HomeMy WebLinkAboutPACKET Estes Valley Board of Adjustment 2010-02-02Prepared: January 22, 2010
Revised:
AGENDA
ESTES VALLEY BOARD OF ADJUSTMENT
Tuesday, February 2, 2010
9:00 a.m. - Board Room, Town Hall
1. PUBLIC COMMENT
2. CONSENT
a. Approval of minutes dated December 1, 2009
3. REQUESTS
a. Lot 6, Block 2,
Owner:
Applicant:
Request:
Staff Contact:
4. REPORTS
Park Entrance Estates, 530 Heinz Parkway
Scott and Michelle Spreen
Andy Human
Variance from EVDC Table 4-2, which requires a 25-foot
minimum building setback from the rear property line.
Request to allow encroachment into the minimum setback
for construction of a proposed detached garage.
Dave Shirk
Staff Level Reviews
a. 1100 North Lane
Kinley Residence — Minor Modification
b. 1875 Moraine Avenue
Rippling River Estates — Minor Modification
5. ADJOURNMENT
Note: The Estes Valley Board of Adjustment reserves the right to consider other
appropriate items not available at the time the agenda was prepared.
RECORD OF PROCEEDINGS
Regular Meeting of the Estes Valley Board of Adjustment
December 1, 2009, 9:00 a.m.
Board Room, Estes Park Town Hall
Board: Chair Chuck Levine, Members John Lynch, Bob McCreery, Wayne
Newsom, and Al Sager; Alternate Member Bruce Grant
Attending: Chair Levine, Members Lynch, McCreery, and Sager
Also Attending: Director Bob Joseph, and Recording Secretary Karen Thompson
Absent: Member Newsom, Planner Shirk, Planner Chilcott
Chair Levine called the meeting to order at 9:00 a.m.
1. PUBLIC COMMENT
None
2. CONSENT AGENDA
Approval of minutes dated September 1, 2009
It was moved and seconded (McCreery/Lynch) to APPROVE the minutes as
presented, and the motion passed unanimously with one absent.
3. METES & BOUNDS PARCEL LOCATED AT 2025 MORAINE AVENUE, 189 & 191 E.
RIVERSIDE DRIVE, Owner: Stonewood Properties, LLC, Applicant: Don Chasen —
Request for variance from §7.5.F.2.b(6), which requires a 25' Landscape Butler from
the property line. Request to allow an access drive to be located within the
Landscape Buffer Zone.
Director Joseph reviewed the staff report. The purpose of this variance request was to
allow an access driveway to be located within the required 25-foot Landscape Buffer Zone
in order to develop this property with nine residential/accommodations units in an A -
Accommodations zoning district.
Director Joseph stated this same variance request was before the Board of Adjustment on
October 2, 2007, under a different property owner/applicant, and the variance was
approved unanimously, with the following condition: District -buffer landscaping standards
shall be applied in place of arterial -street standards. The original development never came
to fruition and, therefore, the variance approval expired on October 2, 2008.
The applicant's property lies between the river and Spur 66. Staff's view was the property
had some constraints due to the narrow width, which, combined with the required
setbacks, created a limited developable area. The proposed site plan kept the footprint of
the buildings in compliance with all applicable setbacks by pushing them north closer to
the highway. Part of the driveway on the east end needs a variance requiring Board
approval.
In accordance with Section 3.6.C, Standards for Review of the Estes Valley Development
Code, staff has determined that special circumstances exist that are not common to other
areas of buildings similarly situated. This parcel has a steep drop from the road, and the lot
is significantly narrow, considering the river and arterial road setbacks. In determining
practical difficulty that may result from strict compliance with this Code's standards,
Director Joseph stated the property is currently undeveloped and could be designed to
meet all setbacks. Staff has determined this variance is not substantial. Also, because of
the slope and the grade difference between the driveway and the highway, you tend to
RECORD OF PROCEEDINGS
Estes Valley Board of Adjustment
December 1, 2009
look out across the site and would probably not be aware of the encroachment, which
mitigates the negative impact of the variance. Therefore, staff believes the essential
character of the neighborhood will have minimal impact, and can be minimized further by
using the district buffer landscape requirement instead of the arterial) street standard. This
should conceal any off -site visual impacts of the encroachment. The applicant purchased
the property in 2008, with knowledge of the setback requirements. Staff feels this variance
request is minor with very few complliicatiions. The sewer easement is already in place and
there is no encroachment into the right-of-way. Staff recommends approval of this variance
with one condition.
Public and Board Member Comment:
Member McCreery was concerned about the density level, and Director Joseph explained
this zoning district could actually support more density than what was proposed. This
particular development plan was a staff-llevel review, and proposes a much lower density
than a previous proposal. The applicant was not in attendance. Director Joseph stated this
was the second development plan for this property by this applicant, who decided to
change the plans for marketability purposes.
Dave Ranglos, adjacent property owner, expressed concern about the density and
preferred to see only three homes on the property. Ann Toil, previous owner of the
property in question, also preferred a three -house plan.
It was moved and seconded (Sager/Lynch) to APPROVE the request for a variance
from EVDC §7.5.F.2.b(6) to allow an access drive to be located within the 25-foot
Landscape Buffer, with the following condition and the motion passed unanimously
with one absent.
CONDITION:
1. District Buffer (landscaping standards shall be applied in place of arterial) street
standards.
4. REPORTS
None.
5. ELECTION OF OFFICERS
Chair Levine announced that two officers were to be elected. According to the Inter -
Governmental Agreement, the incoming Chair is required to be a county resident, while
the Vice -Chair is required to be a town resident. Member McCreery was nominated to
serve as Chair, and Member Levine nominated to serve as Vice -Chair.
it was moved and seconded (McCreery/Sager) to elect Member Bob McCreery as
Chair and Member Chuck Levine as Vice -Chair of the Estes Valley Board of
Adjustment for 2010, and to elect the Community Development Department
Administrative Assistant as the Recording Secretary. The motion passed
unanimously with one absent.
There being no further business, Chair Levine adjourned the meeting at 9:27 a.m.
Chuck Levine, Chair
Karen Thompson, Recording Secretary
Spreen Variance Request
Estes Park Community Development Department
Municipal Building, 170 MacGregor Avenue
PO Box 1200
Estes Park, CO 80517
simmimmemom
Phone: 970-577-3721 Fax: 970-586-0249 www.estesnet.com
DATE: February 2, 2010
REQUEST: Variance from the "E-
1" Estate 25-foot yard setback
requirement.
LOCATION: 530 Heinz Parkway,
within the Town of Estes Park
APPLICANT: Andy Human
PROPERTY OWNER: Scott
Spreen
STAFF CONTACT: Dave Shirk
SITE DATA TABLE:
11111111111111111
1111111111111111
Surveyor: England Surveying
Parcel Number: 3526311006
Development Area: 1.57 acres +/-
Number of Lots: One
Existing Land Use: Single-family residential
Proposed Land use: Same, with a detached
garage
Existing Zoning: "E-1" Estate
Adjacent Zoning -
East: "E-1" Estate
North: "RE" Rural Estate
West: "E-1" Estate
South: "E-1" Estate
Adjacent Land Uses -
East: Single-family residential
North: Single-family residential
West: Single-family residential
South: Single-family residential
Services -
Water: Town
Sewer: UTSD
Fire Protection: Estes Park Volunteer
PROJECT DESCRIPTION AND BACKGROUND: The applicant requests a
variance to Table 4-2 "Base Density and Dimensional Standards" of the Estes Valley
Development Code to allow a detached garage to be built with a comer located 5-feet
from the property line.
REVIEW CRITERIA: In accordance with Section 3.6 C. "Standards for Review" of
the EVDC, all applications for variances shall demonstrate compliance with the
applicable standards and criteria set forth below:
1. Special circumstances or conditions exist (e.g., exceptional topographic conditions,
narrowness, shallowness or the shape of the property) that are not common to other
areas or buildings similarly situated and practical difficulty may result from strict
compliance with this Code's standards, provided that the requested variance will not
have the effect of nullifying or impairing the intent and purposes of either the specific
standards, this Code or the Comprehensive Plan.
Staff Finding: Staff finds that special circumstances exist and practical difficulty
may result from strict compliance with Code standards. Specifically, the shape,
slope, existing site disturbance, and location of the existing structure combine to
create special circumstances.
2. In determining "practical difficulty," the BOA shall consider the following factors:
a. Whether there can be any beneficial use of the property without the variance;
Staff Finding: The property can be put to beneficial use, according the zoning of
the property. Specifically:
• The existing single-family dwelling may continue it's use.
b. Whether the variance is substantial;
Staff Finding: The requested variance could be considered substantial, with a
proposed setback of 5-feet. There is an unused 60-foot wide right-of-way
adjacent to the lot.
c. Whether the essential character of the neighborhood would be substantially
altered or whether adjoining properties would suffer a substantial detriment as a
result of the variance;
Staff Finding: The essential character of the neighborhood would not be
substantially altered, nor would adjoining properties suffer a substantial
detriment.
Page #2 Spreen Setback Request
d. Whether the variance would adversely affect the delivery of public services such
as water and sewer.
Staff Finding: The variance would not adversely affect the delivery of public
services. Specifically:
Public service providers received the variance application for opportunity to
review and comment. No concerns were expressed about adverse impacts to
the delivery of public services.
e. Whether the Applicant purchased the property with knowledge of the
requirement;
Staff Finding: This factor addresses whether or not requirements changed during
current ownership of the property. For example, did the property owner purchase
the property prior to adoption of the required setbacks?
This factor is not intended to address whether or not the property owner reviewed
Estes Valley Development Code to determine which setbacks are applicable to
his/her property.
f Whether the Applicant's predicament can be mitigated through some method
other than a variance.
Staff Finding: The applicant's predicament could be mitigated through some
method other than a variance, though it would result in additional site
disturbance and grading.
3. If authorized, a variance shall represent the least deviation from the regulations that
will afford relief.
Staff Finding: The variance represents the least deviation from the regulations that
will afford relief. The Board should use their best judgment if the request represents
the least deviation.
4. In granting such variances, the BOA may require such conditions as will, in its
independent judgment, secure substantially the objectives of the standard so varied or
modified.
Staff Comment: Staff has provided suggested conditions of approval at the end of
the Staff report.
REFFERAL COMMENTS AND OTHER ISSUES: This request has been submitted
to all applicable reviewing agency staff for consideration and comment. At the time of
Page #3 Spreen Setback Request
this report, no significant issues or concerns were expressed by reviewing staff relative to
code compliance or the provision of public services.
Neighboring Properly Owners. Staff has received one email from a neighbor, who
requested clarification about the location. Once clarified, the neighbor had no objection.
Staff has not received any other correspondence regarding this request.
STAFF FINDINGS AND RECOMMENDATION: Based on the foregoing, staff
finds:
1. Special circumstances exist and practical difficulty may result from strict
compliance with Code standards.
2. The property can be put to beneficial use, according the zoning of the property.
3. The requested variance is not substantial.
4. The essential character of the neighborhood would not be substantially altered, nor
would adjoining properties suffer a substantial detriment.
5. The variance would not adversely affect the delivery of public services.
6. The applicant was unaware of the Code requirement when the property was
purchased.
The Applicant's predicament could be mitigated through some method other than a
variance, though it would result in additional grading and site disturbance.
8. The variance represents the least deviation from the regulations that will afford
relief.
9. This request has been submitted to all applicable reviewing agency staff for
consideration and comment. No significant issues or concerns were expressed by
reviewing staff relative to code compliance or the provision of public services.
10. The submitted conditions or circumstances affecting the property are not of so
general or recurrent a nature as to make reasonably practicable the formulation of a
general regulation for such conditions or situations.
11. Approval of the variance would not result in an increase in the number of lots
beyond the number otherwise permitted for the total subdivision, pursuant to the
applicable zone district regulations.
Page #4 Spreen Setback Request
12. Approval of the variance would not allow a use not permitted, or a use expressly or
by implication prohibited under the terms of this Code for the zone district
containing the property for which the variance is sought;
13. Failure to apply for a building permit and commence construction or action with
regard to the variance approval within one (1) year of receiving approval of the
variance shall automatically render the decision of the BOA null and void.
Therefore, Staff recommends APPROVAL of the requested variance to allow a rear yard
setback of 5-feet in lieu of the 25-foot setback required CONDITIONAL TO:
1. Compliance with the site plan and building design, as approved by the Board of
Adjustment.
2. Setback Certificate. Prior to final inspection, a registered land surveyor shall provide
to the Community Development Department a signed and stamped certificate that
specifically verifies that the structure complies with the approved variance, and shall
include a specific reference to the distance to property lines. Staff recommends a
surveyor set survey stakes for foundation forms to ensure compliance with the
approved variance.
SUGGESTED MOTION: 1 move APPROVAL of the requested variance(s) with
the findings and conditions recommended by staff.
Page #5Spreen Setback Request
9N1TV
P.O. Box 568
Estes Park, Colorado 80517
(970)-586-4544
(970) 586-1049 Fax
January 06, 2010
Dave Shirk, Planner II
Town of Estes Park
P.O. Box 1200
Estes Park, CO 80517
Re: Variance Request
Spreen Residence
530 Heinz Parkway
Dear Dave,
The Upper Thompson Sanitation District submits the following comments for the above referenced
property:
1. The District has no objection to the proposed variance request.
If you have any questions or need further assistance, please do not hesitate to contact me.
Thank you,
Todd Krula
Lines Superintendent
cc: Andy Human
822 Alpine Drive
Estes Park, CO 80517
Memo
To: Bob Goehring
From: Reuben Bergsten
Date: 1-14-2010
1 -8-2---
Re: Variance Request, 530 Heinz Parkway
The Light and Power Department has reviewed the above referenced variance
request to be reviewed by the Estes Valley Board of Adjustment, and has the
following comments:
1) Town of Estes Park, Light and Power has no concems as to the variance
request.
2) For clarification, overhead power service is provided at the south western
comer of the asphalt drive/parking area. Overhead communication / cable TV
is located across Heinz Parkway at the southeast comer of the property. See
image below
1
Eliectric Service
to be undergraunded
Overhead Communication /
CATV
ra�rm�•,w,.!q60m77.�r,rr^wo,1,:v�,,.�r,
• Page 2
a�L
Page 1 of 3
Dave Shirk
From: Alison Chilcott
Sent: Thursday, January 07, 2010 11:02 AM
To: Dave Shirk
Subject: FW: 530 Heinz pkwy
From: Greg Sievers
Sent: Thursday, January 07, 2010 10:55 AM
To: Alison Chilcott
Subject: RE: 530 Heinz pkwy
Thanks for the clarification. It does appear our Town map is incorrect.
PW has no comment on this Board of Adjustments request. it appears unclear who the adjacent
backyard property owner is.
Greg Sievers, Project Manager
Town of Estes Park, Public Works Engineering
P.O. Box 1200
Estes Park, CO 80517
970-577-3586
From: Alison Chilcott
Sent: Thursday, January 07, 2010 10:06 AM
To: Greg Sievers
Subject: RE: 530 Heinz pkwy
Greg,
Here's what I found on the Larimer County website.
Alison
Parcel Number: 35263-11-006
Tax District: 3304
Schedule Number: R0576964
Current Mill Levy: 70.082
General Information
Owner Name & Address Property Address
SPREEN, LOUIS SCOTT 530 HEINZ PKWY
KENNEDY-SPREEN, MICHELE ESTES PARK 80517-0000
4642 229TH PL SE
SAMMAMISH, WA 98075
Subdivision #: 0202 - PARK ENTRANCE ESTATES
Neighborhood #: 33525
1/11/2010
IP
Statement of intent
Submitted to: Estes Valley Board of adjustment
For: Scott and Michele Spreen
530 Heinz Parkway, Estes Park, Co.
The attached application for a set back variance to construct a two car garage at the above
residence is based on the following>
• It is the only feasible site for a garage on the lot.
• It would be built on the existing driveway footprint.
• It would allow reasonable turn around space at the existing house level.
• The slope off of the edge of the south side of the existing driveway is very steep
and would require extensive and high retaining walls and backfill to locate a
garage there.
• The impact of building on the proposed location will have little or no impact on
adjoining properties.
• Building on the proposed location will have little or no visible ground damage to
the lot and is expected to make no unsightly impact on the existing lot and slopes.
• Alternative garage locations are non existent without major and cost prohibitive
earthworks.
Your consideration of this variance request is appreciated.
Andrew E. Human
for: Scott and Michele Spreen
ESTES VALLEY
BOARD OF ADJUSTMENT
APPLICATION
Submittal Date:
Record Owner(s): y 11164,4 tzc P'1-tr
Street Address of Lot: C3 o Hi~'An_
Legal Description Lot: Block:
Subdivision: rival Eivr itkr'c.T 14
Parcel ID #
Site Information
Lot Size
Existing Land Use
Proposed Land Use
Existing Water Service VTown
Proposed Water Service f""" Town
Existing Sanitary Sewer Service
Proposed Sanitary Sewer Service
Existing Gas Service Xcel
Site Access (if not on public street)
Are there wetlands on the site?
Variance
Specific variance desired (state development
„ Primary Contact Information
r Well - Other (Specify)
r Well r Other (Specify) N%l9
1' "' EPSD f'" UTSD 1 Septic
EPSD r UTSD f Septic
Other V.,, None
code section #): ' ��Lit
Name of Primary Contact Person nro y :4-41A-L,9A1
Complete Mailing Address
Primary Contact Person is i" Owner
Attachments
r 'Application fee (see attached fee schedule)
Statement of intent (must comply with standards set forth in Section 3.6.0 of the Estes Valley Development Code)
1 copy (folded) of site plan (drawn at a scale of 1" = 20') **
17 1 reduced copy of the site plan (11" X 17")
**The site plan shall include information in Estes Valley Development Code Appendix B.VII.5 (attached).
The applicant will be required to provide additional copies of the site plan after staff review
(see the attached Board of Adjustment variance application schedule). Copies must be folded.
V,Z I�&P,A' az Jrri PA2 C 20fl7
Applicant r Consultant/Engineer
APPIMPIMMIM
Town of Estes Park 4. P.O. Box 1200. 170 MacGregor Avenue 4. Estes Park, CO 80517
Community Development Department Phone: (970) 577-3721 4. Fax: (970) 586-0249 www.estesnei.com/ComDev
Revised 11 /6/2009
Record Owner(s)
Mailing Address
Phone
Cell Phone
Fax
Email
Sce
Applicant r
Mailing Address
Phone /'1 S'�6
Cell Phone 41 7
Fax 6
Email
,e.A„rL4E S?LEE
Consultant/Engineer
Mailing Address
Phone
Cell Phone
Fax
Email
APPLICATION FEES
For variance applications within the Estes Valley Planning Area, both inside and outside Town limits
See the fee schedule included in your application packet or view the fee schedule online
at www.estesnet.com/ComDev/Schedules&Fees/PlanningApplicationFeeSchedule.pdf.
All requests for refunds must be made in writing. All fees are due at the time of submittal.
APPLICANT CERTIFICATION
► I hereby certify that the information and exhibits herewith submitted are true and correct to the best of my knowledge
and that in filing the application I am acting with the knowledge and consent of the owners of the property.
► In submitting the application materials and signing this application agreement, I acknowledge and agree that the
application is subject to the applicable processing and public hearing requirements set forth in the Estes Valley
Development Code (EVDC).
► I acknowledge that I have obtained or have access to the EVDC, and that, prior to filing this application, I have had the
opportunity to consult the relevant provisions governing the processing of and decision on the application.
(The Estes Valley Development Code is available online at www.estesnet.com/ComDev/DevCode.)
► I understand that acceptance of this application by the Town of Estes Park for filing and receipt of the application fee by
the Town does not necessarily mean that the application is complete under the applicable requirements of the EVDC.
► I understand that this variance request may be delayed in processing by a month or more if the information provided is
incomplete, inaccurate, or submitted after the deadline date.
► I understand that a resubmittal fee will be charged if my application is incomplete.
► The Community Development Department will notify the applicant in writing of the date on which the application is
determined to be complete.
► I grant permission for Town of Estes Park Empioyees and Members of the Board of Adjustment with proper
identification access to my property during the review of this application.
► I acknowledge that I have received the Estes Valley Board of Adjustment Variance Application Schedule and that
failure to meet the deadlines shown on said schedule shall result in my application or the approval of my application
becoming NULL and VOID. I understand that full fees will be charged for the resubmittal of an application that has
become null and void.
► I understand that I am required to obtain a "Variance Notice" sign from the Community Development Department and
that this sign must be posted on my property where it is clearly visible from the road. I understand that the corners of
my property and the proposed building/structure corners must be field staked. I understand that the sign must be
posted and the staking completed no later than ten (10) business days prior to the Estes Valley Board of Adjustment
hearing.
O. I understand that if the Board of Adjustment approves my request, "Failure of an applicant to apply for a building
permit and commence construction or action with regard to the variance approval within one (1) year of
receiving approval of the variance shall automatically render the decision of the BOA null and void." (Estes
Valley Development Code Section 3.6.D)
Names:
Record Owner PLEASE PRINT:
. H S PR.i:l<nI /Inciffs-ztr /Cc NAd[ 11 y .<4/2
Applicant PLEASE PRINT: A E kr�►A M
Signatures:
Record Own
Applicant
Date
a.-
Zoning Districts
Table 4-2
§ 4.3 Residential Zoning Districts
Base Density and Dimensional Standards'Residential Zoning Districts
Zoning
Mild
Max. N
Denetty
(units/acre)
plynimh Lot .,
Standards [D) [67
(Ord.- 2�7:g 1)
Minimum j,bltdinglStrn
pjy
" [9] (Ord 25 7 11)-
B
M
lining
-, 4i ►}.
14nae
'(s f)
A
Width
{�M).
Fral ►( )
$IJ
.� ��
)
F1 (' )
hef h
�4 4Li ��., r
• `
RE-1
1110 Ac.
10 Ac.
200
50
50
30
20
RE
1/2.5 Ac.
2.5 Ac.
200
50
50
50
30
20
E-1
1
1 Ac. [3]
100
25
25
25
30
20
25-
E
2
Y2 Ac. [3]
75
arterials;
15-other
streets
10
15
30
20
25-
R
4
'/a Ac.
60
arterials;
15-other
streets
10
15
30
20
R-1
8
5,000
50
15
10
15
30
20
Single-family
25-
R-2
4
= 18,000;
60
arterials;
10
Duplex =
27,000
15-other
streets
10
30
20
RM
Residential
Uses:
M ax
40,000,
5,400 sq.
ft./unit
[4]
60;
Lots
25-
(Ord.
1 B-01
Min = 3nd
Senior
[8] (Ord.
25-07 § 1)
Greater
than
arterials;
15-other
10 [6]
10
30
20 [7]
#14)
Institutional
Living Uses:
Senior
Institutional
100,000
sq. ft.:
streets
Max 24
Living Uses:
200
Y2 Ac.
Notes to
Table 4-2:
[1] (a) See
Chapter 4, §4.3.D, which allows a reduction in minimum lot size (area) for single-family residential
subdivisions that are required to set aside private open areas per Chapter 4, §4.3.D.1.
(b) See Chapter 11, §11.3, which allows a reduction in minimum lot size (area) for clustered lots in open space
developments.
(c) See Chapter 11, §11.4, which allows a reduction in minimum lot size (area) for attainable housing.
(d) See Chapter 7, §7.1, which requires an increase in minimum lot size (area) for development on steep slopes.
(Ord. 2-02 §1)
[2] See Chapter 7, §7.6, for required setbacks from stream/river corridors and wetlands. (Ord. 2-02 #5; Ord. 11-02 §1)
[3] If private wells or septic systems are used, the minimum lot area shall be 2 acres. See also the regulations set forth in
§7.12, "Adequate Public Facilities."
[4] Townhome developments shall be developed on parcels no smaller than 40,000 square feet; however, each individual
townhome unit may be constructed on a minimum 2,000 square fool lot at a maximum density of 8 dwelling units per acre.
[5] All development, except development of one single-family dwelling on a single lot, shall also be subject to a maximum floor
area ratio (FAR) of .30 and a maximum lot coverage of 50%. (Ord. 25-07 §1)
[6] Zero side yard setbacks (known as "zero lot line developmenf") are allowed for townhome developments.
[7] Minimum building width requirements shall mt apply to mobile homes located in a mobile home park.
[8] Single-family and duplex developments shall have minimum lot areas of 18,000 s.f. and 27,000 s.f., respectively. (Ord 18-01
rf14)
[9] All structures shall be set back from public or private roads that serve more than four adjacent or off -site dwellings or
lots. The setback shall be measured from the edge of public or private roads, the edge of the dedicated right-of-way or
recorded easement or the property line, whichever produces a greater setback. The setback shall be the same as the
applicable minimum building/structure setback. (Ord. 11-02 §1; Ord. 25-07 §1)
[10] See Chapter 1, §1.9.E, which allows an Increase in the maximum height of buildings on slopes. (Ord. 18-02 #3)
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