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HomeMy WebLinkAbout01-18 Comments (2)Marian Harders, AICP, LEED AP Planner (703) 680-4664 Ext. 5121 mharders r thelandlawyersxom Federal Express WALSH CoLUCC1 I.UBELEY & WALSH PC February 13, 2018 Frederick County Department of Planning & Development Attn: Candice Perkins 107 North Kent Street Winchester, VA 22601 (540) 665-5651 Re: Rezoning Application, Stonewall IV Equus Capital Partners, Ltd. (Applicant) Property Identification No.: 43 A 21, 43 A 21B, 43 19 4 & 43 A 24 (the "Property') Dear Ms. Perkins: Enclosed please find a package containing the following items to be filed in connection with the above -referenced Rezoning application: 1. One (1) copy of the executed Rezoning application fotfn signed by the property owners. 2. One (1) CD ROM containing digital copies all the submission material identified herein. 3. One (1) copy of the Property Location Map. 4. One (1) copy of the "Adjoining Property Owners" list. 5. One (1) copy of the real estate tax records for each property, showing no taxes due. 6. One (1) copy of the Impact Analysis Statement, dated February 13, 2018. 7. One (1) copy of the draft Proffer Statement, dated February 13, 2018. 8. One (1) copy of the cultural resources report entitled "Cultural Resource Survey and Assessment of Glengary (BDHR #034-1099), prepared by Dutton & Associates, dated October 2017. 9. One (1) copy of the Transportation Impact Analysis entitled "Stonewall IV," prepared by Kittelson & Associates, dated December 2017. ATTORNEYS AT LAW 703 680 4664 Y WWW. THELANDLAWYERS.COM 4710 PRINCE WILLIAM PARKWAY i SUITE 300 1 WOODBRIDGE, VA 22192-5199 ARLINGTON 10.3 528 4700 1 LOUDOUN 703 737 3633 Planning and Development February 13, 2018 Page 2 10. One (1) copy of the General Development Plan entitled "Stonewall IV," prepared by Dice Engineering, PLC, dated February 12, 2018. Once you have had an opportunity to review the application together with the supporting documents, please contact my office if you require additional information Kindly return your review comments to my attention, Marian Harders c/o Walsh, Colucci, Lubeley & Walsh, 4310 Prince William Parkway, Suite 300, Woodbridge, VA 22192. Sincerely, WALSH, COLUCCI, LUBELEY & WALSH, P.C. Marian B. Harders, AICP, LEED AP MBH Enclosures: As stated cc: Dan DiLella (email only) John Knott (email only) Dennie Dunlap (email only) P0788664.DOC Marian Harders, MCP, LEED AP Planner (703) 680-4664 Ext. 5121 mharders@,thelandlawyers. corn WALSH COLUCCI LUBELEY & WALSH PC April 12, 2018 Federal Express Frederick County Department of Planning & Development Attn: Candice Perkins 107 North Kent Street Winchester, VA 22601 (540) 665-5651 Re: Rezoning Application, Stonewall IV Equus Capital Partners, Ltd. (Applicant) Property Identification No.: 43 A 21, 43 A 21 B, 43 19 4 & 43 A 24 (the "Property') Dear Ms. Perkins: In connection with the above, please find the following items to be filed in connection with the above -referenced Rezoning application: 1. One (1) copy of the executed Rezoning application form signed by the property owners. The original application form was submitted to your office on February 14, 2018. 2. A check in the amount of $18,891.00, made payable to County of Frederick. 3. A copy of the death certificate for John S. Morris, Jr. 4. One (1) copy of the Property Location Map. 5. One (1) copy of the "Adjoining Property Owners" list. 6. One (1) copy of the real estate tax records for each property, showing no taxes due. 7. One (1) copy of the Impact Analysis Statement, dated April 12, 2018. S. One (1) copy of the Proffer Statement, dated April 12, 2018. 9. One (1) copy of the General Development Plan entitled "Stonewall IV," prepared by Dice Engineering, PLC, dated April 5, 2018. 10. One (1) CD ROM containing digital copies all the submission material identified Herein. ATTORNEYS AT LAW 703 680 4664 1 WWW THELANDLAWY ERS COM 4310 PRINCE WILLIAM PARKWAY t sUI'rE 300 t WOODBRIDGE, VA 22192-5199 ARLINGTON 703 528 4700 1 LOUDOUN 703 737 3633 Candice Perkins April 12, 2018 Page 2 On February 14, 2018, the following documents were submitted to your office and are referenced here as part of our formal application: 1. A copy of the cultural resources report entitled "Cultural Resource Survey and Assessment of Glengary (BDHR #034-1099), prepared by Dutton & Associates, dated October 2017. 2. A copy of the Transportation Impact Analysis entitled "Stonewall IV," prepared by Kittelson & Associates, dated December 2017. We offer the following in response to the several comments received from reviewing agencies regarding the draft rezoning application, dated February 13, 2018. Where appropriate changes have been made to the Proffers submitted and the Impact Analysis has been revised as needed: Planning and Development, March 19, 2018 Agency Comment Applicant Response 1. Northeast Land Use Plan - Land Use. The 2035 Comprehensive Plan and the Northeast Land Use Plan. provide The Applicant concurs that this application is guidance on the future development of consistent with the Comprehensive Plan, and the property. The property is located that it is accessible to public utilities, being within the SWSA. The 2035 located within the Sewer and Water Service Comprehensive Plan identifies these Area. properties with an industrial land use designation. The proposed M1 Zoning .is Transportation issues are addressed in detail in generally consistent with the Northeast response to the comments from the Land Use Plan as it relates to this area. Transportation Department and VDOT, below. The land use plan depicts future Route 37 on the western boundary of the properties and access to Route 37 from Lenoir Drive. The application. fully addresses future Route 37 through the property; however, the access to Route 37 is not acknowledged in the impact statement or the proffers. 2. Generalized Develon--tnetit. The GDP The GDP has been updated, as recommended should be revised to remove all by Staff. buildings, the GDP should be more general and show the property, proffered Candice Perkins April 12, 2018 Page 3 improvements, access and buffers. The GDP should also be reduced to 11x17 or 8%x11. 3. Proffer 1. - #evelOQMe) t and Use of the Proffer #1 has been revised. Please see the Prol2ertv. Proffer 1.1 states that two detailed response to the Department of buildings will be constructed, given there Transportation comments below, based on is a gross square footage cap, it appears changes to the ITE Trip Generation Manual, the requirement for two structures may 10th Edition. not be necessary. Also, consider eliminating use limitation for warehousing and distribution. 4. Proffer 3 - Utilities. Proffer 3.1 requires Comment noted. This Proffer has been deleted the use of public water and sewer and the per Staff's recommendation. These are matters construction of improvements to provide for final site plan and applicable ordinances such service. This proffer should be will be complied with. removed as it is already required. Only requirements above and beyond all County requirements should be provided in a proffer statement. 5. -Proffer 4. S tXwCtjnwa te r Comment noted. This Proffer has been deleted I'�taRacenveEdt/Iavioner.9:t. Stormwater per Staff's recommendation. These are matters management is a site development for final site plan and applicable ordinances requirement. Existing County will be complied with. requirements should be removed. Only requirements above and beyond all County requirements should be provided in a proffer statement. 6. Proffer 6 -• Lig°rtirr1. Building mounted Comment noted. This Proffer has been deleted and pole mounted lighting and. the use of per Staff's recommendation. These are matters downcast full cutoff fixtures are required for final site plan and applicable ordinances by the Zoning Ordinance. Only will be complied with. requirements above and beyond all County requirements should be provided in a proffer statement. 7. Access Easenientb The access easement Please see the comments below with respect to to parcel 43-A-23 does not align with the Transportation. proposed access to the subject properties off Lenoir Drive. Provide clarification on The Applicant is aware of the access easement Candice Perkins April 12, 2018 Page 4 the location of these two entrance points. to the identified parcel, and has no intention of Staff recommends that the Applicant cutting off access to it, or of improperly work with the residential property to interfering with the easement. relocate the access easement to align with the new entrance proposed on Lenoir Drive. This is also the general location of the future coruiection to existing Route 37 identified in the Comprehensive Plan (see comment 1). 8. Transportation CortiYaents. Please note Response to the Transportation and VDOT that the transportation comments on the comments are set out below. rezoning application from John Bishop, Assistant Director - Transportation, are being provided to you in a separate letter. Staff may also provide additional comments related to the proposed changes if warranted subject to adjustments requested by VDOT. 9. Agency Com nne zss, Please provide Responses to agency comments are provided appropriate agency comments from the below. following agencies: Virginia Department of Transportation, Frederick County Department of Public Works, Frederick County Fire Marshal, Frederick Water, Virginia Department of Health, the County Attorney, the Historic Resources Advisory Board (DRAB) and the Frederick -Winchester Service Authority. 1.0. Fees. Based on the fees adopted by the A check in the amount of $18,891.00 is Board of Supervisors on April 23, 2008, included with this submission package. the rezoning fee for this application would be $18,891.00 based upon acreage of 88.91. acres County Attorney, March 20, 2018 Agency Comment Applicant Response 1. Title to one of the parcels (43 -A -21B) is in A copy of the death certificate for Mr. John S. the name of Cheryl G. Morris and John S. Morris, Jr. is provided with this submission. Morris, Jr. husband and wife as tenants by Candice Perkins April 12, 2018 Page 5 the entireties, with common law right of survivorship. I understand from the signature line on proffer statement that Mr. Morris is deceased. We will need submission of sufficient evidence of that fact, such as the type of statement typically included under oath, in a deed conveying property so titled reciting the fact of the death of one of the tenants by the entireties. 2. In the heading section of the Proffer The signature block in the Proffer Statement Statement Equus is identified as Equus has been revised to reflect Equus Capital Capital Partners, Ltd. and in the signature Partners.. Ltd. block it is identified as Equus Capital Partners, LP. I realize that Virginia corporate law may have certain naming requirements that conflict with those of the state law of entity formation, resulting in the use of a different suffix in Virginia but the use of the suffix should nonetheless be consistent throughout the Proffer Statement. 3. In the first paragraph of the introduction, the These corrections have been made. action is twice referred to as a "proffer amendment". These references should instead be to a "rezoning" 4. In the second paragraph of the introduction, The second paragraph of the Proffer Statement the definition of the term "Applicant" should has been modified per Staff's recommendation. be expanded to include the current owner of the Subject Property as well. 5. The third paragraph of the introduction does The third paragraph has been deleted for not seem to fit where it has been placed. The clarity. provisions of the Proffer Statement are not limited merely to instances in which specific plans or exhibits reference them. 6. Proffer 2 - The area indicated to be dedicated The Applicant's engineer has compared the for Route 37 right of way does not GDP with the Board's action of December 12, necessarily appear to encompass a sufficient 2017, and has advised the Applicant that the Candice Perkins April 12, 2018 Page 6 portion of the right of way area as shown by the Comprehensive Plan depiction on the County's GIS. Staff will want to confirm the extent of the proposed dedication area. 7. Proffers 3, 4, and 6 - Most of the provisions of these proffers simply restate ordinance requirements and, to that extent, are not appropriate for inclusion in the Proffer Statement. 8. Proffer 5 - The proffer should indicate payment simply to Frederick County and not the Frederick County Board of Supervisors. 9. Signature blocks - Because, among other things, we require that proffer statements, once a rezoning is approved, be recorded in the land records, any and all signatures will need to have notarizations. area shown for dedication on the GDP matches the area identified for the Proposed Route 37 interchange. As noted above, Proffers 3, 4 and 6 have been deleted. These are matters for final site plan and applicable ordinances will be complied with. Proffer 5 has been revised per Staff's comment. Comment noted. A notary block has been added to the signature page for both the Applicant and the Owner. Frederick County Department of Transportation, March 28, 2018 Agency Comment 1. Ti afiic: Shtdi - Land. Use. The traffic study uses 820,000 sq. ft. of high cube warehouse. This results in daily trips of 1,378. This trip generation is significantly lower than the standard warehouse worst case scenario of uses that could potentially populate this property under the Ml Zoning District and your proffer statement as currently written. Specifically, the trip generation is significantly lower than the standard warehouse distribution trip generation. While proffer 1.1 does limit the property use to warehouse and distribution, it does not make the distinction of high cube. This is a significant discrepancy impacting the veracity of the Traffic Impact Analysis. This is most easily addressed with a clarification within the Applicant Response After these comments were received, the Institute of Transportation Engineers (ITE) published, and the Virginia Department of Transportation adopted, the 10th Edition of its Trip Generation Manual. The TIA was developed using the Ninth Edition. This has a direct bearing on the case, and on the proper drafting of the Proffers in response to the Department's understandable comment. A "Warehouse" (ITE Land Use Code 150), which was the initially proffered use, is defined as "a building primarily devoted to the storage of materials, but it may also include office and maintenance areas." The Department is correct that under the Ninth Edition of the ITE a pure warehouse would have been considered to generate far more trips per day than a "high - cube" warehouse — which is what the TIA had Candice Perkins April 12, 2018 Page 7 proffer statement. I modeled, and what the Applicant had intended. According to this new Edition, however, estimated trips generated by a "warehouse" have been reduced dramatically, and the proposed warehouse here would generate a weekday average of only 1,341 trips, slightly fewer than the 1,378 trips that were employed in the TIA — for a high -cube warehouse. It is unnecessary, therefore, to alter the proffer to eliminate warehousing as a use. The ITE Manual now recognizes that warehousing will not generate trips that exceed what was modeled in the TIA. This has been the Applicant's actual experience at its other facilities in Frederick County and elsewhere, and now the technical studies have, in effect, caught up with its practical experience. The category of land use formerly identified as High -Cube Warehousing (HCW), has now been broken into three separate categories with dramatically differing trip generation characteristics. There is no longer a Land Use Code 152. A High -Cube Transload and Short Term Storage Warehouse (ITE Land Use Code 154) is defined as "a building that typically has at least 200,000 gross square feet of floor area, has a ceiling height of 24 feet or more, and is primarily used for the storage and/or consolidation of manufactured goods prior to their distribution to retail locations or other warehouses. A typical HCW has a high level of on-site automation and logistics management. The automation and logistics enable highly efficient processing of goods through the HCW. The HCWs included in this land use include transload and short-term facilities. Transload facilities have a primary function of consolidation and distribution of pallet loads Candice Perkins April 12, 2018 Page 8 2. t o"iLoa c hexisiye Ilya- 1 aste.r•n. Road Plan, The Eastern Road Plan portion of the County Comprehensive plan calls for ramp access from Lenoir Drive to Route 37. The site layout and proffers, as currently submitted, does not allow for this future connection to take place. This is an important connection that, when constructed, offers significant positive traffic impacts to the surrounding area and this site. Participating in this for manufacturers, wholesalers, or retailers." In this instance, such a high -cube facility would generate an estimated 1,148 average weekday trips. The Applicant specializes in High -Cube Transload and Short Term Storage Warehousing, but in order to provide itself market flexibility it wishes to retain the right to use any structures that may be permitted for the Property, and under the new ITE Manual that would include both Warehousing (LUC 150) and High -Cube (LUC 154). Therefore, the Applicant has edited Proffer 1.1 to clarify the uses on the property will be restricted to warehousing uses as those defined by Land Use Codes 150 and 154, as set out in the ITE Manual, 10th Edition. The Applicant respectfully observes that the Comprehensive Plan also calls for the construction of an interchange between Proposed Route 37 and existing Route 37 with northbound ramps commencing roughly 600 feet from the point that any "slip ramp" from Lenoir Drive could reasonably connect with existing Route 37. According to Kittelson & Associates, the construction of such a slip ramp would meet neither VDOT nor AASHTO ' As noted, the ITE has abandoned Land Use Code 152 and now has four Codes for warehousing activities. LUC 150 remains "Warehouse," and LUC 154 is the High -Cube Transload and Short Term Storage Warehouse. In addition, there are two new subcategories. LUC 155 is a "High -Cube Fulfillment Center," a building that is defined as a High -Cube Transload Warehouse, but a fulfillment center warehouse includes structures "characterized by a significant storage function and direct distribution of ecommerce products to end-users. These facilities typically handle smaller packages and quantities than other types of HCWs and often contain multiple mezzanine levels." LUC 156 for a "High -Cube Parcel Hub Warehouse," is again defined as is a High -Cube Transload structure, but such a warehouse "typically serve[s] as regional and local freight -forwarder for time -sensitive shipments via air freight and ground carriers. These sites also often include truck maintenance, wash, or fueling facilities." Both LUC 155 and 156 generate as much as 5 to 6 times the traffic of LUCs 150 and 154. The Applicant does not intend to construct either such facility on the Subject Property. Candice Perkins April 12, 2018 Page 9 improvement is particularly important due to the proposed development traffic that is being added to an already overburdened network and particularly intersections such as Route 11 and Welltown Road which the TIA clearly demonstrates are/will be functioning below level of service C. standards. It is also the case that the Applicant neither owns nor controls the right-of-way necessary to complete any connection of Lenoir Drive to existing Route 37. Furthermore, this is an improvement the need for which is not generated by this project, but which is more generally required by the public necessity and planning. According to the Traffic Impact Analysis submitted by Kittelson, the relevant intersections that were required to be studied are already functioning below LOS C, but at an acceptable level of service. By 2020 Total Traffic Conditions, assuming the Applicant is permitted to industrial warehouse buildings totaling 820,000 square feet, with primary access via a single full - access driveway along Lenoir Drive are estimated to generate approximately 1,378 net new weekday daily trips, 90 weekday a.m. (62 in, 28 out), and 98 weekday p.m. (30 in, 68 out) peak hour trips. Under these conditions all study intersections are anticipated to operate at LOS D or better during all study time periods under 2020 build out conditions. They are doing so at the present. By the 2026 Design Year all study intersections that currently operate at LOS D or better during all study time periods will continue to do so. This is with the exception of the US Route 11/1-81 Northbound Ramp Terminal/Redbud Road intersection during the weekday p.m. peak period. This connection is forecast to continue to operate at LOS E during the weekday p.m. peak hour. This drop in service, however, is due exclusively to background growth and not to this project. Candice Perkins April 12, 2018 Page 10 Thus, based on the results of the analysis, with which VDOT agrees, no off-site transportation improvements are recommended. All study intersections are projected to continue to operate acceptably, assuming full build -out of the Stonewall IV development. Notwithstanding this, and in recognition of the County's continued insistence on the eventual viability of the slip ramps, the Applicant's engineer has relocated the entrance into the development off of Lenoir Drive so that it will not preclude the future construction of those ramps by others, nor will it interfere with or impede or require the relocation of the easement that provides access to the Jenkins Parcel, 43A-23. 3. Route 37. Regarding the proffer for the The Applicant's engineer has compared the Route 37 right-of-way, I would suggest GDP with the Board's action of December 12, adding language in addition to being 2017, and has advised the Applicant that the consistent with the GDP that it is consistent area shown for dedication on the GDP matches with the Eastern Road Plan update adopted the area identified for the Proposed Route 37 by the Board of Supervisors on December interchange. 13, 2017. This way, if there is any unintentional disconnect between the GDP and what was adopted by the Board, the intent is clear. VDOT, March 9, 2018 Agency Comment Applicant Response VDOT Staunton District Planning performed a Acknowledged. review of the Stonewall IV Rezoning TIA completed by Kittelson & Associates, Inc. submitted on February 14, 2018. Overall, the methodology used for the analysis was found to be acceptable and no revisions are required. The comments below are offered as reference notes for minor issues we found. Candice Perkins April 12, 2018 Page 11 1. Typos were found on some of the lane Acknowledged. group level of service figures, where the LOS shown does not match the correctly reported LOS shown on the corresponding traffic conditions tables. 2. For future reference, please ensure Acknowledged. coordinated phases match the provided signal plans. For this corridor, all signals should be programmed with phases 2 and 6 as the coordinated phases. Only the Rt. 11/Redbud Rd signal is currently programmed with only phase 2 as the coordinated phase. This does not appear to have a substantial impact for this TIA, so no revisions are required. 3. The Rt. 11/Redbud Rd eastbound left turn Acknowledged. was modeled with a 3 second lost time adjustment in both the AM and PM peak hours. VDOT requires that this setting be 0 for all movements. Since this setting degrades signal performance rather than improving it, no revisions are required. 4. The Rt. 11/Redbud Rd eastbound and Acknowledged. westbound left turns are modeled with permissive- protected operation, but actually operate using flashing yellow arrows. The turn type for these movements should be programmed using the "Dallas permissive + protected" setting with the "Permitted Flashing Yellow" box checked. This does not appear to have a substantial impact for this TIA, so no revisions are required. 5. The TIA scoping form identifies ITE Land See the detailed and revised response to the Use Code 152, High -Cube Warehouse / Department of Transportation comments Distribution Center as the trip generation above. With the advent of the 10th Edition of for the proposed rezoning development, the ITE Manual the situation has changed which was utilized in the technical analysis sufficiently that the Applicant's address of this of the study. However, Proffer 1.1, dated issue has changed so as to remove this as an Candice Perkins April 12, 2018 Page 12 February 13, 2018 indicates the issue. development of the property will be limited to 820,000 square feet, used solely for warehousing and distribution. The High - Cube Warehouse / Distribution Land Use is much less intense in character than traditional warehouse / distribution uses, which have the potential to double the trip generation utilized in the traffic analysis of the study. VDOT District Planning recommends consideration of adjusting the proffer to identify the allowable use to be more in-line with the definition of Land Use Code 152 in the most current ITE Trip Generation Manual or limit the permitted daily trip generation of the site to 1,378 as specified in the TIA. 6. The 2035 Frederick County See the response to the Department of Comprehensive Plan Northeast Frederick Transportation comment above. Area Plan identifies a future transportation improvement of a ramp connection to Route 37 south from Lenoir Drive. The current layout of the site as illustrated on the GDP proposes the development entrance at the current termini of Lenoir Drive, which would be in conflict with the future improvement. VDOT District Planning would recommend adjustments to the layout of the site to be in conformance with the Frederick County Comprehensive Plan. Department of Public Works, March 12, 2018 Agency Comment Applicant Response A detailed review shall occur at the time of site Acknowledged. plan submission. Candice Perkins April 12, 2018 Page 13 Department of Fire and Rescue, Office of the Fire Marshal, February 15, 2018 Agency Comment I Applicant Response Plan approval status = APPROVE I Acknowledged. No comments. Frederick -Winchester Service Authority, February 19, 2018 Agency Comment Applicant Response Capacity consideration deferred to FrederickI Acknowledged. Water. Frederick Water, February 22, 2018 Agency Comment 1 PJ - 3 The project parcels are located within the sewer and water service area (SWSA) and in an area presently served by Frederick Water. SWSA enables access to public water and sewer service by county policy. Location within the SWSA does not guarantee that sanitary sewer and water capacities are available to serve the property. The rezoning application proffer states that the proposed use will be limited to a warehouse and distribution facility on no larger than 820,000 gross square feet. The impact analysis statement is silent of the proposed water and sewer demands. Facilities for conveyance of water to, and sanitary sewer from, the subject properties do presently exist. Until the proposed uses' Applicant Response Acknowledged. These issues will be accommodated a final site plan. Comment noted. Proposed water and sewer demands are addressed in the revised Statement of Justification provided with this submission. It is impossible to project proposed demand for sewer and water usage until an end user is obtained but as noted below, warehousing facilities do not require much sewer or water service and the actual needs can be determined and accommodated at final site plan. Acknowledged. Warehousing facilities have minimal demand for sewer, and both sewer and water usage will be determined when an end Candice Perkins April 12, 2018 Page 14 projected water and sewer demands are user is obtained. known, it is unknown if the existing conveyance network has the capacity to accommodate the projected demands. 4. The proffer statement is silent on Acknowledged. These are matters that will be improvements that would be constructed by determined at final site plan, as the Authority the Applicant to meet water and sanitary recognizes. sewer demands. Accordingly, the comments offered herein are general in nature. The ultimate decision regarding the ability to serve the property with adequate water and sanitary sewer will be determined at the time the site's use is determined, conveyance facilities are constructed, and water and sewer connection fees are paid to Frederick Water. Sanitary sewer system capacity is not reserved until the sewer connection fee is paid to Frederick Water, and physical connection to the system is made. 5. Water and sanitary sewers are to be Acknowledged. constructed in accordance with the FCSA standards specifications. Dedicated easements may be required and based on the layout vehicular access will need to be incorporated into the final design. 6. Please be aware that the FCSA is offering Acknowledged. these review comments without benefit of knowledge of the projected water and sewer demands of the site. Department of Parks and Recreation, February 16, 2018 Agency Comment Applicant Response This application appears to meet Parks and Acknowledged. Recreation requirements. Candice Perkins April 12, 2018 Page 15 Historic Resources Board, March 28, 2018 Agency Comment Applicant Response i; I�, iiF,a �. ;,� t� ,t =�f 11- tori: 1,_cso-QrcF_s The Applicant has proffered to prepare a (i lltl> ,._s On!e a I,t jr� i- l> ;acs t on the HABS level III for the residential structure - s }rs*� c., i,.o,,nrt r #034-1099 ile.: jgr located on the subject property. This has been 't addressed in the Proffer Statement. i -Js sti'uct Ire is poi, nbaiiy eligible -16or file Nasional register of Historic P':•.acf s. After i4 iC hC' this .Tl .i1�11 ?,1)d i1he A,-'J'06:'ca!,..!.is the *: }vis i t tioa?d'}RAL} {!1 R:r_Yvall ofi Uitis yvitj t tc; t;)l.(io >1'itio.: I x 3 ;�Y;.1C.ar_i, perform .� tsLOl i c Bu l di l,, Slii r _-'y O 1A 13', S-aii .i.: 111 J F l`s 31;; ";< cl?';;' Site. ,.uscF,t! > t\1Pli: t v _;s .:i�, a'trL. z✓re:'a :�:� `''%L'`,.i.3 Ci r S�t�dii• :.iii'=el Eiatlo r of 11i o i c a I Once you have had an opportunity to review the application together with the supporting documents, please contact my office if you require additional information Sincerely, WALSH, COLUCCI, LUBELEY & WALSH, P.C. I /Z -- Marian B. Harders, AICP, LEED AP Enclosures: As stated Candice Perkins April 12, 2018 Page 16 cc: Dan DiLella (email only) John Knott (email only) Dennie Dunlap (email only) P0799579.DOC