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HomeMy WebLinkAboutZMA199500004 Review Comments 1995-12-18 COUNTY OF ALBEMARLE OF A MEMORANDUM TO: Members of the Planning Commission FROM: Greg Kamptner, Assistant County Attorney DATE: December 18, 1995 RE: Comments on UREF Proffers Attached for your consideration is a copy of this office's comments on UREF's proffers. These comments were given to the Planning Department and to Steven Blaine, UREF's attorney, on Friday, December 15. The overwhelming majority of our comments merely request that the final version of the proffers be clarified. GK:res COUNTY OF ALBEMARLE gMilZt MEMORANDUM TO: Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning FROM: Greg Kamptner, Assistant County Attorney DATE: December 15, 1995 RE: Comments on UREF Proffers Please accept the following as this office's comments on the UREF proffers dated December 7, 1995. Our primary concerns are with the proffers pertaining to declaration of covenants, conditions and restrictions (Comments 7 through 14), the phasing of the project for determining the applicability of the road improvement proffers (Comments 24 through 31), and the proffer pertaining to the grade separated interchange (Comment 32). However, we have addressed other issues as well, including all of the preliminary comments contained in the memorandum to you dated December 11, 1995. Page references in this memorandum are to the 23 page working draft of the proffers revised December 7, 1995, that includes staff comments. 1. Introduction (Page 1): The text states that if the property is rezoned to PD-IP in "substantial accordance" with the rezoning application, the property will be developed in "substantial conformance" with the proffers and the zoning ordinance. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 2 • The applicant should clarify the meaning of "substantial accordance." In addition, since the rezoning includes the proffers (PD-IP and proffers), as the applicant revises these proffers the rezoning could be evolving away from what was proposed in the rezoning application. Thus, by revising the proffers the rezoning may be becoming not in "substantial accordance" with the application. • The applicant should clarify the second clause of the above statement, and clarify the meaning of "substantial conformance." As the statement now reads, the applicant is merely assuring that the property will be developed in "substantial conformance" with the proffers and the zoning ordinance. Because the proffers are part of the zoning applicable to the property, the applicant must comply with the proffers, recognizing that the proffers themselves may allow for some flexibility in their application. Likewise, the applicant may not merely "substantially" conform with the zoning ordinance; rather, the applicant must comply with the zoning ordinance. 2. Introduction (Page 1): The applicant states that if the rezoning application is denied or approved with conditions not agreed to by the applicant, the proffers shall immediately be null and void. • The applicant should recognize that the County may not impose conditions on the rezoning. The only conditions that may be a part of the rezoning are those that are voluntarily proffered. Thus, the only conditions that the County could impose that the applicant might not agree to would be those imposed pursuant to a subsequent special use permit. The applicant's statement would allow the property to be rezoned (removal of the proffers) automatically and unlawfully; property may be rezoned only by a legislative act of the Board of Supervisors. The applicant should clarify that the proffers are not conditioned upon agreement with conditions of a subsequent special use permit. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 3 3. Introduction (Page 1): The applicant states that the proffers will not be interpreted to authorize any person to vary from: (1) any State statutory, regulatory or code minimum standards; or (2) any County ordinance or regulation, except as permitted in the PD-IP zoning district. • The applicant should clarify what it means to not "vary" from minimum State law requirements. The language could be construed to supersede any proffer that is affected by State law. For example, in Proffer 2.3(a)(i), the design guidelines will set forth the types of materials to be used in the construction of buildings. Would the above statement supersede Proffer 2.3(a)(i) so that the types of building materials could not vary from the minimum building materials requirements of the Building Code? • The applicant should clarify what it means to not "vary" from a County ordinance or regulation. The language could be construed to supersede any proffer that requires more than what is already required under County ordinance or regulation. 4. Proffer 1.1 (Page 2): The applicant states that development of the property will be in general accordance with its zoning application plan. • The applicant should clarify the meaning of"general accordance." • The zoning application plan should be reexamined to confirm that there are no proffers that are inconsistent with the zoning application plan. 5. Proffer 1.1 (Page 2): The applicant states that plans or exhibits, if referenced in the proffers, are limited to the purpose for which they are submitted. • The applicant should clarify whether an "exhibit" is different from an "illustration," which is used in the prior sentence of the proffer. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 4 • The applicant should clarify what it means by the word "submitted." Note that the prior sentence in this proffer states that submitted plans and illustrations are deemed illustrative unless they are referenced in the proffers. Thus, the applicant should clarify the proffer so that "submitted" is replaced with "referenced in a proffer." • Without these clarifications, the last two sentences of Proffer 1.1 are circuitous: Plans or exhibits, if referenced in a proffer, are limited to the purpose for which they were submitted; plans or illustrations are illustrative only. The statements do not say what the effects of the plans, illustrations, or exhibits are if they are cited in a proffer. 6. Proffer 1.2 (Page 2): The applicant states that the project will be developed consistent with "applicable zoning and these Proffers" . . . by the submission of site development plans. • The applicable zoning and the proffers are not two separate things. If the rezoning is approved, the proffers are a part of the applicable zoning. • The applicant should clarify that site development plans need not only be submitted, but also approved. In addition, so that the statement is more complete, the applicant should also clarify the proffer to refer also to the subdivision ordinance. • The proffers do not provide for a timed phasing of the build out of the project. The phasing controls only road improvements (though other improvements are also contingent upon the road improvement phasing). 7. Proffer 2.1 (Page 3): The applicant states that a declaration will be recorded to run with the land that will provide for the coordinated development of the property in accordance with design and architectural guidelines. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 5 • The applicant should confirm whether "coordinated development" is synonymous with the requirement that the development "be planned and developed as a whole," as provided in section 8.3(a) of the zoning ordinance. • The applicant does not state when the declaration will be prepared and placed on the property. • Unless Proffers 2.2, 2.3, 2.4 and 2.5 are sufficient by themselves to assure that the development will be planned and developed as a whole, we question whether a rezoning to PD-IP is justified without knowing the contents of the declaration itself. • The applicant should clarify where the design guidelines will be. In Proffer 2.1, the applicant states that design and architectural guidelines will be incorporated by reference in the declaration. However, in Proffer 2.2 the applicant states that the declaration shall provide design and architectural guidelines, and in Proffer 2.3, the applicant lists certain elements of the design guidelines "that shall be set forth in the declaration." • The applicant should clarify whether Proffer 2.5, Maintenance of Common Areas, will be part of the declaration. It appears that Proffer 2.5 will not be part of the declaration. • The applicant should clarify whether the declaration providing for coordinated development will be subject to prior County approval so that the County is able to assure that the development will be planned and developed as a whole. 8. Proffer 2.1 (Page 3): The applicant states that the clear intent of the declaration will be that the County will have no rights or obligations to enforce the covenants, conditions and restrictions. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 6 • It should be noted, however, that this statement does not abridge the County's right to enforce any of the proffers, including Proffers 2.1, 2.2, 2.3, 2.4 and 2.5. 9. Proffer 2.1 (Page 3): The applicant states that the declaration shall not authorize any variance from State or County minimum standards, except as allowed in the PD-IP zoning district. • The applicant should clarify this statement because its plain meaning is that, if the declaration imposes standards greater than County minimum standards, County minimum standards must apply because "variance" from those standards is not allowed. • The applicant should clarify the last clause of this statement because it gives the mistaken impression that the PD-IP zoning district allows a development to avoid even minimum standards. Whatever standards exist in the PD-IP zoning district are, at the very least, minimum standards. Modifications are applicable only to the requirements set forth in section 8 (planned development districts -- generally) of the zoning ordinance. 10. Proffer 2.2(a) (Page 3): The applicant states that the declaration will provide for coordinated development of the property. • Because planning and developing the property as a whole is critical to the PD-IP zoning district, the applicant should clarify how the declaration will provide for the project being planned and developed as a whole. Does the "high quality architectural and landscape design and a harmonious, well-balanced" development referenced in Proffer 2.2(b) satisfy the "planned and developed as a whole" requirement? • If coordinated development is based on the fixed standards in Proffer 2.3, then Proffer 2.3 should be clarified to assure that there is, in fact coordination. For example, Proffer 2.3(a)(i) states that the declaration will set forth the types of materials to be Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 7 used in the construction of buildings. However, the proffer does not state that the declaration will limit the type of materials used and, therefore, it does not, in and of itself, assure that the project will be planned and developed as a whole. • If coordinated development is based on the design guidelines in Proffer 2.4, then the applicant should clarify Proffer 2.4 to explain how the development will be planned and developed as a whole. 11. Proffer 2.2(c) (Page 3): The applicant states that no hazardous materials, including medical wastes, will be disposed within the project. • By the applicant including this provision in the declaration, Proffer 2.1 precludes the County from enforcing it, unless it may be separately enforceable as a proffer (See Comment 8, above). 12. Proffer 2.5(b) (Page 4): The applicant states that the organization(s), if formed, will be bound by the declaration's covenants and restrictions. • The applicant should clarify this proffer to include not only covenants and restrictions, but also "conditions." 13. Proffer 2.5(c) (Page 4): The applicant states that it or the organization will provide a means for identifying common areas as to location, size and other elements in one or more restrictive covenants. The applicant also states that restrictive covenants pertaining to the common areas will run for a period of twenty-five years. • The applicant should clarify this proffer to eliminate any confusion that it might be construed to supersede the need to identify the location and size of common areas in a site development plan or a plat. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Feeler, Director of Planning December 15, 1995 Page 8 • The applicant should clarify the meaning of "provide a means for identifying common areas." • The applicant should clarify when the restrictive covenants will be recorded (e.g., within a certain period following approval by the County of the site development plan for that phase). 14. Proffer 2.5(d) (Page 4): The applicant states that nothing in the proffer prevents the organization from changing the status of open space from common to limited common areas as provided in the proffers. • The applicant should clarify what a "limited common area" is, or cross-reference to a specific section number of the proffer statement or the exhibit where the term is defined. • Although the proffer refers to changing the status of open space from common to limited common areas "as provided herein," it is unclear where in the proffer statement that provision is located. • The applicant should clarify whether the intent of this proffer is to create, within the requirements of the plan, a power in the organization(s) to change the status of open space in a manner not otherwise provided for in the zoning ordinance (e.g., by revising a site development plan or a plat). 15. Proffer 3.1 (Page 6): The applicant states that the calculation of the total gross floor area excludes, among other things, temporary office trailers and modular buildings. • The applicant should clarify whether the word "temporary" modifies both "office trailers" and "modular buildings." • The applicant should clarify the meaning of "temporary," or include a durational limit. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 9 • In reference to the 3,000,000 square feet of developed floor space, this proffer refers to "total gross floor area." Proffer 5.3 refers to "gross square footage." The applicant should use one term consistently, and the term should have a recognized meaning and method of calculation. 16. Proffer 4.1 (Page 7): The applicant states that the flood plain would be subject to County regulations. • The applicant should clarify whether the reference to "regulations" includes all applicable ordinances, or does it refer only to the special regulations contained in the zoning ordinance. 17. Proffer 4.2 (Page 7): The applicant states that it will implement in phases an overall stormwater management plan for the project, in general accordance with a stormwater management plan attached as an exhibit. • The applicant should clarify whether the phases for implementing the stormwater management plan are connected to the phased site development plans referenced in Proffer 1.2, or the phases that trigger road improvements referenced in Proffer 5.4, or some other mechanism. Since stormwater management is required as part of the site development plan process (section 32.7.4 of the zoning ordinance), the stormwater management plans would be reviewed and approved by the County as part of the site development plan process. • The applicant should clarify the meaning of "general accordance." At the very least, mandatory elements of the plan should be identified. 18. Proffer 4.3 (Page 7): The applicant states that wetlands will not be disturbed in the development of the project. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 10 • The applicant should clarify the meaning of "in the development of the project." This proffer may not restrict the applicant from disturbing the wetlands once the project is developed. 19. Proffer 4.4 (Page 7): The applicant states that no single facility may consume more than 125,000 gallons per day without a special use permit. • The applicant should clarify the meaning of "facility." • This proffer does not address the cumulative impacts of multiple "facilities" in the project that are, for example, just below the daily limit. • The applicant should clarify how daily water consumption will be determined. Specifically, the applicant should clarify whether daily consumption will be determined from an average over a period of time, or will be based on peak use (e.g., if the facility consumes 125,000 gallons per day one day per year, it would have to obtain a special use permit), or some other criteria. 20. Proffer 4.4 (Page 7): The applicant states that the design guidelines' design review process will include recommendations to users for water conservation techniques. • The applicant should consider moving this statement to a proffer pertaining to the design guidelines, such as Proffer 2.4. • The proffers pertaining to design guidelines do not specifically refer to a "design review process," though it appears that it will be an implementation of the design committee procedures referenced in Proffer 2.4(c). • This proffer does not require that water conservation techniques actually be implemented by any water user. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 11 21. Proffer 5.2(b) (Page 8): The applicant states that it will construct to VDOT standards a relevant portion of a road phase within six months of the issuance of certificates of occupancy for three users along such relevant portion of a road phase. • The applicant should clarify the meaning of "relevant portion." • This statement appears to be less than what is otherwise required by section 31.2.3 of the zoning ordinance, which requires that improvements be completed within one year, and gives the zoning administrator the authority to require improvements such as "safe and convenient access to public roads" prior to issuance of a certificate of occupancy. • Depending on the way the project builds out, years could pass before three certificates of occupancy are issued to uses along a "relevant portion" of a road phase. 22. Proffer 5.2(b) (Page 8): The applicant states that, anything to the contrary notwithstanding, the proffer to construct roads to VDOT standards shall not require completion of such roads before the issuance of a certificate of occupancy for a building served by that relevant portion of the road so long as adequate bonds are in place. • Given that this language appears to be contrary to section 31.2.3.1 of the zoning ordinance, the applicant should clarify the meaning of this statement. • The applicant should clarify the meaning of the phrase "anything to the contrary notwithstanding." 23. Proffer 5.3 (Pages 9-12): The applicant outlines the phasing of the development for triggering particular proffered road improvements. • As noted in Comment 15, Proffer 3.1 refers to "total gross floor area." This proffer refers to "gross square footage." The Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 12 applicant should use one term consistently, and the term should have a recognized meaning and method of calculation. 24. Proffer 5.4 (Page 12): The applicant states that it will design and construct offsite road improvements in phases. • The applicant should clarify whether it may proceed to the phase II development before the road improvements for phase I are completed. Language in Proffers 5.4(a) and (b) appear to allow the applicant to proceed to the next phase before the prior phase's improvements are required. For example, Proffer 5.4(a) states in part that applicant "shall be permitted to develop beyond total Phase I Density in advance of completing construction of the Phase I road improvements" if it is shown that LOS "D" is maintained at certain locations . 25. Proffer 5.4 (Page 12): The applicant states that, unless an earlier time is required, road improvements for each applicable phase will be completed or bonded, or contributed for, before issuance of certificates of occupancy for the building densities ceilings. • The applicant should clarify whether this statement applies to onsite road improvements, offsite road improvements or both. In context, and considering Proffer 5.2(b) (see Comments 21 and 22), this statement appears to refer to offsite road improvements only. • The applicant should clarify whether the "building densities ceilings" refers to any individual ceiling in the phasing tables or whether it refers to the cumulative ceiling for the particular phase. 26. Proffer 5.4(a) (Page 12): The applicant states that it will construct the phase I road improvements before achieving total phase I density or earlier if "specified below" or a need is created by such development and is demonstrated by a traffic analysis approved by VDOT. Wayne Cilimberg, Director, Department of Planning and Community Development Ron ICeeler, Director of Planning December 15, 1995 Page 13 • The applicant should clarify whether what is "specified below" is the traffic study referred to later in the proffer. (See the next bulleted comment.) The text that follows in the proffer refers only to the traffic analysis approved by VDOT. • The applicant should clarify whether the traffic analysis referred to in the statement above is also the "traffic study" referred to later in the proffer, i.e., the "traffic study approved by VDOT" pertaining to the Route 649/Road A, Route 606/Quail Run, Route 606/Route 649, and Road A/U.S. 29 intersections. • The proffer should clarify when the traffic analysis may be requested (e.g., at any time), by whom, and whether responsibility for the cost of the analysis will be borne by the applicant. 27. Proffer 5.4(a)(1)-(4) (Pages 13 and 14): The applicant lists the road improvements for phase I. • The applicant should consider reorganizing these subparagraphs so that they correspond to the order of the phase I improvements as listed on Exhibit 5.3. 28. Proffer 5.4(a)(4) (Page 13): The applicant states that it will make a prorata contribution or $100,000, whichever is less, upon completion of two left turn lanes at the U.S. 29/Route 649 intersection. The applicant later states that the prorata contribution may be used to fund a portion of the design and engineering costs in order to expedite the widening of Route 649, but only if the applicant is afforded the opportunity to participate in the design and engineering process. • The applicant should explain why it should be allowed to contribute less than its prorata share toward the improvements if that share would be greater than $100,000. • The applicant should clarify that if the prorata contribution is used to "expedite the widening of Route 649," that the applicant Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 14 will provide the contribution prior to completion of that project. The applicant should also clarify whether the prorata contribution to expedite the widening of Route 649 is also subject to the $100,000 cap. • The applicant should clarify whether the "building densities ceilings" refers to each individual ceiling in the phasing tables or whether it refers to the cumulative ceiling for the particular phase. 29. Proffer 5.4(b) (Page 14): The applicant states that it will construct the phase II road improvements before achieving total phase II density or earlier if "specified below" or a need is created by such development and is demonstrated by a traffic analysis approved by VDOT. • The applicant should clarify what is "specified below" because the only thing relevant "specified below" that follows in the proffer refers to the analysis approved by VDOT pertaining to the intersection of Route 649 and Road A. • The applicant should clarify whether the traffic analysis referred to in the statement above is also the traffic analysis pertaining to the intersection of Route 649 and Road A referred to in Proffer 5.4(b)(4). • The proffer should clarify when the traffic analysis may be requested (e.g., at any time), by whom, and whether responsibility for the cost of the analysis will be borne by the applicant. 30. Proffer 5.4(b)(1) (Page 14): The applicant states that it will construct a two-lane collector road extending from U.S. 29 to Route 649 through the project within six months of the issuance of the first occupancy permit for any building density within phase II. The applicant adds that this road will be widened to four lanes when traffic volumes create the need for such widening. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 15 • The applicant should clarify the language of the first sentence above, because it may be inconsistent with Proffer 5.2(b), which states in part: "Applicant shall construct to VDOT standards a relevant portion of a road phase within six months of the issuance of certificates of occupancy for three (3) users along such relevant portion of a road phase." (See Comment 21, above) • The applicant should change the term "occupancy permit" to "certificate of occupancy." • The applicant should clarify how it will be determined "when traffic volumes create the need for such widening," and who may make that determination. 31. Proffer 5.4(c) (Pages 14 and 15): The applicant states that it may develop the project through the total phase III density if certain conditions occur. • The applicant should clarify whether this statement means that the applicant may proceed to the phase III density without limitation if one of the conditions occurs. For example, if as provided in Proffer 5.4(c)(1), the applicant designs and constructs a third southbound lane on U.S. 29 from the entrance to the project at Road A to Route 649, may the applicant proceed to phase III density even though not all phase I and phase II road improvements are completed? • Are there any phase III road improvements that are critical to address project impacts at phase I or phase II density that would not be proffered if phase III density is not reached? 32. Proffer 5.4(d) (Page 15): The applicant states that it will dedicate an area for construction of a grade separated interchange, but this is conditioned upon other adjoining landowners (with land that is necessary for such interchange) contributing their prorata share of land for such interchange, as needed. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 16 • The applicant should clarify whether this means that all other adjoining landowners must contribute. • The applicant should also clarify what it means to contribute a prorata share. Specifically, the applicant should clarify whether this language means that if any adjoining landowner does not "contribute" the land, but sells it, or fails to contribute a "prorata share," that the proffer is a nullity. • The applicant should explain the criteria that will be used to determine a "prorata share." If a separated grade interchange is required, the amount of land VDOT will acquire from a particular landowner will depend on the location of the interchange. • The November 14, 1995 proffers reserved an amount of land for twenty years for a grade separated interchange. This reservation is no longer proffered. 33. Proffer 6.1 (Page 17): The applicant states that the active recreation and picnic areas will follow the phasing schedule of the offsite road improvements. • The applicant should clarify when, within a phase, the recreation and picnic areas would be constructed. For example, during the second phase, would the second phase recreation improvements be constructed at the beginning of the phase, be phased in proportionally to the second phase build out, be constructed at the end of the second phase build out, or would they be constructed according some other schedule? • If the project never reaches phase III (for road improvement purposes), then those recreation and picnic areas designated for phase III will not be built. 34. Proffer 6.1 (Page 17): The applicant states that it will convey the developed recreational areas to the County if the County so requests. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 17 • The applicant should clarify whether "convey" means a gift, or a conveyance upon payment of full market value of the property, or something else. 35. Proffer 6.1 (Page 17): The applicant states that active recreation areas will not be lighted with stadium lighting. • The applicant should clarify the meaning of "stadium lighting." 36. Proffer 6.2 (Page 17): The applicant states that it will restrict development of areas not shown as development parcels on the open space system phasing plan, subject to boundary adjustment during the project build out. • The applicant should clarify whether the phrase "boundary adjustment during the project buildout" means anything other than acknowledgment that boundaries will be established by plat, and that the boundaries shown on the plat may be adjusted from those shown on the open space system phasing plan. • The applicant should clarify whether there is a limit to the extent that a boundary may be adjusted on the plat from that shown on the open space system phasing plan (regardless of the fact that the applicant has proffered that the open space will be at least 200 acres of the project). 37. Proffer 6.3 (Page 18): The applicant states that the green belt will remain in its natural state, except for some specified improvements. • The applicant should clarify whether "natural state" has a meaning that is different from the term "undeveloped" used in Proffer 6.2. The allowed improvements are generally the same (the difference being that common area amenities will be allowed in open space). Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 18 38. Proffer 6.3 (Page 18): The applicant states that at such time the County decides to establish along the Rivanna River a public area or park, and upon request by the County, the applicant will convey the green belt to the County. • The applicant should clarify whether it will convey the green belt to the County if the County decides to establish a public area or park at any location along the Rivanna River within the County, or only if it decides to establish a public area or park on that portion of the river located on the project. • The applicant should clarify whether "convey" means a gift, or a conveyance upon payment of full market value of the property, or something else. 39. Proffer 6.4 (Page 18): The applicant states that it will develop within one year a preservation plan. • The applicant should clarify whether this plan is subject to County review and approval. • The applicant should clarify the meaning of"develop within one year." The applicant should clarify whether the phrase means that it will develop the plan within one year of the proffer taking effect, or whether it means only that the plan will be completed within one year development of the plan begins. 40. Proffer 7.1 (Page 19): The applicant states that it will landscape the streets in accordance with the standards in a street tree master plan for phase I. • The applicant should clarify that these standards will apply to all phases, not only phase I. • Section 32.7.9.6 of the zoning ordinance requires the planting of street trees as part of the site development plan approval process, and would be required at that time, and not according to the road improvement phases. Wayne Cilimberg, Director, Department of Planning and Community Development Ron Keeler, Director of Planning December 15, 1995 Page 19 • It is unclear whether the street tree master plan referenced in the proffer presently exists. 41. Proffer 8.1 (Page 20): The applicant states that its proffer to dedicate a site for the fire station is conditioned upon the design of the fire station meeting the project's design guidelines. • The applicant should clarify that the fire station will be subject to the project's design guidelines only if the fire station is built within the project. • The cost of compliance with the design guidelines could make the construction of a fire station within the project infeasible. 42. Proffer 10.1 (Page 22): The applicant states that the signatories are the only legal title owners of record. • Code of Virginia 15.1-492:1 requires that all owners sign the proffers, not just those "legal title owners of record." GK:res 95.599.001