below 10,000 SF. Applicant's Tentative Lot Layout states that Lot 4 is only 8,857 SF, again excluding the flag and the paved drive. Again, the portion of the flag outside the paved drive is small, meaning that deducting the paved drive alone creates a lot smaller than 10,000 SF. The Tentative Lot Layout states that Lot 5 is 9,638 SF without the flag and paved drive. Since there is more substantial area of the flag outside the paved drive on Lot 5, professional measurement would be required to conclude that Lot 5 fails if only the paved drive is excluded. But if both the flag pole and the paved drive are excluded, then Lot 5 fails as well. 15 (NOTE - The Tentative Lot Layout Notes discussed here were filed as part of Applicant's second PA, this being the third. However, the dimensions of Lots 4, 5 and 6, including the flag poles and paved drive, remain the same in the current version. Also, the lot sizes listed in the TLL Notes did not exclude any parking pads and driveways for Lots 4-6. The zoning rule is thus violated even if parking pads and driveways are properly included in lot area calculations.) (NOTE - Whenever anyone criticizes the upper private drive on which Applicant also seeks a Street Exception so that it can access five units (vs. the three allowed by Standard), the reply is always to threaten to dump direct access of Lots 2 and 3 back onto Prospect, which can't handle it. However, the zoning problems here are unrelated to the issue of lots 2 and 3. This problem relates to the fact that Lots 4-6 are flag lots and that can't be :fixed by the usual Uwhy, we'll just put Lots 2 and 3 back on Prospect" argument.) 6. West End of Prospect Street Considerations. The western end of Prospect presents its own complications because of additional reduced ROW, an even narrower roadway, and the presence of many large trees in the grove at the northwest corner of Applicant's property. The proposal presented to the PC attempted to resolve competing interests in the this area. Unfortunately, the PC discarded the most important of these proposals. Issues include: a. location of sidewalk/saving trees - The proposal at the PC called for locating a sidewalk on the south side of Prospect within the roadbed. This was thrown out by the PC, who wanted the sidewalk to instead be located in the five feet immediately south of the roadway. This will jeopardize at least three large trees which all parties, including the Tree Commission, thought should be saved. The homeowners directly served by this sidewalk, Kip Sigetich and Rebecca Reid, are willing to to have the sidewalk placed inside the roadway in order to save the trees. PC John Fields had a good suggestion of slightly 16 ralslng this area to delineate a walking surface without disrupting auto travel. This worthy compromise should be reinstated. How can you justify a street exception based on saving trees, only to kill them with a sidewalk? b. location of utility pole and support wire - A major problem with the west end is adequate space for fire truck access into the Sigetich/Reid house. Part of this problem arises from location of a utility pole and support cable at the NW corner of Applicant's property. Removal of this pole would allow for greater access. Since Applicant wants to bury utilities in the subdivision, why can't this pole be removed as well? After all, why should Applicant's Iview lots' have a primary view of a utility pole and transformer? c. parking in the western stub - this is currently a no parking zone, but people park there anyway, creating severe access problems for homeowners there. While the Street Standards call for one-side parking on a 22' street (the dimension to which this section is supposedly going to be paved), those standards are also contemplate a Inetwork of interconnected city streets,' where Itravelers can choose from many available routes.' Handbook, p. 4. Those Standards do not contemplate dead ends as found here. (Handbook, pp. 7, 41) The proposal presented to the PC included a Staff Condition that called for the Fire Department to conduct a test for access once the road was complete, before determining whether west end parking would be allowed. This was thrown out by the PC, even though NO ONE OPPOSED IT. At a minimum, the test should be reinstated. 7. A security bond should be required in order to enforce this development's tree protection plans. Applicant's Landscape Architect John Galbraith has submitted a very worthy and tree protection plan. ~'he problem is that it is so extensive and expensive that it will encourage non-enforcement. And non-enforcement of tree protection plans is at epidemic levels in the City of 17 Ashland. will the Applicant call Mr. Galbraith when it is time for him to do his work? This Applicant has a suspect history regarding tree protection. At the Beach Street Condos (in the 400 block of Beach St.), Applicant made the entire large excavation on that property, not only without tree protection fences, but without having filed a tree protection plan, as required by law. A beautiful evergreen street tree was pruned by backhoe. This occurred after opponents of the Mt. pines project made known to Applicant their fear that the tree protection plans would not be enforced. So, it's not just that Applicant failed to prot.ect trees on Beach Street, but that it did so AFTER it should have known it was a big issue in this PA...not to mention required by the rules. The Planning Staff, however, cut off any discussion of this history before the Tree Commission, alleging it dealt with a prior PA. But the prior PA (Beach St. Condos) was long closed (indeed, construction was already underway), so that such PA could in no way be unfairly impacted by a discussion. And what can be more relevant to the issue of whether a security bond is required than an Applicant's own track record? A security bond should be imposed to make sure that Mr. Galbraith's worthy plan in enforced and doesn't become just another scrap of paper in the City's files. Such a bond is authorized by 18.61.250. 8. The planning procedure below was replete with ex parte communications, undisclosed potential conflicts of interest and disregard of the rules of procedure. These include: 1. One of the PCer's disqualified herself on actual conflict of interest grounds from the PA scheduled immediately before this one at the PC's October hearing. She then spent the time taken up by that other PA locked 18 in conversation with Applicant's representative, Mr. Cochrane, both in a group with Applicant's engineer and then alone with Mr. Cochrane. 2. After the end of the October hearing, one of the PCers not only entertained, but initiated an ex parte communication with Dr. Phillips. Immediately after introducing himself, this PCer loudly asked what Dr. Phillips would think about doing an LID as part of the fix on Prospect. This was said loudly enough to be heard by other neighbors who were still there. Since an LID imposes costs (and other headaches) on local citizens, the mere suggestion of an LID can discourage public participation, contrary to public policy. It was thus an ex parte communication on a very sensitive subject. 3. At the November hearing, this PCer failed, as required by state and city law, to disclose this ex parte communication at the time the Chairman called for disclosures. 4. When the undersigned objected and asked for a recusal (as he was probably required by state law to do in order to preserve error), it was revealed that another PCer also had an undisclosed ex parte communication as well and that the head of the City's Planning Department knew about it. Yet, neither the second PCer nor the Planning Director spoke up when the PC Chairman called for disclosure of ex parte communications. 5. Then, both the PC Chairman and the Planning Director repeatedly tried to cut off what the undersigned was saying. The Chairman, Mr. Chapman, even blurted Iwe're not going to lawyer this up!' The Ithis' referred to by the Chairman is a quasi- judicial proceeding with rules that are supposed to be followed. Indeed, it is likely that the undersigned was required by Oregon state law to make objections or see them waived. Further, every citizen who watched this unfold was at risk of concluding - see how you get slapped down if you show up at these hearings and try to make a difference...why bother? This cannot help encourage public participation. 19 6. At least one PCer (the one talking extensively with Mr. Cochrane before the OCtober hearing) has a substantial business relationship with Applicant's representative, Mr. Stone. It is POSSIBLE that any person in that situation COULD be effected by thinking - if I don't support Mr. Stone here, will it have an adverse financial impact on me in the other projects on which I'm working with him? And Icould' influence is the test for disclosing potential conflicts of interest under Oregon law. No disclosure was made. 7. The PC Chairman disregarded the normal rules of procedure by giving both the Staff and Applicant a second bite at the apple in the November hearing. At the October hearing, which was adjourned, both the Staff and Applicant spoke at length. The citizen-opponents (there were no citizens speaking for the proposal) began, but did not finish their presentation when time ran out. Thus, IT WAS THE OPPONENTS TURN TO TALK! Instead, the Staff and Applicant got to start allover again in November with full presentations and the citizens didn't get to start having their say until 8:30. Because so many objected, the PC didn't begin deliberation until close to 10:00, by which time everyone was tired and the room was hot. This resulted in a rushed consideration which, among other things, tossed out in a heartbeat the required Fire Department access test on Prospect. The only PCer who mentioned ROW dedication (Olena Black) found her suggestion very quickly disregarded. When citizens show up to these planning hearings they are told, in essence, that only the standards, the criterion, and the rules count. When the same standards, criterion and rules turn out to benefit people like those objecting to this PA, however, a far different tale often unfolds and the results of the PA suffer for it. Is it any wonder that the lquality and livability' that is so admired in an earlier age, seems so absent from our own. 20 CONCLUSION This Council has a unique opportunity to help assure the land at issue will be developed in a quality and livable way, enhancing, not detracting from the neighborhood in which it will sit. And you can do so by simply applying the standards, criterion and rules that are available to you. You can prove that the wonderful residential developments like Quail Haven right across the street are not just Ithings of the past.' The Council should vote Ino' and send this project back to the drawing board. Application of the zoning rules will obviously require substantial alterations that can't be cured by the expedient of piling on more conditions. Respectfully submitted, Randall Hopkins 21