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HomeMy WebLinkAboutPolicy Discussion regarding Board of Adjustment Purview Commission Memorandum REPORT TO: Honorable Mayor and City Commission FROM: Brian Krueger, Associate Planner Chris Saunders, Assistant Planning Director Tim McHarg, Planning Director SUBJECT: Policy Discussion regarding Board of Adjustment Purview and Development Review Processes MEETING DATE: August 29, 2011 AGENDA ITEM TYPE: Action Item RECOMMENDATION: Review the background information in this memorandum and provide direction for possible future Unified Development Ordinance (UDO) amendments. RECOMMENDED MOTION: No motion is necessary. This is a policy discussion that requires no formal action by the City Commission. BACKGROUND: Several variance, deviation and conditional use applications have been reclaimed by the City Commission over the past few months. The reasons for reclaiming these applications have varied. Some have been at the applicant’s request; some have been at Staff’s request; some have been because previous components of the development proposal were considered by the Commission. Because of this recent increase in the number of reclaimed applications that would routinely be heard by the Board of Adjustment (BOA), the Mayor and Commission expressed interest in a policy discussion regarding the purview of the BOA. However, Staff would request the Mayor and Commission to consider expanding the scope of this policy discussion to address the development review process more generally. The Commission Work Plan includes several items that are related to a discussion of variance, deviation and conditional use review processes. These Work Plan items are as follows: 2. Implement the adopted economic development plan b) Commitment to a business-friendly process with a focus on retention and expansion of local businesses · Expand Planning Director administrative approvals · Reduce Conditional Uses · Implement administrative deviation and alternative compliance processes 122 Planning Staff believes that a policy discussion regarding the purview of the Board of Adjustment within a broader context of these Work Plan items would be beneficial. If the policy discussion is limited to the Commission considering permanently reclaiming to itself the purview of the BOA, Staff is concerned that there may be unintended consequences on the workload of the Commission and the efficiency of the development review process. These concerns are summarized as follows: · Reviewing all variance, deviation and conditional use applications would detract from the time available to the Commission for broader policy discussions. · The Commission calendar can be congested, particularly during those times of the year when budget, capital improvement program, and work plan discussions dominate the agendas. This may result in delays for applicants as they await openings on the Commission agenda. · Preparation of staff reports, providing public notice, and holding public hearings consume a significant amount of staffing resources. For relatively minor applications that do not generate any public comment, there may be more efficient review processes that provide equivalent outcomes. Planning Staff has identified seven specific areas of change that are recommended for consideration and direction by the Commission. These potential areas of changes to the UDO were developed from a pragmatic and functional approach to improving the current review processes for variance, deviation and conditional use applications. 1. Converting Conditional Uses to Permitted Uses: Staff has identified some uses that are currently listed as Conditional Uses that could be converted to Principal Uses without any additional changes. This would simply move some uses from a Conditional Use to a Permitted Use in specific zone districts. These uses could then be reviewed administratively as site plan, sketch plan or reuse applications, depending on the nature of the application. The administrative decision would be subject to the Commission reclaim and appeal procedures. An example of one use where this might be considered would be Printing Office and Publishing Establishments in the B-3 district (Central Business District) where they are a Conditional Use. With changes in technology the impacts associated with printing and publishing have decreased and might not merit review as a Conditional Use. This process could work in concert with a process to redefine some uses, as discussed below under Recommendation No. 4. 2. Converting Conditional Uses to Permitted Uses with the addition of Standards for Specific Uses: The UDO contains Chapter 18.40, Standards for Specific Uses. This chapter lists uses with the potential for negative impacts to the community and provides specific standards for each of these uses in order to mitigate the potential impacts. These specific standards must be met in addition to the baseline standards of setbacks, lot coverage, landscaping, parking and other site development standards. Staff has identified some uses that are currently listed as Conditional Uses that could be converted to Principal Uses with the inclusion of standards for those specific uses. These uses could then be reviewed administratively as site plan, sketch plan or reuse applications, depending on the nature of the application. The administrative decision would be subject to the Commission reclaim and appeal procedures. 123 An example of this approach would be to move Automobile Repair from a Conditional Use to a Permitted Use in the B-2 zone district (Community Business District). Additional standards could be written into the Special Standards Chapter to mitigate for or not allow outdoor storage, outdoor vehicle storage, inoperable vehicles, and salvage vehicles. 3. Creating a New Category of Special Uses: The new category of Special Use would require a Special Use Permit. The criteria for a Special Use Permit would be similar in criteria and public notice requirements to a Conditional Use Permit, but would not require a public hearing and would be an administrative decision by the Planning Director. This process could be a stand-alone approval for certain uses or could be used in concert with standards for specific uses similar to that outlined above for the Conditional Use Permit process. An example of a use that may be appropriate for a Special Use Permit would be On Premise Consumption of Alcohol. This use is currently a Conditional Use in all commercial zones and as such is the subject of a majority of the conditional uses permitted over the past five years by the department. Most conditions imposed on these permit types are very similar and could be codified into Specific Use Standards. The Special Use Permit would still require noticing and the consideration of public comment prior to any decision, as well as being subject to the Commission reclaim and appeal procedures. 4. Redefining Uses and Differentiating in Operation Scale: Over time, the character of land uses change based upon the demands of the market and changes in technology. New land uses can arise for these same reasons. The use tables within the code could be updated to better reflect the range of uses that occur today and might occur in the future in the City. At the same time, certain uses could be better defined by intensity and size in order to permit those smaller scale uses with little opportunity for negative impacts to be permitted outright and those larger uses in both physical size and intensity to be classified as either a Special or Conditional Use. For example, manufacturing could be redefined as a use group with three subheadings: Artisan, Light, and General. A detailed definition to describe a range of intensity and size could be developed for each subcategory. Under this approach, an artisan that manufactures jewelry or pottery may be able to be allowed outright in the B-1 (Neighborhood Business District), B-2, or B-3 zoning districts while a light manufacturer such as a welding fabrication shop, seat cover manufacturer or truck accessory manufacturer would remain permitted only in the more industrial M zones. 5. Expanding Allowances for Accessory Uses: Accessory uses are listed in the use tables inconsistently. Many permitted and legal businesses include accessory uses that are not specifically listed as accessory uses or as allowed uses within the zoning district in which they are located. Many accessory uses are permitted through the use of a Special Temporary Use Permit (STUP) for a limited period of time with provisions for renewal. This results in uncertainty for business owners, consumption of staff resources to track and renew STUPs, and inconsistencies over time. 124 Because of these inconsistencies and confusion over what is listed and what is not listed, Staff recommends removal of all accessory uses from the use table. In lieu of listing specific uses, the code could include a revised and expanded section on the interpretation of uses that would list specific criteria to provide a context for the acceptable classification of a use as accessory to the principal use. Such criteria could include customer types, hours of operation, percentage of gross square feet allocated to a use, vehicle trips generated, how a business advertises itself, and relative percentages of sales activity. 6. Creation of Processes for Administrative Deviations: The UDO currently allows deviations from the numerical standards within the zoning ordinance. In the Neighborhood Conservation Overlay District, the code allows an “unlimited” deviation that could include up to full relief from (i.e. waiver of) an applicable standard. In the Entryway Corridor Overlay District the code allows up to a 20% deviation above or below a listed numerical standard. Areas within the City that are not within one of the Overlay Districts do not have the ability to ask for relief from code standards other than through a variance process. Today, deviations are only available through a public hearing process and approval by the Board of Adjustment or City Commission. The deviation process could be revised to include an administrative Planning Director approval for some deviations, the addition of a deviation process for areas outside of Overlay Districts, and revised criteria and standards for what constitutes a deviation and how much one could deviate from a standard. One example of this concept would be to offer deviations outside of Overlay Districts up to 10% above or below a listed standard subject to criteria. The standards to which the administrative deviation could apply could include setbacks, height, lot, and/or parking. An example of a criterion would be that an administrative deviation is available only for expansions to existing structures and lots and would not be available for new lots and new structures. 7. Transfer of approval authority. The Staff and Planning Board worked in early 2011 to identify who approves what kind of things in the UDO. A list of these approvals is attached. Over the years, there are numerous types of approvals that have been assumed specifically by the City Commission. The list identifies 57 City Commission specific approvals while only 15 of those are required by statute. In connection with the other possible changes identified in options 1-6 a review of those approval actions assigned to the City Commission should be reviewed. Any changes to transfer approval authority to administrative staff could be integrated with the other code amendments. The administrative decision would be subject to the Commission reclaim and appeal procedures. Staff believes that implementing some or all of these seven potential areas for change would significantly improve the efficiency and flexibility of the development review process without reducing the quality of the built environment or quality of life outcomes in the community. UNRESOLVED ISSUES: None at this time. ALTERNATIVES: The policy discussion will be sufficiently broad to consider a full range of alternatives relative to these issues. 125 FISCAL EFFECTS: The work necessary to implement the City Commission’s policy direction on these issues has been budgeted as part of the Planning Department’s ongoing effort to address the individual components of the Commission’s Work Plan. Attachments: None. Report compiled on: August 12, 2011 126 community planning zoning subdivision review annexation historic preservation neighborhood planning urban design GIS CITY OF BOZEMAN DEPARTMENT OF PLANNING AND COMMUNITY DEVELOPMENT Alfred M. Stiff Professional Building 20 East Olive Street P.O. Box 1230 Bozeman, Montana 59771-1230 phone 406-582-2260 fax 406-582-2263 planning@bozeman.net www.bozeman.net TO: CITY COMMISSION FROM: PLANNING STAFF RE: APPROVAL STRUCTURE IN TITLE 18, UNIFIED DEVELOPMENT DATE: AUGUST 22, 2011 Title 18, Unified Development Ordinance (UDO) , Bozeman Municipal Code contains procedures and standards for subdivision and site development. It pulls together many different subjects and can apply in many different circumstances. Some of the procedures are given specific steps and approval requirements by state law. Only Commission actions are mandated to give final approvals. All of the UDO is affected by a myriad of state and federal laws and judicial rulings. To help understand the dynamics of the UDO, a chart of sections of the document is provided below. It lists: what sections the approval body is/are mentioned in; which approval body is/are affected; and whether that approval is required by statute. This list was prepared in support of the City Commission’s 2011-2012 work plan. The chart is not exhaustive of all possible approvals. Some actions require consultation and approval by agencies outside of the City as well as within the City’s organization. The external agencies are not listed. Generally, the assignment of responsibilities for approval are laid out in Section 18.64.010. As noted in that section, the City Commission has reserved to itself the ability to take back review of an application which normally is delegated to others. The City Commission has also reserved to themselves, as the original review body, some specific items they consider of community importance such as the review of large scale retail. In the last quarter of 2010, the Planning Board and Staff discussed various options to consider to revise the City’s land use and development processes. Staff committed to providing several options for consideration. This memo presents for consideration and discussion 20 possible changes. A prioritization is offered for consideration as well. This list of potential changes is limited to the approval authority. Other options will be presented for discussion under other procedural or standards discussions later. The recent set of text amendments approved by the Commission in June began implementing the Planning Board and Staff discussions. Shading is provided to help indicate subject matter. Items in white are generally applicable. Items in blue are specific to subdivisions. Items in green are specific to zoning. Yellow text shows item, person, and priority to possibly alter the designated approval authority and the priority for consideration. REVIEW TYPE City Commission State Law Required Board of Adjustment Planning Director City Engineer 1 City owned land 18.02.080 - Any approval 1 Medium When compliant 127 Page 2 REVIEW TYPE City Commission State Law Required Board of Adjustment Planning Director City Engineer 2 Correction of Errors, Amendments, or Vacation of Final Plat 18.04.030 1 1 3 Concurrent Review 18.06.030 - Allows simultaneous state and local review of infrastructure plans 1 1 4 Preliminary Plat 18.06.040.D - Approve preliminary plat 1 1 5 Final Plat 18.06.060.E - Allows recording of plat and sale of lots 1 1 6 Final Plan 18.08.040 - Subdivisions by rent or lease 1 1 7 Exemptions from Surveying and Filing Requirements but Subject to Review 18.10.030 - Subdivisions by rent or lease 1 1 8 Procedures and General Requirements 18.10.060 - Approval of subdivision exemptions 1 9 Official Map Replacement Conditions 18.14.030 - Replace the zoning map 1 1 10 Boundary Interpretation Guidelines 18.14.040.B - Interpret the zoning map when it isn't clear 1 11 Boundary Interpretation Guidelines 18.14.040.C - Interpret the zoning map when it isn't clear 1 12 Classification of Particular Uses - Planning Director and City Commission Authority 18.14.050.A - When there is a new use 1 1 13 Zoning of Annexed Territory 18.14.060 - Initial zoning at the time of annexation 1 1 14 Additional RMH Performance Standards 18.16.080.A.2 - minimum size of RMH zoning district 1 Low Delete Standard 15 Special Standards 18.19.070.A - Minimum size of UMU zoning district 1 16 Conservation District Designation or Recision 18.28.030 - Designation as a historic land mark or added to historic preservation review 1 17 Certificate of Appropriateness 18.28.040 - Approve projects 1 1 1 - Majority 18 Deviations from Underlying Zoning Requirements 18.28.070 - grant special exceptions 1 1 Medium 19 Demolition or Movement of Structures or Site Within the Conservation District 18.28.080.B - Approve removal of structure 1 1 High 20 Demolition or Movement of Structures or Site Within the Conservation District 18.28.080.C - Approve removal for historically significant structures 1 Medium 128 Page 3 REVIEW TYPE City Commission State Law Required Board of Adjustment Planning Director City Engineer 21 Deviations from Overlay or Underlying Zoning Requirements 18.30.080.A - Approve special exceptions 1 1 Medium 22 Introduction 18.34.010.D - Approval for conditional uses 1 23 Sketch Plan Review 18.34.050.A.3 - Determination of submittal requirements 1 24 Site Plan Review 18.34.070.B.1.a - Approval of site plans 1 25 Site Plan Review 18.34.070.B.2 - Approval of site plans with special exceptions and conditional uses 1 Medium 26 Site Plan Review 18.34.070.B.3.a - Approval of master site plans 1 1 (when compliant) 27 Board of Adjustment Consideration and Records for Conditional Use Permits 18.34.100 - Approval of conditional uses 1 1 (F.2 only) 28 Final Site Plan 18.34.130.A - Approve final site plan 1 29 Final Site Plan 18.34.130.D - Approve final site plan e1tensions 1 30 Final Site Plan 18.34.130.E - Approve final site plan e1tensions 1 31 Amendments to Sketch and Site Plans 18.34.150.B - Approve amendments 1 32 Re-use, Change in Use or Further Development of Sites Developed Prior to the Adoption of this Ordinance Codified in this Title 18.34.170.A 1 33 Improvements to Existing Developed Sites Independent of Site Plan Review 18.34.180.A - Allow incremental improvements without full site plan review 1 34 Special Temporary Use Permit 18.34.190.C - Allow short term activities 1 35 Application and Uses of a Planned Unit Development 18.36.020.D - Approve planned unit development 1 36 Planned Unit Development Review Procedures and Criteria 18.36.040.C.3 - Approval of final PUD plan 1 37 Planned Unit Development Review Procedures and Criteria 18.36.040.C.4.a - Approve minor changes to a PUD 1 38 Planned Unit Development Review Procedures and Criteria 18.36.040.C.4.b - Approve major changes to a PUD 1 39 Duration of Planned Unit Development Approval 18.36.060.A.2 - Extend preliminary approval 1 129 Page 4 REVIEW TYPE City Commission State Law Required Board of Adjustment Planning Director City Engineer 40 Duration of Planned Unit Development Approval 18.36.060.A.3 - Extend preliminary approval beyond 1 year 1 High 41 Duration of Planned Unit Development Approval 18.36.060.B.1 - Extend final PUD plan approval 1 42 Duration of Planned Unit Development Approval 18.36.060.B.2 - Extend final PUD plan approval beyond 1 year 1 High 43 Planned Unit Development Design Objectives and Criteria 18.36.090.E.a.(7).(b).(v) - Locate open space outside of PUD boundaries 1 44 Use of Lands - Buildings and Structures 18.38.030.D.2 - Alternate muncipal infrastructure requirements 1 45 Home Based Businesses 18.40.110.C.4 - Determine when a conditional use permit is required 1 46 Manufactured Homes on Individual Lots 18.40.130.D - Approve siting of manufactured home on individual lots 1 47 Portable Carry-Out Food and Beverage Buildings 18.40.160.E - Approve special temporary use permit 1 1 48 Large Scale retail, size limiations and design and site develompent guidelines and requirements 18.40.180.C.4 - Approve site development 1 Medium 49 Stable, Commercial 18.40.190.G - Require dust control 1 50 Stable, Commercial 18.40.190.H - Provide for adequate parking 1 51 Tennis and Raquet Club 18.40.200.C - Approval for holding tournaments 1 High 52 Tennis and Raquet Club 18.40.200.E - Restrict hours of operation 1 High 53 Neighborhood Centers 18.42.020.F - Allow location of stormwater facilities 1 54 Municipal Water, Sanitary Sewer and Storm Sewer Systems 18.42.070.A.3 - Exception to not extend infrastucture to adjacent property 1 55 Municipal Water, Sanitary Sewer and Storm Sewer Systems 18.42.070.B.1 - Maximum length of dead end water mains 1 56 Municipal Water, Sanitary Sewer and Storm Sewer Systems 18.42.070.B.2 - Maximum length of service lines 1 57 Grading and Drainage 18.42.080.B - Exceptions to stormwater controls 1 58 Lighting 18.42.150.B.3 - Allow alternate lighting standard 1 130 Page 5 REVIEW TYPE City Commission State Law Required Board of Adjustment Planning Director City Engineer 59 Lighting 18.42.150.D.7.j - Allow high intensity lights for special events 1 60 Streets, General 18.44.010.A - Exception from extending streets to adjacent property 1 Low 61 Streets, General 18.44.010.E.1 - Turn- arounds on dead end streets 1 62 Streets, General 18.44.010.G - Partial street construction 1 63 Streets, General 18.44.010.I - Allowance for cul-de-sac 1 64 Street Names 18.44.040.A.2 - Allowing names of streets 1 65 Street Improvement Standards 18.44.060 - Plans and specifications for streets 1 66 Street Improvement Standards 18.44.060.A - Approval of proposed street surfacing 1 67 Street Improvement Standards 18.44.060.B.2 - Alley specifications 1 68 Street Improvement Standards 18.44.060.C - Traffic signal spacing 1 69 Access 18.44.090.A.1.a - Approval of curb cuts and sidewalks 1 70 Access 18.44.090.G - Location and width of drive accesses 1 71 Access 18.44.090.H - Modifications to property accesses 1 72 Stall, Aisle and Driveway Design 18.46.020.F - Alternatives to surfacing for parking areas 1 73 Stall, Aisle and Driveway Design 18.46.020.J.3 - Alternatives to curbing 1 74 Number of Parking Spaces Required 18.46.040.B.1 - Classification of parking requirement for non-specified uses 1 75 Joint Use of Parking Facilities 18.46.050.B - Allow joint use of parking area 1 76 Mandatory Landscaping Provisions 18.48.050.E.1 - Minimum landscaping requirements for street frontage 1 77 Mandatory Landscaping Provisions 18.48.050.H.2 - Protection of landscaped areas 1 78 Mandatory Landscaping Provisions 18.48.050.L.3 - Maximum allowed slope for landscaped areas 1 79 Cash Donation in-Lieu of Land Dedication 18.50.030 - Determine if land or money best meets requirements 1 1 Medium If CC not otherwise required 80 Park Use 18.50.040 - Determination of park usage 1 131 Page 6 REVIEW TYPE City Commission State Law Required Board of Adjustment Planning Director City Engineer 81 Location 18.50.050.A - Suitable location for parks 1 1 1 82 Waiver of Required Park Dedication 18.50.100 - Waive park dedication 1 1 83 Sign Permitted Upon Issuance of a Sign Permit 18.52.060 - Approve sign permits 1 84 Sign Permitted Upon Issuance of a Sign Permit 18.52.060.D - Deviations for signs 1 85 Comprehensive Sign Plan 18.52.070 - Approve integrating elements in a comprehensive sign plan 1 86 Historic or Culturally Significant Signs 18.52.160 - Approve exceptions 1 87 Application 18.52.170 - Review of sign applications 1 1 88 Application Requirements and Procedures for Regulated Activities in Regulated Wetland Areas 18.56.070.B.1 - Approval of sketch plans for wetland changes 1 89 Floodplain Administrator 18.58.060 - Designates the floodplain administrator 1 90 Flood Hazard Evaluation 18.58.090.B.4.d.(2) - Contents of flood hazard report 1 91 Flood Hazard Evaluation 18.58.090.C - Allow waiver of flood hazard report 1 92 Changes to or Expansions of Nonconforming Uses 18.60.020.A.1 - Change or expand non-residential 1 High 93 Changes to or Expansions of Nonconforming Uses 18.60.020.B.1 - Residential 1 High 94 Nonconforming Area and Bulk Requirements for Existing Lots 18.60.030.A - Allow use of substandard lot 1 High 95 Purpose of DRC, DRB, ADR, WRB, and BOA 18.62.010.A - Establishes general responsibilities 1 96 Purpose of DRC, DRB, ADR, WRB, and BOA 18.62.010.A.5 - Assigns specific duties 1 97 Purpose of DRC, DRB, ADR, WRB, and BOA 18.62.010.C - Appointment of DRB members 1 98 Purpose of DRC, DRB, ADR, WRB, and BOA 18.62.010.F - Appointment of WRB members 1 99 Purpose of DRC, DRB, ADR, WRB, and BOA 18.62.010.G - Appointment of BOA members 1 1 100 General Procedures, Noticing and Timing 18.62.020.A - Establishment of review fee 1 132 Page 7 REVIEW TYPE City Commission State Law Required Board of Adjustment Planning Director City Engineer 101 Review Authority 18.64.010.A - Overall review authority 1 102 Review Authority 18.64.010.B - General Planning Director authority for review of applications 1 103 Review Authority 18.64.010.C - General BOA authority for review of applications 1 104 Administration and Enforcement - Planning Director Authority 18.64.020.A - Authorize Planning Director to administer Title 18 1 105 Administration and Enforcement - Planning Director Authority 18.64.020.C - Authority to stop work 1 106 Enforcement Planning Director 18.64.030 - Assignment of enforcement authority 1 107 Stop Work Order - Planning Director, Building Official, City Engineer Authority 18.64.040 - Can issue order to cease all work 1 1 108 Building Permit Requirements 18.64.100.F - Extension of approval duration 1 109 Fee Schedule 18.64.140.A - Authority to set fee schedule 1 110 Violation - Penalty - Assisting or Abetting - Additional Remedies 18.64.160.E - Authorization to record a notice of violation 1 Low 111 Purposes 18.66.010.B - Authorization for zoning variances 1 112 Purposes 18.66.010.C - Authorization for subdivision variances 1 113 Administrative Project Decision Appeals 18.66.030 - Who hears appeals 1 114 Administrative Interpretation Appeals 18.66.040 - Decide appeals of administrative decisions 1 115 Deviations 18.66.050 - General authority to hear deviations 1 Medium w/ parameters 116 Zoning Variances 18.66.060.D.1 - Authorization to approve variances 1 117 Initiation of Amendments and Changes 18.68.010 – Approve amendments to the text of the UDO 1 1 118 Protest Text Amendments 18.68.040 - Standard to override a protest of a zoning text change 1 1 119 Public Hearing Procedures and Requirements 18.70.030 - Approve zone map amendments 1 1 120 Covenants 18.72.010 - Approval of covenants 1 1 121 Covenants 18.72.030.H.2 - City assumption of responsibility of private improvements 1 133 Page 8 REVIEW TYPE City Commission State Law Required Board of Adjustment Planning Director City Engineer 122 Standards for Improvements 18.74.020.B - Approval of improvements to be dedicated to the public 1 123 Completion of Improvements 18.74.030.B.1.b - Street installation improvements and guarantees 1 124 Completion of Improvements 18.74.030.C - Site improvements 1 125 Completion of Improvements 18.74.030.D.13 - Concurrent construction plan 1 126 Improvements Agreements 18.74.060.A.3 - Determine applicability of requirement for improvement agreement for COAs 1 127 Improvements Agreements 18.74.060.B - Determine exception for requirement for street paving 1 128 Improvements Agreements 18.74.060 C.2.c - Reduction of security for improvement agreement 1 129 Improvements Agreements 18.74.060 C.2.d - Reduction of security for off-site improvements 1 Medium 1 130 Improvements Agreements 18.74.060 C.3.d - Extension of security for site improvements 1 131 Improvements Agreements 18.74.060.E - Assign responsibility for signing on behalf of City 1 132 Notice Requirements for Application Processing 18.76.030.C - Determine additional noticing requirements 1 133 Final Plat 18.78.070.D - Approval final plan for park development with final plat 1 134 Artificial Lot 18.80.220 - Determine the area of an artificial lot 1 Existing 57 15 12 50 30 134