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HomeMy WebLinkAbout1998-03-10 Public hearingNOTICE OF PUBLIC HEARING Notice is hereby given that a public hearing will be held by the City Council of Iowa City, Iowa, at 7:00 p.m. on the 10th day of March, 1998, in the Civic Center Council Chambers, 410 E. Washington Street, Iowa City, Iowa; at which hearing the Council will consider the following: An ordinance amending Title 14, Chapter 6, "Zoning," Article E, "Commercial and Business Zones," Section 2, Neighborhood Commercial Zone (CN-1) regarding size restrictions on restaurants. 2. An ordinance amending the approved preliminary Sensitive Areas Development Plan for Lot 51 of Walden Hills, containing 2.9 acres and located within the OSA-8, Sensitive Areas Overlay Zone at the northeast corner of Shannon Drive and Irving Avenue. Copies of the proposed ordinances are on file for public examination in the office of the City Clerk, Civic Center, Iowa City, Iowa. Persons wishing to make their views known for Council consideration are encouraged to appear at the above-mentioned time and place. MARIAN K. KARR, CITY CLERK ppdadminlnph0223.doc Prepared by: Scott Kugler, Assoc. Planner 410 E. Washington Street, Iowa City, IA 52240; 319-356-5243 ORDINANCE NO. AN ORDINANCE AMENDING TITLE 14, CHAPTER 6, "ZONING," ARTICLE E, "COMMERCIAL AND BUSINESS ZONES," SECTION 2, "NEIGHBORHOOD COMMER- CIAL ZONE (CN-1)" REGARDING SIZE RESTRICTIONS ON RESTAURANTS. WHEREAS, the City established the CN-1, Neighborhood Commercial Zone, to encourage the establishment of small scale neighborhood oriented commercial uses within residential neighborhoods to help meet the day-to-day needs of neighborhood residents, and WHEREAS, in order to discourage the development of uses that are out of scale with adjacent residential neighborhoods, and to minimize potential negative impacts of commercial developments on their surrounding residential neighborhoods, the CN-1 zone regulations contain size limits on certain types of uses, including restaurants, and WHEREAS, currently, restaurants containing up to 2,500 square feet of gross floor area are permitted as provisional uses in the CN-'I zone, and those exceeding 2,500 square feet require approval of a special exception, and WHEREAS, the City Council has determined that the use of the current standard based on the gross floor area of the restaurant is not an appropriate method of measuring the scale or intensity of a restaurant use and whether it is appropriate for the CN-1 zone, but rather a standard based on the occupant load of the facility would be a better measure of the potential impact of the restaurant on the surrounding neighborhood. NOW, THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF IOWA CITY, IOWA: SECTION I. Title 14, Chapter 6, Zoning, Article E, Commercial and Business Zones, Section 2, Neighborhood Commercial Zone (CN-1), be amended as follows: Ordinance No. Page 2 a. Section 14-6E-2C, Provisional Uses, be amended as follows: 5. Restaurants, provided the floor area doos not oxcood two thousand fivo hundrod (2,500) squaro feot occupancy load does not exceed 100 for any one restaurant, and the total floor area allocated to restaurant use will not exceed twenty percent (20%) of the total existing or proposed commercial floor area in a CN-1 zone. b. Section 14-6E-2D, Special Exceptions, be amended as follows: 6. Restaurants that exceed two thousand five hundrod (2,500) squaro foot in floor aroa an occupancy load of 100, except the total floor area allocated to restaurant uses will not exceed twenty percent (20%) of the total existing or proposed commercial floor area in a CN-'I zone. SECTION II. REPEALER. All ordinances and pads of ordinances in conflict with the provisions of this Ordinance are hereby repealed. SECTION III. SEVERABILITY. If any section, provision or part of the Ordinance shall be adjudged to be invalid or unconstitutional, such adjudication shall not affect the validity of the Ordinance as a whole or any section, provision or pad thereof not adjudged invalid or unconsti- tutional. SECTION IV. EFFECTIVE DATE. This Ordi- nance shall be in effect after its final passage, approval and publication, as provided by law. Passed and approved this day of ,1998. MAYOR ATTEST: CITY CLERK Approved by City Attorney's Office ppdadmin~or(Acn 1 .doc City of Iowa City MEMORANDUM Date: February 27, 1998 (for March 5 meeting) To: Planning and Zoning Commission From: Scott Kugler, Associate Planner Re; Proposed CN-1 Zone Amendments Regarding Restaurants At the Commission's February 19 meeting, possible amendments to the CN-1 zone regulations regarding size limitations on restaurants were discussed. Attached please find a draft of an ordinance which was prepared based on the fourth option that was discussed in the February 13 memorandum. The ordinance would establish an upper threshold for restaurants permitted as provisional uses based on the occupancy load of the~facility, rather than on floor area. An occupancy load of between 85 and 100 persons is incorporated in the amendment. If this approach is pursued, the Commission and City Council should determine where the threshold should fall within this range. It is estimated that a typical 2,500 square foot restaurant would have an occupancy load of about 85 persons. This estimate increases to 100 persons for a 3,000 square foot restaurant. These are general estimates based on the information collected by staff regarding existing restaurants within Iowa City. The actual occupancy load for a restaurant would take into account the floor area dedicated to the various types of indoor spaces that make up the restaurant, as well as the type of seating being provided. The City Council has scheduled a public hearing on this item for its March 10 meeting. The Commission should be prepared to vote on this item at the March 5 meeting if possible. City of Iowa City MEMORANDUM Date: To: From: Re: February 13, 1998 (for February 19 meeting) Planning & Zoning Commission Scott Kugler, Associate Planner Proposed CN-1 Zone Amendment - Restaurant Floor Area Limitations City Council has requested that staff and the Commission review possible amendments to the provisions of the Neighborhood Commercial (CN-1) zone that deal with restaurants. This request is a result of a number of unsuccessful attempts that have been made to locate a restaurant within the CN-1 zone at Court Street and Scott Boulevard. A summarized history of past attempts to gain approval to construct the restaurant is provided below, followed by a number of options that could be pursued to address the concerns raised by Council. However, staff feels that it is appropriate to first discuss the intent of the CN-1 zone and how the current regulations regarding restaurants came about. The intent section of the CN-1 zone reads as follows: The Neighborhood Commercial Zone (CN-1) is intended to permit the development of retail sales and personal services required to meet the day-to-day needs of a fully developed residential neighborhood. Stores, businesses and offices in the Zone should be useful to the majority of the neighborhood residents, should be economically supportable by nearby population, and should not draw community- wide patronage. A grocery store or grocery store/drugstore combination is favored at the principal tenant in a Neighborhood Commercial Zone. In general, the CN-1 Zone is intended for the grouping of a grocery store and small retail businesses and office uses which are relatively nuisance-free to surrounding residences and which do not detract from the residential purpose and character of the surrounding neighborhood. The location and development of neighborhood commercial sites should follow the criteria set forth for such sites in the Comprehensive Plan, as amended. In the past, it was not uncommon for light commercial uses such as a family owned grocery store or a neighborhood tavern/restaurant to be found within residential neighborhoods. Examples in Iowa City include the former Seaton's store at the corner of Court Street and Muscatine Avenue, and former commercial buildings within the Northside and Goosetown neighborhoods, many of which have now been converted to residences. However, for much of this qentury there has been a concerted effort in most American cities to separate residential and commercial uses to the extent possible. This has occurred mainly as a result of the increased mobility of the general population since the advent of the automobile and the changing nature of commercial developments to accommodate customers in automobiles. As a result, commercial areas tend to be located such that 2 nearly every trip to the store must be made by car, thus increasing congestion on the cities' street systems. The CN-1 zone is intended to be a step in the opposite direction by providing small areas throughout the city where some of the shopping or service needs of residents of the surrounding neighborhood can be provided within walking distance or a short drive from their homes. The development of a CN-1 zone with neighborhood oriented uses is not expected to eliminate vehicular trips to regional commercial areas, but it is hoped that these trips will become less frequent if some of the neighborhood residents' needs are provided nearby. The danger in permitting commercial uses within residential neighborhoods is that they have the potential to draw additional traffic into the surrounding neighborhood and produce other negative impacts on nearby properties if the scale and nature of the commercial uses are not carefully managed. It is for this reason that the CN-1 zone includes limitations on the types and sizes of businesses that may locate there, and also contains design provisions aimed at integrating the commercial areas into the rest of the neighborhood. There are limitations on the number of parking spaces that can be provided for most uses, landscaping requirements, provisions to ensure pedestrian connections to the surrounding areas, and some building design guidelines, all of which are intended to result in an attractive, small scale appearance that will be compatible with the surrounding area. The very nature of the CN-1 zone and the population it is intended to serve almost requires that its development be delayed pending the development of the surrounding residential neighborhood. This requires patience on the part of the developer. An example is the Walden Square development on Mormon Trek Boulevard, which slowly developed over a number of years until the surrounding population grew to a level which could help support the types of businesses permitted in the CN-1 zone, along with business from through- traffic on Mormon Trek Boulevard. One of the reasons that the Scott Court CN-1 zone has not experienced the rapid development of neighborhood oriented uses is because only half of its immediate neighborhood market area is developed (generally the area west of Scott Boulevard). Unless a CN-1 zone is introduced into an existing neighborhood on an infill site, it is likely that there will be a delay before neighborhood oriented uses are attracted to the site. Otherwise, businesses locating there will have to rely on a much broader customer base and draw customers into the neighborhood from a wider region. Restaurants in the CN-1 Zone: Currently, the CN-1 zone allows restaurants of up to 2,500 square feet as provisional uses, meaning that they can be established upon administrative approval of a site plan and the issuance of a building permit, without any public review before a City board or commission. For restaurants containing more than 2,500 square feet, a special exception is required, which involves a public review of the plans by the Board of Adjustment. The Board can approve or deny the application based on general standards that deal with an application's potential impact on surrounding properties, and on an application's compliance with the Zoning Chapter. Restaurants with drive-thru or drive- up windows are not permitted. The current regulations were adopted in 1994 after being reviewed by the Commission and City Council. Prior to that time, all restaurants in the CN- 1 zone required a special exception regardless of their size. The changes were requested by a developer who felt that smaller restaurants would be consistent with the intent of the CN-1 zone and should be subject to less stringent review than larger restaurants. The 1994 change allowed for a more streamlined approval process for smaller scale restaurants. In researching the 1994 amendment, staff studied existing restaurants within the City and reviewed standards suggested in various planning and zoning publications to determine where the threshold should fall. The 2,500 square foot limitation was consistent with both sets of findings. In implementing the regulations, the size of the restaurant is based on the gross floor area of the building, which includes all of the facility, including the seating area, kitchen, and storage areas. Since that time, special exceptions have been approved to permit two 3,200 square foot restaurants within the Walden Square development and to allow a 3,376 square foot restaurant at 200 Scott Court. Two applications have been denied for restaurants of 4,000 and 4,666 square feet at 200 Scott Court. History of Attempts to Develop a Restaurant at 200 Scott Court: As mentioned above, Council's request to consider changes to the CN-1 zone regulations was driven by problems that a specific proposed restaurant has had in trying to locate within the Scott Court CN-1 zone. The proposed development of this restaurant has been the subject of three special exception applications before the Board of Adjustment, two of which were denied, and a failed attempt to obtain a building permit following the one Board approval for the restaurant. Since the Planning and Zoning Commission was not directly involved in these cases, a brief history is provided below. In 1995, an application was filed by John and Ada Streit for a special exception to allow a 4,000 square foot restaurant to be constructed on the property located at 200 Scott Court. The application was accompanied by a site plan which indicated that 46 parking spaces were to be provided, which exceeded the maximum number of parking spaces permitted for that use in the CN-1 zone. No building elevations were provided, as required. In addition, the site plan contained a number of deficiencies and did not comply with a number of Zoning Chapter provisions. Staff attempted to work with the applicants to design a scaled- back plan that was more consistent with the intent of the CN-1 zone, but the applicants chose to go forward with their original submittal. Staff recommended denial of the application based on the size and scale of the proposed use and its inconsistency with the intent and design provisions of the CN-1 zone, as well as the technical deficiencies contained on the site plan. The Board of Adjustment concurred with staff's assessment and denied the request. In 1996, an application was filed by Steve Kohli, who intended to be the lot owner and developer of the Streits' restaurant. The application was for a 3,376 square foot restaurant and a 35-space parking lot with 11 additional "landbanked" spaces which could have been added if it was demonstrated that they were needed after the facility was opened. Staff worked with the applicant to have the technical deficiencies with the site plan corrected, and recommended approval of the application subject to conditions. The Board of Adjustment approved the application with conditions as recommended by staff. In 1997, property owner Plum Grove Acres applied for a building permit to construct the restaurant. However, the plans included a 1,200+ square foot basement area, for a total of 4,576 square feet. Under the Zoning Chapter, the square footage of a use includes all space devoted to that use, including basements and additional stories. The Building Official was of the opinion that a few hundred square feet of basement floor area could be added for mechanical equipment such as a furnace or water heater, but the size being proposed would likely result in the restaurant use occupying a portion of the basement, such as 4 storage or office area. The applicant was unwilling to diminish the size of the basement to coincide with the accommodation proposed by the Building Official. Staff felt that the location of these components of the restaurant in the basement would result in more of the first floor of the restaurant being devoted to seating area. It appeared that what was requested was in excess of the size of the restaurant approved by the Board, and a building permit was not issued. Later in 1997, an application for a special exception for a 4,666 square foot restaurant was submitted by Hodge Construction Company on behalf of the Streits. This application was similar to the application previously approved, but included a 1,290 square foot basement. The Board denied this application based on the size and scale of the restaurant. Current Request/Options: Council is now requesting that staff and the Commission reassess the way restaurants are regulated in the CN-1 zone. All components of a restaurant are counted when determining the size of a restaurant, not just the seating area. The definition of floor area includes "[t]he total of all floors of a building . . ." and includes "[sipaces in the basement or cellar... if used for a principal or accessory use permitted in the zone in which the building is located." In the absence of a kitchen, food preparation area, or an area to store food, a seating area is not much of a restaurant. If in the case of the Streits' proposal much of the storage and office space was permitted to be located within a basement, the main level floor area available for seating would have been much larger and would have allowed a more intensive use of the property than originally contemplated when it was approved. Additional information has been collected on the size of existing Iowa City restaurants and is attached to this memorandum. Since the existence of basement storage areas was not investigated in 1994 when the restaurant size limitations were put in place, staff attempted to collect this information, as well as floor area and occupancy or number of seats, for a number of Iowa City restaurants. Of the 34 restaurants included, seven contained finished basement areas, four contained unfinished basement areas, and 23 contained no basements. It does not appear that the additional information on basements would have affected staff's recommendation in 1994 regarding the floor area threshold of 2,500 square feet. Staff's research of other ordinances and national planning publications conducted in 1994 suggested that there be a maximum floor area for a restaurant in a neighborhood commercial zone of 2,500 to 3,000 square feet, and the research on Iowa City restaurants suggested a similar figure. A decision was made to allow restaurants of 2,500 square feet by right, and allow the Board to approve larger restaurants on a case by case basis if it feels that they are appropriate for the CN-1 zone. Staff is unaware of any substantial changes recommended by national planning and zoning publications for restaurants in neighborhood commercial areas over the past few years. In general, the recommendation is aimed at limiting negative impacts on surrounding residential properties that can be generated by higher occupancy restaurants. Iowa City's CN-1 zone is a bit more flexible in that restaurants over the specified size are permitted by special exception rather than simply excluded from that zone. Listed below are a number of different options that have been identified for amending the CN-1 zone with regard to restaurants. Staff recommends that the Commission discuss the proper course of action at its February 19 meeting, after which it can review a specific ordinance with the proposed code changes being recommended, if any, at the March 5 meeting. Although all of the options could be pursued, if changes are to be made to the regulations staff feels that the fourth option is the most appropriate. Option One - No Change: Obviously, with this option the CN-1 zone regulations would not be changed, and the Streits could either scale back their plans to conform to the regulations, or find an alternative location within a more suitable commercial zone, such as the CC-2 or CH-1 zone. Option Two - Add Specific Criteria for Determining Appropriate Scale of Restaurant: This option involves adopting design and intensity of use standards for restaurants within the CN-1 zone, with drive-thru or drive-up windows still being prohibited. Depending on the nature of the design standards, this could ensure that a development is adequately screened and buffered from residential areas, is well designed and landscaped, and architecturally "fits" into the neighborhood in terms of appearance. Building size would likely be one of a number of factors considered. Others might include site design, size of the parking lot, a site's location within the neighborhood and its anticipated traffic impact, and the type of restaurant and its expected turnover of customers (i.e., fast food rs. full service). This option could involve retaining the threshold that separates those restaurants permitted as provisional uses and those requiring a special exception, or could be administered by staff, with appeals of the site plan process coming before the Commission. In the former case, the approval process would not change, but the criteria for evaluating a larger restaurant would be spelled out in the ordinance and available for potential applicants to review before submitting a special exception application. In the latter case, the standards would have to be written as objectively as possible if a staff review is to be effective. While the decision in either case would still be somewhat subjective, it would be clear to applicants what factors will be considered. If this type of review is conducted at the staff level, it should be subject to a major site plan review regardless of the size of the facility, rather than a minor site plan review (currently a commercial use under 10,000 square feet requires only a minor site plan review). The major site plan process allows for some notification of the neighborhood, and gives the applicant, the Building Official, and the owners of 20% of the surrounding property within 200 feet of the site an opportunity to seek a public review of the site plan before the Planning and Zoning Commission if they are not satisfied with the site plan or staff decision. This option would require additional staff time to draft a set of standards. Option Three - Increase Square Foot Requirement of Those Permitted By Right: If 2,500 square feet is felt to be too low of a figure for a restaurant within the CN-1 zone, it could be increased. However, staff is not comfortable arbitrarily choosing a number without some rational basis or research to substantiate it. Other communities, such as Pittsburgh, have higher limits within their neighborhood commercial zones of around 3,000 square feet. The Board of Adjustment has approved special exceptions to allow two 3,200 square foot restaurants within the Walden Square CN-1 zone and one of 3,376 on Scott Court. However, staff feels that it is not advisable to just put a figure in place that allows the establishment of a large restaurant with no public review or no additional criteria. 6 Option Four - Change the Way Scale of the Restaurant is Calculated: It has been suggested that one way to address the problem is to base the size limitations on the footprint of the building rather than the gross floor area. Staff does not feel that this is the best option since multiple-story restaurants and basement seating areas are permitted, if proper means of egress are provided to meet the building and fire codes. However, the idea of changing the way the size of a restaurant is measured to determine the intensity of use could be considered. The threshold could be changed such that the component of the use that is likely to have the greatest impact on the surrounding neighborhood, the seating area, is the primary means of determining the scale of the restaurant and whether or not it is appropriate for the CN-1 zone. If the restaurant regulations are to be amended, staff feels that this option is probably the one with the most potential. However, staff is unaware of other communities who have such a standard in place. Basing a standard strictly on the size of the seating area would be difficult, as this information is not readily available and would involve a somewhat time consuming task of analyzing approved building plans contained in the files of the Housing and Inspection Services Department. It would also not address differences in the types of seating being provided within the seating area. However, information on the occupancy load of existing restaurants is more readily available, as this needs to be determined in order to calculate the number of parking spaces required, size of the restroom facilities required, proper exiting requirements, etc. The calculation of a restaurant's occupancy load includes kitchen and storage areas, but these areas are included at a much lower ratio of persons to floor area than the public areas of a restaurant. The provision of additional square footage for storage, whether provided in a basement or on the main floor, would have a minimal impact on the occupancy of the building. In the case of the proposed 1,200 square foot basement at 200 Scott Court, the overall occupancy of the building would have increased by only 4 persons (one person per 300 square feet of storage area). If however, that 1,200 square feet of basement area were to result in a corresponding increase in the size of the seating area on the main floor, the increase in the occupancy load would be much greater (generally, one person per 15 square feet or 80). Using occupancy to establish a threshold would be more appropriate than size of seating area or floor area of the restaurant. For instance, the occupancy of a certain size seating area can vary by the type of seating being provided (booths vs. moveable tables and chairs, counter space, etc.). In addition, some restaurants with relatively little kitchen and storage space in relation to their seating areas might meet an overall floor area limitation, but result in a much more intensive use than others of the same size (China Buffet and Jimmy's Brick Oven Cafe on the attached table appear to have obtained a fairly high occupancy in relation to their floor area). To determine an appropriate occupancy limit for restaurants in the CN- 1 zone which roughly corresponds to the 2,500 square feet now permitted, some analysis of the information contained on the attached table is necessary. One approach might be to sort the restaurants into categories based on whether or not they seem appropriate for the CN-1 zone, and see if such a categorization suggests an appropriate occupancy level for a neighborhood commercial center restaurant. Another approach might be to come up with an estimate of the occupancy load of a typical 2,500 square foot restaurant, the figure currently being used, and establish the threshold in that manner. Both approaches are discussed below. In categorizing the restaurants found in the attached table, staff feels that the following restaurants might be considered to be appropriate for a neighborhood commercial zone: Floor Area Name Occupancy (including basement) Blimpie/Heyn's 98' 2974 Blimpie (Rochester) 32* 1000 Bruegger's 72 3000 Chill & Grill 43 2300 Cottage 90' 3160 Hamburg Inn 50 3200 Happy Joes 65 2212 Hungry Hobo 1 O0 3220 Linn St Care 70 1716 Quizno's 34* 1232 Sushi Po Po 63 1836 *Number of seats vs. occupancy load Note: Restaurants appearing on the attached table for which an occupancy load was not listed were excluded from this list, as well as fast food type restaurants which would typically be accompanied by a drive-thru service not permitted in the CN-1 zone. Most of these restaurants clearly meet the intent of the neighborhood commercial zone, although those with occupancy loads of 90 to 100 may be pushing the limit of what should be permitted in the CN-1 zone without the need for a special exception review. The figures suggest that an occupancy load of less than 100 be used as the threshold for requiring a special exception. Those with occupancy loads of over 100 seem to be more regional in nature and are perhaps more appropriate for different commercial zones, unless it can be demonstrated through the special exception review process that they will not have a substantial impact on the surrounding neighborhood and will be compatible with the neighborhood in terms of design and scale. In considering the second approach, staff divided the total occupancy of each restaurant listed in the attached table by the gross floor area of the facility, to determine how much floor area each contains per one unit of occupancy. In most cases, about 30 square feet of overall restaurant space is provided per one occupant, although this can fluctuate based on the amount of floor area devoted to kitchen and storage space. Both the mean and median of the resulting ratios also equals approximately 30. If this factor is applied to a 2,500 to 3,000 square foot restaurant, an occupancy load of between 83 and 100 persons is suggested as an appropriate CN-1 zone restaurant size. Both methods suggest a similar occupancy range for establishing a maximum restaurant size that should be permitted by right within the CN-1 zone. Similar to the existing regulations, this maximum threshold would be established for restaurants to be permitted as provisional uses, and those above this limit would be required to seek Board approval of a special exception. Such a standard would address the component of the restaurant that most closely reflects the degree of impact that it is likely to have on the surrounding neighborhood. The size of the kitchen or storage area is not nearly as relevant as the number of people that can be accommodated at the facility. Staff continues to recommend that no drive-thru or drive-up facilities be permitted in the CN-1 zone. One drawback associated with this option has to do with the amount of information that needs to be submitted by an applicant at the time of special exception review. Rather than submitting more general preliminary plans at the special exception stage, and spending the money to refine those plans only if the special exception is approved, and applicant must now have more detailed plans prepared prior to the special exception review to determine what the occupancy of a restaurant will be, at the risk of the plans not being approved by the Board of Adjustment. Summary: Changes are being suggested to the CNol regulations pertaining to restaurants because of difficulties that one developer has had in gaining approval for the construction of a restaurant at 200 Scott Court. Whatever course of action the Commission and City Council choose to take on this matter, staff recommends that the changes be well thought out and thoroughly examined to determine whether they are best for the CN-1 zone and the development of neighborhood oriented commercial centers. It is unwise to base a change in zoning regulations on a single proposal without closely considering the impact that change will have city-wide. ATTACHMENTS: 1. Iowa City Restaurants Characteristics List. Approved by: Robert Miklo, Senior Planner Department of Planning and Community Development 0 ~ 0 0 0 0 0 ZZ ~ Z ~$ 8 o$-~ o MICHAEL W. KENNEDY ~JOHN D. CRUISE STEVEN C. ANDERSON KIRSTEN H. FREY KANDIE K. BRISCOE KENNEDY, CRUISE, ANDERSON ~ FREY, L.L.P. LAWYERS 920 S. DUBUOUE STREET * P.O. BOX 2000 IOWA CITY, IOWA 52244 March 3, 1998 City Council Members City of Iowa City 410 East Washington Street Iowa City, IA 52240 AREA CODE tELEPHONE 351-8181 FAX 351-0605 OF COUNSEL. CHARLES A. BARKER Re: Proposed Amendment to the Ordinance Regarding Restaurants in the CN-1 Zone Dear Council Members: I represent Plum Grove Acres, Inc. It is my understanding that you have before you for your consideration proposed amend- ments to the CN-1 zone provisions of the zoning ordinance. I would like to talk to you briefly about these proposed amendments and the issue of restaurants in the CN-1 zone in general. It is my understanding that you have been presented with a proposed ordinance dealing with the appropriate size of restau- rants in this commercial neighborhood area. I would like to urge your favorable consideration of this proposed ordinance. In its report, the Iowa City Staff asked you to develop an ordinance that is well thought out and not merely designed to address the needs of one restaurant owner. At the same time, City Staff goes into great detail about the history of that one restaurant owner and his attempts to obtain a special exception to operate a res- taurant in a CN-1 zone in eastern Iowa City. I agree that the ordinance should be designed to meet the needs of the community as a whole and not the needs of the individual. However, the story of that one restaurant owner is a prime example of why this amendment to the ordinance is necessary. The City Staff report points out that in 1996, approval of a special exception was granted to Steve Kohli on behalf of John and Ada Streit for a restaurant with 3,376 square feet and a 35 space parking lot with eleven spaces land banked. When a build- Page -2- March 3, 1998 ing permit was sought on the project, the applicant was told that because there was a basement on the building plans, there was more than 3,376 square feet in the building and, as a result, the permit was denied. A new special exception request was filed which included the area of the basement in the square footage calculations. This request was denied, despite the fact that the number of tables in the proposed restaurant in both applications was the same. The restrictions on the CN-1 zone are designed to make sure that commercial uses within the area are consistent with the neighborhood feel of the area and are not too intensive for the surrounding residential property. In this case, the impact on the neighborhood between the applications had not changed at all. The foot print of the building was exactly the same; the number of parking spaces was exactly the same; and the number of tables was the same. The only difference was the inclusion of a non- public basement storage area and office space in the square foot- age calculations -! a change that has absolutely no impact on the surrounding neighborhood. As the attachment to this letter clearly points out, there are 72 units of apartments and townhouses to the north of the proposed site, 96 units to the south, 78 units to the west, and a possible 60 or more units to the east. The net result is that at least 548 people live within walking distance of the proposed restaurant. This is clearly a perfect location for a restaurant as anticipated by the commercial neighborhood zone. Given the goals of the CN-1 zone and the restrictions on the commercial uses therein, the use of an occupancy load requirement makes more sense than the use of a square footage requirement. The occupancy load tells us how many people the commercial use can accommodate, which is directly tied to the restaurant's im- pact on the neighborhood. The only real question is what occu- pancy limit should be established for those uses which do not re- quire a special exception. With respect to the proposed ordinance before you, I would like to point out a few things. First of all, in the Staff's re- port to the Planning and Zoning Commission, a copy of which has been presented to you, the Staff lays out 11 restaurants that it believes clearly meet the intent of the CN-1 zone. This memoran- dum, however, uses seating numbers for four of those restaurants rather than occupancy figures so the occupancy numbers in this chart are understated. Page -3- March 3, 1998 Second, City Staff points out that these 12 restaurants clearly meet the intent of the CN-1 zone and should therefore be used as references for determining what the appropriate limit on occupancy should be. The staff then goes on to state that those with high occupancy loads may be pushing the limit of the CN-1 zone. This statement clearly evidences faulty logic. The whole purpose for looking to these restaurants as benchmarks is to de- termine what the occupancy limit should be. One cannot say that they are perfect examples of CN-1 restaurants except for the fact that their occupancy levels are too high when the whole purpose of looking at the restaurants is to determine an appropriate oc- cupancy level. Furthermore, one restaurant that is located in the CN-1 zone has been left off this list. Jimmy's Brick Oven Caf~ has 3,126 square feet and has seating for 195 people. Its occupancy would be even higher. In light of the fact that this restaurant was approved in the CN-1 zone, it must be suited and appropriate for the zone. Thus, we believe the appropriate occupancy limit at or below which no special exception is required should be 130 per- sons. Finally, as long as you are considering whether or not to amend this ordinance, it seems to me as though you might as well correct other deficiencies in the existing ordinance at the same time. The ordinance currently limits the total floor space used by restaurants to 20% of the total commercial floor space in the CN-1 zone. Other sections of this ordinance have been amended to reflect the fact that this limitation is to "existing or pro- posed" commercial space. Without this amendment, the issue of what types of uses are acceptable in a CN-1 zone depends entirely upon building order. In summary, my client, Plum Grove Acres, Inc., respectfully requests that you pass this ordinance by changing the eligibility requirements to be based upon an occupancy load figure rather than a square footage figure and that you establish the maximum occupancy load at 130 persons. We are also requesting that you change the ordinance to include the word "existing or proposed" so that the second half of the ordinance will read as follows: "and the total floor area allocated to restaurant use will not exceed twenty percent (20%) of the existing or proposed total public commercial floor area in a CN-1 zone." I thank you for your time spent on this problem. I plan on attending the City Council session to discuss this issue with you in more detail and I will be available to answer your questions Page -4- March 3, 1998 at that time. eration. Once again, I thank you for your time and consid- KHF/kas cc: Bruce R. Glasgow John A. Streit kfS~\i62b594'~ Kirsten H. Frey ~ COURT HILL - SCOTT BOULEVARD PART IX The area in question is surrounded by several multi-family uses including: NORTH: 52 apartment units and 20 townhouses SOUTH: 72 apartment units and 22 townhouses WEST: 36 apartment units, 26 duplexes and 16 units in existing 4-plexes EAST: 7 vacant lots and 5 acres zoned for multi-family Thus, this restaurant site is currently surrounded by 246 existing apartments and townhouses and has the possibility of being surrounded by an additional 60 units. Assuming that there are two persons per dwelling unit, at least 548 persons would be within walking distance of the proposed restaurant site. kfS\o62b5948 NOTICE OF PUBLIC HEARING Notice is hereby given that a public hearing will be held by the City Council of Iowa City, Iowa, at 7:00 p.m. on the 10~h day of March, 1998, in the Civic Center Council Chambers, 410 E. Washington Street, Iowa City, Iowa; at which hearing the Council will consider the following: 1. An ordinance amending Title 14, Chapter 6, "Zoning," Article E, "Commercial and Business Zones," Section 2, Neighborhood Commercial Zone (CN-1) regarding size restrictions on restaurants. 2~',~ An ordinance amending the approved __ 2 preliminary Sensitive Areas Development Plan for Lot 51 of Walden Hills, containing 2.9 acres and located within the OSA-8, Sensitive Areas Overlay Zone at the northeast corner of Shannon Drive and Irving Avenue. Copies of the proposed ordinances are on file for public examination in the office of the City Clerk, Civic Center, Iowa City, Iowa. Persons wishing to make their views known for Council consideration are encouraged to appear at the above-mentioned time and place. MARIAN K. KARR, CITY CLERK ppdadm~nJn!~0223.doc Prepared by: Scott G. Kugler, Assoc. Planner, 410 E. Washington Street, Iowa City, IA 52240; 319-356-5243 ORDINANCE NO. ORDINANCE AMENDING THE ZONING CHAPTER BY CONDITIONALLY AMENDING THE USE REGULATIONS AND THE APPROVED PRELIMINARY SENSITIVE AREAS DEVELOPMENT PLAN FOR LOT 51 OF WALDEN HILLS, A 2.9 ACRE PROPERTY LOCATED IN THE SENSITIVE AREAS OVERLAY ZONE (OSA~) AT THE NORTHEAST CORNER OF SHANNON DRIVE AND IRVING AVENUE. WHEREAS, the applicant, Walden Wood Associates, II, LLC, has requested that the City rezone approximately 2.9 acres of property located at the northeast comer of Shannon Drive and Irving Avenue by amending the approved use regulations under the approved sensitive areas development plan for Lot 51 of Walden Hills; and WHEREAS, the proposed rezoning will allow alterations to the plan which will result in a lower density and an improved streetscape; and WHEREAS, Iowa Code ~j414.5 (1997) provides that the City of Iowa City may impose reasonable conditions on granting an applicant's rezoning request, over and above existing regulations, in order to satisfy public needs directly caused by the requested change; and WHEREAS, the applicant acknowledges and agrees that certain conditions and restrictions are reasonable to ensure that the proposed development will not negatively impact the existing residential neighborhood to the east, specifically by providing for adequate access to the proposed development and by addressing neighborhood compatibility through ensuring a development similar in appearence to that indicated on plans and elevations submitted by the applicant; and WHEREAS, the applicant has agreed to develop and use this property in accordance with the terms and conditions of a Conditional Zoning Agreement to ensure that access and neighborhood compatibility issues are appropriately addressed. NOW, THEREFORE, BE IT ORDAINED BY Ordinance No. Page 2 THE CITY COUNCIL OF THE CITY OF IOWA CITY, IOWA: SECTION I. APPROVAL. Subject to the terms and conditions of the Conditional Zoning Agreement attached hereto and incorporated by reference herein, the previously approved Sensitive Areas Development Plan for the following described property is hereby amended as depicted on the revised Sensitive Areas Development plan associated with this ordinance: Lot 51, Walden Hills, Iowa City, Iowa, in accordance with the recorded plat thereof. SFCTION II. TONING MAP. The Building Inspector is hereby authorized and directed to change the zoning map of the City of Iowa City, Iowa, to conform to this amendment upon the final passage, approval and publication of this Ordinance as provided by law. SI=CTION III. CONDITIONAL ?ONING AGRFEMFNT. Following final passage and approval of this Ordinance, the Mayor is hereby authorized and directed to sign, and the City Clerk to attest, the Conditional Zoning Agreement between the applicant and the City. SFCTION IV. CFRTIFICATION AND RFCORDING. After passage and approval of the Ordinance, and after execution of the Conditional Zoning Agreement, the City Clerk is hereby authorized and directed to certify a copy of this Ordinance and the Conditional Zoning Agreement for recordation in the Office of the County Recorder of Johnson County, Iowa, at the Applicant's expense, all as provided by law. SFCTION V. RFPFALI=R. All ordinances and parts of ordinances in conflict with the provisions of this Ordinance are hereby repealed. SFCTION VI. SFVI=RABILITY. If any section, provision or part of the Ordinance shall be adjudged to be invalid or unconstitutional, such adjudication shall not affect the validity of the Ordinance as a whole or any section, provision or part thereof not adjudged invalid or unconsti- tutional. SFCTION VII. FFFFCTIVF DATE. This Ordi- nance shall be in effect after its final passage, approval and publication, as provided by law. Passed and approved this day of ,1998. MAYOR ATTEST: CITY CLERK City of Iowa City MEMORANDUM Date: January 30, 1998 (for February 5 meeting) To: Planning and Zoning Commission From: Scott Kugler, Associate Planner Re: REZ97-0018/SUB97-0030. Lot 51, Walden Hills. Attached please find a copy of the most recent version of the revised preliminary sensitive areas development plan and preliminary plat for Lot 51 of Walden Hills. The most recent change involves the proposed subdivision of the lot into 25 small lots ranging in size from 2,589 square feet to 5,041 square feet, with the remaining 1.25 acres being designated as an outlot for open space and the private drives. A typical building lot would contain one dwelling unit, a driveway to an attached garage at the rear of the building, and side yards of 3.5 feet. The appearance of the development would be no different than the most recent proposal, which showed all of the units on one lot, but with an identical building arrangement. The subdivided lots would allow potential buyers more favorable finance terms in purchasing the units, according to the applicant. Staff recommended approval of the previous version of the plan. Staff feels that the proposed small lot concept is in line with the design guidelines contained within the Sensitive Areas Ordinance, as well as the Housing Goals and Strategies contained on page 45 of the Comprehensive Plan, encouraging smaller owner occupied houses on smaller lots. In addition, the proposal is consistent with the concepts presented in the Iowa City Community Housing Forum Report (December, 1997) regarding small lot zoning and reduced lot widths. While the recommendations contained in these documents generally suggest lots of 4,000 square feet, most of the proposed lots in this development contain less than 3,000 square feet. However, the gross area per dwelling unit for this development, including the shared open space of Outlot 51-A, is over 5,000 square feet. The individual lot lines could be redrawn such that most lots contain over 4,000 square feet by extending them farther back onto the property over the access drives and the outlot. The resulting development would be no different than that being proposed. The proposed lot lines seems to make it more clear that the open space on the outlot is to be shared by all, rather than split into separate ownerships. Because of the large common open space being provided, staff feels that the lot size, lot width, and setback reductions being requested are justified. Other Zoning Chapter compliance issues, such as parking and tree requirement. s, are adequately provided for on the plan. The City's tree regulations would not normally apply to single-family lots. However, staff feels that this is a planned residential development with multiple dwelling units regardless of how the lots are being split up, and that the tree requirements should be enforced as part of the development plan approval. The plan shows an adequate number of trees to meet the requirements of the Zoning Chapter. In terms of technical compliance with the City's subdivisions regulations, it appears that the plat is in conformance with the City's subdivision regulations, provided that the City agrees to the proposed lot size, lot width, and side yard reductions being proposed. There are some minor deficiencies that will need to be addressed, but it is anticipated that these items will be addressed prior to the February 5 meeting. Staff recommends that these items be addressed before the Commission votes on the plat. The Senior Building Official has noted that although the building separation distances are adequate, the amount of overhang on the units will be limited to six inches unless constructed of non-combustible materials. There is a six-foot separation required between the buildings, with an allowable one-foot projection into that area. However, another provision of the building code requires that any projections into the six-foot required area be of non-combustible materials. The buildings are proposed to be seven feet apart, which leaves six inches for an overhang for each building without encroaching into the six-foot required area. This may slightly impact the building elevations submitted for these units. Given the number of units contained within the overall subdivision, staff recommends that as a condition on the approval of the plat, that Shannon Drive be constructed from Rohret Road to its intersection with Irving Avenue prior to the development of any lot within this subdivision, and to the north property line of former lot 51 prior to the development of Lots 68-79. Staff feels that this is necessary to avoid excess traffic from this development utilizing the streets within the existing neighborhood to the east. Although some of the roads within Walden Hills have been constructed, the current street system would encourage the use of Coil Drive or other streets within the Walden Woods subdivision for access. Connecting Shannon Drive directly to Rohret Road would provide a more direct access to the proposed lots and help avoid additional traffic within Walden Woods. STAFF RECOMMENDATION: Staff recommends that REZ97-0018/SUB97-0030, a request for a revised preliminary sensitive areas development plan and preliminary plat of a Resubdivision of Lot 51, Walden Hills, a 2.9 acre, 25-1ot residential subdivision located at the northeast corner of Shannon Drive and Irving Avenue, be approved, subject to the construction of Shannon Drive from Rohret Road to its intersection with Irving Avenue prior to any development on Lots 55-79, and extended to the north in front of lots 68-79 prior to or concurrent with the development of said lots 68-79, subject to the appearance of the dwellings substantially conforming to the elevations and illustrations submitted by the applicant, and subject to approval of a revised grading plan prior to Council consideration. ATTACHMENTS: 1. Location map. 2. Preliminary plat and revised sensitive areas development plan. Approved by: Robert Miklo, Senior Planner Department of Planning and Community Development <C 0 0 City of Iowa City MEMORANDUM Date: To: From: Re: January 9, 1998 (for January 15 meeting) Planning & Zoning Commission Scott Kugler, Associate Planner REZ97-0018/SUB97-0030. Lot 51, Walden Hills At the December 18 meeting this item was deferred at the request of the applicant to allow it time to consider the possibility of subdividing this property into individual lots. Staff has received no revised plans or other information indicating the applicant's intent. As indicated at the December 18 meeting, the current plan on file is ready to be voted on and staff recommends approval of that plan if the applicant chooses to go forward with it. Please refer to the staff recommendation below in this instance. If the applicant intends to submit revised plans, staff recommends deferral to allow sufficient time for staff review. A waiver of the 45-day limitation period will be needed if this item is to be deferred again. STAFF RECOMMENDATION: Staff recommends that REZ97-0018/SUB97-0030, a request for a revised preliminary sensitive areas development plan and preliminary plat for Lot 51 of Walden Hills, a 2.9 acre, 25-unit development located at the northeast corner of Shannon Drive and Irving Avenue, be approved, subject to the construction of Shannon Drive to provide vehicular access to Rohret Road prior to the issuance of building permits for Lot 51, and subject to approval of a revised grading plan prior to Council consideration. Approved by: Robert Miklo, Senior Planner Department of Planning and Community Development City of Iowa City MEMORANDUM Date: To: From: Re: December 12, 1997 (for December 18 meeting) Planning and Zoning Commission Scott Kugler, Associate Planner REZ97-OO18/SUB97-0030. Lot 51, Walden Hills Attached please find a copy of the revised preliminary sensitive areas development plan and preliminary plat for Lot 51 of Walden Hills, as well as building elevations for the detached dwellings being proposed for the site. The plan now indicates that a total of 25 dwelling units are to be constructed along Shannon Drive and Irving Avenue. The four town house units previously proposed for the rear of the lot have been removed from the plan and replaced with an area of open space. The building elevations indicate that four different floor plans will be utilized in the development, each with three different facade treatments available. Although the plan does not indicate how the different types of units will be distributed on the site, it appears that there will be some variety within the streetscape, which the Commission felt was important in earlier discussions. The elevation drawings indicate that the units will contain two or three bedrooms, and range in size from 998 to 1470 square feet. Staff feels that the revised plan represents an improvement over the previously approved plan for Lot 51, will present a more attractive appearance from the street, and will be more compatible with the surrounding neighborhood once this subdivision is built out. Concerns were raised earlier about the "garagescape" being created behind the units. This is a result of removing the garages and driveways from the front yard, and while it may be somewhat less attractive at the rear of the homes, staff feels this is outweighed by the improvement to the appearance of the development from the street and neighborhood. Staff feels that the removal of the four town house units previously proposed at the rear of the lot will improve the development in a number of ways. It will create an area of usable open space for the residents of the lot, which was lacking in previous versions of the plan. Although Lot 51 is adjacent to a large outlot, this outlot provides for mainly passive recreational uses and a trail. Since the design of the dwelling units with the attached garages provides no "back yard," the open space will likely be appreciated by future residents, as it could provide an area for a grill, picnic table, sunbathing, or a play area for children. A better view of the pond and Willow Creek natural area will also be provided for all of the units, rather than just those few along the north edge of the lot. In addition, the change in design will result in the private drives at the rear of the units being single-loaded rather than double-loaded, which should help to mitigate the appearance of the rear garages. STAFF RECOMMENDATION: Staff recommends that REZ97-0018/SUB97-0030, a request for a revised preliminary sensitive areas development plan and preliminary plat for Lot 51 of Walden Hills, a 2.9 acre, 25 unit development located at the northeast corner of Shannon Drive and Irving Avenue, be approved. ATTACHMENTS: 1. Location map. 2. Preliminary sensitive areas development plan and preliminary plat. 3. Proposed building elevations. Approved by: Robert Miklo, Senior Planner Department of Planning and Community Development ,,', // WA T£R TO WN BEDROOMS 2. 5 BATHS GE OR GE TO WN 1276SQ FT. !iXTlil.;l()l{ (; F. XTF, I(101~. STAFF REPORT To: Planning and Zoning Commission Item: REZ97-0018/SUB97-0030. Lot 51, Walden Hills: Amended SADP and Preliminary Plat GENERAL INFORMATION: Applicant: Contact person: Requested action: Purpose: Location: Size: Existing land use and zoning: Surrounding land use and zoning: Comprehensive Plan: Applicable Code requirements: File date: 45-day limitation period: Prepared by: Scott Kugler Date: November 6, 1997 Walden Wood Associates, II, LLP 325 E. Washington Street Iowa City, Iowa 52240 Phone: 337-4195 MMS Consultants 1917 S. Gilbert St. Iowa City, IA 52240 Phone: 351-8282 Approval of an amended Sensitive Areas Development Plan and Preliminary Plat for Lot 51 of Walden Hills. To alter the proposed development plan and easement locations for this lot. At the northeast corner of the proposed Shannon Drive and Irving Avenue. 2.9 acres Vacant, OSA-8 North: East: South: West: Willow Creek, West High; Vacant, OSA-8; Vacant, OSA-8; Vacant, OSA-8. Residential, 2-8 dwelling units per acre Chapter 14-7, Land Subdivisions October 16, 1997 November 30, 1997 BACKGROUND INFORMATION: The applicant, Walden Woods Associates II, LLP, is requesting approval of an amended preliminary Sensitive Areas Development Plan and preliminary plat for Lot 51 of Walden Hills, containing 2.9 acres. Previously, Lot 51 was to be the site of 35 dwelling units, including three four-plexes along Shannon Drive and 23 attached units in groups of three, six and eight per building, with the buildings running perpendicular to Irving Avenue. The revised plan includes the four-plexes as previously proposed, but the other units are to be replaced with 20 town houses arranged mainly along Irving Avenue with the garage access to the rear of the buildings, for a total of 32 dwelling units. With the revised plan, the location of storm and sanitary sewer lines and access easements would change, and thus a revised preliminary plat for this lot is also being proposed. ANALYSIS: Preliminary Plat: The only reason to revise the preliminary plat for this Lot is the revised access plan and easement locations. There are a few corrections that are needed on the plat/plan. Staff recommends deferral pending resolution of these items. A revised grading plan is also required as a result of the changes to this plan. This should be approved prior to Council consideration of the plat. Revised Sensitive Areas Development Plan: Lot 51 does not contain any sensitive features requiring review under the Sensitive Areas Ordinance. However, this lot was contained on the overall Sensitive Areas Development Plan for Walden Hills. Major changes to the previously approved plan requires an amended plan. Although this plan is called an amended Sensitive Areas Development Plan, the City is really being asked to approve a revised housing arrangement on this lot. No sensitive features contained within the Walden Hills development will be impacted further as a result of the revised plan. Staff feels the proposed plan for Lot 51 is an improvement over the previously approved plan. The revised plan will present a more attractive appearance to the rest of the neighborhood than the previous proposal. The drive behind the townhouses will function similar to an alley and remove the garages for these units from the streetscape. Staff recommends that the applicant consider also replacing the proposed four-plexes with similar townhouse units, which would also improve the traffic situation along Shannon Drive. The four-plexes along Shannon drive would result in six of the units having driveways backing out onto the collector street. A similar townhouse arrangement could be designed to share the access drive being proposed along Irving Avenue. Since the four-plexes were approved in the previous plan, staff feels it is not reasonable to require this change to the plans, but passes this recommendation on to the developer as a suggestion for approving the development. As an incentive for changing the plan, it may also be possible to reclaim some of the dwelling units being lost as a result of the revised plan. The four units being proposed at the rear of the lot are not the most desirable in terms of their visibility or the view from the front of the units, which will consist of garage doors and decks of the units fronting on Irving Avenue. However, these units will have a view of the pond and stream corridor open space located to the north of the lot. Staff is concerned about the construction of these units prior to the construction of Shannon Drive out to Rohret Road. This would result in a great deal of traffic traveling through the Walden Wood subdivision initially. Therefore, staff recommends that the approval of this plan and plat be conditioned on the improvement of Shannon Drive prior to the issuance of building permits for Lot 51. STAFF RECOMMENDATION: Staff recommends that REZ97-O018/SUB97-0030 be deferred pending the resolution of the deficiencies and discrepancies listed below. Upon resolution of these items, staff recommends that the request for a revised preliminary Sensitive Areas Development Plan for Lot 51 of Walden Hills be approved, and that the request for a revised preliminary plat for Lot 51 of Walden Hills be approved, subject to the approval of a revised grading plan prior to City Council consideration of the plat, and subject to the improvement of Shannon Drive to provide a connection to Rohret Road prior to the issuance of building permits for Lot 51. DEFICIENCIES AND DISCREPANCIES: The legend contains some errors and missing information. DEVELOPERS ATTORNEY needs an apostrophe (DEVELOPER'S). Public Works has not yet commented on the revised plan. ATTACHMENTS: 2. 3. 4. Location map. Revised preliminary Sensitive Areas Development Plan and preliminary plat. Previous plan for Lot 51. Building elevations for proposed townhouses. Approved by: Robert Miklo, Senior Planner Department of Planning and Community Development 0 0 z Z 0 ] O0 OL~ Z NOTICE OF PUBLIC HEARING Notice is hereby given that the City Council of Iowa City will hold a public hearing on the loth day of March, 1998, at 7:00 p.m. in the Council Chambers of the City of Iowa City, 410 E. Washington Street, Iowa City, Iowa, regarding a long-term management plan for the reduction and maintenance of the deer population in Iowa City. Persons interested in expressing their views concerning this matter, either verbally or in writing, will be given the opportunity to be heard at the above-mentioned time and place. 03/06/98 11:06 ~3193351535 U of I ADMISSION ~]002/002 DeerMana§ement Commiteee Minority Report"* .... There were things I liked about Plan B (e.g., the nesting of the four items relating to the killing of deer under 4b.; the wording of 4e.), but the wording of 4d. bothered me too much to vote for Plan B. As an editor, I "do" words for a living. For me, there is a significant difference in meaning between ~may be utilized" and "will be considered." It is possible to interpret "may" as "permi~ion" or as "perhaps." I like that leeway. "Will" is an imperative. The word "utilized" implies action. Ironically, "considered" is the wor. d peop.le on the..committeq. used when they talked about the meaning of section 4d., however there was resistance to'r~pla 'clog' "utilized" with "considered." Who knows what methods to maintain the deer herd may be utilized in the future? But don't we all believe that every available method should be "considered?" The other sticking point for me was that I believe each individual on this committee compromised quite enough to reach the unanimous consensus to select sharpshooting as the best method of removing deer from our community. It bothered me that the DNR/ NRC's unhappiness with our decision held as much sway over the committee as it did. [ prefer not to play that game. Respectfully, Janet ~ 905 Fifth Ave. Iowa City, LA 52240 March 6, 1998