HomeMy WebLinkAboutRecommendation Sheet PLANNER 10/16/2008
:City of Springfield .
Development Services Department
225 Fifth Street
Springfield, OR 97477
LAND DIVISION TENTATIVE PLAN
Staff Report & Decision
SPRINGFIELD
~-
Project Name: Brandt-Drury Partition .
Project Proposal: Partition. one lot (4 acres)
. . to create three parcels
Case Number: SUB2008-00016
Project Location: 6595 Main Street
17-02-34-44, TL 1200
Zoning: Medium Density Residential (MDR)
Overlay District(s): Hillside Development (HD)
Applicable Refinement Plan: N/A
Refinement Plan Designation: N/A
Metro Plan Designation: Medium Density Residential (MDR)
Pre-Submittal Meeting Date: February 26, 2008
Application Submittal Date: March 6, 2008
DRe Meeting Date: April 1 , 2008
Decision Issued Date: April 11, 2008
Recommendation: Approval with Conditions
Appeal Deadline Date: April 26; 2008
Associated Applications: PRE2008-00013 (PRE), lON2007-00051 (DIM), DRC2005-00007 (SPR)
POSITION REVIEW OF NAME
I Planner II Land Use Planning Molly Markarian 726-4611
I Transportation Planninll Engineer Transportation Gary McKenney 726-4585
I Public Works Civil Engineer Utilities, Sanitary & Storm Sewer Eric Walter 736-1034:
I Deputy Fire Marshal Fire and Life Safety Gilbert Gordon 726-2293
I Enqineering Technician SUB Electric Utilities I Guenter Matvszak 736-3296
I Civil Engineer I SUB Water Utilities I Rebecca Templin 726-2396
I Service Planning Manager L T8 Facilities I Will Mueller 682-6194:
rABBl!Ic~Nrrl1'SjOE~EUCl)BMENrr~REMIEWlllE;t\M~l~Iir'.,~1
Owner/Applicant Applicant~s Representative
Michael Brandt-Drury . Stacy Salladay
7906 Thurston Road . ... J j ~fIf1ch Engineering, Inc.
Springfield, OR 97478 . Date Received:J!!J (ie. ~ Fifth Street
PIaMe~ LD J(}~qfield,OR 97477
Case No. SUB200B-00016
I b{;11
10111
DEelSION
This staff report and decision grants approval with conditions to the subject application, as of the date
of this decision. The standards of the Springfield Development Code (SDC) applicable to each criterion
of approval are listed herein and are satisfied by the submitted plans and notes (see Appendix A)
unless specifically noted in this decision with findings and conditions necessary for compliance. The
plat, as well as the installation of public and private improvements, must conform to the approved
tentative plan or as conditioned herein. This is a limited land use decision made according to city code
and state statutes. Unless appealed, the decision is final. Please read this document in its entirety.
REVIEW PROeESS
This application has been reviewed under the procedures listed in SDC 5.1"130, Type II Applications,
and SDC 5.12-100, Land Divisions - Partitions and Subdivisions. This application was accepted as
complete on March 6, 2008, and this decision is issued on the 36th day of the 120 days permitted per
ORS 227.178.
eOMMENTS REeEIVED
Applications for Type II limited land use decisions require notification of property owners and occupants
within 300 feet of the subject property and any applicable neighborhood association, allowing for a 14-
day comment period on the application per SDC 5.1-130. The property'owner, applicant, if different,
and parties submitting written comments during the comment period have appeal rights and are mailed
a copy of this decision for consideration. In accordance with SDC 5.1-130, notice was mailed to the
property owners and occupants within 300 feet of the subject property on March 10, 2008.
No written comments were received during the comment period. .
SITE INFORMATION
The subject property is a 4 acre (174,012 square feet), reversed L-shaped lot on the south side of Main
Street between 65'h Place and 6th Street and is located inside t~e City limits. The northern half of the ,
property is relatively flat while the southern half of the property is steeply sloped to the southwest, and
soils are mapped as Dixonville-Philomath-Hazelair Complex-43C, Pengra Silt Loamc105A, and Coburg-
Urban Land Complex-32.
Currently, the northern half cif the property has a delineated wetland, as well asa development on it,
including a single-family detached house, a four-plex, and two duplexes, all of which take 'access from a .
driveway off Main Street. . These existing structures and associated site development, including
required recreation areas, were approved via Site Plan Review Case No. DRC2005-00007. There are
also two right-of-ways that have been reserved for future right-of-way dedication, Aster Street on the
northern half of the property, and Dogwood Street on the southern half of the property. The property is
encumbered by a deed restriction prohibiting future development beyond the existing development until
such a time as one or both of those right-of-ways are constructed and provide local street access to the
southern half of the property.
. While property in the vicinity of the subject property is zoned both Low Density Residential and Medium
Density Residential, the property is zoned and designated, Medium Density Residential. Land
immediately surrounding the property to the north, west, south,' and northeast is zoned Low Density
Residential while adjacent property to the southeast is zoned Me<!ium Density Residential.
LAND DiViSIONS - PARTITIONS AND SUBDIVISIONS - TENTATIVE PLAN eRITERIA
SDC 5.12-125 states that an application shall be approved or approved with conditions upon
determination that the criteria listed in SDC 5.12-125 A. through J. have been satisfied and that if
conditions cannot be attached to satisfy the approval criteria, the~pplication shall be denied.
eriterion 11SDe 5.12-125 A.I
The request conforms to the provisions of this Code pertaining totoVparcel size and dimem{ons.
Case No. SUB200B.00016 Date Received: 0 1f.tJ 0
Planner: Ii)
~
Finding: SDC 3.2-215 states that on standard parcels on east-west streets in all residential zoning
districts, the minimum area' shall be 4,500 square feet, and the minimum street frontage shall be 45
feet. In addition, SDC 3.2-215 states that on panhandle parcels in all residential zoning districts, the
minimum area in the pan porti9n shall be 4,500 square feet, and the minimum street frontage shall be
26 feet for multiple panhandles with individual frontage based on the number of panhandles.
Finding: SDC 3.2-215 stipulates minimum parcel sizes and dimensions for parcels within the Hillside
Development Overlay District (HD) that are larger than those outside the district. The HD standards
apply to the subject property since as stated in SDC 3.3-510, the HD standards apply in residential
zoning districts to development areas below 670 feet in elevation where any portion of the development
area exceeds 15% slope. However, given the intent of the HD as outlined in SDC 3.3-505, the fact that
the northern half of the property, which is essentially flat, is already fully developed, and the fact that
the southern half of the property, which triggers the HD, cannot be developed until local street access is
provided for the southern half of the property, the HD standards will not be applied to the subject land
division. However, any future land divisions or development south of the Aster Street future right-of-
way dedication shall be .subject to the HD standards.
Finding: The applicant proposes to create three parcels as follows:
I Parcel
I 1
I 2
I 3
Parcel Tvpe
Standard
Panhandle
Panhandle
Area
17,837 sq, ft.
143,890 sq. ft.
6,052 sq. ft.
Street Frontage
84 ft.
13 ft.
13 ft.
Street Name
Main Street
Main Street
Main Street
Street T vpe I
East-West I
East-West I
East-West '
.Finding: This application meets the requirements of SDC 3.2-215.
Conclusion: This application satisfies Criterion 1 (SDC 5.12-125 A).
Criterion 21SDe 5.12-125 B.I
The zoning is consistent with the Metro Plan diagram and/or applicable Refinement Plan diagram, Plan
District map, and Conceptual Development Plan.
Finding: The subject property is zoned Medium Density Residential and is designated
Medium Density Residential by the Metro Plan diagram ,and there is no applicable refinement plan.
There are no applicable Plan District maps or Conceptual Development Plans for this property, and no
change to the zoning designation or boundaries is proposed.
. Conclusion:' This application satisfies Criterion 2 (SDC 5.12-125 8.).
eriterion 3ISDe5.12-125 C.l
Capacity requirements of public'and private facilities, including but not limited to water and electricity;
sanitary sewer and storm water management facilities; and streets ahd traffic safety controls shall not
be exceeded and the puplic improvements shall be available to serve the site at the time of
development, unless otherwise provided for by this Code and other applicable regulations. The Public
Works Director or a utility provider shall determine capacity issues.
Finding: The Development Review Committee (DRC), including representatives from the City's
Development Services Department, Public Works Department, and Fire and Life Safety Department, as
well as the Springfield Utility Board (SUB) reviewed the application, and their comments have been
incorporated into the findings and conditions below.
Finding: Criterion 3 contains two categories of development standards with sub-sections. The
application as submitted complies with any applicable sub-sections of the development standards
unless otherwise noted with specific findings and conditions. The development standards relating to
/0 It&/or .
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. <"? m (I
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Case No. SUB200B.00016
Date Received:
Planner. W
30111
Criterion 3 include but are not limited to the infrastructure standards discussed in SDC 4.1-100, 4.2-
100, and 4.3-100:
4.2-100 Infrastructure Standards -
Transportation
4.2-105 Public Streets
4.2-110 Private Streets
4.2-115 Block Length
4.2-120 Site Access and Driveways
4.2"125 Intersections
4.2-130 Vision Clearance
4.2-135 Sidewalks
4.2-140 Street Trees
4.2-145 Street Lighting
4.2-150 Bikeways
4.2"155 Pedestrian Trails
4.2-160 Accessways
4.3-100 Infrastructure Standards-,.
Utilities
4.3-105 Sanitary Sewers
4.3-110 Stormwater Management
4.3-115 Water Quality Protection
4.3-120 Utility Provider Coordination'
4.3-125 Underground Placement of Utilities
4.3-130 Water Service and Fire Protection
4.3-135 Major Electrical Power Transmission Lines
4.3-140 Public Easements
4.3-145 Wireless Teleco.mmunications Systems Facilities
Street Trees
Finding: 4.2-140 B.1. states that existing trees may meet the requirement for street trees (i.e. trees on
the City Street Tree List specified in the EDSPM) if excavation 'or filling for proposed development is
minimized within the dripline of the tree.
Finding: .The application indicates that four scattered trees exist approximately 15 - 20 feet behind the
sidewalk fronting proposed Parcel 1. Since these trees do not meet the EDSPM requirements for
location or type of tree, they may not be considered street trees. . However, photos from a City staff site
visit in October 2007 in preparation for the Development Issues Meeting associated with this application
indicated that the trees identified on the plans do not exist on the 'property. However, there are three
actual street trees located in the front yard setback of proposed Parcel 1. The actual existing stre'et
trees on the site are adequate to meet the requirements of SDC 4.2-140.
Condition 1:. Excavation or filling in the vicinity of the existil')g street trees, as well as any future
removal of these trees, must conform to the standards of the SDC and EDSPM. Since' these street
trees are located on private property, maintenance of the trees shall be performed by the property
owner as per SDC 4.2-140 C.2.
Finding: As conditioned above, this application meeets the requirements fo SDC 4.2-140.
Sanitarv Sewers. Storm water Manaaement Utilitv Provider Coordination. & Water Service and
Fire Protection .
Finding: SDC 4.3-105, 110, 120, and 130 outline the utility infrastructure st~ndards of the City. As
stated previously, the subject property has an approved Site Plan, Case No. DRC2005-00007. As
such, existing facilities and easements are adequate to meet the requirements of SDC 4.3-105., 110,
120, and 1'30, as long as all easements proposed on the Tentative Plan are also recorded.
Condition 2: Prior to plat approval, the applicant shall record and document on the plat all utility and
drainage easements proposed on the Tentative Plan.
Finding: As conditioned above, this application meets the requirements of SDC 4.3-105, 110, 120,
and 130. .
Conclusion: This applic.ation satisfies Criterion 3 (SDC 5.12-125 C.) as conditioned herein.
Date ReCE;ill",ecl: I 0 I, G 10 zr .
Planner. V~ D.tCut;drv
. . i~11
Case No. SUB200B.00016
40111
eriterion 41SDC 5.12-125 DJ
The proposed .land division shall comply with all applicable public and private design and construction
standards contained in this Code and other applicable regulations.
Finding: Criterion 4 contains four categories of development standards and requirements. As such,
the application must comply with the development standards of SDC Chapter 4 not addressed by
Criterion 3, as well as the development standards for the applicable zoning district not addressed by
Criterion 1. In addition, the application must comply with the requirements of any applicable overlay
district andlor refinement plan. The application as submitted complies with the applicable development
standards and requirements unless otherwise noted with specific findings and conditions. The
development standards and requirements relating to Criterion 4 include but are not limited to the
fu~~: .
Chapter 4 - Development Standards
4.4-100 Landscaping, Screening, & Fence
Standards
4,5-100 On-Site Lighting Standards
4.6"100 Vehicle Parking, Loading, & Bicycle
Parking Standards
4.7-100 Specific Development Standards for. .
Certain Uses
4.8-100 Temporary Uses
Applicable Overlay District
3.3-500 Hillside Development
3.2-200 Residential Zoning Districts
3.2-215 Base Zone Development Standards
3.2-220 Additional Panhandle Lot/Parcel
Development Standards.
3.2-225 Base Solar Development Standards
3.2-230 Cluster Subdivisions
3.2-235 Residential Manufactured Dwellings
3.2-240 Multi-Unit Design Standards
Applicable Refinement Plan
No refinement plans apply to the subject propert~
Base Zone Deve/onment Standards
Finding: SDC 3.2-205 states that in Medium Density Residential (MDR) districts, development must
fall within the density range of eleven to twenty dwelling units per acre (du/acre) and that fractions will
be rounded down to the next whole number.
Finding: The density for proposed Parcels 1, 2, and.3 are 12 dulacre, .59(0) dulacre, and 9 dulacre,
respectively. While Parcels 2 and 3 do not meet minimum density standards, development beyond that
which already exists on the property is not possible until local street access is provided on or abutting
the property, Th'erefore, as long as a conceptual future developrT]ent plan ensures that the overall
minimum density can be met for those parcels, this application'can meet the requirements of SDC 3.2-
205.
Finding: The conceptual future development plan submitted with this application only showed the
possibility for an additional 32 dwelling units to be constructed on "the southern portion of Parcel 3,
which would still result in Parcels 2 and 3 not meeting the minimum density standards for MDR districts.
However, on April 7, 2008, the applicant submitted a revised conceptual future development plan
showing the potential for a minimum of 36 additional dwelling units to be constructed on the southern
portion of Parcel 3. The existing dwelling units on Parcels 2 and 3, as well as the conceptual future
development plan, result in the potential for the total acreage of Parcels 2 and 3 to meet the density
standards of the SDC in MDR districts. .
Finding: This application meets the requirements of SDC 3.2-20'5:
Multi-Unit Desian Standards
Finding: As part of Site Plan Review Case No. DRC2005-00007, the applicant was required to provide
active'and passive recreation areas, trash receptacles, and vehicular and bicycle parking spaces in
conformance with the Multi-Unit Design Standards outlined in SDC 3.2-240 D. Existing facilities are'
Case No. SUB200B.00016 . Date Received: /O/J,Ip/Of 50111
Planner: W )).e{){<;UJf\:) >>:b II
adequate to meetthe requirements of the SDC as long as the easements proposed on the Tentative
Plan are recorded and include joint maintenance agreements.
Condition 3: Prior to plat approval, the applicant shall record and document on the plat all jOint use
and access easements proposed on the Tentative Plan. In addition, the applicant shall include in such
easement documents joint maintenenace agreements.
Finding: As conditioned above, this application meets the requirements of SDC 3.2-240 D.
Conclusion: This application satisfies Criterion 4 (SDC 5.12-125 D.) as conditioned herein.
eriterion 5 IS De 5.12-125 E. \
Physical features, including, but not limited to: steep slopes with unstable soil or geologic conditions;
areas with susceptibility of flooding; significant clusters of trees and shrubs; watercourses shown on the
WQLW Map and their associated riparian areas; wetlands; rock outcroppings; open spaces; and areas
of historic and/or archaeological significance, as may be specified in Section 3.3-900 or ORS 97.740-
760, 358.905-955 and 390.235-240, shall be protected as specified in this Code or in State or Federal
law.
',1
Finding: The Metro Plan and any applicable refinement plans, Water Quality Limited Watercourses
Map, State Designated Wetlands Map, Hydric Soils Map, Natural Resources Map, Wellhead Protection
Zone Map, FEMA Maps, Willamalane Park and Recreation Comprehensive Plan, and the list of Historic
Landmark sites have been consulted, and there are features needing to be protected or preserved on
the subject property.
Finding: A wetland was delineated and Department of State Lands (DSL) permits were obtained for
. the subject property as part of Site Plan Case No. DRC2005"00007. The wetland, identified as M3 and
not locally significant on the City's Local Wetland Inventory, is located on the northern half of the
property, south of the southernmost existing dwelling units. Since the subject application involves only
land division and no actual structural development, no additional protection of the wetland is required at
this time beyond that which was previously required at the time of Site Plan Review.
Finding: If any historic or archaeological artifacts are discovered during construction, ORS 97.740-
760, 358.905-955, and ORS '390.235-240 may apply. If any human remains are discovered during
construction, it is a Class C"felony to proceed under ORS 97.745,
Conclusion: This application satisfies Criterion 5 (SDC 5.12-125 E.).
Criterion 6/SDe 5.12-125 F.l,
Parking areas and ingress-egress points have been designed to: facilitate vehicular traffic, bicycle and
pedestrian safety to avoid congestion; provide connectivity within the development area and to adjacent
residential areas, transit stops, neighborhood activity centers, and commercial, industrial and public
areas; minimize driveways on arterial and collector streets as specified in this Code or other applicable
regulations and comply with the ODOT access management standards for State highways.
Finding: The DRC, including representatives from the City's Public Works Department and the Oregon
Department of Transportation (ODOT), reviewed the application, and their comments have been
incorporated into the findings and conditions below.
Finding: Installation of driveways on a street increases the number of traffic conflict points. The
greater number of conflict points increases the probability of traffic crashes. Therefore, SDC 4.2-120
A.1. states that all developed parcels shall have an approved access to a public street or alley along
the frontage of the property, a private street that connects to the public street system, or a public street
by an irrevocable joint uselaccess easement serving the subject property. .
Case No. SUB200B-00016
Date ReceiVed: /0 I (("lo '(
Planner. (j) ~&WYL b ~ I \
60111
Finding: The application indicates that existing access to' the subject property is via a 20-foot wide
concrete driveway .onto Main Street near the east property line, and the applicant has proposed
keeping this access for Parcels 1, 2, and 3, The applicant has proposed access easements along the
driveway, parking, and walkway areas of the subject property to continue to provide access for all three
parcels onto Main Street.
Finding: SDC 3.2-220 A.4. states that no more than four lotslparcels or eight dwelling units shall take
primary access from one multiple panhandle driveway: The proposed land division would result in the
nine existing dwelling units taking primary access from a multiple panhandle driveway. However, given
that the driveway was approved to serve nine dwelling units as part of Site Plan Review Case No.
DRC2005-00007 and the panhandle standards are only being triggered due to the division of the
existing developed land, SDC 3.2-220 A.4. will not be applied to the subject land division.
Finding: Existing facilities, as well as Condition 4 above, are sufficient to meet the requirements of
SDC 4.2-120 A.1. and SDC 3.2-220 A.4. .
Finding: SDC 4.2-130 states that all parcels shall maintain a clear area at each access to a public
street in order to provide adequate sight distance for approaching traffic,
Finding: SDC 4.2-130 B. states that no screen or'other physical obstruction is permitted between two
and a half feet and eight feet above the established height of the curb in. the triangular area. SDC 4.2-
130 C. states that the triangular area for driveways is ten feet along each property line.
Condition 4: Vision clearance areas shall, be maintained at each access to a public street as per SDC
4.2-130.
Finding: As conditioned above, this application meets t~e requirements of SDC 4.2-130.
Conclusion: This.application satisfies Criterion 6 (SDC 5.12-125 F.) as conditioned herein.
eriterion 71SDe 5.12-125 G.I.
Development of any remainder of the property under the same ownership can be accomplished as
specified in this Code.
Finding: No property under the same ownership remains. Therefore, Criterion 7 is not applicable.
Conclusion: This application satisfies Criterion 7 (SDC 5.12-125 G.).
eriterion8 ISDe 5.12~125 H. \
Adjacent land can be developed or is provided access that will allow its development as specified in this
Code. .
Finding: Adjacent land is currently developed with residential dwellings and has access to public
streets by way of direct frontage.
Conclusion: This application satisfies Criterion 8 (SDC 5.1.2-125 H.).
eriterion 9 (SDe 5.12-125 1.\
Where the Partitiof! of property that is outside of the city limits but within the City's urbanizable area and
no concurrent annexation application is submitted, the standards ,specified in SDC 5.12-12,51. 1. and 2.
shall also apply.
Finding: The subject property is located inside the city limits. Therefore, Criterion 9 is not applicable.
Conclusion: This application satisfies Criterion 9 (SDC 5.12-1251.).
Case No. SUB200B_00016
Date ReceiVed; lol/tplo(
Planner: W ~. ((
1- ();;)
70111
eriterion 10 ISDe 5.12-125 J.\
Where the Subdivision of a manufaCtured dwelling park or mobile. home park is proposed, the approval
criteria in SDC 5.12-125 J. 1. through 7. apply:
Finding: The application does not propose the subdivision of a manufactured dwelling park or mobile
home park. Therefore, Criterion 10 is not applicable.
Conclusion: This application satisfies Criterion 10 (SDC 5.12c125 J.).
SUMMARY OF eONDlTIONS OF APPROVAL
NOTE: This summary of the conditions of approval is provided as a courtesy to the applicant. The
applicant should, however, carefully read the decision in its entirety to understand the basis for each
condition. In addition, as stated earlier, the applicant must comply with the entire decision, and the plat,
as well as the installation of public and private improvements, must conform to the approved tentative
plan or as conditioned herein.
1. Excavation or filling in the vicinity of the existing street trees, as well as any future removal of
these trees, must conform to the standards of the SDC and EDSPM. Since these street trees
are located' on private property, maintenance of the trees shall be performe~ by the property
owner as per SDC 4.2-140 C.2.
2. Prior to plat approval, the applicant shall record and document on the plat all utility and
drainage easements proposed on the Tentative Plan.
3. Prior to plat approval, the applicant shall record and document on the plat all joint use and
access easements proposed on the Tentative Plan. In addition, the applicant shall include in
such easement documents joint maintenenace agreemel']ts.
4. Vision clearance areas shall be maintained at each access to a public street as per SDC 4.2-
130.
eONeLUSION
The application, as submitted and conditioned herein, complies with the ten criteria listed in SDC 5.12-'
125 A. through J. The tentative plan approved as submitted and conditioned herein may not be
substantively changed during the platting process without an approved modification application in
accordance with SDC 5.12-145.
WHAT NEEDS TO BE DONE?
SDC 5.12-140 A states that for partitions, a plat pre-subr:nittal mlleting shall be held within one year of
the tentative plan approval. Therefore, the applicant has up to one year from the date of this decision
to meet SDC standards and the conditions of approval contained'herein and to submit a plat application
for pre-submittal. SDC 5.12-140 A. also states that the applicant shall submit the mylars and
application fee within 180 days of the pre-submittal meeting.' If, however, the applicant. has not
submitted the plat application within these timeframes, the tentative plan approval shall become null
and void and re-submittal is required. Please refer to the plat application packet available at the
Development Services Department, as well as 5.12-135 through 5.12-150, for more detailed
information on the platting process.
Please note that the plat, as well as the installation of public and private improvements, must conform
to the approved tentative plan or as conditioned herein. In addition, please note that no individual
parcels may be transferred and no building permits will be issued untiUhe plat has been recorded at
. Lane County and the applicant has submitted five (5) recorded, rolled paper copies of the plat and three
(3) copies of required documents to the Development Services Department.
Date Received: 10 J 1 ~I 06
Planner: I.J) lQCvb lOY\
<6 o:tll
(
Case No. SUB200B-D0016
B 0111
ADDITIONAL INFORMATION
The application, all documents, and supporting evidence are available for free inspection. (copies are
available for a fee) at the Development Services Department.
APPEAL
This decision is considered a Director's Type II decision and as such,' may be appealed to the
Planning Commission. SDC 5.3-115 states that only the property owner, applicant, if different, and
those persons who submitted written comments within the 14-day comment period have standing to
appeal this decision. SDC 5.3-115 also states that an appeal applicationin accordance with 5.3-100
shall be filed with the Development Services Department within 15. calendar days of the Director's
decision (the date of this decision). In accordance with this policy and the Oregon Rules of Civil
Procedures, Rule 10(c), the appeal period for this decision expires at 5:00pm on April 26, 2008.
QUESTIONS
Please call Molly Markarian in the Development Services Department Planning Division at 726-4611 or
email heratmmarkarian@ci.springfield.or.usif you have any questions.
PREPARED BY
Molly Markarian
Planner II
Urban Planning Section
Case No. SUB200B.00016
Date Received: I ~ 1&/ nr
Planner. LD ~ q fb l (
,
90111
Original Submittal
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