HomeMy WebLinkAboutZMA202300001 Narrative 2023-02-21February 20, 2023
1193 Seminole Trail
Rezoning Application Narrative
ZMA 2023-
Project Description
RMD Properties, LLC (the "Applicant') is the owner of property located at 1193 Seminole Trail (State Route 29)
in the Rio Magisterial District. The Applicant wishes to develop the property as a mixed -use development, with
a small retail/commercial space and multi -family apartments (the 'Project'). The subject property is further
described below (the "Property"):
061WO-02-OA-00200 3.23 ac. RMD Properties, LLC
The Property is the southern -most County parcel on the east side of Route 29, abutting the boundary with the
City of Charlottesville, as shown below:
The Property currently contains a grocery store, and car repair shop, is zoned C1 Commercial, and is designated
on the Comprehensive Plan and the Places29 Master Plan for Urban Density Residential use. An area
comprising approximately 2.4 acres is designated for Neighborhood Service Center on the Places29 Master
Plan. The Applicant proposes to rezone the Property from C1 Commercial to Neighborhood Model District
("NMD") to develop a mixed -use building to include non-residential and multi -family apartments.
February 20, 2023
Surrounding Area
The surrounding area is comprised of a large variety of commercial, retail, and office uses. There is a proposed
Wawa gas station under construction to the north (adjacent to Greenbrier Drive); to the south is a City of
Charlottesville property which contains an existing restaurant, and the US Post Office is located just south of the
restaurant. To the east is a vacant lot proposed to be parking for the Virginia Institute of Autism which is located
across Hillsdale Drive. Across Route 29, to the west, is Seminole Place (the former Comdial building) which
houses a number of industrial and commercial businesses, as well as Albemarle County High School Center I.
Below is a map showing the Property and surrounding area.
Comprehensive Plan Land Use Designations
The Places29 Master Plan Future Land Use Map designates the Property for Urban Density Residential and
Urban Mixed Use, as part of a Neighborhood Service Center. The Property is outlined in yellow on the image
below of the Places29 Land Use Map. Urban Density Residential recommends 6-34 dwelling units per acre and
a maximum building height of 4 stories or 45 feet. Neighborhood Service Center recommends 3-20 dwelling
units per acre and a maximum building height of 3 stories.
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February 20, 2023
Application Plan
The proposed Application Plan prepared by Timmons Engineering, dated February 20, 2023 (the "Application
Plan"), and Code of Development dated February 20, 2023 are enclosed with this application. The Project
proposes a five -story building that contains approximately 10,000 square feet of non-residential space, and a
maximum of 290 multi -family residential dwelling units with structured parking and modern amenities. Proposed
amenities include a multi -use path across the frontage, modern amenities both inside and outside of the building,
a sidewalk/walking trail that will provide pedestrian connection from Route 29 to Hillsdale Drive, and a plaza area
outside of the retail/commercial space.
A main entrance on the northern -most side of the Property is proposed to be a shared entrance with the proposed
Wawa, and will be a right -in and right -out only entrance. On the southernmost portion of the Property, a right -in
only entrance is proposed. Additionally, an emergency connection to the rear of the property is proposed that
will connect to Hillsdale Drive that can also serve as a bike/pedestrian connection. Travelways and parking areas
will be privately owned and maintained, as is typical with all multi -family communities under single ownership.
The Project is located within the Albemarle County Service Authority jurisdictional service area and would thus
be served by public water and sewer, and a conceptual points of connection to existing water and sewer lines
are shown on the Application Plan.
Because Route 29 is a designated Entrance Corridor, the building design and materials, and other elements of
the Project such as plantings and signage will be subject to the jurisdiction of the Architectural Review Board. In
addition, the Code of Development contains architectural standards that provide for a variety of architectural
materials and elements that will create a cohesive appearance, and provide articulated features and details to
add visual interest and eliminate blank walls.
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February 20, 2023
Consistencv with the Comprehensive Plan
The Comprehensive Plan is a guiding document for growth, development, and investment in Albemarle County.
The Comprehensive Plan is a general guide and does not have the status of a zoning ordinance, which allows
flexibility in how it is interpreted. The Places29 Master Plan was developed and approved over 10 years ago and
is outdated in many respects. For instance, since the adoption of the Places29 Master Plan, the Rio29 Small
Area Plan and Rio29 Form Based Code ordinance were adopted which implemented a form -based approach
over density limitations. The Project is approximately a half mile south of the designated Rio29 Small Area
boundary.
As stated above and as shown on Tables LU-1 and LU-2 within the Places29 Master Plan, Urban Density
Residential recommends a maximum building height of 4 stories or 45 feet, and 6-34 dwelling units per acre,
and Neighborhood Service Center recommends a maximum building height of 3 stories and 3-20 dwelling units
per acre.
The Project contemplates a maximum of five (5) stories and 290 dwelling units, which equates to approximately
90 dwelling units per acre. This density is appropriate for this location adjacent to Route 29, which is a 10-lane
divided highway, and in close proximity to a large variety and number of retail, gas stations, offices, and
institutional uses (such as the High School Center I location across Route 29 at Seminole Place, the Virginia
Institute of Autism on Hillsdale Drive, and the Laurels of Charlottesville Skilled Nursing/Rehabilitation facility at
Greenbrier/Hillsdale intersection), among many other nearby destinations, services, and convenience areas.
As required by the Neighborhood Model District regulations, at least 20% of the project area will be set aside as
green space and amenity areas. While the precise amenities have not yet been determined, they will likely
include a playground/tot lot, pool and roof deck, fitness area, club room/lounge, and a plaza.
The Project would offer needed housing options for County residents and employees of nearby business and
employment centers that is close to public transit and community amenities, and would significantly contribute
to the urban redevelopment of the surrounding area as envisioned by the Rio29 Small Area Plan, including by
adding more residents who will support the implementation of the Rio29 Small Area Plan.
As noted above, the property is immediately adjacent to the City of Charlottesville, which recently adopted a new
Comprehensive Plan and land use designations. The property directly to the south of the Project is designated
within the Citv's Comprehensive Plan as Urban Mixed Use Node, which is described as "Urban mixed use
districts that support community housing, employment, and commercial development." This designation
recommends building heights of up to 10 stories.
The Project is consistent with many important elements of the Comprehensive Plan and Places29 Master Plan
including:
1. The proposed uses are consistent with the Places29 Master Plan designation of Urban Density
Residential and Urban Mixed Use (Neighborhood Service Center), in that the Project proposes a mix of
residential dwelling units and retail.
2. Neighborhood Model Principles (further discussed below): Pedestrian Orientation; Mixture of Uses;
Neighborhood Center; Interconnected Streets and Transportation Networks; Multi -modal Transportation
Opportunities; Relegated Parking; Redevelopment; Respect Terrain and Careful Grading and Re-
grading; Clear Boundaries with the Rural Area.
3. From the Growth Management Section of the Comprehensive Plan
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February 20, 2023
a. Objective 1, Strategy 1a: Continue to encourage approval of new development proposals in the
Development Areas as the designated location for new residential, commercial, industrial, and
mixed -use development.
4. From the Development Areas Section of the Comprehensive Plan:
a. Objective 2a: Continue to require and provide sidewalks and pedestrian paths in the Development
Areas.
b. Objective 2o: Promote redevelopment as a way to improve and take advantage of existing
investment in the Development Areas.
c. Objective 4: Use Development Area land efficiently to prevent premature expansion of the
Development areas.
d. Objective 5: Promote density within the Development Areas to help create new compact urban
places.
e. Objective 6: Promote infill and redevelopment that is compatible with surrounding neighborhoods
and uses.
5. From Housing Albemarle:
a. Objective 1: Increase the supply of housing to meet the diverse housing needs of current and
future Albemarle County residents.
i. Strategy 1a: Allow, encourage, and incentivize a variety of housing types (such as
bungalow courts, triplexes and fourplexes, accessory dwelling units, live/work units, tiny
homes, modular homes, and apartment buildings); close to job centers, public transit and
community amenities; and affordable for all income levels; and promote increased density
in the Development Areas.
There are many elements of the Comprehensive Plan that the Project is clearly consistent with, however, the
Project does have higher building height and residential density than is recommended by the Places29 Master
Plan. In order to obtain feedback regarding these issues, the Applicant worked with County staff, and a work
session with the Planning Commission was held on October 25, 2022. At that meeting the Planning Commission
stated their support for increased density and building height in this location, if designed well. In addition, a
number of Commissioners encouraged the Applicant to increase the density and height for the Project even
further, as well as to incorporate sustainable design elements. The Applicant evaluated the feedback from the
Planning Commission regarding increasing the density and height even more than currently proposed; however,
adding more density and height results in more units and more parking needed, and will tend to make the project
too large to be absorbed by the market in a reasonable timeframe, and too large to finance at reasonable terms
in the Applicant's opinion based on their experience with similar projects around the Country. Thus, while the
developer has proposed to increase the maximum number of units to 290 (from the 275 units discussed at the
Planning Commission work session) by increasing the number of single -occupancy units, additional building
height has not been incorporated into the Project at this time.
Impact on Public Facilities and Infrastructure:
Public Transportation Facilities:
Included with this Application is a Traffic Impact Analysis prepared by Timmons Group (the "Traffic Study").
Traffic counts were conducted on January 26, 2023. The Traffic Study is subject to review and comment by both
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February 20, 2023
the County and VDOT, and full details are included in the Traffic Study, but a summary of its key conclusions
are as follows:
With the project only in 2026, the Route 29/Greenbrier Drive intersection maintains similar levels of
service to background conditions and would not make the side streets worse. The queuing analysis
shows that all existing turn lanes are capable of managing the background volumes.
• While the turn lane analysis for both of the two proposed entrances shows that turn lanes are technically
warranted, for reasons stated in the Traffic Study, it does not recommend that such turn lanes be installed.
The required Access Management Exceptions for both proposed entrances are recommended.
Other Public Transportation and Multi -modal Infrastructure:
The Project proposes to replace the existing standard concrete sidewalk along the frontage of the Property with
a 10-foot wide multi -use asphalt path that will improve the existing pedestrian and bicycle infrastructure. This
new path will be further supported by a grass strip of land between the curb and the new path with a minimum
width of 6 feet, which will provide for an improved pedestrian and bicycling experience over the existing narrow
concrete sidewalk immediately adjacent to the curb (without a grass strip in between). In addition, bike racks and
internal bike and scooter storage are provided to allow for safe storage of the residents' bikes and scooters,
which will further support and enhance multi -modal transportation.
The Project also includes a shared entrance and connection to parcel 61 W-02-A-1 to the north with the proposed
Wawa gas station. A pedestrian access and emergency travelway is also provided that connects to Hillsdale
Drive that will allow residents of the Project to access the bus stop adjacent to the Virginia Institute of Autism on
Hillsdale Drive. These improvements will help create an interconnected network that further supports the existing
and enhanced multi -modal transportation opportunities and distributes impacts on the transportation network.
Schools:
School -aged children living at the Project will attend Woodbrook Elementary, Journey Middle School, and
Albemarle High School. The Project increases the existing inventory of residences in close proximity to existing
transportation networks, places of employment, educational facilities, and nearby services, all as consistent with
and recommended by the Comprehensive Plan, including expressly, the Places29 Master Plan and the newly
adopted Rio29 Small Area Plan. Most importantly, by providing residential units in the designated Development
Area, the Project helps to reduce pressure to subdivide Rural Area land for by -right residential lots, the latter
which is in direct conflict with the fundamental tenants of the Comprehensive Plan and the County's Growth
Management Policy, which is shown below:
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Growth Management
Objective l: Continue to consistently use the Growth Management Policy as the
basis on which to guide decisions on land use, capital expenditures, and service
provision.
Sbnfeuv la: Continue to encourage approval of new development proposals in the
Development Areas as the designated location for new residential, commercial, industrial, and
mixed -use development. Only approve new development proposals in the Rural Area that are
supported by Rural Area goals, objectives, and strategies.
St.ate,ov 161 To help promote the Development Areas as the most desirable place for growth,
continue to fund capital improvements and Infrastructure and provide a higher level of service
to the Development Areas.
Strateav ld Continue to recognize the shared responsibility between the County and new
development to pay for Infrastructure and improvements to the Development Areas to address
the impacts of new development
Below are the yield rates for the proposal using the "Subdivision Yield Analysis" dated August 23, 2021, which
was provided to by the school division:
School
Yield Rate
IApartment/Multi-family
Woodbrook Elementary
0.13
38
Journey Middle
0.06
17
Albemarle High
0.06
17
Total Units:
290
Total Potential Students:
73
Fire/Rescue/Safety:
This project will be served by the nearby Seminole Trail Volunteer Fire Station on Berkmar Drive, which
provides fire and rescue services to this area. The Project includes an emergency access connection from
Hillsdale Drive in addition to the main entrance from Route 29, which provides the two points of access
required by Fire/Rescue.
Public Parks:
The Project will include a variety of recreational amenity areas on site, which will likely include a roof -top amenity
space, tot lot, plaza, pool, fitness room, game room, club room, and workspace. Given this variety of high -quality
on -site amenities, we do not expect there to be a material impact on public parks.
Impacts on Environmental Features
As proposed, the Project does not create any detrimental impacts to any environmental features. There are no
preserved steep slopes on site. While there are managed slopes on the adjacent parcel where emergency
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February 20, 2023
access is proposed, the disturbance to these slopes will be minimal and will adhere to the applicable design
standards of the zoning ordinance. As noted on sheet C2.0 of the Application Plan, the preliminary stormwater
management calculations indicate that channel and flood protection requirements are met through the reduction
of impervious cover in the post -developed condition, but that if stormwater detention facilities become necessary,
that an underground storage facility will be utilized on site. Regardless, the Project will meet the requirements of
the County's Water Protection Ordinance and Department of Environmental Quality.
In addition, by proposing a dense, walkable multifamily community in the heart of the County's designated
development area, in walking and easy biking distance of a large and growing number of shops, services, and
employment areas, the Project will make it easier for residents to minimize or avoid the use of an automobile,
which can reduce traffic congestion and improve regional air quality. The U.S. Environmental Protection Agency
has studied this issue and issued a report entitled "Measuring the Air Quality and Transportation Impacts of Infill
Development, available at the link below.' The Executive Summary of the report includes the following
statements:
Many regions are struggling to balance transportation needs with community revitalization and
environmental protection. The potential for infill development to support all three goals is what
sets it apart as a unique strategy. While the positive impact of redevelopment projects may be
readily apparent at the community level, their regional transportation and air quality benefits can
be harder to quantify.
Fundamentally, well designed neighborhoods in more accessible places make walking, biking
and transit more convenient options. Therefore, policies that increase the amount of urban and
suburban infill development can help more people meet their everyday needs with less driving.
In turn, this can reduce traffic and contribute to better regional air quality. Fundamentally, well
designed neighborhoods in more accessible places make walking, biking and transit more
convenient options. Therefore, policies that increase the amount of urban and suburban infill
development can help more people meet their everyday needs with less driving. In turn, this can
reduce traffic and contribute to better regional air quality.
This aligns with the County's adopted Climate Action Plan. In October 2020, the County adopted the Climate
Action Plan that recommends a number of strategies and actions for renewable energy and other initiatives. The
Project will specifically contribute to the following strategies and actions contained in the Climate Action Plan:
Strategy: Increase opportunities for bicycling, walking, and other alternative forms of personal transportation for
daily travel.
Actions:
• Increase the extent of sidewalks, bike lanes, and shared -use paths in the County's Development Areas,
focusing on strategic, high -impact connections and filling gaps in existing networks.
• Improve the quality of bicycle and pedestrian infrastructure in the Development Areas to make it safer
and more comfortable for users.
Strategy: Through land use planning, provide an urban land -use pattern more conductive to sustainable local
and regional travel, and to protecting carbon sequestration in the Rural Area.
Actions:
• Incentivize denser and more mixed -use development patterns within the Development Areas, including
infill development within existing low -density areas and redevelopment of existing underutilized
commercial sites.
• Increase affordable housing options in areas served by a variety of transportation options.
httos://www.ela.2ov/smartgrowth/measurin¢ air-quality-and-transportation-impacts-infill-development
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Historic Resources:
There are no known historic resources on the Property.
Consistencv with the Neiahborhood Model Principles
Pedestrian Orientation. A concrete sidewalk already exists along the entire frontage of the Property adjacent to
the Entrance Corridor. The proposed multi -use path that would replace the existing concrete sidewalk along the
frontage of the Property will enhance the pedestrian orientation of the Project by widening it and providing a
grass strip at least six feet wide, between the path and the curb. The current concrete sidewalk is directly adjacent
to the curb, without a grass strip. Sidewalks will be located throughout the interior of the site as well, along
travelways and driveways, and sidewalk connections are provided from the site to the multi -use path in multiple
areas. These enhancements to the existing pedestrian network will provide residents with enhanced pedestrian
access to the nearby schools, library, shopping, and many other areas in and around the Route 29 area.
Mixture of Uses. The Project will include non-residential space that is likely to be general retail space, such that
the Project will be a mixed -use project that is fully compatible with this principle. Furthermore, as previously
stated, the surrounding area is comprised of a large variety of commercial, retail, institutional, and office uses.
There is a proposed Wawa gas station to the north (adjacent to Greenbrier Drive); to the south is a City of
Charlottesville property which contains an existing restaurant, and then the US Post Office just south of the
restaurant. To the east is a vacant lot proposed to be parking for the Virginia Institute of Autism which is located
across Hillsdale Drive. Across Route 29, to the west, is Seminole Place (the old Comdial building) which houses
a number of industrial and commercial businesses, as well as Albemarle County High School Center I. Within a
half mile of the Project is additional shopping and restaurants at Seminole Square Shopping Center, Stonefield,
and 291h Place. As shown by the future land use map in the Places29 Master Plan, the Property is designated
for urban density residential use to support an overall mixture of uses in and around the area. Whether
considered at the micro -level within the Project itself, or within the macro -level in the broader context of the
Project's proximity to these other mixed -use areas, the Project fully satisfies this principle.
Neighborhood Center. The Property is identified as a Neighborhood Service Center designation within the
Comprehensive Plan. The Project includes a retail/commercial space as well as a public plaza which will be
accessible from the proposed multi -use path. The Project is a part of a larger neighborhood that is oriented
toward, and complementary to other nearby Centers including 291h Place, Seminole Square Shopping Center,
and Stonefield, which each provide a large variety of services. Residents would be afforded many benefits by
this proximity with its own retail/commercial space, but also the proximity to these nearby Centers, some of which
are immediately adjacent, and others which are located approximately a half mile to a mile from the Property.
The Project would provide an extraordinarily convenient location for employees of the Virginia Institute of Autism,
the Pepsi Cola Bottling Plant, and Seminole Place (including teachers and staff for High School Center 1), among
many other nearby employers.
Transit is located along Hillsdale Drive to the east of the Project, and will be accessible by the proposed
emergency access/bike/ped connection. In addition, there are sidewalks and bike lanes along Hillsdale Drive.
Providing an emergency access/bike/pedestrian path that connects to Hillsdale Drive and the sidewalks and bike
lanes, enhances the accessibility of the residents to access these nearby Centers without using a car. The half -
mile (or less) distance from the Project to these other Centers is consistent with the Neighborhood Center
principle expressed in Strategy 2f (providing that a half mile is an appropriate distance between homes and a
Neighborhood Center when connected by transit). In light of the variety of on -site and adjacent or nearby
amenities and services, this principle is fully satisfied.
Mixture of Housing Types and Affordability. The Project is proposing multi -family housing type. While the
Neighborhood Model District requires a minimum of two housing types, a waiver has been requested with this
application given the variety of housing in the area. Within a one -quarter to one-half mile radius of the Project
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February 20, 2023
there are single family attached, senior and assisted living, and single family detached housing. It is appropriate
to consider the proposed housing type within the Project in the context of this surrounding development. The
Objective 2, Strategy 2g of Urban Development Areas provides that "(u)less a mixture of housing types
already exists in an area, new development proposals should offer a variety of housing types for different
income levels" (emphasis added). Providing multi -family homes in this location will allow for a variety of housing
types for the area, and when considered in the context for the large number of other housing types in the area,
the broad and fundamental purpose of this principle is met.
Furthermore, the Comprehensive Plan posits a strategy of ensuring that Development Areas provide a variety
of housing types, stating that "a full range of housing types creates choices for residents." A primary impetus for
housing type choice is housing affordability, which apartments are uniquely suited to satisfy. The Comprehensive
Plan also notes that "a mixture of housing types may not be necessary for infill development, depending on the
context and location." As the pie charts accompanying Strategy 2g in the Development Areas chapter and
Strategy 4a in the Housing chapter illustrates, the County has a very low stock of multifamily housing overall and
within the Development Areas specifically, being only four percent (4%) in both calculations:
Figure 9:
Dwelling Units in Development Areas Figure 3: Housing Types in Albemarle County
■SFO
■SFA/TH
■ MF/Condo
® ■MH
So .; AlbMmorM Cov,ty Community 0 ..4op 1 2013
■1 SFD
■2 SFA/TH
■3 MF/Carlo
■a MH
The Comprehensive Regional Housing Study and Needs Assessment published by The Central Virginia
Regional Housing Partnership of the Thomas Jefferson Planning District Commission reports that only three
percent (3%) of the land in Albemarle County is zoned for multifamily housing, while ninety-five percent (95%) is
zoned for single-family housing (Table 14. Residential Zoning by Jurisdiction, 2018). The report goes on to
explain that "(u)nder the goal of protecting single-family neighborhoods, such zoning restricts the opportunities
for multi -family housing and increases mufti -family land prices" (Id., p. 61).
In addition, the Applicant is proposing that 15% of the units constructed within the Project will be affordable for
ten years which will ensure a mix of housing affordability on site, which is the primary goal of this strategy of the
Neighborhood Model Principle. In high -cost areas such as Albemarle County, multifamily housing often provides
the best affordable option close to urban development where people work. For these reasons, we contend that
this principle is fully satisfied.
Interconnected Streets and Transportation Networks. The Project proposes its main entrance along Route 29
which will be a combined entrance with the proposed Wawa service station and convenience store. This will also
allow interconnectivity through the Wawa site out to Greenbrier Drive. Pedestrians and cyclists will have more
options when the Project is completed with its 10-foot multi -use asphalt path and grass strip that will replace the
existing narrow concrete sidewalk next to the curb, as well as the emergency access bike/ped connection to
Hillsdale Drive.
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February 20, 2023
Multi -Modal Transportation Opportunities. The application continues existing multi -model transportation
opportunities that would allow residents of the Project to access the Property by vehicle, on foot, by bicycle, or
by public transit with the existing transit stop along Hillsdale Drive. The Applicant's proposal to enhance the
pedestrian and bicycle infrastructure in the immediate vicinity by replacing the existing narrow sidewalk with a
10-foot wide asphalt multi -use path along the Project's frontage and providing a bike/ped connection to Hillsdale
Drive will further enhance multi -modal transportation opportunities and connections between the Project and the
numerous nearby centers and employment areas.
Parks, Recreational Amenities and Open Space. The Project proposes common recreational areas and other
amenities for residents that will likely include a roof -top amenity space, tot lot, plaza, pool, fitness room, game
room, club room, and workspace. The Applicant's proposed amenities will satisfy the requirements of the zoning
ordinance.
Buildings and Spaces of Human Scale. The proposed building is a total of five stories along the front with a small
inserted stepback and will include architectural features and detailing to add visual interest and eliminate blank
walls, which will support the principle of buildings of human scale. Although the proposed height of the building
is one story taller than the four stories recommended (but not required) by the Places29 Master Plan, it is
consistent with the feedback provided at the work session with the Planning Commission on October 25, 2022,
which not only stated clear support for the proposed five stories, but even stated clear support for considering
an even taller building at this location. Since the Project is located within an Entrance Corridor, it will be subject
to the design requirements and approval of the Architectural Review Board.
Relegated Parking. The parking for the Project will be contained within the building in a structured parking deck.
The design of the building will be such that the parking will be surrounded by residential units and/or the retail
and commercial space, and will not be visible from the surrounding streets. The Site Plan may contain some
short-term parking for prospective residents in the "circle" in the courtyard by the Lobby/Leasing Office, but such
spaces will be limited, and will nevertheless fully satisfy the principle of "relegated parking" given the courtyard's
location on the side of the building toward the rear of the parcel.
Redevelopment. This Project proposes an infill redevelopment of an existing underutilized site. The Property is
currently used for the C'ville Oriental Asian grocery store with a large expanse of parking surrounding the
building, as well as a U-Haul dealership and an automobile repair facility with large numbers of on -site vehicular
storage and vehicles awaiting repair. The redevelopment of the Property in this prime location will allow the
recommendations of the Places29 Master Plan to come to fruition, as well as providing much needed housing
near amenities, shopping, schools, and employment areas.
Respecting Terrain and Careful Grading and Re -grading. The Property is mostly a flat parking lot/storage area
with dilapidated buildings, and some grading will need to occur on the Property during construction. The
Application Plan accounts for managed slopes on the Property, and no preserved slopes are located within the
Property. The Applicant will obtain all required permits and approvals that may be needed to conduct grading on
the Property.
Clear Boundaries with the Rural Area. This principle is not applicable given the location of the Project which is
not adjacent to the Rural Area.
101834199.3
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