Hearings Official Public Hearings

AGENDA Meeting Location: Phone: 541-682-5377 Atrium Building – Sloat Room www.eugene-or.gov/hearingsofficial 99 West 10th Avenue The Eugene Hearings Official welcomes your interest in these agenda items. Feel free to come and go as you please at any of the meetings. This meeting location is wheelchair-accessible. For the hearing impaired, FM assistive-listening devices are available or an interpreter can be provided with 48 hours notice. To arrange for these services, contact the Planning Division at (541)682-5481. WEDNESDAY, DECEMBER 19, 2012 (5:00 p.m.) PUBLIC HEARING ON ZONE CHANGE REQUEST Hollar, Jeff & Shirley (Z 12-1) Assessors Map: 18-03-06-11 Tax Lot: 5900, 6100, 6200, 6300 Location: 85 and 95 East 20th Avenue, 1980 and 1960 Oak Street, and 60 East 19th Alley Request: Change of zoning from R-1 Low Density Residential to R-2 Medium Density Residential Applicant: Jeff and Shirley Hollar/Barbara Joliffe Applicant’s Representative: Larry Reed, JRH Transportation Lead City Staff: Steve Ochs, Associate Planner Telephone: (541) 682-5451 E-mail: steve.p.ochs@ci.eugene.or.us Public Hearing Format: 1. Staff introduction/presentation 2. Public testimony from applicant and others in support of application. 3. Comments or questions from interested persons who neither are proponents nor opponents of the proposal. 4. Public testimony from those in opposition to application. 5. Staff response to testimony. 6. Questions from Hearings Official. 7. Rebuttal testimony from applicant. 8. Closing of public hearing. The Hearings Official will not make a decision at this hearing. The Eugene Code requires that a written decision must be made within 15 days of close of the public comment period. To be notified of the Hearings Official’s decision, fill out a request form at the public hearing or contact the lead City staff as noted above. The decision will also be posted at www.eugene-or.us/hearingsofficial.  Atrium Building 99 West 10th Avenue Eugene, Oregon 97401 Phone: 541-682-5377 Fax: 541-682-5572 www.eugene-or.gov/planning ZONE CHANGE STAFF REPORT Application File Name: Hollar, Jeff & Shirley (Z 12-1) Applicant’s Request: Zone change approval from R-1 Low Density Residential to R-2 Medium Density Residential. Subject Property/Location: Tax Lots 5900, 6100, 6200 and 6300, Assessor’s Map 18-03-06-11; located at 60 East 19th Alley, 1960 Oak Street and 85/95 East 20th Avenue. Relevant Dates: Application submitted on May 18, 2012; supplemental information submitted on June 28, 2012; and November 6, 2012 public hearing scheduled for December 19, 2012. Applicant/Owner: Jeffrey and Shirley Hollar, Barbara Joliffe Lead City Staff: Steve Ochs, Associate Planner, Eugene Planning Division: (541) 682-5453 Purpose of Staff Report: The Eugene Code (EC) requires City staff to prepare a written report concerning any zone change request. In accordance with the Type III land use application procedures (see EC 9.7320) the staff report is printed and available 7 days prior to the public hearing on the request, to allow citizens an opportunity to learn more about the request and to review the staff analysis of the application. The staff report provides only preliminary information and recommendations. The Hearings Official will also consider additional public testimony and other materials presented at the public hearing before making a decision on the application. The Hearings Official’s written decision on the application is generally made within 15 days following close of the public record, following the public hearing (see EC 9.7330). For reference, the quasi-judicial hearing procedures applicable to this zone change request are described at EC 9.7065 through EC 9.7095. Present Request: The properties subject to this request are made up of four contiguous tax lots totaling approximately 15,750 square feet (0.36 acre) which have frontage on Oak Street and East 20th Avenue. The properties are currently developed with single-family dwellings. Abutting property to the west is zoned R-1 and HO Agenda - Page 1 developed with a single-family dwelling. The surrounding area includes a mixture of low, medium and high density zoned properties and is developed primarily with single family homes and multi-family development. The vacant Civic Stadium property is located just to the south of the subject property and a large community commercial area that includes a variety of services is located two blocks to the north. The applicant is requesting approval to change the current zoning of the subject property from R-1 Low Density Residential to R-2 Medium Density Residential. As noted in the applicant’s materials, the applicant initially requested R-2 Medium Density Residential or R-3 Limited High Density Residential with a 40 dwelling unit per acre maximum and height limitation of 30 feet. The applicant’s initial materials spoke almost entirely to a zone change to R-3 but after initial advice from staff that the R-3 zone would not comply with the applicable zone change criteria, the applicant provided an email to staff on July 12, 2012 indicating that R-2 could be an alternative to R-3 in the event the R-3 analysis wasn’t supported. This email requested that all statements referring to R-3 in the application also include R-2. Prior to the initial hearing set for September, staff communicated to the applicant’s representative that the approach of asking for two different zones would not be supported by staff. Subsequently, the applicant put the application on hold and submitted an addendum on November 6, 2012 requesting only a zone change to R-2 Medium Density and withdrawing the request for R-3. A revised public notice was sent out and a new hearing date set. As such, this evaluation addresses only the R-2 request in the November 6, 2012 submittal and not the initial “dual” request for R-2 or R-3. For additional details of the requested zone change and site characteristics, please refer to the applicant’s written statement and other supporting application materials, as well as the following staff evaluation and other attachments. Application Referrals and Public Hearing Notice: The application was initially deemed complete on July 18, 2012. Staff provided information concerning this application to other appropriate City departments, public agencies, and the affected neighborhood group (Friendly Area Neighbors), on July 27, 2012. A Notice of Proposed Amendment was also mailed on July 24, 2012, to the Oregon Department of Land Conservation and Development (DLCD) and a revision to this notice was mailed on November 15, 2012. The public hearing notice was mailed and posted on November 19, 2012, in accordance with the applicable code requirements at EC 9.7315. As of the date of this report, two letters of written testimony has been received. The first letter, from Jim Poverman, the manager of a nearby business, expresses concern about parking availability and traffic in the area and requests that sufficient parking be required. Staff responded to this testimony and explained to Mr. Poverman that the zone change does not include any approval criteria specific to parking, and that any future development proposal would need to meet parking requirements at the time of future land use application or building permit. The other letter, submitted by Dona Cork, owner of property at 74 East 18th Avenue and 1850 Oak Street opposes the re-zoning to R-2 for a variety of reasons, including blocking of alleys, vandalism, renter behavior and the need to update sewers and alleyways in the area. No development is proposal is included as part of this zone change. Approval of the zone change is limited to criteria at EC 9.8865. HO Agenda - Page 2 These criteria do not include standards for future developer or occupant behavior but future development will need to comply with all City requirements including multi-family standards and applicable access standards. Information is provided below at EC 9.8865(3) regarding transportation and the need for future sewer improvements in the area. Any written testimony received after the date of this report but prior to the public hearing will be forwarded to the Hearings Official for consideration in making a decision. Public testimony, written or otherwise, may also be presented at the public hearing and submitted into the record for this matter. Staff Evaluation of Zone Change Request: In accordance with EC 9.7330, the Hearings Official is required to approve, approve with conditions, or deny this Type III land use application for a zone change. The decision must be based on, and be accompanied by, findings that explain the criteria and standards considered relevant to the decision. It must also state the facts relied upon in rendering the decision, and explain the justification for the decision based upon the criteria, standards, and facts set forth. To assist the Hearings Official in rendering a decision on the application, staff presents the following zone change approval criteria (shown below in bold typeface), with findings related to each, based on the evidence available as of the date of this staff report. Staff has also provided a recommendation to the Hearings Official following the staff evaluation, below. EC 9.8865(1): The proposed zone change is consistent with applicable provisions of the Metro Plan. The written text of the Metro Plan shall take precedence over the Metro Plan diagram where apparent conflicts or inconsistencies exist. The applicant’s request for R-2 medium density zoning is consistent with the medium density designation in the Metro Plan. The applicant’s written statement questions whether the Metro Plan diagram is a generalized map or not and notes that “a case can be made that the site is eligible for R-2 density”. Page II-G-2 of the Metro Plan notes that the diagram is parcel-specific if the parcels are within a clearly identified plan designation, i.e. parcels that do not border more than one plan designation. In this case, the parcels are surrounded on all sides by the medium density plan designation and the diagram is therefore parcel-specific. Therefore, the parcel is not only eligible for the R-2 zone, the R-2 zone is the only zone that complies with the parcel specific medium density designation. The applicant addresses consistency with a variety Metro Plan policies in the initial application materials. Staff addresses relevant policies below and also provides context to the role of the policy in relation to this specific zone change. In general, the findings below conclude that the applicant’s R-2 proposal is consistent with applicable provisions of the Metro Plan. A.1 Encourage the consolidation of residentially zoned parcels to facilitate more options for development and redevelopment of such parcels. HO Agenda - Page 3 While the applicant relies on this aspirational policy for support, it supports the consolidation of parcels and is not applicable or relevant to the zone change application. A.2 Residentially designated land within the UGB should be rezoned consistent with the Metro Plan and applicable plans and policies; however, existing agricultural zoning may be continued within the area between the city limits and the UGB until rezoned for urban uses. While this policy is not addressed in the written statement, it provides direction for zone changes and is applicable in this instance. As described above, the parcel is designated for medium density residential use. The proposed R-2 zone change consistent with the plan designation by providing the allowable medium density and is therefore inconsistent with this policy. A.3 Provide an adequate supply of buildable residential land within the UGB for the 20-year planning period at the time of Periodic Review. A.4 Use annexation, provision of adequate public facilities and services, rezoning, redevelopment, and infill to meet the 20-year projected housing demand. These policies provide guidance to the local jurisdiction on how to address the housing demand at the time of periodic review. At the last periodic review, the designations in the Metro Plan were established for this property as appropriate for medium density development. At best, these policies could be considered as general support for a zone change that complies with the applicable plan designation of medium density. A.8 Require development to pay the cost, as determined by the local jurisdiction, of extending public services and infrastructure. The cities shall examine ways to provide subsidies or incentives for providing infrastructure that support affordable housing and/or higher density housing. This policy addresses the development of infrastructure and provides guidance to the City about providing subsidies or incentives that support affordable and higher density housing. This policy is not applicable to the zone change. A.9 Establish density ranges in local zoning and development regulations that are consistent with the broad density categories of this plan. Low density: Through 10 dwelling units per acre (could translate up to 14.28 units per net acre depending on each jurisdictions implementation measures and land use and development codes. Medium density: Over 10 through 20 dwelling units per gross acre (could translate to over 14.28 units per net acre through 28.56 units per net acre depending on each jurisdictions implementation measures and land use and development codes) HO Agenda - Page 4  High density: Over 20 dwelling units per gross acre (could translate to over 28.56 units per net acre depending on each jurisdiction’s implementation measures and land use and development codes) This policy also provides guidance to the City to establish density ranges in zones and is not an approval requirement for this zone change. It does provide context to this proposal as the City has established the R-2 zone which allows for 10 to 28 units per net acre and is appropriate for medium density. The R- 3 and R-4 zones which have been established to allow for over 20 dwelling units per acre, are appropriate for high density. The applicant’s R-2 medium density proposal is consistent with this policy by allowing up to 28 units per acre. Residential Policies A.10, A.11, A.12, and A.13 promote coordinating higher density with services, employment and transportation and creating opportunities for infill and are not in conflict or inconsistent with the existing medium density plan designation. These policies are worded in a general way to provide guidance to the City in determining the plan designation of various areas, and in some cases provide relevant guidance or may serve as requirements for a zone change. A zone change consistent with the medium density plan designation is consistent with these policies to the extent they are relevant. A. 14 Review local zoning and development regulations periodically to remove barriers to higher density housing and to make provision for a full range of housing options. A. 16 Allow for the development of zoning districts which allow overlap of the established Metro Plan density ranges to promote housing choice and result in either maintaining or increasing housing density in those districts. Under no circumstances, shall housing densities be allowed below existing Metro Plan density ranges. These policies provide direction to the City in the development of zoning districts. While the applicant asserts these policies can support an allowance for the requested zone, they could only be used as support if the City were changing zoning districts by amending the zoning ordinance at a legislative level. They are not applicable to this quasi-judicial zone change. The census data, ECO Northwest Study and other information the applicant provides regarding the University of Oregon student population might be relevant if a plan designation change were being justified at the legislative level, but do not inform this zone change. The applicant’s written statement addresses various additional plan text but none of these additional provisions serve as approval criteria to this request. The subject properties are also located in an area identified for Nodal Development in Transplan but because the area is not designated for Nodal Development, the addition of the /ND overlay is not required. Based on these findings, the proposed zone change to R-2, Medium Density Residential is consistent with the Metro Plan diagram and text. HO Agenda - Page 5  EC 9.8865(2): The proposed change is consistent with applicable adopted refinement plans. In the event of inconsistencies between these plans and the Metro Plan, the Metro Plan controls. As indicated in the application materials, the subject property is located within the boundaries of a refinement plan known as the South Willamette Subarea Study (see Exhibit G-1 of the applicant’s materials). While the applicant continues to make a case that the refinement plan is inconsistent with the Metro Plan (based on an earlier high density proposal), the plan is in fact consistent with the Metro Plan as noted below. In short, the refinement plan notes the subject property is appropriate for medium density residential and the subject property is designated for medium density residential in on the Metro Plan diagram. The following recommendation included in the study and adopted by City Council is relevant to this proposal. Recommendation 6 (Page 8): The zoning and planned use designations for the remainder of the study area should remain as is. In particular, the area on the east side of Willamette Street between 19th and the Civic Stadium property is an appropriate area for medium density residential development. The area on the east side of Willamette between 19th and 18th is appropriately designated and zoned as commercial. The subject property is located on East 20th Avenue, east of Willamette Street between 19th and the Civic Stadium property (which is on the south side of 20th). The beginning of this recommendation which reads “The zoning and planned use designations for the remainder of the study area should remain as is” could be read to mean that the existing R-1 zoning should remain. The second sentence though, clarifies that this area is appropriate for medium density residential. This reading is consistent with the Metro Plan medium density designation also. Even if it was read to limit the area to the existing zoning, the Metro Plan medium density designation would prevail. In either instance, the proposed R-2 zoning is consistent with the medium density designation of the subject property as described in the recommendation and further supported by the land use diagram of the Metro Plan. Staff also notes that the subject property is represented on several maps with the West University Refinement Plan. However, the plan area depicted on these maps (such as the Land Use Diagram on page 57 and the Public Facilities map on page 22) clearly identifies the southern boundary of the plan area as 19th Street, indicating that the subject property (on 20th Street) is not within that plan area. Based on these findings, the proposed zone change to R-2 is consistent with the applicable refinement plan diagram and text. EC 9.8865(3): The uses and density that will be allowed by the proposed zoning in the location of the proposed change can be served through the orderly extension of key urban facilities and services. Key urban facilities and services are defined in the Metro Plan as: wastewater service, stormwater service, transportation, water service, fire and emergency medical services, police protection, City- wide parks and recreation programs, electric service, land use controls, communication facilities, and HO Agenda - Page 6 public schools on a district-wide basis (see Metro Plan page V-3). As confirmed by referral comments from Public Works staff the minimum level of key urban facilities and services are available or in the case of wastewater, can be made available. Wastewater The development site is served with a six-inch (6”) pipe that was constructed in 1929 and slip-lined in 2011 to eliminate inflow and infiltration. During the slip-line construction, Public Works staff determined that the pipe currently surcharges due to uneven grades and the number of connections. Additional units on this line would not be allowed. The applicant’s written statement acknowledges that the existing six-inch pipe within East 19th Alley that currently serves the subject properties must be upgraded to a standard eight-inch in order to accommodate additional future development. The entire line, approximately four hundred and fifteen feet (415’), from the manhole (#3384) west of the properties in Oak Alley to the twelve-inch (12”) main trunk east of Oak St. (to manhole #3370) would need to be upgraded and all existing service lines would need to be reconnected at time of future building permit for a re-development of the site. The existing 12-inch main is approximately 5 feet deep, which means the construction of the 8-inch pipe will be shallow and a concrete liner will be required under paved streets. Systems Development Charges could be offset with the applicant’s construction of an 8-inch pipe system through SDC credits upon review of privately engineered public improvement. Stormwater There are ten-inch (10”) and eighteen-inch (18”) piped public stormwater facilities within East 20th Avenue and Oak Street which are sufficient to serve the subject properties. Streets These properties are adjacent to East 20th Avenue and Oak Street, minor arterials, though as the applicant acknowledged, the future development will likely take access from East 19th Alley. Given the above findings, all key urban services are currently available, or can be extended in an orderly manner to the subject property, as required. EC 9.8865(4): The proposed zone change is consistent with the applicable siting requirements set out for the specific zone in: (a) EC 9.2735 Residential Zone Siting Requirements. These siting requirements apply only to the R-1.5 zone. As this request is for R-2, this criterion does not apply. EC 9.8865(5): In cases where the NR zone is applied based on EC 9.2510(3), the property owner shall enter into a contractual arrangement with the City to ensure the area is maintained as a natural resource area for a minimum of 50 years. The criterion is inapplicable, as the proposed zone change does not include the NR zone. HO Agenda - Page 7 Transportation Planning Rule The applicant’s supplemental written statement generally addresses transportation and the Transportation Planning Rule and provides trip generation information, but does not specifically address the relevant provisions of the Transportation Planning Rule at OAR 660-012-0060(1). Nonetheless, based on the proposal, the zone change is allowed pursuant to 0060(9). As adopted, OAR 660-012-0060(1) states: (9) Notwithstanding section (1) of this rule, a local government may find that an amendment to a zoning map does not significantly affect an existing or planned transportation facility if all of the following requirements are met. (a) The proposed zoning is consistent with the existing comprehensive plan map designation and the amendment does not change the plan map: (b) The local government has an acknowledged TSP and the proposed zoning is consistent with the TSP; and (c) The area subject to the amendment was not exempted from this rule at the time of an urban growth boundary amendment as permitted in OAR 660- 024- 220(1)(d), or the area was exempted from this rule but the local government has a subsequently acknowledged TSP amendment that accounted for urbanization of the area. The City Attorney has provided the following documents for the record: 1. DLCD’s December staff report to Land Conservation and Development Commission (LCDC) (for 12/8/11 LCDC Meeting), including Options #1, 1A, 2 and 2A for OAR 660-012-0060(9) and written testimony from the public. 2. Written testimony from Senator Lee Beyer (regarding 0060(9)) that was submitted after the DLCD packet was distributed. 3. DLCD’s Option #1B for 0060(9), handed out by DLCD at the 12/9/11 LCDC Meeting 4. The amendments to OAR 660-012-0060 that were adopted by LCDC 5. The amendments to OAR 660-012-0060 that were filed with the Secretary of State The City Attorney has also provided the following summary with regard to legislative history: By way of brief history, for LCDC’s December, 8, 2011, meeting, DLCD staff presented the LCDC with four options for the wording of 0060(9); Options #1, #1A, #2 and #2A. While Option #1 had majority support from the TPR-RAC, based on DLCD staff’s recommendation, the LCDC-OTC joint subcommittee recommended that LCDC adopt Option #2. Option #2 required a demonstration that “the proposed zoning is consistent with the TSP assumptions about development of the area of the proposed amendment.” On December 9, 2011, in response to HO Agenda - Page 8  testimony and concerns raised by LCDC regarding Option #2 the previous day, DLCD presented LCDC with yet another option for 0060(9); Option #1B. This Option #1B, tweaked Option #1A by adding the phrase “and the proposed zoning is consistent with the TSP.” In DLCD’s December 9 document setting forth Option #1B, DLCD stated that the “variation on Option #1 was drafted based on testimony that proposed amendments should be allowed if they are consistent with both the comprehensive plan map and the TSP, but that Option #2 defined consistency too narrowly and would not work in many cases.” LCDC ultimately adopted a slightly revised version of Option #1B. Based on the plain language of 0060(9), as well as LCDC’s specific rejection of Option #2 that would that would have required that the proposed zoning be “consistent with the TSP assumptions about development of the area of the proposed amendment,” the City believes that it is reasonable to find that a proposed zone change meets the criteria of 0060(9) if, in addition to satisfying the other criteria, the current comprehensive plan map designation (with which the proposed zone change is consistent) was in place in 2001, the year that the City Council adopted TransPlan. This finding is sufficient because, pursuant to state and local requirements, in order for the City Council to have adopted TransPlan, the Council was required to conclude that TransPlan is consistent with the City’s adopted comprehensive plan. A proposed zone that is consistent with the 2001 comprehensive plan map designation, together with the City Council’s conclusion in 2001 that TransPlan is consistent with the comprehensive plan map, is sufficient to support a finding that the proposed zone is consistent with TransPlan. For the reasons discussed below, the City finds that the proposed zone change does not significantly affect an existing or planned transportation facility because all of the requirements in OAR 660-012- 0060(9) are met. 0060(9)(a): The proposed zoning is consistent with the existing comprehensive plan map designation and the amendment does not change the plan map: As discussed above at EC 9.8865(1), the subject properties are designated as medium density residential on the City’s adopted comprehensive plan map (i.e., the Metro Plan diagram). The proposed R-2 medium density zoning is consistent with the current comprehensive plan map designation for medium density residential l use. The amendment does not change the plan map. 0060(9)(b): The local government has an acknowledged TSP and the proposed zoning is consistent with the TSP: The City of Eugene’s adopted and acknowledged Transportation System Plan (TSP) is the Eugene- Springfield Metropolitan Area Transportation Plan (TransPlan). The Eugene City Council adopted the HO Agenda - Page 9 current version of the plan on September 10, 2001, by Ordinance No. 20234. 1 In 2001, the criteria for adopting TransPlan (classified as a “major update” to the 1986 version), was as follows: “(a) Consistency with the relevant statewide planning goals adopted by the Land Conservation and Development Commission; and (b) Consistency with the Eugene-Springfield Metropolitan Area General Plan (Metro Plan).” In support of its adoption of the 2001 TransPlan, the City Council adopted 50 pages of legislative findings demonstrating its compliance with these two criteria. Both before and since the City Council adopted the 2001 TransPlan, the subject properties were designated on the City’s adopted comprehensive plan map (Metro Plan diagram) as medium density residential. In adopting TransPlan, the City Council found it to be consistent with the Metro Plan, which includes the Metro Plan diagram. Since the 2001 Metro Plan diagram designated the subject properties as medium density residential, the 2001 finding that TransPlan is consistent with the Metro Plan is a finding that TransPlan is consistent with a medium density residential designation for these properties. Because a medium density zoning on these properties will not change (is consistent with) the property’s medium density plan map designation, and TransPlan is consistent with the medium density designation, a medium density zoning on these properties is consistent with the City’s acknowledged TSP. Additionally, pursuant to OAR 660-012-0030(3), within UGBs, the determination of local and regional transportation needs must be based on population and employment forecasts and distributions that are consistent with the acknowledged comprehensive plan. The City’s 2001 finding that TransPlan is consistent with OAR 660-012-0030(3) specifically states that TransPlan relied on the same forecasts and distributions that were relied upon for the Metro Plan periodic review. Because the 2001 Metro Plan designates the subject properties as medium density, the forecasts and distributions relied upon for TransPlan were based on that same medium density designation. Since TransPlan was found to be consistent with OAR 660-012-0060(3), and acknowledged as such, the City finds that the determination of transportation needs embodied in, and addressed by, TransPlan, is consistent with the subject property’s medium density designation. 0060(c): The area subject to the amendment was not exempted from this rule at the time of an urban growth boundary amendment as permitted in OAR 660-024-220(1)(d), or the area was exempted from this rule bur the local government has a subsequently acknowledged TSP amendment that accounted for urbanization of the area. The subject properties were not exempted from the TPR at the time of an urban growth boundary amendment. Based on the findings above, the proposed zoning map amendment does not significantly affect an existing or planned transportation facility. 1 The City Council has subsequently amended TransPlan by Ordinance No. 20442 (enacted on November 9, 2009) and Ordinance No. 20461 (enacted on August 11, 2010). Those amendments are immaterial to these findings. HO Agenda - Page 10 Staff Recommendation: Based upon the available evidence and findings above, staff recommends that the Hearings Official approve the applicant’s zone change request to R-2 medium density residential. Attachments: The entire application file is available for review at the Eugene Planning Division. The Hearings Official will be provided a copy of the entire record which will also be made available for review at the public hearing. The following item is also attached for reference: A. Vicinity Map For More Information: Please contact Steve Ochs, Associate Planner, Eugene Planning Division, at (541) 682-5453, or by e- mail, at steve.p.ochs@ci.eugene.or.us HO Agenda - Page 11 Hollar, Jeff & Shirley (Z 12-1) 18-03-06-11/05900, 06100, 06200, 06300 Change of zoning from R-1 Low Density Residential to R-2 Medium Density Residential W O W W 19th Aly E 19th Aly [ [ [ W 20th Ave [ E 20th Ave e tte Willam Aly ´ Zoning [ Subject Site HO Agenda - Page 12 7/19/12