Agenda 02/28/2013 sookane
Valle
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Spokane Valley Planning Commission Agenda
City Hall Council Chambers, 11707 E. Sprague Ave.
February 28, 2013 6:00 p.m.
I. CALL TO ORDER
II. PLEDGE OF ALLEGIANCE
III. ROLL CALL
IV. APPROVAL OF AGENDA
V. APPROVAL OF MINUTES: January 24, 2013
VI. PUBLIC COMMENT: On any subject that is not on the agenda
VII. COMMISSION REPORTS
VIII. ADMINISTRATIVE REPORT
IX. COMMISSION BUSINESS
1. OLD BUSINESS:
a. Finding of Fact: CTA-01-13 Amendment to the Spokane Valley Municipal
Code.
2. NEW BUSINESS:
b. Study Session: CTA-02-13 Amendment to the Spokane Valley Municipal
Code. SEPA Categorical Exemptions.
X. FOR THE GOOD OF THE ORDER
XI. ADJOURNMENT
COMMISSIONERS CITY STAFF
BILL BATES -CHAIR JOHN HOHMAN,CD DIRECTOR
KEVIN ANDERSON SCOTT KUHTA,PLANNING MGR,AICP
CHRISTINA CARLSEN LORI BARLOW,SENIOR PLANNER
ROBERT MCCASLIN
STEVEN NEILL
JOE STOY-VICE CHAIR CART HINSHAW,SECRETARY
W W W.SPOKANEVALLEY.ORG
CITY OF SPOKANE VALLEY
Request for Planning Commission Action
Meeting Date: February 28, 2013
Item: Check all that apply: ❑ consent ® old business ❑ new business
❑ public hearing ❑ information ❑ admin.report ❑ pending legislation
FILE NUMBER: CTA-01-13
AGENDA ITEM TITLE: Findings of Fact—Amendment to the Spokane Valley Municipal Code
DESCRIPTION OF PROPOSAL: A city initiated text amendment to amend Spokane Valley
Municipal Code (SVMC) 19.120, Permitted Use Matrix, and Table 19.60-1, Commercial Development
Standards,to allow Townhouses in the Neighborhood Commercial Zone as a permitted use.
GOVERNING LEGISLATION: RCW 36.70A.106; SVMC 17.80.150 and 19.30.040
PREVIOUS ACTION TAKEN: Chapter 19.120, Permitted Use Matrix, was amended by City Council
on September 25, 2012 (Ordinance No. 12-022). A study session with the Planning Commission was
conducted on January 24,2013.
BACKGROUND: On September 25,2012, City Council adopted a significant amendment to Chapter
19.120,Permitted Use Matrix,making a number of changes,mostly to the office and mixed use zones.
Most of the changes expanded the uses allowed in these zones. One change recommended to the
Planning Commission and Council was to remove Townhouses as a permitted use in the Neighborhood
Commercial (NC)zone. This proposal would make Townhouses a permitted use in the NC zone.
The Planning Commission conducted a study session on January 24,2013,followed by a public hearing
on February 14,2013. Following the public hearing,the Planning Commission voted unanimously to
approve the proposed amendment.
RECOMMENDED ACTION OR MOTION: Move to approve proposed findings for CTA-01-13,to
allow Townhouses as a permitted use in the Neighborhood Commercial zone.
STAFF CONTACT:
Scott Kuhta,AICP,Planning Manager
ATTACHMENTS:
A. Findings and Recommendations, CTA-01-13
CTA-04-12 RPCA for Study Session
ATTACHMENT A
FINDINGS AND RECOMMENDATIONS
OF THE SPOKANE VALLEY PLANNING COMMISSION
February 28,2013
The following findings are consistent with the Planning Commission's decision to recommend approval.
Background:
1. Spokane Valley development regulations were adopted in September 2007 and became effective on
October 28,2007.
2. The city-initiated code text amendment proposes to amend Spokane Valley Municipal Code (SVMC)
19.120, Permitted and Accessory Uses and Table 19.60-1-Commercial Development Standards, to
allow Townhouses in the Neighborhood Commercial (NC)Zone as a permitted use.
3. The Planning Commission held a public hearing on February 14, 2013 and voted 5-0 to recommend
approval of the amendment to City Council.
Planning Commission Findings:
1. Compliance with SVMC 17.80.150F Approval Criteria
a. The proposed city initiated code text amendment is consistent with the applicable provisions of
the Comprehensive Plan;
Finding(s):
i. Land Use Goal LUG-1 Preserve and protect the character of Spokane Valley's residential
neighborhoods.
ii. Land Use Policy LUP-1.3 Review and revise, as necessary, existing land use regulations to
provide for innovation and flexibility in the design of new residential developments,
accessory dwelling units and in-fill development.
iii. Land Use Goal LUG-2 Encourage a wide range of housing types and densities
commensurate with the community's needs and preferences.
iv. Land Use Goal LUG-4 Provide neighborhood and community scale retail centers for the
City's neighborhoods.
v. Land Use Policy LUP-4.4 Encourage Mixed-use residential and commercial and office
development in Neighborhood Commercial designations where compatibility with nearby
uses can be demonstrated.
vi. Housing Goal HG-1: Encourage diversity in design to meet the housing needs of the
residents of the community and region.
vii. Housing Policy HP-1.1: Consider the economic impact of development regulations on the
cost of housing.
viii. Economic Goal EDG-7: Maintain a regulatory environment that offers flexibility,
consistency,predictability and clear direction.
ix. Economic Policy EDP-7.2: Review development regulations periodically to ensure clarity,
consistency and predictability.
Findings and Recommendations of the Spokane Valley Planning Commission Page 1 of 2
ATTACHMENT A
x. Neighborhood Policy NP-2.2: Review and revise as necessary, existing land use
regulations to provide for innovation and flexibility in the design of new residential
developments, accessory dwelling units, and in-fill development.
b. The proposed amendment bears a substantial relation to public health, safety, welfare, and
protection of the environment.
Finding(s):
i. Allowing Townhouses in Neighborhood Commercial zones will provide flexibility for
property owners to develop their property with uses other than office or commercial.
ii. The amendment will provide increased housing options and more opportunity for infill
residential development.
iii. The public health, safety, welfare, and protection of the environment are furthered by
ensuring that the City's development regulations are consistent with goals and policies in
the adopted Comprehensive Plan.
2. Conclusion(s):
a. The proposed city initiated code text amendment is consistent with the City's adopted
Comprehensive Plan and the approval criteria contained in SVMC 17.80.150F.
b. The Growth Management Act (GMA) stipulates that the comprehensive land use plan and
development regulations shall be subject to continuing review and evaluation by the City.
Recommendations:
The Spokane Valley Planning Commission therefore recommends City Council adopt the proposed city-
initiated code text amendments to SVMC 19.120, Permitted and Accessory Uses and Table 19.60-1-
Commercial Development Standards.
Approved this 28th day of February,2013
Bill Bates,Chairman
ATTEST:
Can Hinshaw,Planning Commission Secretary
Findings and Recommendations of the Spokane Valley Planning Commission Page 2 of 2
CITY OF SPOKANE VALLEY
Request for Planning Commission Action
Meeting Date: February 28, 2013
Item: Check all that apply: ❑ consent ❑ old business ® new business
❑ public hearing ❑ information ® admin.report ❑ pending legislation
FILE NUMBER: CTA-2013-0002
AGENDA ITEM TITLE: Study session—Amendment to the Spokane Valley Municipal Code
DESCRIPTION OF PROPOSAL: A city initiated text amendment to amend Spokane Valley
Municipal Code (SVMC) 21.20.040 SEPA Categorical Exemptions, to adopt the maximum exemption
levels allowed by WAC 197-11-800(1)(d).
GOVERNING LEGISLATION: RCW 36.70A.106; WAC 197-11-800(1) ( c ); SVMC 17.80.150 and
19.30.040
PREVIOUS ACTION TAKEN: None
BACKGROUND: Washington State Department of Ecology was directed by the 2012 Legislature to
complete two rounds of updates to the SEPA rules(Chapter 197-11 WAC). The Legislature directed
Ecology to modernize the rules that guide state and local agencies in conducting SEPA reviews,in light
of the increased environmental protections in place under Growth Management Laws (RCW 36.70A),the
Shoreline Management Act(RCW 90.58) and other laws. The legislation set up two rounds of rule
updates: A narrowly-focused initial round(targeted to be complete by December 31,2012 and a broader
round of SEPA rule updates during 2013.The initial rule making considered two specific topics:
• Increasing the thresholds for SEPA review of minor construction projects under Washington
Administrative Code (WAC) 197-11-800(1) and(23)(c); and
• Improving the efficiency of the environmental checklist in WAC 197-11-960.
The update became effective January 28,2013, and allows the city to increase the maximum exemption
levels requiring environmental review as described in the attached staff report,thereby reducing permit
review times and eliminating redundancy in the review process. This proposal would amend the current
SEPA rules to reflect the maximum thresholds allowed by State Law.
RECOMMENDED ACTION OR MOTION: No action recommended at this time. The Planning
Commission will conduct a public hearing and consider the proposed amendment on March 14,2013.
STAFF CONTACT:
Lori Barlow,AICP, Senior Planner
ATTACHMENTS:
A. Staff Report and Findings CTA-2013—0002
B. Proposed Amendment
CTA-2013-0002 RPCA for Study Session
ATTACHMENT A
COMMUNITY DEVELOPMENT DEPARTMENT
somiane/O0 F� PLANNING DIVISION
STAFF REPORT AND RECOMMENDATION TO THE
lle PLANNING COMMISSION
CTA-2013-0002
STAFF REPORT DATE: Feb. 20,2013
HEARING DATE AND LOCATION: March 14, 2013, beginning at 6:00 p.m., Spokane Valley City Hall
Council Chambers, Valley Redwood Plaza Building, 11707 East Sprague Avenue, Suite 101, Spokane
Valley,Washington 99206.
PROPOSAL DESCRIPTION: A city initiated text amendment to amend Spokane Valley Municipal Code
(SVMC) 21.20.040 SEPA Categorical Exemptions, to adopt the maximum exemption levels allowed by
WAC 197-11-800(1)(d).
PROPONENT: City of Spokane Valley Community Development Department, 11707 E Sprague Ave,
Suite 106, Spokane Valley,WA 99206
APPROVAL CRITERIA: Spokane Valley Comprehensive Plan, Spokane Valley Municipal Code (SVMC)
Title 17 General Provisions.
SUMMARY OF RECOMMENDATION: The Planning Division recommends the Planning Commission
approve the proposed amendment as put forth.
STAFF PLANNER:LORI BARLOw,AICP, Senior Planner, Community Development Department
ATTACHMENTS:
Exhibit 1: Proposed text amendment to SVMC 21.20.040
A. BACKGROUND INFORMATION
1. APPLICATION PROCESSING: SVMC Chapter 17.80, Permit Processing Procedures. The
following summarizes application procedures for the proposal.
Process Date
Pre-Application Meeting: N/A
Application Submitted: N/A
Determination of Completeness: N/A
Published Notice of Public Hearing: 2/22/2013 and 3/8/2013
Sent Notice of Public Hearing to staff/agencies: To be completed by 2/28/13
Staff Report and Recommendation CTA-2013-0002
2. PROPOSAL BACKGROUND: The proposal is to amend Spokane Valley Municipal Code (SVMC)
Chapter 21.20 State Environmental Policy Act(SEPA)to increase the thresholds for specific land
use categories that would trigger environmental review under SEPA. SEPA is a Washington
State law that requires the majority of land use decisions made by every state and local agency to
be reviewed for environmental impacts. The Department of Ecology is the state agency
responsible for SEPA oversight.
Ecology was directed by the 2012 legislature to complete two rounds of updates to the SEPA
rules(Chapter 197-11 WAC). The legislature directed Ecology to modernize the rules that guide
state and local agencies in conducting SEPA reviews,in light of the increased environmental
protections in place under Growth Management Laws(RCW 36.70A),the Shoreline
Management Act(RCW 90.58)and other laws. The legislation set up two rounds of rule updates:
A narrowly-focused initial round(targeted to be complete by December 31,2012 and a broader
round of SEPA rule updates during 2013.The initial rule making considered two specific topics:
• Increasing the thresholds for SEPA review of minor construction projects under Washington
Administrative Code (WAC) 197-11-800(1) and(23)(c); and
• Improving the efficiency of the environmental checklist in WAC 197-11-960.
Senate Bill 6406 directed Ecology to convene a SEPA Advisory Committee to assist Ecology in
updating the SEPA exemption thresholds and the environmental checklist. Scott Kuhta,Planning
Manager,participated in the Advisory Committee representing the only jurisdiction from the east
side of the state.
The reason to increase the thresholds for SEPA review is to make the process more efficient and
reduce redundancy. Each SEPA review process requires agency and public notice, followed by
subsequent comment and appeal periods. The purpose of the review is to identify impacts that
would not be addressed by city regulations. If impacts are identified,jurisdictions can
"condition"projects with special requirements,or mitigation. Traffic impacts generated by new
development are commonly mitigated through the SEPA process.
However,with the resulting code requirements associated with GMA, SMA,and other laws
protecting the environment,most jurisdictions have the codes in place to ensure impacts are
addressed and/or prevented. As this is the case with Spokane Valley,the SEPA review for minor
construction projects is an exercise in redundancy and does not result in any meaningful project
modifications or mitigation. The resulting impact of the review is an increase in the time period
necessary to complete project review and issue permits by 4—6 weeks. Reducing the amount of
review time is advantageous to the development community in many ways,including financing,
facilitating construction windows,maintaining project schedules,etc..
SEPA rules identify default thresholds for"Minor New Construction"that exempt a project from
SEPA review. If the project is equal to,or smaller than the exempt level,environmental review is
not required. The default thresholds are identified in the table below. The rules,even prior to the
recent legislative update, allowed jurisdictions to adopt flexible thresholds and increase the
applicable project threshold that would exempt a project from SEPA review. These are the
thresholds being modified by the legislative update, as well as the city's code text amendment.
The City adopted the flexible thresholds in the 2007 Spokane Valley Municipal Code. The
current"Minor New Construction-Flexible Thresholds" adopted by the City and identified in
SVMC section 21.20.040 Categorical exemptions are identified in the table below.
Page 2 of 5
Staff Report and Recommendation CTA-2013-0002
Minor New Construction—
Minor New Construction -Default Thresholds Flexible Thresholds(Current
City Regulations)
(i)The construction or location of four detached single family residential (i)20 dwelling units.
units.
(ii) 30,000 square feet.
(ii)The construction or location of four multifamily residential units.
(iii) 12,000 square feet; 40
(iii)The construction of a barn, loafing shed, farm equipment storage automobiles.
building, produce storage or packing structure, or similar agricultural
structure, covering 10,000 square feet, and to be used only by the (iv) 40 automobiles.
property owner or his or her agent in the conduct of farming the
property. This exemption shall not apply to feed lots. (v) 500 cubic yards.
(iv)The construction of an office,school, commercial, recreational,
service or storage building with 4,000 square feet of gross floor area,
and with associated parking facilities designed for twenty automobiles.
This exemption includes stand-alone parking lots.
(v)Any landfill or excavation of 100 cubic yards throughout the total
lifetime of the fill or excavation not associated with an exempt project in
subsection (b)(i), (ii), (iii), or(iv); and any fill or excavation classified as
a Class I, II, or III forest practice under RCW 76.09.050 or regulations
thereunder.
The legislative update to the rules revised and clarified language relating to the "residential", "parking
lot" and"landfill and excavation" categories of minor new construction by separating thresholds for
single family projects from multi-family projects, and eliminating the differentiation between stand alone
parking lots and parking lots associated with primary uses. As a result of the new categorization, the
changes to the flexible thresholds are not just an increase to the units, area, automobiles, etc. The update
became effective January 28, 2013, and allows the city to increase the maximum exemption levels
requiring environmental review as indicated in the table below. These are the new thresholds proposed
for adoption by this amendment.
Fully planning GMA counties All other counties
Other
Incorporated and unincorporated Incorporated and
Project types unincorporated UGA areas unincorporated areas
Single family residential 30 units 20 units 20 units
Multifamily residential 60 units 25 units 25 units
Barn, loafing shed, farm 40,000 square feet 40,000 square feet 40,000 square feet
equipment storage,
produce storage or
packing structure
Office, school, 30,000 square feet and 12,000 square feet 12,000 square feet
commercial, recreational, 90 parking spaces and 40 parking and 40 parking
service, storage building, spaces spaces
parking facilities
Landfill or excavation 1,000 cubic yards 1,000 cubic yards 1,000 cubic yards
Page 3 of 5
Staff Report and Recommendation CTA-2013-0002
B. FINDINGS AND CONCLUSIONS SPECIFIC TO THE MUNICIPAL CODE TEXT
AMENDMENT
1. Compliance with Title 17(General Provisions) of the Spokane Valley Municipal Code
a. Findings:
SVMC 17.80.150(F)Municipal Code Text Amendment Approval Criteria
i. The City may approve Municipal Code Text amendment,if it finds that
(1) The proposed text amendment is consistent with the applicable provisions of the
Comprehensive Plan;
Staff Analysis: The proposed amendment is consistent with the applicable policies
of the Comprehensive Plan which direct the city to provide effective,predictable,and
clear customer service.
Relevant Comprehensive Plan goals and policies are shown below:
Introduction Goal G-1: Create a government that places a premium on providing
effective customer service.
Introduction Policy IP-1: The City should periodically evaluate programs,
procedures,processes and other opportunities of reaching the customer service goal.
Economic Goal EDG-7: Maintain a regulatory environment that offers flexibility,
consistency,predictability and clear direction.
Economic Policy EDP-7.2: Review development regulations periodically to ensure
clarity,consistency and predictability.
(2) The proposed amendment bears a substantial relation to public health,safety,
welfare, and protection of the environment;
Analysis: The amendment bears substantial relation to public health, safety,welfare
and protection of the environment. The proposed amendment will provide efficient,
predictable, and clear customer service while meeting the requirements for
environmental review contained in WAC 197-11-800-(1)(d).
b. Conclusion(s):
The proposed text amendment is consistent with the approval criteria contained in the SVMC.
2. Finding and Conclusions Specific to Public Comments
a. Findings:
No public comments have been received to date.
b. Conclusion(s):
Public noticing has not been initiated for CTA-1-13 as of this date.
3. Finding and Conclusions Specific to Agency Comments
a. Findings:
No agency comments have been received to date.
b. Conclusion(s):
No concerns are noted.
Page 4 of 5
Staff Report and Recommendation CTA-2013-0002
C. OVERALL CONCLUSION
The proposed code text amendment is consistent with the Comprehensive Plans policies and goals.
D. STAFF RECOMMENDATION
The Planning Division,after review and consideration of the applicable approval criteria,recommends the
proposal to adopt the maximum to adopt the maximum exemption levels allowed by WAC 197-11-800-
(1)(3).
Page 5 of 5
CTA-2013-0002
Proposed Changes increasing the Flexible Thresholds in the Categorical
Exemptions Section of SVMC 21.20.040 consistent with WAC 197-11-800
21.20.040 Categorical exemptions.
Categorical exemptions are set forth in WAC 197-11-800.
A. Application. If a proposal fits within any of the exemptions set forth in this section, the proposal shall be
categorically exempt from the threshold determination requirements of WAC 197-11-720, except as
follows:
1. The proposal includes an activity that is not exempt under WAC 197-11-908, Critical areas; or
2. The proposal is a segment of a proposal that includes a series of actions, physically or
functionally related to each other, some of which are categorically exempt and some of which
are not; or
3. The proposal includes, or is a part of, a series of exempt actions that are physically or
functionally related to each other and that together may have a probable significant adverse
impact in the judgment of an agency with jurisdiction.
B. Flexible Thresholds. The City adopts the following exempt levels for new construction pursuant to WAC
197-11-800(1)(c):
1. For single family residential dwelling units, up to 22 30 dwelling units.
2. For multifamily residential dwelling units, up to 60 units
23._For agricultural structures, up to 30,000 square feet. For barn, loafing shed, farm equipment
storage, produce storage or packing structure buildings up to 40,000 square feet
43. For office, school, commercial, recreational, service or storage buildings, up to 12,000
30,000 square feet of gross floor area and with associated parking facilities designed for up to 40-
90 parking spaces.
4. For parking lots, up to/10 parking spaces.
5. For landfills and excavations, up to 5-09 1,000 cubic yards.
C. Procedure. The agency or applicant may proceed with the exempt aspects of a proposal prior to
conducting environmental review of the nonexempt aspects of a proposal; provided, that the requirements
of WAC 197-11-070 are met.
D. Written Findings. The lead agency is not required to document that a proposal is categorically exempt;
however, the lead agency may note on an application that a proposal is categorically exempt or place
such a determination in the agency's files. (Ord. 07-015 § 4, 2007).
Spokane Valley Planning Commission
DRAFT Minutes
Council Chambers— City Hall, 11707 E. Sprague Ave.
February 14, 2013
I. CALL TO ORDER
Chair Bates called the meeting to order at 6:00 p.m.
II. PLEDGE OF ALLEGIANCE
Commissioners, staff and audience stood for the pledge of allegiance
III. ROLL CALL
COMMISSIONERS Present Absent CITY STAFF
Bill Bates-Chair Erik Lamb,Deputy City Attorney
Joe Stoy—Vice Chair Scott Kuhta,Planning Manager
Steven Neill
Kevin Anderson r '
Christina Carlsen r E
Robert McCaslin p r
Can Hinshaw, secretary
Commissioner Neill was excused from the Planning Commission Meeting.
IV. APPROVAL OF AGENDA
Commissioner Stoy made a motion to approve the agenda as presented. This motion was
passed unanimously.
V. APPROVAL OF MINUTES
Commissioner McCaslin made a motion to approve the January 24, 2013 minutes as
presented. This motion was passed unanimously.
VI. PUBLIC COMMENT
There was no public comment.
VII. COMMISSION REPORTS
Commissioner McCaslin stated that he attended his father's memorial in Olympia. Chair Bates
stated that applications are being accepted by March 4, 2013 for the vacant Planning
Commission seat. March 12, 2013 the City Council decides who will take the seat.
Planning Commission Minutes Page 1 of 3
VIII. ADMINISTRATIVE REPORTS
Planning Manager Scott Kuhta reviewed the Commission's Advanced Agenda.
IX. COMMISSION BUSINESS
A. Unfinished Business:
There was no unfinished business.
Public Hearing: Opened at 6:14 PM.
Seeing no one testified the Public Hearing closed at 6:20 PM.
B. New Business:
Planning Manager Scott Kuhta provided an over view of CTA-01-13, a proposal amendment to
allow Townhouses in the Neighborhood Commercial zone. Mr. Kuhta reviewed the proposed
setbacks and maximum height standards for Townhouses in the NC zone, specifically that the
standards in the R-4 would be used. The following sections would be amended if approved:
1. 19.60.070 Supplemental Permitted Use Regulations.
2. Table 19.60-1 Commercial Development Standards.
3. Table 19.40-1 Residential Zone Dimensional Standards (in feet).
Commissioner Carlson asked about lot coverage standards. Mr. Kuhta stated that the NC zone
does not have maximum lot coverage standards and that the open space, storm water, parking
and setbacks would limit lot coverage.
Commissioner Anderson pointed out that the R-4 zone requires a minimum 5-foot setback
while the regulations in 19.40-1 specify a 6-foot minimum setback and asked which one is
correct. Mr. Kuhta responded that the 6-foot setback would be between the Townhouse
buildings and the 5 foot setback would be from the adjacent lot. Mr. Anderson then asked why
the definition of a Townhouse states that it must have 3 attached units while the standards in
19.40-1 says 6 units attached together. Mr. Kuhta responded that the two sections must read
together, that a Townhome must have at least 3 units attached by definition and not more than
6 units attached per the standards in 19.140-1
Commissioner Anderson then inquired about the zoning difference between a Townhouse and
a duplex. Deputy City Attorney Erik lamb stated a duplex is a single building on one lot. A
town house is a separate lot and separate ownership. Chair Bates had concerns that if a
developer came to the city and wanted to put townhouses in a Neighborhood Commercial zone
that we would have to go thru this whole process again. Mr. Kuhta reassured Chair Bates that
once the permitted use is put back in the code, then the property owner would only need a
building permit.
Commissioner Anderson was curious why the legends are different colors on the Municipal
map and zoning maps. Mr. Kuhta stated he will take a look at that and make sure it's consistent
within the map.
Planning Commission Minutes Page 2 of 3
Commissioner Carlsen made motion to allow Townhouses houses in the Neighborhood
Commercial Zone as a permitted use. Planning Commission voted unanimously 5-0 to
recommend approval of CTA-01-13.
GOOD OF THE ORDER
There was nothing for the good of the order.
X. ADJOURNMENT
The being no other business the meeting was adjourned at 6:25 p.m.
Bill Bates, Chairperson
Can Hinshaw, PC Secretary
Date signed
Planning Commission Minutes Page 3 of 3