HomeMy WebLinkAboutMinutes PC 06-21-11A
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City of Carmel
CARMEL PLAN COMMISSION
JUNE 21 9 2011
City Hall Council Chambers, 2 nd Floor
One Civic Square
Carmel IN 46032
6:00 PM
Members Present: John Adams, Jay Dorman, Brad Grabow, Judy Hagan, Nick Kestner, Steve Lawson,
Kevin "Woody" Rider, Susan Westermeier, Ephraim Wilfong
Members Absent: Steve Stromquist
Also Present: Ramona Hancock, Plan Commission Secretary
John Adams was officially sworn in and introduced as the newest member of the Plan Commission
Ephraim Wilfong is currently serving as the Plan Commission appointment to the Board of Zoning Appeals and
represents the unincorporated area of the City. Mayor Brainard will appoint a member to the Board of Zoning
Appeals to fill the position vacated by Leo Dierckman.
Steve Lawson and Nick Kestner jointly agreed to accept the election to the Hamilton County Plan Commission, each
serving part of a 12 month period in a non voting capacity. The Hamilton County Plan Commission currently meets
the third Wednesday of every month.
The minutes of the May 17, 2011 meeting were approved as submitted.
Communication, Angie Conn: A request for tabling Turkey Hill Minit Market for 30 days was received from the
Indianapolis Department of Water Works, followed by a written letter of opposition stating reason for denial. Note:
The Plan Commission rejected the request for Tabling; comments from Indianapolis Dept of Water can be given at
public hearing this evening and at the Committee level.
Legal Counsel Report, John Molitor: Up -date on the Johnson Garage a demolition permit has been issued, but as
yet, the garage has not come down —the Court granted an additional 30 days for compliance; tentative hearing date
is set for July, at which time the garage should either be removed or in violation (contempt of court.)
H. Public Hearings
1. Docket No. 10110012 DP /ADLS: Legacy PUD Turkey Hill Minit Market.
The applicant seeks site plan and design approval for an automobile fuel station, retail store,
carwash and also seeks the following zoning waiver approval:
2. Docket No. 10110013 ZW: Section 9.02, Legacy PUD ordinance Z- 501 -07, maximum
15 -ft front yard building setback.
The site is located at 7729 E. 146" St. (at River Rd.) and is zoned PUD/Planned Unit
Development. Filed by Charlie Frankenberger of Nelson Frankenberger.
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Present for Petitioner: Jon Dobosiewicz, Land Use Professional with Nelson Frankenberger; Steve
Fuller, Turkey Hill; Charlie Frankenberger, Nelson Frankenberger; other members of the development
team.
Overview:
Site consists of 1.9 acres
Site is the corner use block within Legacy PUD
Site located at southwest corner of 146 Street River Road
Legacy PUD approved by City Council 2007
Future Development anticipated south west of site, within remainder of corner use block
Proposal is for construction of new fuel center car wash
Proposal requires following approvals:
1. Approval of DP /ADLS from Plan Commission
2. Zoning Waivers for front build -to -line
3. Variance from BZA to allow mechanical scrolls signs
4. Independent approval of underground storage by Carmel Utilities Carmel Dept of
Engineering
Carmel is undertaking a study to assist in guaranteeing compliance with all Carmel Ordinances
regulations
New building is pulled up to 146 Street (required by Ordinance)
Setback along River Road is subject of request of zoning wavier
Legacy PUD requires a front yard setback not to exceed
Water lines traverse the real estate in southwest direction along eastern boundary line
Site designed as if protective easement in place
Fuel Canopy located south of Bldg screened from 146 Street
Parking is behind and beside the building
Pathway connections located between 146 and River Road
Additional drive access previously proposed was removed at request of City Engineer
Parcel located to west south of subject site will use same access points no additional
driveway access points to perimeter public street
North bldg elevation faces 146 Street; south elevation faces parking area
Building shares common design in terms of bldg materials general style with recently opened
store at Range Line Road Carmel Drive
Particular attention paid to screening mechanical areas providing 360 degree architecture
similar to Range Line Road location
Canopy car wash maintain same bldg materials design elements as primary bldg
Color of canopy changed to match panels below window -sets
All site lighting will meet Ordinance Standards review at Committee
Site landscaping meets standards of Legacy PUD approved by Carmel Urban Forester
Signage for location: wall ground; no free standing ground signs for individual businesses or
signage proposed on canopy structure itself
Proposed site development should lead to additional development at corner use block as per the
Legacy PUD
Request forwarding to Special Studies Committee
Public Remonstrance /Favorable: None
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Organized Remonstrance/Unfavorable:
Bryan Weese, attorney, Bingham, McHale, representing Indpls Dept of Water. Remonstrance
materials submitted in January; Dept of Water Concerns:
1. Use presents significant public safety health concerns
2. No design standard that can guarantee the Whitewater aquifer will not be subject to
possible contamination
Plan Commission has authority to deny this use reference Chapter 24 of Carmel Ordinance
Section 24.01 provides that Development Plan application shall generally be considered
favorably by Commission implying that Commission could view it unfavorably as well
Requirements of 24.02 are vital components to review in approval process —DOW believes this
is a situation where Commission can apply approval concepts deny the application
Proposed use is not consistent with policies for the district as set forth in Comp Plan not
compatible with existing land uses
Upon examining Legacy PUD history, impression is that no consideration was given to
protection of the aquifer. It appears that no specific uses for corner retail parcel were ever vetted
by any public body no particular use at this location was reviewed to determine compliance
with the Ordinances or the Comp Plan.
Original PUD had several separate distinct use pockets
Table of Uses establishes permitted or possible uses for this site that have not been the subject of
specific review
No reference in Table of Uses to protection of the aquifer, and no apparent discussion of a gas
station at The Legacy
Comments from Oct 2006 meeting state that the way the PUD Ordinance is written, everything
except a detached, single family must return to the Plan Commission for ADLS Development
Plan approval the Commission will be allowed a second look
Second Look can be more than just reviewing landscaping plans building facades
Impact of proposed use and its compatibility with surrounding uses is a required appropriate
part of Development Plan approval process
Even if design of fuel station can be absolutely, guaranteed, no spillage —which is impossible
its presence in the middle of the aquifer creates a risk of off -site contamination that does not
presently exist
Approval would create tanker traffic along 146 Street, thru the aquifer that does not now exist
Risk of on site off -site contamination should be reduced to greatest extent possible, there is no
way to guarantee it will not occur
Harm resulting from a spill would be an environmental catastrophe that would negatively affect
the City of Carmel and its neighbors for months or years
Risk of contamination connected with the fuel station far outweighs any private benefit that
might be derived
Indpls Dept of Water respectfully requests that the Commission deny this Development Plan
based upon criteria expressly provided for in the Ordinance the Comprehensive Plan
Additional Organized Public Remonstrance/Unfavorable:
John Davis, attorney, Church, Church, Hittle Antrim, representing the Service Advisory Board
S of Dept of Water Works of City of Indianapolis "SAB" encompasses series of communities
surrounded by Indpls and served by former Indpls Water Company created in 2001 when
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Mayor Peterson acquired the Water Company
Water from Indpls Water's White River north plant serves SAB communities of Fishers, Indpls,
Noblesville, Westfield
Proposed fuel station is in a drinking water supply aquifer that affects the members who asked
for representation this evening
Letter sent to Doug Haney, Carmel Counsel, and John Duffy, Carmel Utilities, December 15,
2010 in opposition to this proposal copy provided to the Plan Commission
Letter of opposition dated December 27, 2010 from City of Westfield Mayor Andy Cook to Mike
Hollibaugh also furnished to Plan Commission
Letter of opposition dated January 20, 2011 from Hamilton County Surveyor Kent Ward to Mike
Hollibaugh
Letter of opposition dated January 14, 2011 from Indpls Dept of Water to Mike Hollibaugh along
with a letter from Indiana Dept of Environmental Management (IDEM) confirming that this site
is in a wellhead protection area
Letter of opposition dated January 21, 2011 from Noblesville Mayor Ditslear to Mike Hollibaugh
Letter of opposition dated February 11, 2011 from Town of Fishers Council President Scott
Fautless to Mike Hollibaugh
Letter of June 15, 2011 from Indianapolis Water re- affirming their opposition to the proposed
fuel station, with an attachment from Keramida, Inc. Environmental
Copies of all afore mentioned letters were to have been provided to Plan Commission Members
In 2008, there were 8,000 gals of fuel spilled due to a broken gasket when the delivery truck was
filling an under- ground tank on Main Street in Carmel
In an aquifer, a spill can be just as devastating as a leak
Carmel wells are currently not within the one year time of travel how environmentalists
measure the threat a one year time of travel of a contamination thru an aquifer
Two wells being proposed by John Duffy, Carmel Utilities, are within the one year time of travel
The proposed development is not worth losing two wells
The Service Advisory Board requests that the Plan Commission deny the proposed use
Indpls Water has been a good neighbor to the City of Carmel and has worked with Carmel on
Carmelot Park, and River Road Park.
The surrounding communities are asking for reciprocation and request that Carmel not put a
potential source of pollution in their aquifer
No right way to do the wrong thing putting a gas station in a drinking aquifer is not the right
thing to do
General Public Comments/Unfavorable:
Ann McKiever, Director of Environmental Stewardship for Citizens Energy Group, 2020 North
Meridian Street, Indianapolis
Citizens has entered into an asset purchase agreement with City of Indpls for drinking water
wastewater utilities
Dept of Water Works has previously provided comments opposing the proposed fuel station due
to potential risks to ground water other environmental contamination
Groundwater contamination can materially and adversely impact the drinking water supply
The aquifer serves as a resource for thousands of people in Hamilton County, including residents
of Carmel Westfield
Based on potential risks, Citizens Energy Group joins the Dept of Water Works in opposition to
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the proposed fuel station and convenience store within the one year time of travel for the
delineated wellhead protection area
There are other viable, economic development uses for this site that would be protective of the
aquifer and provide for commercial and economic value for the community
Additional General Public Comments/Unfavorable:
Larry Reiser, 8050 East 146 Street, representing 3 area land- owners: Teresa Rayburn, Sherry
Forney, and self. The impact of a fuel station, if a breach of fuel tanks would occur, would
immediately not one year away directly damage the wells on our properties. It is difficult to
imagine that this body would approve a fuel station located at this low level of elevation, next to
a major floodway. Approval would be an irresponsible act by this Board.
Rebuttal, Charlie Frankenberger:
Legacy PUD enacted in 2007 allows a mixed -use community on the corner
Pursuant to the approved PUD Ordinance, a fuel center is a permitted use
In 2007, discussion occurred by Plan Commission City Council regarding a fuel center and its
proximity to wellheads
Also in 2007, Indpls Water Company (in attendance tonight) was a member of Carmel Technical
Advisory Committee but did not, at that time, object to a fuel center as a permitted use
When Legacy PUD was enacted in 2007, it was decided by the Plan Commission City Council
that a fuel center would be a permitted use, and if a fuel center was later proposed, tank safety
would be carefully reviewed by Carmel Dept of Utilities Carmel Dept of Engineering
In 2007, it was clearly understood when the Legacy PUD was enacted that allowing a fuel center
as a permitted use in no manner relieved a subsequent user from complying with Carmel's tank
safety regulations
Appearance before the Commission this evening is for DP /ADLS review, not permission for a
fuel center
A fuel center is already a permitted use and not part of the DP /ADLS review
Regardless of DP /ADLS review, regardless of DP /ADLS approval, tank safety will be
independently reviewed —and is currently being independently reviewed —by Carmel's Dept of
Utilities and Engineering
If Turkey Hill's tank safety plan does not comply fully with Carmel's very rigorous tank safety
requirements, it cannot get a building permit —even if there is DP /ADLS approval
The request for DP /ADLS approval must comply with any number of other independent,
applicable Ordinances and regulations
Plan Commission DP /ADLS review approval of Turkey Hill's plan and building design does
not in any manner relieve Turkey Hill from complying with Carmel's requirements for wellhead
protection and storm -water pollution prevention.
Indpls Water Company letter to Plan Commission dated 6/15/2011 was mentioned. The Water
Company indicated that as part of DP review, the Plan Commission can deny an already
permitted use. The Water Company suggests that the DP criteria be used to prohibit a permitted
use; however DP review criteria pertained to the development plan and not the review of a use or
a tank
Even if there is DP /ADLS approval, absent compliance, as determined by John Duffy and as
determined by Mike McBride in the Carmel Depts., the fuel center cannot be built
In the DP /ADLS review process by the Plan Commission, tank safety requirements some facts
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and science discussed this evening are not really relevant
Dept of Utilities has hired an expert to oversee the plan and the implementation of the plan
Dept of Utilities asked Turkey Hill to pay $36,000. to retain the expert
Turkey Hill has paid the fee; the study is underway
Carmel's decision, but the other jurisdictions are welcome to participate
Dept Comments, Angie Conn:
Utilities Dept has hired an outside consultant to do a study of the ground water to review
storm -water drainage runoff protection plan
Ground water study will take approx 6 weeks to complete
Dept has approx 11 outstanding items; petitioner is working with Dept to address mostly lighting
landscaping items
Dept recommends referral to July 05 Special Studies Committee at 6:00 PM
Legal Counsel Comments, John Molitor:
Key provisions of Ordinance:
1. Commission is to review Development Plan application to determine if the Plan satisfies the
development requirements in the Ordinance in the zoning district
2. Four main considerations: Consistency with the policies for the district as set forth in the
Comp Plan; Surrounding zoning existing land use; compatibility with existing platted
residential uses; compatibility of proposed project with existing development in the district
Plan Commission is not second guessing uses that were allowed when the PUD was enacted
City Council has already decided which uses would be allowed
Generally speaking, the Plan Commission's jurisdiction is limited to looking at normal review
for Development Plans, i.e. compatibility of structures, traffic circulation, ADLS
Other issues concerns brought before the Commission this evening are generally covered
under other City Ordinances regulations
Comments from Commission Members:
Decision re tanks and ground water rests with John Duffy, Utilities Mike McBride,
Engineering not in Plan Commission's purview
Geist Reservoir has a fueling station for boats; drinking water comes from Geist
Turkey Hill Minit Market at Range Line Carmel Drive is a showcase example of integrating
such a facility into an existing business environment
Any consequence for denying a petition that complies with the Ordinance? (would be mandated
by the Court system no financial consequence)
Question of Sequence wait until Survey completed Engineering Utilities has signed off?
(Ordinance does not specify who goes first)
Issue of tanks has nothing to do with Plan Commission
Special Studies will deal with further review
If outdoor vending (ice, propane, Red Box, ATM, etc.) any outdoor sales should have
appropriate controls restricted for clutter purposes
Looking back perhaps 10 years, have there been any environmental citations /issues, delivery
risks, or any other challenges with Turkey Hill? Need to know the record on this
Hamilton County Commissioners grant the curb cuts along 146' Street reason for hearing?
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Dept will research and report
Docket No. 10110012 DP /ADLS, Legacy PUD, Turkey Hill Minit Market and Docket No. 10110013
ZW, Legacy PUD, were referred to the Special Studies Committee meeting on July 05, 2011 at 6:00 PM
in the Caucus Rooms of City Hall.
I. Old Business
1. Docket No. 11020013 DP /ADLS: Woodland Terrace CCRC.
The applicant seeks site plan design approval for a continuing care retirement community
(CCRC) on 7 acres. The application also seeks the following zoning waiver request:
2. Docket No. 11030006 ZW: Ordinance Chapter 23.08.01.D: front building setback.
The site is located at 136` Street Smokey Row Rd.) and Pro Med Lane, and is zoned B-
6/Business, within the US 31/ Meridian Street Overlay. Filed by Charlie Frankenberger of
Nelson Frankenberger, on behalf of Justus Homes, Inc.
Present for Petitioner: Jim Shinaver, attorney, Nelson Frankenberger; Walt Justus, President, Justus
Companies; Consultant Chris White, Owner Site Solutions Group; Dan Weir, Architect; Jon
Dobosiewicz, Land Planner with Nelson Frankenberger; Rick Reynolds, Engineer.
Overview:
First Appeared April 19, 2011 for Public Hearing
Appeared before Subdivision Committee on May 04, 2011
Returning to Plan Commission with a favorable recommendation
Proposal complies with standards and requirements of the Zoning Ordinance
Proposal is for a new, high quality, state -of -the -art Senior Living Facility
Site is located at intersection of Smokey Row Road Pro -Med Lane— facility to be known as
Woodland Terrace
Parcel is zoned B -6 /Business, within the US 31 corridor Overlay
Proposed Facility classified as a Continuing Care Retirement Community (CCRC) as defined by
Carmel's Zoning Ordinance
Dept Staff has confirmed that the CCRC is a permitted use on the real estate
Levels of Service include:
1. Independent Living
2. Assisted Living
3. Skilled Nursing Care
All three levels of care will be available upon construction of first building phase —not phased in
Development Plan and ADLS request are fully detailed in informational brochures
Landscape plan for over -all site— reviewed approved by the Urban Forester
Landscape plan includes tree preservation /replacement
Justus has gone above beyond tree preservation /best management practices as well as maintaining
more than required by the US 31 Overlay regulations
Site contains 1.45 acres of tree preservation on overall 7 -acre site, approximately 20.5% tree preservation
Within a tree preservation area, 100% of all the trees are being preserved, regardless of diameter
Tree preservation area located along eastern portion of site, adjacent to Kensington neighborhood
has required buffer of 15 feet per zoning ordinance— however, prior zoning commitments dictate
a 50 -foot buffer in width and runs along the entire eastern portion of site
Second tree preservation area along Smokey Row Road existing and natural tree cover being
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preserved zoning ordinance requires 10 -foot buffer; Justus is proposing a tree preservation area
that will be between 20 feet and 40 feet along that segment of Smokey Row Road
Overall, site will contain 46.5% greenspace and planting areas which exceed Overlay
requirement of 35% landscaping for this project exceeds both planting requirements and
required bufferyard widths
Since the May 04 Committee meeting, Justus has agreed to add 24 additional trees along the
eastern edge of the buildings —along the western edge of the 50 -foot tree preservation area,
adjacent to the building
Justus is willing to re- locate the additional 24 trees from the edge of the building to place them
still within the 50 -foot bufferyard area -but closer to the adjacent residences of Kensington,
perhaps 3 trees per adjacent lot. Note: Justus is not required to plant the additional 24 trees, and
not required to disperse them in the manner explained, but they are willing to do that in order to
provide more effective screening to the adjacent neighborhood
In 1997 when the property was platted, provision was made for a 40 -foot front yard bldg setback
along Smokey Row Road
The Zoning Ordinance may require a 60 -foot front yard setback along Smokey Row Road
The Justus Company is asking for a reduction of less than 35% in the front yard bldg setback so
that the 40 -foot bldg setback that was established by the prior plat can be maintained
Without the requested zoning waiver approval, the bldg would have to be pushed back another
30 feet or so from Smokey Row Road
Allowing the zoning waiver will allow greater setbacks along the east for the bldg and also
allows the additional landscaping
Underlying zoning for this site allows a bldg of 100 feet in height; prior rezone approval contains
a commitment that bldg height will not exceed 50 feet
This building does comply with the height requirements of the Zoning Ordinance
Per suggestions of the Dept, the petitioner has reduced the parapet wall of the east elevation of
bldg (facing Kensington)
The re- design of the wall screen will still allow effective screening of roof mounted equipment
As previously stated, the height, the scale, and floor area ratio conform to the requirements of the
zoning ordinance
Shifting the bldg closer to Pro -Med Drive would disrupt the parking configuration and would
also affect the setbacks the bldg would not be in compliance with zoning requirements and
would necessitate discretionary approval thru the BZA process regarding variances
Justus has agreed to construct the remainder of the path along Smokey Row Road, down to Old
Meridian Street and provide a continuous connection from Woodland Terrace as well as pathway
entrance to Meadow Lark Park
This project is in compliance with Zoning Ordinance Standards
The petitioner requested a vote on the zoning waiver first
Dept Report concludes by saying that in their professional opinion, the proposal meets the
requirements of the zoning ordinance Dept Staff recommends approval of DP /ADLS petition,
subject to Engineering Dept's final approval of construction documents
Dept Report, Angie Conn:
As stated, petitioner has made additional changes to project after Committee review
Dept thinks the project meets quantitative requirements of Zoning Ordinance
Dept recommends approval conditioned upon Engineering Dept approval of final construction
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documents stormwater plan
Subdivision Committee Report, Brad Grabow:
Petitioner adequately characterized deliberation discussion points
Committee validated, confirmed, tested numerous aspects of compliance of petition with
applicable portions of the ordinance
Committee discussions covered quantitative standards build -to line, required buffer width vs
proposed buffer width, bldg height vs 50 -foot height limit, bldg coverage, bldg separation, traffic,
parking in each case the conclusion was that the quantitative aspects have been complied with
or exceeded
Also discussed was a CCRC from a zoning standpoint or permitted use this project, as a
CCRC, can be deliberated from two perspectives: Is this a CCRC? The relevant question is: "Is
this a CCRC as defined in the zoning ordinance
City definition of a CCRC is less restrictive than that of the State or what one might think of in
terms of a CCRC
In the City definition, the conclusion is that as proposed, the petition meets that standard
Ultimate Vote from Committee was to return this Docket to Commission with a 3 -1 favorable
recommendation
Commission Member Comments:
Extremely important for community to provide care for seniors in Carmel
Concerns with proposal: Proposal has more in common with a multiple family dwelling than a
CCRC; Engineering activities currently under way regarding drainage stormwater need to be
completed; it is understood that the petitioner does meet the quantitative requirements
concern is how adequately proposal actually meets qualitative requirements; there are still
issues that need to be worked out, particularly construction of a 50 foot tall bldg less than 90
feet away from residential homes already 20 feet below grade level; urges further work before
moving ahead
Project complies by the numbers, but some aspects of zoning ordinance not well- suited to this
property. Standards exist elsewhere in the Overlay that do not apply in this area but probably
should. Legally, the petition as it stands now complies with'those standards, but if we look only
a half mile south in the Overlay and see a bldg height restriction limited to 40 feet of distance
between non residential use and residential use, and this petition where the bldg is only 65 feet
away from a residential use but 50 to 60 feet high we are talking about a 26 foot height Iimit
south of Main Street, but in this area a 50 foot height, and that does not seem to make sense.
There are different opinions regarding the traffic study: some say an earlier study will suffice
because it was based on assumption that were more aggressive than current proposal; time has
passed there are questions as to whether or not the study was even done at an appropriate
time, considering the traffic flow thru this area. New "hybrid" information has been received
from ITE trade assoc in Washington which shows data for CCRC's and implies that based on 9
CCRC's nationally, the average peak travel times or trips would be Iess than that of an office
bldg previously proposed by petitioner but that is based on a different definition of a CCRC
and may not be a fair comparison. A new traffic study may be warranted in this case we
would all benefit from further information. Tree protection best practices talk about putting
construction fences up at drip line, but in this case, one of the TPA's at the south end of the
property is right at the edge of development; the TPA on the east side of this property is only 15
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feet away —the bldg is only 15 feet away from the TPA and does not leave enough room for the
roots of the trees and still be compatible for construction of the foundation
Parking complies with the ordinance, but with high use of outside service providers as
described by the petitioner, our current ordinance is based on the number of beds and units and
employees, any outside contractors or service providers would not be covered under the current
parking provision standards
There is a lot of gap to be closed between the neighbors and the petitioner there is still work
to be done
A positive move might be to refer this back to Committee for additional work
Additional Questions:
1. Is underground parking feasible?
2. Parking garages: a single structure with an overhead door an asset or a liability?
3. Multi -use path: Has petitioner actually obtained the easement to construct the path? The intent is
honorable, but does the petitioner have the right to do so?
4. Tree Preservation does that mean existing "specimen" trees, if damaged, there is a replacement
policy that goes along with tree preservation?
5. Levels of care described as three impression is that there was more independent living with
supplemental, rehabilitation services. If there are three levels of care, how does that break out in terms
of what is required parking? Can we relieve the petitioner of some parking? Is "land- banking" an
alternative in respect to how the building is positioned on the site today?
Motion: Sue Westermeier to return Docket Nos. 11020013 DP /ADLS and 110300006 ZW, Woodland
Terrace CCRC to Subdivision Committee for further review on July 05, 2011, seconded by Woody
Rider, Motion Approved 9 -0.
J. New Business
Judy Hagan requested the status of the Monon Overlay Adoption
Judy Hagan also requested that the Urban Forester or someone in that Dept take a look at a
landscaping plan for the ponds to move the geese out. If edges of the pond are planted, the geese
will go away ducks are fine
Judy Hagan asked that the CCRC stay on the list of definitions to be refined.
Jay Dorman asked that the Subdivision Committee work on tightening the CCRC Ordinance in
conjunction with Dept Staff
K. Adjournment 7:50 PM
.Jay Dorman, President
(69 L
R. mona Hancock, Secretary
//-Aft) 44 00/2.60 r0A-".*
PAO O"
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