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Ord. 2570 - Annexation of Lowrie Property (9008 Parr Road NE) COUNCIL BILL NO. 3092 ORDINANCE NO. 2570 AN ORDINANCE ANNEXING APPROXIMATELY 24.65 ACRES OF TERRITORY KNOWN AS THE LOWRIE PROPERTY (LOCATED AT 9008 PARR ROAD NE, MARION COUNTY, OREGON) INTO THE CITY OF WOODBURN WHEREAS, the subject property is legally described in Exhibit "A" and mapped in Exhibit "B", which are affixed hereto and by this reference incorporated herein; and WHEREAS, the subject property is Marion County Tax Lot 052W13 00800; and WHEREAS, consistent with Oregon Revised Statutes (ORS) 222.1 11 (2) the owner of real property in the territory to be annexed initiated by petition a proposal for annexation, a copy of the petition being on file with the City Recorder (ANX 2018-02); and WHEREAS, the applicant, Emerio Design, LLC, obtained written consent from the owners of the territory and has requested annexation of the subject property; and WHEREAS, the property to be annexed is within the City Urban Growth Boundary (UGB); and WHEREAS, the property to be annexed is contiguous to the City and can be served with City services; and WHEREAS, on January 24, 2019 the Woodburn Planning Commission considered the annexation application and, after a duly advertised public hearing, recommended approval of the annexation; and WHEREAS, on February 25, 2019, the Woodburn City Council held a public hearing, reviewed the record, heard all public testimony presented on said application, and upon deliberation concluded that the proposed annexation meets the applicable approval criteria under City of Woodburn Development Ordinance (WDO) 5.04.01 C.; NOW, THEREFORE, THE CITY OF WOODBURN ORDAINS AS FOLLOWS: Page - 1 - Council Bill No. 3092 Ordinance No. 2570 Section 1. That the subject property, legally described in Exhibit "A" and mapped in Exhibit "B", is annexed to the City of Woodburn. Section 2. That the City Council adopts the Analysis & Findings, affixed hereto as Exhibit "C" and by this reference incorporated herein. Approved as to form: City Attorney D Approved: Eric Swenson, Mayor Passed by the Council "O-rcjn 111 ';101 Submitted to the Mayor Approved by the Mayor PUX'rCJA..P 13, Filed in the Office of the Recorder i 2-4n C� ATTEST: Heather Pierson, City Recorder City of Woodburn, Oregon Page - 2 - Council Bill No. 3092 Ordinance No. 2570 EM- Civil Engineering Land Survey " its Land Use Planning Construction Management ANNEXATION DESCRIPTION JOB NO. 041-025 TAX LOT 800 05 2W 13 MAY 29, 2018 EXHIBIT A (PAGE 1 OF 2) A TRACT OF LAND LOCATED IN THE S.W. 1/4 AND THE S.E. 1/4 OF SECTION 13, TOWNSHIP 5 SOUTH, RANGE 2 WEST OF THE WILLAMETTE MERIDIAN, MARION COUNTY, OREGON, BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING ON THE EXISTING CITY LIMIT OF THE CITY OF WOODBURN ON THE EAST LINE OF THE LAND DESCRIBED IN REEL 3822, PAGE 457, MARION COUNTY DEED RECORDS (TAX LOT 800 05 2W 13), SAID POINT BEING ON THE SOUTH RIGHT OF WAY LINE OF PARR ROAD (COUNTY ROAD NO. 517, 30.0 FEET FROM CENTERLINE); THENCE ALONG SAID EXISTING CITY LIMIT AND SAID EAST LINE, SOUTH 00°18'51" WEST, 1596.67 FEET TO THE SOUTHEAST CORNER OF SAID TAX LOT 800; THENCE, LEAVING SAID EXISTING CITY LIMIT, ALONG THE SOUTH LINE OF SAID TAX LOT 800, NORTH 89020'17" WEST, 660.14 FEET TO THE SOUTHWEST CORNER THEREOF; THENCE ALONG THE WEST LINE OF SAID TAX LOT 800, NORTH 00°16'47" EAST, 1593.02 FEET TO THE SOUTH RIGHT OF WAY LINE OF SAID PARR ROAD (30.0 FEET FROM CENTERLINE); THENCE ALONG SAID SOUTH RIGHT OF WAY LINE SOUTH 89041'21" EAST, 89.40 FEET TO AN ANGLE POINT THEREON (SAID ANGLE POINT BEARS NORTH 00°31'24" EAST, 540.45 FEET, SOUTH 89041'21" EAST, 1297.99 FEET, AND SOUTH 00°21'00" WEST, 30.00 FEET FROM THE NORTHERLY NORTHWEST CORNER OF THE PETER RAYMOND DLC NO. 88); THENCE CONTINUING ALONG SAID SOUTH RIGHT OF WAY LINE, SOUTH 89°39'00" EAST, 571.69 FEET TO THE POINT OF BEGINNING. CONTAINING 24.19 ACRES MORE OR LESS. REGISTERED PROFESSIONAL LAND SURVEYOR OREGON JANUARY 15, 1987 JON T. FEIGION 2252 EXPIRES 12-31-19 REFERENCE SURVEY: SN 34512 MARION COUNTY SURVEY RECORDS 8285 S.W. Nimbus Avenue « Beaverton, Oregon 97008 r 503-515-5528 1 TEL ..�_..........._.� .. .__........___..._ 503-639-9592 FAX www.emeriodesign.com EXHIBIT A (PAGE 2 OF 2) A TRACT OF LAND LOCATED IN THE S.W. 1/4 AND THE S.E. 1/4 OF SEC. 13, T.5S., R.2W., W.M. MARION COUNTY, OREGON PARR ROAD S00'21'00"W (COUNTY ROAD NO. 517) 30.00' 60' S89"'41'21"E 1297.99'—_' //- Ir d/ S89"39'00"E 571.69'-"��, L301 J- ECL S89*41'21"E POINT OF BEGINNING EAST LINE u') 69.40' OF REEL 3822, PAGE 457 S4 goo to ui C14 NORTHERLY NW to CORNER PETER 0) LO RAYMOND DLC 880) DESCRIBED AREA LO 24,19 ACRES -700 io SCALE:1"=300' 00 1 z 0 300, 600 Tk- JOOO -VL Soo LEGEND I ECL EXISTING CITY LIMIT Cily OF WOODBURN TL TAX LOT, MARION COUNTY TAX MAP 05 2W 13 REGISTERED PROFESSIONAL LAND SURYO R N69"20'17"W ECL 660.14' TL 12p0 j OREGON� JANUARY 15, 1 87 ................... JON T. FEIGION '4 ii d ii i,a T 2252 REFERENCE: SN 34512 MARION COUNTY SURVEY RECORDS EXPIRES 12-31-19 DRAWN BY. JTF CITY OF WOODBURN mrlmy J13 JOB NO.: 041-025 ANNEXATION EXHIBIT SCALE: 1"=300' 9008 PARR ROAD 6445 SW FALLBROOK PLACE, STE. 100 BEAVERTON, OREGO88 97008 DATE: 5-29-18 MARION COUNTY, OREGON TEL: (503) 746-8812 FAX: (503) 639-9592 TAX LOT 800 05 2W 13 www.emeriodesign.com Attachment 102 Analyses & Findings This attachment to the staff report analyzes the application materials and finds through statements how the application materials relate to and meet applicable provisions such as criteria, requirements, and standards. They confirm that a given standard is met or if not met, they call attention to it, suggest a remedy, and have a corresponding recommended condition of approval. Symbols aid locating and understanding categories of findings: Symbol Category Indication Requirement (or guideline) met No action needed Requirement (or guideline) not met Correction needed Requirement (or guideline) not applicable No action needed ......................................................................."..............i .. " ...................................................."......(......................................). Section references are to the Woodburn rn Develo j_� r ��„� ����: u��a�ice ADO Table of Contents Location.........................................................................................................................................................1 LandUse &Zoning........................................................................................................................................1 StatutoryDates.............................................................................................................................................3 AnnexationProvisions ..................................................................................................................................3 ApplicantIdentity........................................................................................................................................11 Location Address(es) 9008 Parr Rd NE Tax Lot(s). 052W13....00800... Nearest Parr&Stubb Rds intersection Land Use & Zoning Comprehensive Plan Land Use Designation Low Density Residential with Nodal Development Overlay Zoning District Nodal Single Family Residential (RSN), upon annexation Overlay District(s) none Existing Use(s) Vacant rural dwelling ............................................................. SII"CIIII SII ANX 2018-02 Staff Report Attachment 102 Page 1 of 11 For context, the comprehensive plan land use map designations and zoning are illustrated below and the zoning is tabulated further below: Pa o l��lll�lill�l s F Fj Y r _F F G Ci Comprehensive Plan land use map excerpt Zoning map excerpt (Note: The City geographic information system[GIS]is not yet updated to show RMN zoning to the north within the annexed Smith Creek Development site(ANX 2017-05;Ordinance No. 2566, Exhibit"C"map.) Cardinal Direction Adjacent Zoning North East of Stubb Rd: Nodal Multi-Family Residential (RMN) West of Stubb Rd: No City zoning because not yet annexed; would be RMN East Public and Semi-Public(P/SP) [Centennial Park] South No City zoning because not yet annexed;would be RSN West Northerly: RMN Southerly: RSN ANX 2018-02 Staff Report Attachment 102 Page 2 of 11 Statutory Dates Application November 2, 2018 Completeness 120-Day Final March 2, 2019 per Oregon Revised Statutes (ORS)?? .178. (The nearest and Decision Deadline prior regularly scheduled City Council date is February 25, 2019.)* *However, the Assistant City Attorney had counseled staff on January 16, 2018 that an annexation request is not subject to the 120-day deadline for final action per 227.178(8). Annexation Provisions Because the proposal is for annexation, per 5.04 it requires a Type IV review with City Council decision. The applicant submitted application materials on June 8, 2018 and revised and additional materials on October 3, 2018 (excerpted within Attachment 103). 2.05.04 Nodal Overlay Districts C. Master Planning Requirement 1.A master development plan shall be approved by the City Council for the entire area designated as Nodal Overlay on the Comprehensive Plan Map, prior to annexation of any property within the Nodal Development Overlay Comprehensive Land Use Plan map designation.The master plan shall be conceptual and non-binding in nature, but may be used as a general guide for development within the Nodal Overlay Districts. 2.The required master plan shall show: a)The location and rights-of-way for existing and planned streets.These streets shall provide access to all existing and proposed parcels,consistent with the Transportation System Plan (TSP); b)The location and size of existing and planned sanitary sewer,storm water and water facilities,at adequate levels to serve existing and proposed development; c)The location and area of the Riparian Corridor and Wetlands Overlay District(RCWOD). Planned streets and public facilities that cannot reasonably avoid the RCWOD shall be indicated; d)A development plan for the Nodal Neighborhood Commercial center, neighboring multi- family areas,and potential parks,including planned pedestrian and bicycle connections within the Nodal Overlay District as shown on the Transportation System Plan,and pedestrian and bicycle connections to Southwest Industrial Reserve areas; e)A development plan for all residential areas,demonstrating consistency with applicable nodal design standards. The applicant e-mailed staff on January 16, 2019 confirming that he wishes ANX 2018-02 to reference the Nodal master plan that Stafford Land Company already produced as part of ANX 2018-02 Staff Report Attachment 102 Page 3 of 11 annexing the territory to become the Smith Creek Development (ANX 2017-05). This Nodal master plan accompanied the first annexation of property with the Comprehensive Plan Nodal overlay, and the City Council accepted and adopted it via Resolution No. 2124 on November 13, 2018 and its Exhibit "A". For convenient context, below is a shrunken reproduction of one of the master plan sheets focusing on open space, off-street bicycle/pedestrian paths, and a road and street network: ..................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................... EXHIBIT C-15-2 � NODAL OPEN SPACE& + r r d PATHWAY PLAN NODAL OVERLAY BOUNDARY r' + v P !s r a o BIKE PATHS,SIDEWALKS & PATHWAYS 1 � HOUSES WITH ALLEYS r + 11_a -I Ii. qf{' $ u ® APARTMENTS t r ' j e t { I 1 4 C 4 �a F rry IN y;{,� t......• G J A� on rasi+rvc � �, I a 91 u „t m,m - -- ✓ DISCLAIMER. ALL CONCEPTUAL ELEMENTS SHOWN 'OUTSIDESMfTH CREEK RESIDENTIAL 2 h�+ DEVELOPMENTARE NON BINDING ON ANYADIACENTPROPERTVOWNFR. B Resolution No. 2124 Exhibit "A"Nodal Master Plan Sheet of 8 Open Space& Pathway Plan 5.04.01 Annexation A. Purpose: The purpose of this Type IV review is to provide a procedure to incorporate contiguous territory into the City in compliance with state requirements,Woodburn Comprehensive Plan,and Woodburn Development Ordinance. B. Mandatory Pre-Application Conference: Prior to requesting annexation to the City, a Pre- Application Conference(Section 4.01.04)is required. ... C. Criteria: 1. Compliance with applicable Woodburn Comprehensive Plan goals and policies regarding annexation. ANX 2018-02 Staff Report Attachment 102 Page 4 of 11 2. Territory to be annexed shall be contiguous to the City and shall either: a. Link to planned public facilities with adequate capacity to serve existing and future development of the property as indicated by the Woodburn Comprehensive Plan; or b. Guarantee that public facilities have adequate capacity to serve existing and future development of the property. 3. Annexations shall show a demonstrated community need for additional territory and development based on the following considerations: a. Lands designated for residential and community uses should demonstrate substantial conformance to the following: 1) The territory to be annexed should be contiguous to the City on two or more sides; 2) The territory to be annexed should not increase the inventory of buildable land designated on the Comprehensive Plan as Low or Medium Density Residential within the City to more than a 5-year supply; 3) The territory proposed for annexation should reflect the City's goals for directing growth by using public facility capacity that has been funded by the City's capital improvement program; 4) The site is feasible for development and provides either: a) Completion or extension of the arterial/collector street pattern as depicted on the Woodburn Transportation System Plan; or b) Connects existing stub streets,or other discontinuous streets,with another public street. 5) Annexed fulfills a substantial unmet community need,that has been identified by the City Council after a public hearing. Examples of community needs include park space and conservation of significant natural or historic resources. b. Lands designated for commercial,industrial and other uses should demonstrate substantial conformance to the following criteria: ... D. Procedures: 1. An annexation may be initiated by petition based on the written consent of: a. The owners of more than half of the territory proposed for annexation and more than half of the resident electors within the territory proposed to be annexed; or b. One hundred percent of the owners and fifty percent of the electors within the territory proposed to be annexed; or C. A lesser number of property owners. 2. If an annexation is initiated by property owners of less than half of property to be annexed, after holding a public hearing and if the City Council approves the proposed annexation,the City Council shall call for an election within the territory to be annexed. Otherwise no election on a proposed annexation is required. E. Zoning Designation for Annexed Property: All land annexed to the City shall be designated consistent with the Woodburn Comprehensive Plan,unless an application to re-designate the property is approved as part of the annexation process. F. The timing of public improvements is as follows: ANX 2018-02 Staff Report Attachment 102 Page 5 of 11 1. Street dedication is required upon annexation. 2. Dedication of public utility easements(PUE) is required upon annexation. 3. Street improvements are required upon development. 4. Connection to the sanitary sewer system is required upon development or septic failure. 5. Connection to the public water system is required upon development or well failure. 6. Connection to the public storm drain system is required upon development. Regarding subsection B., staff hosted the pre-application conference (Pre-App 2018-01) on March 21, 2018. Regarding the criteria of subsection C.: 1. The City Comprehensive Plan, Section G. Growth Management and Annexation contains annexation policies on pp. 30-31. The annexation criteria in the WDO already reflect the goals, including efficient City services. First, the territory to be annexed is within the Woodburn Urban Growth Boundary (UGB). The premise of a UGB is to define an area feasible for the City to provide services to greenfield development over approximately 20 years as described in the Comprehensive Plan. So, in this way the annexation of territory within the UGB is consistent with the comp plan. Second, the territory also is adjacent to infrastructure that development can make use of or extend into the territory to develop it: • Roads and street: Parr Road borders to the property to the north, providing a means of access. The road is now also under City jurisdiction following annexation of the right-of-way (ROW) between Centennial Park to the east and a little past Stubb Road to the west by the Stafford Lan Company for the Smith Creek Development through application ANX 2017-05 and Ordinance No. 2565, Exhibit "B" map, adopted November 13, 2018 and per the City Charter effective 30 days later on December 13, 2018. • Transit: Along Parr Rd, the City can run transit vehicles. • Potable water: The City geographic information system (GIS) illustrates public water lines both within Parr Road and to the east Centennial Park. • Sanitary sewer: A public sewer line is to the east within Centennial Park and that approaches the east boundary of the territory. • Stormwater sewer: The south side of the Parr Rd ROW includes a ditch that conveys east to a stormwater line near the northeast corner of the property at 828 Parr Rd (Tax Lot 052W13 00600), approximately 800 feet east of the territory. ANX 2018-02 Staff Report Attachment 102 Page 6 of 11 • Other: Other franchise utility providers attend to such utilities as electric power, cable television and internet, natural gas, and cellular wireless telephony, often using existing or extended ROWs. The applicant had stated verbally to staff that the landowner has no intention of subdividing and developing the territory until the developer or developers of the Smith Creek Development—the territory generally north of Parr Road and east of Stubb Road annexed through Ordinance No. 2565 — provides the infrastructure upon which Smith Creek Development is premised. At that point, developers of adjacent greenfield properties to the south and west within the UGB can annex and build off that infrastructure at lesser cost to themselves. (As described in the Final Order for the Smith Creek Development dated November 2018, per Condition SUB-1 that project of nine phases might take as long as until 2026 to record final plats and construct fully. The subject territory is across Parr Road from Phase 3A, which includes the south leg of Stubb Road, and Phase 4A.) Were the Smith Creek Development not to be, the WDO and other City development regulations would still require a developer of the subject territory to extend infrastructure in order to develop. The proposal does not conflict with the goals and meets the goal of efficient City services. 2. The territory is contiguous to the City. Per the comp plan and with implementation through the WDO, upon development of the territory the City would require improvements that guarantee that public facilities have adequate capacity to serve such development. The Public Works Department identified no impediments to serve the existing vacant house. Additionally, the applicant's narrative (p. 7) states: "The subject property is currently contiguous with the city limits on one (1) side (i.e. east property boundary). All public utilities and services are available to the site either within Parr Rd. or by extending stormwater lines to the north and discharging into Smith Creek after being treated. A preliminary stormwater report has been included in this application to demonstrate adequate capacity for stormwater facilities." Staff concurs. 3. Examining the considerations under subsection a.: 1) The territory to be annexed is contiguous to city limits on two sides— north and east. ANX 2018-02 Staff Report Attachment 102 Page 7 of 11 2) The comp plan land use map designates the territory Low Density Residential. The applicant's request to annex indicates anticipated market need for housing types such as detached houses, corner duplexes, and row houses that would be permitted upon application of the RSN zone. There is probably an oversupply of annexed Low Density Residential because though the vast majority of such land was under active land use entitlement (such as for planned unit development and subdivisions) or building permit reviews or was undergoing construction, with the late 2018 annexation of the Smith Creek Development territory this is no longer the situation. That property of 150 gross acres split between Low and Medium Density Residential is also entitled for development of 820 dwellings in the form of 708 houses and 112 row houses. The significance of this becomes clearer with compared with data now available as the City enters into Task 3 of its Housing Needs Analysis (HNA) long-range planning project. The consultant's memo "Woodburn Housing Needs Analysis, Draft Housing Needs Forecast, Task 2 deliverable" that was Attachment 103 of the staff memo to the Commission on December 13, 2018 concludes with an estimated forecast or projection that over the next 20 years (to about 2039) Woodburn will need a total of 3,000 more dwellings of which about 1,910 would be houses and 411 would be rowhouses or townhouses (p. 10, table Exhibit 15). Dividing that those numbers by four based on the assumption of dividing 20 years into four 5-year periods and an assumption of even and steady market development, the rounded numbers are 478 houses and 103 row houses or townhouses. Thus, it is clear with new information subsequent to the Smith Creek territory annexation that the Smith Creek Development alone could provide more than a 5-year supply of 20-year projected needed housing on its portion of UGB land designated Low and Medium Density Residential. However, staff notes that the aforementioned Smith Creek Development is nine phases and per its Condition SUB- might take as long as until 2026 to record final plats and construct fully— longer than a 5-year window. Second, the applicant expressed intention to not pursue development until the Smith Creek Development actually develops and extends City infrastructure so as to become adjacent to the subject property. Also, the applicant has no reason to spend more money on extending infrastructure when sooner or later the developer or developers of the Smith Creek property will pay for the infrastructure that serves that development and incidentally bring it close to the subject property. There is no corollary subdivision application with the annexation application. For these ANX 2018-02 Staff Report Attachment 102 Page 8 of 11 reasons, staff believes the consideration of 2) about buildable land inventory is of little importance and that the proposal poses no threat of manifesting a glut of market-rate housing. The applicant's narrative states on p. 8: "As further discussed in responses above to Section 5.03.06.B.5 of this report [Technical Report 2 Residential Land Needs Analysis, May 2005], if the average population increase from the year 2018 to 2020 will be approximately 560 persons per year, as projected by EcoNorthwest's lower growth rate,this equals a need for a housing supply of over 180 housing units per year.This is based on an average household size of 3.11 persons per dwelling unit.The future housing construction on the subject site will start in approximately 2020—2021 with occupancy around 2022-2023. With construction of approximately 100 housing units over a 3 to 5-year period, this equals between 20 to 34 housing units per year.This is well within the amount of housing projected by the City of Woodburn for absorption annually, which results in balanced urbanization for the city.The availability of Low and Medium Destiny land in the city limits is currently very low, and annexation of the subject property will provide needed territory for development to create a supply of Low density land. This need is demonstrated in the Comprehensive Plan as the lands in the Nodal District are described as a unique housing variation need. As this area proposed for annexation will be one of the first Nodal areas to be developed in the City, it will allow the area to meet this undeveloped demand for a new housing type mix described in the Comprehensive Plan. Once this new land is available for development, the absorption rate is expected to be higher than historical averages, due to the fact that the zone allows for and the applicant is proposing a new housing type not available in other zones." Staff concurs. 3) The applicant's narrative states on p. 9: "[W]ith the development of the Smith Creek project immediately north of the subject property, additional facilities will be made available to the subject property, so approving the annexation proposed will direct growth to use both the City's existing facilities, as well as those constructed as part of the Smith Creek development." Staff concurs. ANX 2018-02 Staff Report Attachment 102 Page 9 of 11 4) The mostly flat site with no obvious physical constraints and is physically feasible for urban residential redevelopment. Regarding subsection a), staff expects that a developer of the subject property would extend Stubb Road. The developer or developers of the Smith Creek property will improve the road into a major thoroughfare pursuant to Transportation System Plan (TSP) Figure 7-1 that classifies Stubb Road as Access Street class and will also join it with Harvard Drive. This serves to make the intersection of Parr and Stubb Roads ideal for access to the subject property. A second reason for staff expectation is because of both the adopted Nodal master plan illustrating Stubb Road extending south across and through the subject property all the way to the UGB. A third reason is that as part of the March 21, 2018 pre-app, staff made clear through slide presentation images and text as well as spoken word during the pre-app that based on WDO 3.01.05 Street Layout staff desires extension of Stubb Road across the subject property so that a local street network serving the southwestern area within the UGB can branch out westward. The applicant had verbally agreed to the concept and included a copy of the subsequent April 11, 2018 pre-app memo by staff among the application materials. Subsection b) is not applicable. 5) The applicant asserts no unmet community need, and the Council has not yet identified such a need. Annexation of the subject territory demonstrates substantial conformance by conforming with all the above five considerations except consideration 2). Regarding D., the applicant obtained the requisite written consent and such that no election is needed. Regarding E., the applicant confirms the proposal includes no request to amend the Comprehensive Plan land use designation or upon annexation to designate the territory with City a zoning district other than RSN. (Pursuant to Comprehensive Plan Policy Table 1, RSN is the only zoning district that implements Low Density Residential that has also the Nodal Development Overlay.) Regarding F., the applicant need not address subsection 1. Because the City already annexed adjacent Parr Road ROW via the Smith Creek territory annexation (Ordinance No. 2565, Exhibit "B" map). Regarding subsection 2., Public Works staff indicated that dedication of public utility easements (PUEs) is deferred until development. The criteria are met. ANX 2018-02 Staff Report Attachment 102 Page 10 of 11 Applicant Identity Applicant Steve Miller, Senior Planner/ Project Manager Emerio Design, LLC Applicant's n/a Representative Landowner(s) Clyde H. Lowrie,Jr. & Umbrella Game LLC ANX 2018-02 Staff Report Attachment 102 Page 11 of 11