Loading...
HearingExaminerDecision.pdf 1 2 3 /L— hC 95ahb5{ 4 th 121 5 Avenue North, Edmonds WA 98020 www.edmondswa.gov 5 DEVELOPMENT SERVICES DEPARTMENT PLANNING DIVISION 6 7 8 BEFORE THE HEARING EXAMINER FOR THE CITY OF EDMONDS 9 Phil Olbrechts, Hearing Examiner 10 RE: Woodway Court II 11 FINDINGS OF FACT, CONCLUSIONS Preliminary Plat OF LAW AND FINAL DECISION 12 PLN20160023 13 INTRODUCTION 14 15 The applicant is proposing a five-lot preliminary plat for a 54,913sf (1.26 acres) property in the RS-8 zone located at 23800 104th Avenue West into five lots. The 16 proposed preliminary plat is approved subject to conditions. 17 ORAL TESTIMONY 18 19 Kernen Lien, Edmonds Senior Planner, summarized the staff report. He noted that for the alley on the south, the City Council adopted Resolution 1005 around the year 20 2000 limiting access to specified private lots, which is why access for the proposed subdivision is located to the north. The project site used to be part of a cemetery. It 21 s have some maintenance sheds. A 22 primary concern raised by neighbors was prohibiting access on the southern access, so staff have added a recommended condition of approval prohibiting access to the 23 alley to ensure that the requirements of Resolution 1005 are met. 24 Ryan McDuffie, applicant, affirmed there would be no access to the south. There is a tract dedicated to dealing with a potential asphalt encroachment. The applicant hopes 25 to just give the asphalt back to the City. Preliminary Plat p. 1 Findings, Conclusions and Decision Rob Nelson, neighbor, noted that there are numerous trees located in Tract999 and 1 they should be saved. The neighbors are agreeable with the dirt piles from the cemetery being removed from the project site. He is concerned that the removal of the 2 piles will direct water onto adjoining property. He noted that two years ago the City had to install sump systems to deal with runoff from new development. 3 want to see a stormwater problem happen again. In response to examiner questions, 4 have, including standing water. He is also concerned with rodent damage. He 5 ve any specific code provisions for rodent control. However, as a result of the Woodway Meadows preliminary plat approval he spent 6 six months getting rid of rats on his property. Woodway Highlands was the same thing. Rodent control should be done before clearing is undertaken. He would like to 7 see a fence placed on the south alley side of the project to prevent alley access. He 8 noted that another project had fencing on the property lines to prevent access. He wanted to know if the cemetery sheds at the project site contain any hazardous 9 materials. 10 Claude Tate, neighbor, noted he lives adjacent to proposed Lot No. 1. He noted that the project site is flat a 11 down the southern alley to the east identified by Mr. Nelson. 12 Sheila Nelson, neighbor, said she was told that meters would be placed along the 13 southern alley. She wanted to know if there were adequate easements for meter access. Also, when the vegetation on Woodway Meadows was cleared, there was an 14 influx of rats. Woodway Meadows was approved several years ago. The Meadows project also called drainage problems. 15 16 Eric Montgomery, neighbor, wanted to know if the south alley was 20 feet wide and also wanted to know if the meter readers would use the south alley. He was also 17 concerned about new adjoining homeowners looking into his home. Mr. Montgomery was also concerned about stormwater impacts. 18 Mr. Lien showed a Google Earth aerial photograph of the project site. Preliminary 19 plat approval has been granted for a nearby 4-eve 20 any work has been done yet. Woodway Highlands is located in the Town of Woodway to the west and was approved approximately in the year 2000. Woodway 21 Meadows was approved in the early 1970s and is also located to the west. The project water and sewer lines will be located in the alley to the south. Construction work will 22 have to be done in the southern alley that may involve some disruption to alley access. The recommended conditions of approval require notice to be provided to the 23 properties served by the alley before any construction work is done that may disrupt 24 access. The approximate location of water meters is depicted in the civil plans and the final location will be set during engineering review. The southern alley is a parcel 25 owned by the city and its 20 feet wide Preliminary Plat p. 2 Findings, Conclusions and Decision Jeanie McConnell, Edmonds Engineering Program Manager, noted that preliminary 1 stormwater design has been prepared according to City standards. Project site soils infiltrate well. The soils have an infiltration rate of 10 inches per hour but the 2 applicant has taken a conservative approach and designed its system for a rate of two inches per hour. She noted that code standards require that off-site stormwater flows 3 not be increased as a result of the project and that often off-site conditions are improved. In response to examiner questions, Ms. McConnell noted that current 4 stormwater standards do provide for better stormwater control than the regulations 5 that applied to the Woodway Meadows and Highlands projects Her experience with the current stormwater standards is that they improve upon pre-development off-site 6 stormwater impacts. 7 Mr. Lien noted that the height of the new homes are limited to a 25 foot height from 8 average grade. 9 In response to a question from the examiner asking if the applicant would have a problem with a condition requiring rodent control, Mr. McDuffie responded that he 10 if there was a rodent problem. to sustain rats under current conditions. The majority of trees in Tract 999 will be 11 removed to accommodate access improvements. There is an existing water main in 12 the southern alley and he believes the utility will be tapping meters into that line. Most likely the meters will be in Tract 998. In response to an examiner question about 13 placing a fence on the southern property line, Mr. McDuffie responded that a fence . 14 EXHIBITS 15 16 Ex. 1 Attachments 1-24 of the Staff Report 17 Ex. 2 Staff Report 18 FINDINGS OF FACT 19 Procedural: 20 1. Applicant/Owner. Preferred Funeral Services. 21 2. Hearing. The Hearing Examiner conducted a hearing on the application 22 on October 13, at 3:00 p.m. at the Edmonds Public Safety Complex in the Council Chambers. 23 24 Substantive: 25 3. Site/Proposal Description. The applicant is proposing a five-lot preliminary plat for a 54,913sf (1.26 acres) project site in the RS-8 zone located at th 23800 104th Avenue West into five lots. The subdivision will be accessed off 104 Preliminary Plat p. 3 Findings, Conclusions and Decision Avenue Westwith all of the houses in the development fronting a private access tract 1 (Tract 999). The subject property is relatively level. Over the years, the site has been used to stockpile dirt from cemetery operations. Three stock pile areas are identified 2 on the preliminary engineering plan in Attachment 4. These stockpiled areas of dirt are identified for removal. Most of the site is current covered in blackberries. The 3 survey (Exhibit 1, Attachment 3) identified 12 trees on the site and a hedge. All the trees and the hedge are located where the access road is proposed and thus will all be 4 removed. 5 The following table summarizes the dimensions of the proposed lots: 6 Required Proposed Proposed 7 1 Lot Area Gross Area Net Area (sq. ft.) (sq. ft.) 8 Lot 1 8,000 9,854 9,854 Lot 2 8,000 8,236 8,236 9 Lot 3 8,000 8,380 8,380 Lot 4 8,000 8,289 8,289 10 Lot 5 8,000 8,039 8,039 Tract 998 0 1,038 1,038 11 Tract 999 0 11,077 0 12 4. Characteristics of the Area. The site is located within a single-family residential neighborhood in southwest Edmonds. The subject property and the 13 surrounding area are zoned RS-8 (single-family residential; 8,000 square foot 14 minimum lot size). The subject property is part of the Restlawn Cemetery. Though no plots exist on the subject property, there are maintenance sheds for the Restlawn 15 Cemetery located on the property. Restlawn Cemetery is just north of the site. The surrounding area is developed with single-family residences. 16 17 5. Adverse Impacts. There are no significant adverse impacts created by the proposal. Impacts are more specifically addressed as follows: 18 A.Critical Areas. There are no shorelines or critical areas or buffers on or 19 affecting the subject site.. No adverse environmental impacts are anticipated. 20 B.Rodents. Evidence presented by neighboring property owners suggests the 21 presence of rats that must be mitigated by conditions of approval. Citizen comments from the adjoining Forest Glen neighborhood (Exhibit 1, 22 Attachment 23) and testimony from Rob Nelson and Sheila Nelson expressed concern that land clearing activities would result in an influx of rats to 23 adjacent properties, as has occasionally happened in the past with other developments. The applicant contends there is no habitat for rats on the 24 subject site, though no evidence exists as to whether rats do or do not live 25 within the brambles currently occupying the site. Since neighbors have raised a reasonable inference that rats may be present at the site and the applicant has not provided any compelling evidence to the contrary, a finding of no off-site impacts as required by subdivision criteria cannot be made absent a condition Preliminary Plat p. 4 Findings, Conclusions and Decision requiring assessment the presence of rats and extermination as necessary. As 1 conditioned, potential rat impacts are adequately addressed. 2 C.Alley Access. Forest Glen residents expressed several concerns related to the adjacent alley bordering the project to the south including the rights of access, 3 maintenance, an encroachment, and water meter locations. The concerns are related to whether the proposal will violate the restricted use of the alley, 4 which was limited by a City Council resolution. As conditioned, the proposal 5 will not expand the use of the southern alley beyond that intended by the City Council. 6 Specifically, the Forest Glen neighborhood (Ex. 1, Att. 23) noted City of 7 Edmonds Resolution No. 1005 (Ex. 1, Att. 24) limits the access to the private 8 alley and precludes use by the proposed lots. The Resolution does limit access to the lots as created at the time of the Resolution in 2000, however it permits 9 utility and emergency access. None of the proposed lots will take access from the alley. They will access Tract 999 on the north side of the development. 10 Construction access will primarily occur from the north, though utilities installation will occur in the alley. The applicant will provide an access 11 easement to the City for that portion of the alley that encroaches onto parcel 12 004527000000500, but the alley itself will not be widened. A condition of approval will require the applicant to record a note on the face of the plat 13 stating the access restrictions imposed by Resolution 1005. The conditions of preliminary plat approval also restrict access onto the southern alley, thus 14 ensuring that no driveways or other driveway connections will be made to the alley. 15 16 With respect to water meter locations, it appears likely that water meters will be accessed by public utilities from the southern alley since the water mains 17 serving the project site are located in or adjacent to the southern alley and the water meter locations are depicted near the alley in project civil plans. As 18 previously noted, Resolution No. 1005 has a provision allowing franchised utility companies to use the alley to maintain utility facilities and access them. 19 Given the small amount of traffic generated by meter readings, the current 20 existence of utility lines and the express authorization for utility use, there's no basis to require the meters to be relocated. A condition of preliminary plat 21 approval requires alley that may limit access. Any impact to the alley caused by the 22 development of the site will be repaired by the developer. 23 D.Grading. The grading of the proposal will not adversely affect adjoining uses. 24 The Forest Glen neighborhood (Ex.1, Att. 23) requested the applicant bring the finished grade to level with the cemetery and the adjacent alley on the 25 south side. As proposed, the grading of the proposal is consistent with City development standards and is appropriate for the project site. As determined below, the proposal will also not create any adverse stormwater impacts. Preliminary Plat p. 5 Findings, Conclusions and Decision Given these factors, it is determined that the proposed grading will not create 1 any significant adverse impacts. 2 Pertinent grading standards include ECDC 20.75.085.A.2, which requires proposals to minimize grading by using shared driveways and by relating 3 street, house site and lot placement to the existing topography. The Comprehensive Plan Vegetation and Wildlife Goals (B.4) similarly 4 encourages minimal grading. The proposal minimizes grading because all the 5 proposed residences will gain access via the proposed private drive shown as Tract 999 on the preliminary plat map, and the future home sites generally 6 conform to the existing topography. The proposal will remove the stockpiles of dirt on the subject but does not propose further extensive grading. The 7 grading plan is consistent with the subdivision approval requirements and the 8 Comprehensive Plan. 9 E.Views. The maximum height for a new house in the RS-8 zone is 25 feet from average original grade, which serves to minimize the negative impact to 10 existing views in the vicinity. Aside from the height limits, the Edmonds Community Development Code does not contain specific regulations 11 regarding private view protection within single-family zones so there is no 1 12 code authority to impose any additional view protections. 13 F.Hazardous Conditions. The staff report notes that there are no known hazardous conditions, such as flood plains, steep slopes, or unstable soil or 14 geologic conditions at the project site. At the hearing a neighbor questioned whether the maintenance sheds contained any hazardous substances, but there 15 is nothing to reasonably suggest that such materials would be present. Given 16 that there is no evidence to the contrary, the staff finding is taken as a verity. 17 6. Adequacy of Infrastructure and Public Services. As conditioned by this decision, adequate infrastructure will serve development as follows: 18 A.Drainage: Drainage will be adequately provided. The Forest Glen 19 neighborhood (Ex. 1, Att. 23) and testimony expressed concern regarding 20 drainage into the adjacent alley and neighboring properties. The drainage standards impose detailed requirements that mandate that the 21 development maintain pre-development off-site stormwater flow volumes and velocities (Chapter 18.30 ECDC). Consequently, no adverse impacts to 22 adjoining properties are anticipated. A preliminary drainage assessment, Ex. 23 1 Adverse impacts the severity of which are not subject to reasonable dispute, such as rat infestation, 24 can be addressed by general subdivision standards that require the mitigation of off-site impacts. In contrast, aesthetic and view impacts are highly subjective and can only be mitigated if there can be no 25 reasonable disagreement as to whether the impact is considered significantly adverse. Cf. Anderson v. Issaquah, 70 Wn. App. 64 (1993). No one can seriously dispute that a potential rat infestation is a significant adverse impact. There can be plenty of disagreement over whether view blockage caused by a 25 foot home is significantly adverse. Preliminary Plat p. 6 Findings, Conclusions and Decision 1, Att. 5,has been completed for the project andreviewed by engineering 1 staff. A storm system designed for the 50-year storm event (2% chance of occurrence in any given year) will be located in Tract 999. The emergency 2 overflow is not connected to any other storm system. Engineering will require the overflow to be moved further away from the property line during civil 3 review to provide the overflow opportunity to infiltrate preventing runoff from the development. 4 5 B.Transportation: All of the proposed lots will front the access Tract 999, which will not be a highway, arterial or collector street. Tract 999 will enter the site 6 th from 104 Avenue West which is a local street th Comprehensive Transportation Plan. With Tract 999 taking access from 104 7 Avenue West, and having all of the proposed residences fronting Tract 999, 8 transportation impacts are minimized. 9 C.Parks and Open Space: According to ECDC 20.75.090, before or concurrent with the approval of the final plat of any subdivision, the subdivider shall 10 dedicate land, pay a fee in-lieu of dedication, or do a combination of both, for park and recreational purposes. With the adoption of Ordinance 3934 in 2013, 11 park impacts are now addressed through the assessment of park impact fees in 12 accordance with Edmonds City Code (ECC) Chapter 3.36. No park dedication or fees are required with the subdivision. Park impact fees will be assessed 13 with issuance of the future building permits on the new lots consistent with ECC 3.36. 14 D.Water and Sewer: The Staff Report (Ex. 2) states water and sewer service 15 will be provided by Olympic View Water and Sewer. Olympic View Water 16 and Sewer District were notified of the development and certified capacity via the Edmonds Utility Consortium form. Olympic View Water and Sewer 17 District will also review the civil construction plans for the development. 18 E.Schools and Sidewalks: The proposal is served by adequate schools and has safe walking conditions to and from school. The subject parcel is primarily 19 served by three area schools: Sherwood Elementary, College Place Middle 20 School, and Edmonds Woodway High School. The site is within one mile of Sherwood Elementary which means it is not served by a school bus. The 21 Edmonds School District provides a suggested walking route north along 104th Avenue West to 106th Avenue West and Sherwood Elementary 22 (Attachment 23). Along this suggested walking route, there exists a wide shoulder which provides safe pedestrian travel to 106th Avenue West where a 23 sidewalk is present on the east side of the road to Sherwood Elementary. The 24 bus stop for College Place Middle school is located on the corner of 104th Avenue West and 237th Place SW with safe walking route along the shoulder 25 to the bus stop. The bus stop for Edmonds Woodway High School is located at Firdale Avenue and 100th Avenue West. The City of Edmonds recently Preliminary Plat p. 7 Findings, Conclusions and Decision installed sidewalks along 238th Street SW, so there is also a safe walking 1 route to the Edmonds Woodway High School bus stop. 2 CONCLUSIONS OF LAW 3 Procedural: 4 5 1.Authority of Hearing Examiner. ECDC 20.01.003 provides the Hearing Examiner with the authority to hold a hearing and issue a final decision on 6 preliminary subdivision applications, classifying them as Type III-B applications. 7 Substantive: 8 2. Zoning Designation. The subject property is zoned Single-Family 9 Residential (RS-8). 10 3. Review Criteria and Application. Chapter 20.75 ECDC governs the review criteria for subdivisions. Relevant criteria are quoted below and applied 11 through corresponding conclusions of law. 12 13 ECDC 20.75.085(A): Environmental. 14 1. Where environmental resources exist, such as trees, streams, ravines or wildlife 15 habitats, the proposal shall be designed to minimize significant adverse impacts to 16 the resources. Permanent restrictions may be imposed on the proposal to avoid impact. 17 18 2. The proposal shall be designed to minimize grading by using shared driveways and by relating street, house site and lot placement to the existing topography. 19 3. Where conditions exist which could be hazardous to the future residents of the 20 land to be divided, or to nearby residents or property, such as flood plains, steep 21 slopes or unstable soil or geologic conditions, a subdivision of the hazardous land shall be denied unless the condition can be permanently corrected, consistent with 22 paragraphs A(1) and (2) of this section. 23 4. The proposal shall be designed to minimize off-site impacts on drainage, views 24 and so forth. 25 4. The criterion is satisfied. As determined in Finding of Fact No. 5, as conditioned there are no significant adverse environmental impacts associated with the project and there are no environmental resources on or near the site. As noted above in Preliminary Plat p. 8 Findings, Conclusions and Decision Findingof Fact No. 3, all of the trees are located within the proposed road right of 1 way. Though the City promotes the retention of as many trees as practicable and encourages the location of building areas with the goal of retaining as many of the 2 trees as possible, the location of the road lines up with an access road from an earlier 3 short subdivision to the east. Resolution No. 1005 prohibits new access from the alley to the south, so there is no other feasible access for the property in order to save trees. 4 As further determined in Finding of Fact No. 5D, the proposal minimizes grading 5 through use of a shared private access tract to serve all proposed lots. As determined in Finding of Fact No. 5E and F, there are no adverse view impacts created by the 6 proposal and the project site has no hazardous conditions. A preliminary drainage plan 7 was submitted with the preliminary plat, Ex 1, Att. 5 and as determined in Finding of Fact No. 6 the proposed drainage facilities have been determined to be adequate. An 8 impact that is fairly unique to the project has been identified by neighbors as a 9 potential rat problem as determined in Finding of Fact No. 5. In order to minimize off-site impacts caused by the displacement of rats as required by ECDC 10 20.75.085(A)(4) above, a condition is added to this decision requiring the applicant to 11 hire an exterminator to assess the presence of rats and exterminate as needed. 12 ECDC 20.75.085(B): Lot and Street Layout. 13 1. Lots shall be designed to contain a usable building area. If the building area would be difficult to develop, the lot shall be redesigned or eliminated, unless 14 special conditions can be imposed on the approval which will ensure that the 15 lot is developed properly. 16 2. Lots shall not front on highways, arterials or collector streets unless there is 17 no other feasible access. Special access provisions, such as shared driveways, turnarounds or frontage streets may be required to minimize traffic hazards. 18 3. Each lot shall meet the applicable dimensional requirements of the zoning 19 ordinance. 20 4. Pedestrian walks or bicycle paths shall be provided to serve schools, parks, 21 public facilities, shorelines and streams where street access is not adequate. 22 5. The criterion quoted above is met. As determined in the staff report, all 23 proposed lots meet the dimensional requirements of the RS-8 zoning district. Each lot contains a buildable area as is readily evident from the plat map, Ex. 1, att. 3, 24 and the fact that the project site is flat without any environmental constraints. The 25 proposed lots do not front on any highways, arterials or collector streets. As noted in Finding of Fact No. 6, sidewalks and wide shoulders provide a continuous walking path from the proposed subdivision to Sherwoood Elementary and to bus Preliminary Plat p. 9 Findings, Conclusions and Decision stops for College Place Middle School and Edmonds Woodway Hight School.The 1 staff report private access road, however, the design drawings, Ex. 1, att. 4, do show a road 2 cross-section that appears to at least propose a five foot shoulder along the private 3 access road. 4 ECDC 20.75.085(C): Dedications. 5 1. The city council may require dedication of land in the proposed subdivision 6 for public use. 7 2. Only the city council may approve a dedication of park land to satisfy the requirements of ECDC 20.75.090. The council may request a review and written 8 recommendation from the planning advisory board. 9 3. Any approval of a subdivision shall be conditioned on appropriate dedication 10 of land for streets, including those on the official street map and the preliminary 11 plat. 12 6. Per the City Engineering Division requirements, Ex. 1, att. 11, no 13 dedications are required. 14 15 16 ECDC 20.75.085(D): Improvements. 17 1. Improvements which may be required, but are not limited to, streets, curbs, 18 pedestrian walks and bicycle paths, sidewalks, street landscaping, water lines, sewage systems, drainage systems and underground utilities. 19 2. The person or body approving a subdivision shall determine the improvements 20 necessary to meet the purposes and requirements of this chapter, and the requirements of: 21 a. ECDC Title 18, Public Works Requirements; 22 b. Chapter 19.75, Fire Code, as to fire hydrants, water supply and access. 23 24 This determination shall be based on the recommendations of the community development director, the public works director, and the fire chief. 25 7. The project has undergone extensive review by the community development director, the public works director (specifically engineering) and Fire Preliminary Plat p. 10 Findings, Conclusions and Decision District No. 1. The proposal providesfor adequate public infrastructure as determined 1 in FOF No. 6. Further, since RCW 58.17.110 mandates that preliminary short plats may not be approved absent a finding of adequate infrastructure, the criterion above is 2 broadly construed to require the findings required by RCW 58.17.110 and those 3 findings are made as detailed in FOF No. 6. 4 ECDC 20.75.085(E): Flood Plain Management. All subdivision proposals shall 5 comply with the criteria set forth in the Edmonds Community Development Code for flood plain management. 6 7 8. This project is not in a Flood Plain Management area. 8 DECISION 9 All subdivision criteria are met and the subdivision is approved as proposed in Ex. 1 10 att. 3 through 6 and as described in this decision, subject to the following conditions: 11 1.This application is subject to all applicable requirements contained in the 12 Edmonds Community Development Code (ECDC). It is the responsibility of the applicant to ensure compliance with all applicable requirements. 13 14 2.The applicant is responsible for obtaining all local, state, and/or federal permits or approvals applicable to the proposal. 15 3.The cemetery maintenance structures located on the property must be demolished 16 prior to submitting for final approval of the subdivision. 17 4.In accordance with Resolution No. 1005, none of the lots can provide access to 18 the alley on the south side of the subdivision. 19 5.The developer must provide notice to property owners that have access of the alley on the south side of the development at least one week prior to beginning 20 any work in the ally the would limit access to those properties. 21 6.Prior to recording, the applicant must complete the following requirements: 22 a.Civil plans must be approved prior to recording. In completing the civil 23 plans, the following must be addressed: 24 i. as 25 ii.Tract 999 shall be striped and/or signed no parking to provide fire access as determined by the fire marshal. Preliminary Plat p. 11 Findings, Conclusions and Decision 1 b.Make the following revisions to the plat: 2 i.Indicate the locations of all new easements, and provide easement descriptions and maintenance provisions for all new easements. 3 ii.If setbacks are to be included on the plat, confirm that setbacks are 4 shown consistently with Section II.E.3 of this report and add the 5 following statement to the face of the pl 6 iii.Indicate the gross and net areas of each lot on the final plat. 7 8 iv. certification, hold harmless agreement, Development Services and 9 10 v.Make sure all documents to be recorded meet the Snohomish 11 12 7.Submit an updated copy of the title report (plat certificate) with the documents proposed to be recorded. The title report must be prepared within 30 days of 13 submittal for final review. 14 8.Submit two copies of the documents to be recorded for the Planning Division and 15 recorded with the Snoho 16 9.After recording the plat, the applicant must complete the following: 17 a. 18 10.Prior to final plat approval, the applicant shall hire a rat exterminator to assess 19 whether rats are present at the site and to exterminate any rats found thereon. 20 11.The applicant must record a note on the face of the plat stating the access 21 restrictions imposed by Resolution 1005. 22 Dated this 27th day of October 2016. 23 24 25 City of Edmonds Hearing Examiner Preliminary Plat p. 12 Findings, Conclusions and Decision 1 2 Appeal Right and Valuation Notices 3 A party of record may submit a written appeal of a Type III-B decision such as this preliminary plat decision within 14 days of the date of issuance of the decision. The appeal 4 will be heard at a closed record review before the City Council according to the 5 requirements of ECDC Chapter 20.07. 6 Affected property owners may request a change in valuation for property tax purposes notwithstanding any program of revaluation. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Preliminary Plat p. 13 Findings, Conclusions and Decision