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HomeMy WebLinkAboutPUD22-000006 Monument Valley Townhomes HE SR updatedBefore the Caldwell Hearing Examiner City of Caldwell, Idaho Public Hearing Held November 9, 2022 Subject: Case No. : PUD22-000006/SUB22-000034 (Monument Valley Townhomes) Parcels: R34916, R34917, and R34918 Project Planner: Alex Jones, Associate Planner The following land use action is the primary feature of this application: Planned Unit Development (PUD) approval for 39 residential townhome lots with 9 four-plex buildings and 1 tri-plex building on 4.55 acres. The Comprehensive Plan designation for this property is High Density Residential. The subject property is zoned R-3 (High Density Residential). Preliminary Plat approval for the proposed Monument Valley Townhomes. TABLE OF CONTENTS: COURSE OF PROCEEDINGS GENERAL FACTS TESTIMONY APPLICABLE LEGAL STANDARDS COMPREHENSIVE PLAN ANALYSIS FINDINGS OF FACT CONCLUSIONS OF LAW RECOMMENDATION ORDER OF DECISION (Reserved for City Council) CONDITIONS OF APPROVAL COMPREHENSIVE PLAN ANALYSIS-PLANNED UNIT DEVELOPMENT & SUBDIVISION FINDINGS OF FACT CONCLUSIONS OF LAW RECOMMENDATION ORDER OF DECISION (Reserved for City Council) CONDITIONS OF APPROVAL COURSE OF PROCEEDINGS The Caldwell Planning and Zoning Department issued a notice of Public Hearing on application: PUD22-000006/SUB22-000034 (Monument Valley Townhomes) to be held before the Caldwell Hearing Examiner on October 27, 2022. On or before, October 9, 2022, notice was published in the Idaho Press Tribune and on or before, October 7, 2022 notice was mailed to all political subdivisions providing services to the site and to all property owners within 300 feet of the project site; and on or before, October 15, 2022 notice was posted on the site. Files and exhibits relative to this application are available for review in the Planning and Zoning Department, 621 Cleveland Boulevard, Caldwell and at applicable public hearings. Hearing Examiner continued from October 27, 2022 to November 9th, 2022 GENERAL FACTS: APPLICANT: Bob Unger, Unger Enterprises 9662 W Arnold Road, Boise, ID 83702 PROPERTY OWNER: Meadowdale Investments LLC, 13827 W Meadowdale St, Boise, ID 83713 REQUEST: Case Number: PUD22-000006/SUB22-000034: A request Bob Unger of Unger Enterprises, on behalf of Meadowdale Investments LLC, for a Planned Unit Development with a Preliminary Plat for Monument Valley Townhomes, on 4.55 acres. The proposed development consists of 39 residential townhome lots with 9 four-plex buildings and 1 tri-plex building. The gross density of the project is 8.5 dwelling units per acre (DU/acre). The subject property, parcels R34916, R34917, and R34918, is located at the corner of N 3rd Ave and N Illinois Ave. BACKGROUND/SITE REVIEW/ORDINANCE REQUIREMENTS: Planned Unit Development: Approval of Planned Unit Developments is dependent upon the fulfillment of certain requirements. An analysis of those requirements is as follows: Zoning Ordinance: 10-03-07: PLANNED UNIT DEVELOPMENTS: Intent: A planned unit development involves a parcel of land which is planned and developed as a unit under single ownership or control, containing one or more uses, buildings, and common open space or recreational facilities. The planned unit development process is not intended to skirt development rules nor results in a detrimental impact on the surrounding community through its implementation. The administrative procedures for a planned unit development shall be the same as applied to special use permits.    (2)    Purpose: It shall be the purpose of this section to encourage the unified and planned development of a site held in individual or corporate ownership at the time of development by the use of a planned unit development process. Such developments may be permitted without customary division into individual lots, or without specific conformance with the zoning district regulations as applicable to individual lots or traditional subdivisions subject to the regulations as provided in this chapter. (Ord. 2677, 6-18-2007)  A.   The planned unit development process is intended to provide flexibility, latitude and relief from the provisions of the zoning ordinance only if the proposed development is consistent with two (2) or more of the following instances: (Ord. 2967, 7-21-2014)          1.   The development offers a maximum choice of living environments by allowing a variety of housing and building types. Staff Note: The developer is proposing 139 residential townhome lots with 9 four-plex buildings and 1 tri-plex building.          2.   The development promotes mixed use projects which are functionally integrated within the development and provides services to the primary use. Staff Note: N/A          3.   The development provides a layout which preserves and properly utilizes natural topography and geologic features, trees, scenic vistas or other vegetation.          4.   Where a land parcel is constrained or otherwise limited by some obstacle, feature, geometry, condition, or easement that interferes with applying standard development processes. Staff Note: The land parcel is oddly shaped and the topography of the site makes building difficult. The land is constrained by the Notus Canal and the Golden Gate Canal          5.   The development encourages infill development that contributes a compatible design to the existing neighborhood. (Ord. 2677, 6-18-2007) Staff Note: This property is under five (5) acres and is surrounded by other platted developments. Staff Note: This development meets instances 4 and 5 of the PUD requirements.  (3)   Development Standards: The planning and zoning commission and the city council shall consider approval of planned unit developments in accordance with the following standards: (Ord. 2747, 5-19-2008)       A.   Changes: Changes in the development standards and bulk regulations of the underlying zone may be approved as per subsection (6) of this section.       B.   Primary Use: The primary use of the planned unit development shall be a permitted use in the underlying zoning classification. (Ord. 2677, 6-18-2007) Staff Note: The development is proposed as residential, an allowed use in the underlying R-3 zone of High Density Residential.       C.   Percentage: No more than thirty percent (30%) of the total net area ("net area" meaning the gross acreage less all acreage utilized for public right of way dedication and public streets) of the planned unit development shall be devoted to a use or uses not permitted or specially permitted in the underlying zoning classification, except that where any portion of the subject property has an underlying zoning classification of R-1, R-2, R-3, RS-1, and/or RS-2 or any combination thereof and/or any residential use regardless of the zoning classification, no industrial uses shall be allowed as part of the planned unit development. (Ord. 2924, 4-15-2013) Staff Note: The development plan does not propose non-residential uses.       D.   Latitude: Following the spirit and purpose of this section, much greater latitude is permitted than in conventional and traditional regulations for development.       E.   Discretionary Powers: In consideration of the latitude given, the planning and zoning commission and city council shall have discretionary powers in judging and approving or disapproving the imaginative or unique concepts, innovations, and designs which shall be incorporated into the plans presented, provided that the planned unit development shall conform to the general purposes and objectives of the comprehensive plan. Staff Note: The development plan conforms to the general purposes and objectives of the Comprehensive Plan.       F.   Residential Density: The number of dwelling units allowed in a planned unit development shall be calculated by multiplying the gross area and the dwelling units permitted in the underlying land use classification shown on the comprehensive plan map. A planned unit development shall be consistent with the density guidelines provided in the comprehensive plan. The residential density range for a single-family residential subdivision shall not exceed four (4) dwelling units per gross acre. A planned-unit development with mixed uses, such as duplexes, townhouses and compatible non-residential uses, may be permitted at a residential density of not more than twelve (12) units per gross acre. Staff Note: The development plan complies with the density guidelines provided with a proposed gross density of 8.5 units per acre.       G.   Residential Uses: A variety of housing types or residential uses may be included in a planned unit development including attached units (duplexes, townhouses), detached units (patio homes), single-family dwellings, and multiple-family units (triplexes, fourplexes, sixplexes, etc.) regardless of the zoning classification of the district, provided that the overall density of the land use classification is maintained. Staff Note: The development plan complies with the overall density of the underlying land use classification.       H.   Commercial Uses: When planned unit developments include commercial uses, commercial buildings and establishments, the development shall be planned as groups having common parking areas and common ingress and egress points in order to reduce the number of potential accident locations at intersections. A planned unit development shall follow section 10-07-10 (buffers between land uses) of this chapter. The plan of the project shall provide for the integrated and harmonious design of buildings, and for adequate and properly arranged facilities as reasonably necessary for internal traffic circulation. Staff Note: N/A       I.   Future Development: All areas designed for future development or expansion or not intended for immediate improvement shall be landscaped or otherwise maintained in a neat and orderly manner. Staff Note: N/A       J.   Required Setbacks: Attached residential structures and commercial buildings may be permitted in a planned unit development. Staff Note: The development consists of attached townhomes.       K.   Clustering: Every clustered area developed under the planned unit development approach should be designed to abut upon common open space or recreational amenities. Clustering is desired in mixed unit developments. Staff Note:N/A       L.   Parking:          1.   Off street parking for a single-family or two-family residential planned unit development shall be provided as follows:             (A)   Two (2) spaces per unit shall be provided on each subject parcel or clustered in parking pads in close proximity to any dwelling units they serve. Staff Note: The proposed development meets this standard.             (B)   Lots forty-five feet (45') in width and smaller shall provide one additional space per every four (4) residential units in a common parking lot located in close proximity to the residential structures in which it serves. Staff Note: The proposed development meets this standard.          2.   Off street parking for a multi-family residential planned unit development shall be provided as follows: Staff Note: NA             (A)   One and one-half (11/2) spaces per unit shall be provided on each subject parcel or clustered in parking pads in proximity to any dwelling units they serve.             (B)   On street parking may be permitted to accommodate visitors and overflow parking demand under the planned unit development process, but it shall not be counted towards the minimum off street parking requirements. One space per every eight (8) units shall be dedicated for off street visitor parking.             (C)   Off street parking shall not be designed to allow vehicles to back out onto a public street.          3.   Off street parking for a commercial planned unit development shall be provided as follows: Staff Note:NA             (A)   Parking for commercial uses shall be provided as required in section 10-02-05 of this chapter.             (B)   On street parking is not permitted for commercial uses and cannot be counted as off street parking for commercial uses.             (C)   Off street parking shall not be designed to allow vehicles to back out onto a public street.       M.   Access: All lots developed for residential purposes shall have frontage along a public roadway. Staff Note: All streets within the development are proposed to be private streets.       N.   Ownership: A planned unit development shall be under single ownership/control during the planning and developmental stage to ensure that the development can be accomplished in a unified manner. A PUD developer may sell a portion of an approved PUD if the purchaser submits a notarized letter to the planning and zoning director stating that he/she reviewed the order of decision, development agreement, phasing plan, and all other applicable materials and agrees to comply with all conditions of approval.       O.   Planned Unit Development Size: Unless the site qualifies as an infill development, the overall site shall consist of a minimum gross area of five (5) acres. Staff Note: The development area is 4.55 acres.       P.   Phasing Plan: The applicant shall submit a phasing plan for all features and amenities in a planned unit development. The phasing plan shall be approved by city council and may be amended by the planning and zoning director and city engineer. A staff level denial of a requested amendment may be appealed to the city council.       Q.   Classification Of Uses: More than one classification of uses and more than one use within these classifications shall be permitted on a lot or parcel within the same building or different buildings if the proposed individual uses are permitted uses. Any special uses will need to go through the standard special use hearing process. (Ord. 2677, 6-18-2007) Staff Note: NA       R.   Expiration: The completion of the first phase of a planned unit development shall take place within three (3) years of the signature date on the order of decision approving the planned unit development or said approval shall become null and void. For each phase after the first phase there shall be an allowed one year time frame per phase for completion. Should any phase not be completed within its one year time frame, approval on the uncompleted portion of the planned unit development shall become null and void. Exceptions to the time frames may be granted at the time of original approval of the planned unit development, provided said exceptions are requested in the initial application. (Ord. 2805, 11-2-2009)    (4)   Amenities: Any latitude, flexibility or relief provided through this land use application shall be compensated by the addition of some new amenity, within or outside the development. Such an amenity should provide equal or greater value to the development as a whole. The determination of whether the compensation offered is equal to or greater than the relief provided is left to the planning and zoning commission and city council's discretion. (Ord. 2677, 6-18-2007)       A.   Required Amenities: All planned unit developments shall have the following features: (Ord. 2747, 5-19-2008)          1.   Five foot (5') wide asphalt paved micro pathways connecting the residential areas to all nonresidential areas, open space common lots, recreational facilities, major pathways, and school bus pick up locations. (Ord. 2677, 6-18-2007)          2.   Eight foot (8') wide asphalt paved or concrete paved or porous surfaced (other than gravel) major pathways are required in all planned unit developments with a five foot (5') wide landscape buffer on each side of major pathways. Major pathways meeting the standards listed above are required to provide connectivity to adjacent pathways, to comply with the city's pathway master plan, and to provide for connectivity to adjacent properties. In general, major pathways shall meander through the center of the PUD, be entirely located within a platted common lot that is dedicated as a public access easement, and provide connectivity to adjacent parcels of land.          3.   Usable open space (as defined in section 10-07-05 of this chapter) of at least ten percent (10%) of the gross area. Staff Note: The developer has provided for 19.1% qualifying open space within the development.          4.   Varying bermed street landscape buffers of a two to one (2:1) to three to one (3:1) ratio. (Ord. 2747, 5-19-2008)       B.   Required Optional Amenities: Four (4) or more of the following amenities shall be provided as part of each planned unit development: (Ord. 2967, 7-21-2014) Baseball/softball field. Basketball court. Boat dock/river access. Buildings are constructed to LEEDS standards. Community center. Daycare center. Detached/meandering sidewalks. Energy star certified housing. Enhanced paving and design features at intersections as approved by the city engineer. Fishing pond. Golf course/driving range. Gym/health club. Land provided for a public facility (school, fire station, police station, etc.). Playground/tot lot. Rear entry garages. Residential buildings constructed with fire sprinkler systems. Roundabout intersections as approved by the city engineer. Skateboard park. Swimming pool. Tennis court. Other suitable amenities or public benefits deemed worthy by the city council. (Ord. 2677, 6-18-2007; Ord. 2967, 7-21-2014)  Staff Note: The developer is providing the following amenities in compliance with the required code provisions: Gazebo, Picnic tables, grills, benches and playground area. C.   Reduction Of Amenities: The city council may reduce the number of optional amenities depending upon the intensity and value of the amenity(ies) proposed by the applicant. Staff Note: NA    (5)   Application Process: Subdivisions and developments created through the planned unit development process shall provide a narrative and architectural renderings that explain what amenities will be incorporated inside the development to compensate for deviations to the city's development standards and how its construction will satisfy the community's need for a wide range of housing and commercial businesses. Staff Note: Applicant provided complete application and required documents attached herein.    (6)   Flexibility In Applying Zoning Standards: The developer may deviate from the height, lot line setback, and lot dimension schedule found in section 10-02-03 of this chapter with the consent of the planning and zoning commission and city council. Deviations shall be listed in full as a part of the planned unit development application. Modifications to other zoning and subdivision standards will be determined by the planning and zoning commission and city council on a case by case basis. COMPREHENSIVE PLAN DESIGNATION: The current zoning designation of the 4.55 acres is R-3 (High Density Residential). The 2040 Comprehensive Plan designation is High Density Residential. Comprehensive Plan Medium Density Residential: This category includes land that is suitable for infill development or a transitional district to include a mixture of dwelling choices (attached and detached), churches, schools, group day care facilities, public facilities and limited neighborhood commercial uses. The residential density range shall not exceed four (4) dwelling units per gross acre for a single-family residential subdivision and shall not exceed twelve (12) units per gross acre for a mixed use (planned unit development) site. Zoning Ordinance: R-3 HIGH DENSITY RESIDENTIAL: This category includes land that is suitable for more intense land uses and as a transitional district to include single-family housing and multi-family housing such as apartments, townhouses and condominiums and manufactured home parks and subdivisions. This classification is also suitable for professional office development and limited neighborhood commercial uses, public and semi-public uses and compatible institutional uses. The residential gross density shall not exceed 25 units per gross acre and shall not exceed 40 units per gross acre for a mixed use (planned unit development) site COMPREHENSIVE PLAN COMPONENTS APPLICABLE TO THE REQUEST: 2.7.1 Land Use: The subject property is surrounded by the following uses: Direction Zone Comprehensive Plan Current Use  Site R-3 High Density Residential Vacant Lot  North R-1 Low Density Residential Residential  South R-3 High Density Residential Residential  East R-1 Low Density Residential Residential  West M-1/R-2 Manufacturing & Production/Traditional Neighborhood Maufacturing/Residential   2.7.2 Transportation/Connectivity: The subject property has frontage on N Illinois Ave. 2.7.3 Public Services, Utilities and Facilities: The engineering department, fire marshal, building department, police department, Mapping, Airport, Caldwell School District, Golden Gate Irrigation District, COMPASS, Canyon Co Ambulance, Canyon Highway District #4, Nampa Highway District #1. Caldwell Transportation, Idaho Transportation Department, Brown Bus Company, Valley Regional Transit (VRT), Idaho Power, Intermountain Gas Company, Bureau of Reclamation, Canyon County Development Services, Southwest District Health, Boise River Flood Control District #10, Bureau of Land Management, Idaho Fish and Game, Department of Water Resources, College of Idaho and USPS were all sent a request for comment on September 15, 2022. 2.7.4 Engineering comments See Exhibit PA-1 PUBLIC TESTIMONY 3.1 Before the Hearing Examiner, October 27, 2022 APPLICABLE LEGAL STANDARDS 4.1 City of Caldwell Zoning Ordinance No. 1451, as amended. 4.2 City of Caldwell Comprehensive Plan, as amended. 4.3 Idaho Code, Title 67, Chapter 65, Local Planning Act V COMPREHENSIVE PLAN ANALYSIS – PLANNED UNIT DEVELOPMENT with PRELIMINARY PLAT Planned Unit Development in the R-3 (High Density Residential) zone with a gross density of 8.5 units per acre on 4.55 acres. The Caldwell Hearing Examiner accepts the Comprehensive Plan Components: 5.1 The request was found to be consistent with the following Comprehensive Plan Components: GOALS AND POLICIES – Property Rights (Chapter 1) Goal 1: Ensure that land use policies, restrictions, conditions and fees do not violate private property rights, adversely impact property values or create unnecessary technical limitations on the use of the property. Policy 1-1: Establish a sound basis for land use and environmental regulations through comprehensive planning and adopted policies and ordinances. GOALS AND POLICIES – Population (Chapter 2) Goal 1: Maintain a high quality of life and livability in the community. Policy 1-1: Plan for anticipated population and households that the community can support with adequate services and amenities. GOALS AND POLICIES – Land Use (Chapter 5) Goal 1: Establish land-use management policies that protect property rights and the environment, maintain a high quality of life, provide adequate land for all types of development, and adequately buffer non-compatible uses. Policy 1-1: Guide the growth and development of land uses in such a way that the health, safety, and general welfare of residents will be protected. Goal 3: Create communities that are more livable, affordable, connectable and sustainable. Policy 3-1: Create walkable neighborhoods with neighborhood commercial centers and good connectivity between neighborhoods. Staff Note: Although there are no commercial uses proposed in the development, the proposed development provides for connectivity and walkable options by the Solomon drain and to the amenities within the development. Goal 4: Create communities that generate cost effective public services and infrastructure. Policy 4-3: Require developers to meet design principles, development standards, and street and utility improvement requirements as set forth in the City's subdivision ordinance and infrastructure policy. GOALS AND POLICIES – Public Services, Utilities, and Facilities (Public Works) (Chapter 8) GOAL 1: Ensure that there are adequate public services and infrastructure to meet the needs of the public. Policy 1-1: Enforce the policies and implement the recommendations of the Public Facilities Plan. Require land developers to discuss land acquisition needs with a public agency whenever a new facility is necessary. Policy 1-2: Provide for the orderly expansion of public services to meet the needs of population growth, and ensure that adequate infrastructure is in place to serve new development. Policy 1-5: Assure that a development provides adequate water supply for fire flow. GOALS AND POLICIES – Housing (Chapter 14) GOAL 1: Support adequate housing for a range of income levels and residential needs. Policy 1-1: Ensure that public services are available to all housing units. Policy 1-2: Promote infill housing developments in appropriate neighborhoods. GOAL 2: Support enhanced housing standards that will improve the visual appearance of residential neighborhoods Policy 2-1: Require new construction to have enhanced housing features such as eaves, roof pitch, facade improvements, windows, soffits, etc. Policy 2-2: Discourage monotonous housing developments. Policy 2-3: Encourage innovative and unique site-development proposals that incorporate a mix of housing types and density. 5.2 The request for Planned Unit Development (PUD) and Preliminary Plat on 3.56 acres, parcel R3528000000 was not found to be inconsistent with the Comprehensive Plan Components. VI FINDINGS OF FACT – PUD & Preliminary Plat 6.1 The Caldwell Hearing Examiner accepts the facts outlined in the staff report, public testimony and the evidence list. All adopted city ordinances, standards and codes were used in evaluating the application. VII CONCLUSIONS OF LAW – PUD & Preliminary Plat 7.1 The Caldwell Hearing Examiner has the authority to hear this case and recommend to the Caldwell City Council that it be approved or denied. The public notice requirements were met, the hearing was legally noticed and posted and the hearing was held and conducted under the requirements of Idaho Code and City ordinances. VIII RECOMMENDATION – PUD & Preliminary Plat 8.1 Based on the Findings of Fact and Conclusions of Law, the Caldwell Hearing Examiner hereby recommends to the Mayor and City Council that Case Number PUD22-000006/SUB22-000034, a request for a Planned Unit Development and Preliminary Plat for Monument Valley Townhomes with of 39 residential townhome lots with 9 four-plex buildings and 1 tri-plex building on approximately 4.55 acres (parcels R34916, R34917, R34918) with designation of R-3 (High Density Residential), is approved with the conditions of approval listed in Section X (10) to be enumerated in a Development Agreement. IX ORDER OF DECISION (reserved for Hearing Examiner): X CONDITIONS OF PUD & PRELIMINARY PLAT: Comply with all applicable city codes, ordinances, policies, and standards. The development, design, and construction of Monument Valley Townhomes shall be in substantial compliance with the submitted preliminary plat of Case File: PUD22-000006/SUB22-000034 (Exhibit A3) attached hereto). Any substantial deviations, as determined by the Planning & Zoning Director, from said Exhibit A3 shall require City Council approval through a public hearing. The development shall comply with the requirements of the City Engineering Department as listed in Case File Exhibit PA-1 (attached hereto) or as amended. The City Engineer has the discretion to reduce or eliminate certain requirements stated in Exhibit PA-1 that he finds pertinent to the request. The development, design, and construction of Monument Valley Townhomes shall be in substantial compliance with the submitted landscape plan of Case File: PUD22-000006/SUB22-000034 as amended to meet ordinance requirements (Exhibit A8 attached hereto). Any substantial deviations, as determined by the Planning & Zoning Director, from said Case File Exhibit A8 shall require City Council approval through a public hearing. Install a minimum 20-foot wide landscape buffer along N Illinois Ave, a classified Minor Arterial outside of the dedicated public rights of way. The landscape buffer shall contain 1 Class II tree/35 feet of frontage and 7 shrubs/35 feet of frontage and shall contain grass and other vegetative ground cover so that the entire buffer area is covered. The developer/HOA shall be responsible for installation and maintenance of landscaping to the back of curb in the rights of way. The street landscape buffers shall contain a mixture of trees (deciduous and evergreen), shrubs, lawn, vegetative and non-vegetative ground cover so that the entire buffer area is covered. A minimum of seventy percent (70%) of the buffer area shall be covered with a turf-type grass. For new plantings, grass sod installation is required. Seeding, hydro-seeding, or similar methods shall not be allowed and the plant sizes shall meet or exceed the minimum plant sizes as set forth in §10-07-04 (6) as follows: Evergreen trees 6 to 7 foot height minimum  Ornamental trees 2 inch caliper minimum  Shade trees 2 inch caliper minimum  Woody shrubs 2 gallon pot minimum   The development shall utilize cluster mailboxes for delivery of mail. Individual mailboxes shall not be allowed. A cluster mailbox placement plan shall be submitted to the Planning and Zoning department showing coordination with the United States Postal Services prior to submitting the first final plat. All requirements from the Fire Department for access, turnarounds, emergency access, water supply, fire hydrants, etc. shall be met in the development and/or platting of the subject property. Final approval of the location and number of fire hydrants within the development shall be determined by the Fire Marshal and take place by phase at the time of submittal of applicable construction drawings for each phase. The applicant shall post and maintain a “Rules and Regulations” sign at the entryways to the residential subdivision until it is fully developed. The signs would be intended for subcontractors performing work and should include: 1) no dogs; 2) no loud music; 3) no alcohol or drugs; 4) no abusive language; 5) dispose of personal trash and site debris; 6) clean up any mud and/or dirt that is deposited from the construction parcel onto streets; 7) installation of a temporary construction fence that would keep debris from being blown off site by the wind; 8) no burning of construction or other debris on the Property. EXHIBIT “A3” PUD PRELIMINARY PLAT / / EXHIBIT “A13” LANDSCAPE PLAN / / EXHIBIT “A2” APPLICANT PROJECT NARRATIVE / / EXHIBIT “PA1” ENGINEERING MEMORANDUM/ / / / / /