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STATE HIGHWAY 14, EAST FRONTAGE ROAD - ANNEXATION & ZONING (RESUBMITTAL) - 20-00 - SUBMITTAL DOCUMENTS - ROUND 2 -
No�,Ti-t�vx.� aa�o+�va k-" HI=25 a; PLAN pOR PY GAONMt� LOti�MUNfrIGh 36. Were there meetings with "environmentalists" beyond City Boards? Response: Yes. Last December, Citizen Planners organized a meeting between the "environmental' community and the Staff Technical Team. Citizen Planners made the arrangements including invitations to the meeting. Staff helped on the invitations too. Staff and consultants made a presentation, discussed the plan, provided handouts, and listened to and recorded comments. Staff offered to meet again with this group. Although there was some follow-up with a few of the individuals whor attended the meeting, there was never a follow-up request for another meeting from this group. There were other discussions between the "environmentalists" and "development' groups that did not include the Staff Technical Team. The 1-25 Plan Policy Committee was very aware of an encouraged the participation of this group. The Policy Committee encouraged Staff to work with this group. And, on a few occasions, representatives were invited to speak at the Policy Committee meetings. Also, this group self-selected representatives to regularly attend the Policy Committee meetings. The input of the environmental groups was important to the participating jurisdictions. Issues and Answers 18 Revised September10, 2001 www.i25comdor.com Nor) rht PL" G49I.0p).4 70 2 1=26 I1O:. PLLAN pOR were received and incorporated from many community staff members, citizens and advisory boards. And yes, there were meetings with the private sector. Had those not occurred nothing would have happened —no framework for regional cooperation would be on the table. Contrary to statements made by a few citizens, the development community has not had any special influence on the process, nor have they had any special access to the members of the planning team who wrote the Plan. In fact, the development industry meetings were held with full knowledge and agreement by the elected officials Policy Committee. 35. Why were our consultants on the 1-25 Corridor Plan meeting with developers? Response: At a very early stage of the planning process, a few private sector folks approached the staff and. some elected officials and offered to facilitate a dialogue between the Project Planners and the property owners/development industry working in the 1-25 corridor. They organized themselves and made all their own meeting arrangements, mailing lists and invitations and paid all the meeting costs. They called themselves the "Main Street Private Sector Group". The mailing list represented owners of over half the property in the corridor plus key developers, land brokers, planning consultants, attorneys, etc. involved in 1-25 development activity. Staff was invited to 3-4 of their meetings and provided project updates. Typically, there were 35- 100 people in attendance. Staff provided handouts on the project. Technical Team Staff from the participating jurisdictions were also invited and many attended these meetings, as did our Consultants. Later in the project, the larger group formed a subcommittee (5-6 members) that focused on the design standards. The group represented a geographic cross section of the property owners/development industry representatives. Staff and consultants met with this group 3-4 times over a 5-6 month period. The 1-25 Plan Policy Committee was very aware of and encouraged the participation of this group. The Policy Committee supported and encouraged staff to work with this group. And, on a few occasions representatives were invited to speak at the Policy Committee meetings. The input of the property owners and the development industry was important to the participating jurisdictions. Our approach to this group was the same as for any group who wanted to learn more about the Plan. For instance, the Planning Team .also met with the Kiwanis Club, Democratic Forum, Chamber of Commerce, boards and commissions, Citizen Planners, etc. 7[Isuessand Answers evised September 10, 2001 www.i25corridor.com n NOP�?�^FP�PdJ GtJ1�OFjH�DO CORRIDOR PLAN P,6G10NO.1� GOr.u�ttlNf(Gb floodplains and riparian areas; standards that are currently missing from many of the jurisdictions land use controls. Also, the Plan recommends that a Regional Open Space Task for the 1-25 Corridor be immediately organized as a means of addressing the preservation priorities and required resources in the Corridor. The Plan recommends that this task force includes the participation of the various organizations and boards that are involved in open lands protection across the region (both Weld and Larimer County), as well as private sector interests. And finally, the Plan was able to build consensus among'the jurisdictions for giving a further "look" at Transfer of Development Units as a means of preserving open lands; a consensus that was not present prior to the plan. PUBLIC PROCESS 34.The public was not informed of the Regional Plan and did not have adequate opportunity to provide input, and the input was ignored. The development industry was given "special" access to the process. Response: Staff does not agree with this opinion. Rather, we believe the Staff Technical Team and Policy Committee made efforts that were well above and beyond what is normally done or expected in terms of informing the public about the Plan and seeking their input. The preparation of the 1-25 Regional Communities Corridor Plan has involved an extensive community involvement process, as well as an unprecedented collaboration of public and private stakeholders. The process was designed to ensure that an open line of communication was established between the participating communities and their elected officials, the consultant team, residents, business owners, and property owners in the Corridor. This process involved both the ongoing dissemination of materials and feedback, such as through the project website and targeted opportunities for broad public involvement at key steps in the process. The planners conducted well over 100 separate, public meetings over the past eighteen months, including open houses, focus group meetings, public hearings and study sessions with elected officials and appointed boards, and special meetings with special interest groups including representatives from the development industry and environmental groups. This figure does not include the numerous one-on-one meetings with corridor property owners. On at least three occasions, letters and newsletters were sent to each of the 3500+ owners of property in the corridor informing them of the progress of the planning effort and inviting them to the public open houses. To suggest that the comments and suggestions made by others were not considered or did not result in any modifications to the Plan is simply not true. A large number of comments b Issues and Answers Revised September 10, 2001 www.i25corridor.com niyRTrFGRN ooLo+�eo�vo Yid I w25 :M PRNRIpOR Y P,GGIONAL G.p1.�M(JI�M{L' h 31.Will the adoption of the Regional Plan and Design Standards lower Fort Collins standards? Response: The 1-25 Regional Communities Corridor Plan is an important step in approaching these issues in a coordinated, regional manner. It does not diminish or lessen the high standards and policies held by larger communities such as Fort Collins and Loveland. It instead "raises the bar" for those smaller communities who have never had the need or resources to address these issues in the past, and allows the region to craft coordinated solutions which benefit all of the north front range communities, not just the larger cities. 32. How do you counter the claim that the design standards were rushed and largely written by developers? Response: The Staff Technical Team and Policy Committee worked on the design standards for nearly 18 months. There were multiple drafts and countless revisions. The standards reflect an enormous amount of work by staff from the eight participating jurisdictions. The staff worked with the development community on the standards; some of their suggestions were incorporated and many were not. The Staff Technical Team received far more input and suggestions from the . jurisdictions than from the developers. The staff team worked hard to prepare a set of standards that reflected the vision of the Plan that all of the communities could embrace. OPEN LANDS 33.The Open Lands and Natural Areas did not receive sufficient attention in the Plan. Why not? Response: Fort Collins would have preferred too if there had been more in depth analysis in the Plan in regards to this issue. But it did not, for two reasons. First, there are significant local efforts already underway and policies in place for the corridor in regards to the preservation of open lands and natural area and the planners did not Want to duplicate these efforts. For example, Loveland, Larimer County and Fort Collins have mature open space and natural area protection programs. And, the Larimer County Agricultural Advisory Board has identified agricultural lands in the corridor as priorities for protection. Second, the issue of open lands was simply a lower priority for many of the jurisdictions relative to transportation and design. And, as a result a smaller portion of the overall budget (accounted for 5% of allocated funds) was devoted to this issue. With the resources that were available, the Plan did what it could do and more. For instance the Design Standards offers some excellent standards for protecting 1 5 Issues and Answers ' Revised September 10, 2001 www.i25comdor.com niaRTrtr✓r� �olr"o+�,nno i-sa CORRIDOR J. PLAN tiGGrlONMt� GOMMUIW'(IGh decision would be left to each individual community. The vision of the Plan for the corridor focuses on quality development, open lands, and multi -modal transportation network. 28. Why didn't the Regional Plan specify exact sizes or boundaries of the proposed activity centers? Response: There is simply not a "one -size -fits -all" standard for the size of activity centers that the planners could find for a corridor that is diverse as ours in regards to topography, market opportunities, ownership patterns, and existing and approved uses. Rather, we believe this decision can only be made on. a case -by -case basis following more detailed planning at the local level e.g. at the subarea or zoning stage of local land use planning. The Fort Collins 1-25 Subarea planning effort, for example, will include a parcel by parcel land use and zoning plan that will specify the exact boundaries of the activity centers for our segment of 1-25. Nevertheless, pages 13 and 14 of the Development Design Standards for the 1-25 Corridor offers some policy guidance to the jurisdictions in making these local decisions. For example, the Plan provides that activity centers will "generally occur near an 1-25 Interchange or at the intersection of other major roadways", "within 1/2 mile of 1-25", and "within 1/ mile" of a transit facility - Also, a map is included in the Corridor Plan that identifies the general location of these activity centers. 29. "All residential development should be banned from the corridor!" Response: We disagree with the position that urban -level residential development along the interstate corridor should be banned. This is contrary to good planning principles as well as the City's existing policies of maintaining a jobs/housing balance and providing opportunities for residents to live near where they work and shop, and to have access to bus and passenger rail services as they become available. Fort Collins supports the Plan's recommendation to provide high density housing within or adjacent to the activity centers, where a range of services, including transit, are available or planned for the future and where residents can conveniently walk or bike to work or shop. 30. "If residential is permitted, it should include a mix of housing types!" Response: We agree with the need to provide a mix of housing types in residential areas, sensibly removed from the interstate; this is in fact what the Regional Corridor Plan recommends too. More specifically, the Plan recommends that "single family, duplexes, and other similar low -density residences" be permitted outside the activity centers, and "setback from the interstate" a minimum of'/ mile. In Fort. Collins, "similar low density residences" includes multifamily housing types. 4 Issues and Answers Revised September 10, 2001 www.i25corridor.com A10l3TM- i G01.0P')A.7O 1-23 ECORR:: . pIpOR '" P,GGIONP.I� GOP�7MlJIJrr�ih using the City of Fort Collins Traffic Forecast Model output data. The analysis performed used the industry standard, EPA emission factor model, Mobil5b. This model estimates regional emissions for Carbon Monoxide (CO), Nitrogen Oxides (NOX) and Volatile Organic Compounds (VOC). Model results were compared for three different scenarios. The first scenario was based on the currently adopted North Front Range MPO Plan land use patterns and transportation network (baseline scenario). The second scenario used the anticipated land use patterns with only the currently adopted regional roadway network, and the third scenario incorporated anticipated land use patterns with an augmented corridor roadway network. Results show varying degrees of congestion in each scenario. Massive congestion, deteriorating air quality, and failing Level -Of -Service (LOS) result from the anticipated land use patterns with only the currently adopted regional roadway network. The scenario with the anticipated land uses and the augmented roadway network resulted in less congestion than scenario 2, and in some instances better mobility and improved air quality than both scenarios 1 and 2. Existing and planned future development within the 1-25 Corridor area will have impacts upon transportation both within the corridor and the larger northern Colorado region. If this level of development relies solely upon the roadway network reflected in the current 2020 RTP (Scenario 2), the results will be increased congestion and delay, slower average travel speeds and a resultant increase in emissions in both summer and winter seasons. The development of arterial roadways to support and service the intense development in the 1-25 Corridor (Scenario 3) will allow for greater Corridor mobility and less reliance upon Interstate-25 for short, internal trips. This analysis suggests that increased mobility within the 1-25 Corridor results in positive air quality impacts. DESIGN STANDARDS 27. "The Plan speaks of a regional vision for the corridor ... the proposed Plan... increases intensity of development... making a virtual linear city ... no central place, no sense of community, totally created by automobile access to the Interstate... the residents of our region strongly support a vision of agricultural and other open space lands between communities..." Response: From the very beginning, of the 1-25 planning process, the participating jurisdictions agreed that the Plan would compliment the comprehensive plans of the communities and the region (including the Community Separator Study). Ms. Janett's comments discount and/or ignore these adopted plans. It was also agreed by all that the Plan would not seek to address land use patterns on a local or regional scale; those 1 3 Issues and Answers Revised September'10, 2001 www.i25corndor.com NOP,ThtGPYJ GOI`OFjA.DO 1=23 =u PLAN pOR input from citizens, staff, and elected officials from Berthoud, Johnstown, Loveland, Windsor, Timnath, Fort Collins, Larimer County, Weld County, the Colorado Department of Transportation, and the North Front Range Transportation and Air Quality Planning Council (MPO). This Plan was never intended to be a "one -size -fits -all" answer. It was always intended. to be a "conceptual plan" e.g. a vision for the future. It will be up to each of the Corridor communities, either individually or collectively, to take this shared vision to the next, more detailed planning stage, and make it work.best for their citizens' needs. Berthoud, Loveland, and Fort Collins have already begun these steps with subarea analyses that closely examine land use decisions and tailors their respective master street plans to best service anticipated future development in the 1-25 Corridor Planning Area. 25."No land use plan ... our elected officials and public planners are abdicating their responsibility ... the parallel roads will triple the amount of retail/commercial activity ... the result will be that 1-25 will cease to function an inter -regional, through street, but will become an even more congested local access road ... the major roads will have a level of service D, E. and F." Response: From its inception, the objectives of the planning effort for the 1-25 corridor has always been clear: Establish a regional vision that addresses development quality, open lands and natural areas policies, and a multi -modal transportation framework. The participating jurisdictions agreed to these objectives, and all endorsed a resolution that established their commitment to this effort. It was also agreed by all that the Plan would not seek to address land use patterns on a local or regional scale; those decision would be left to each individual community. Fort Collins is currently addressing land use patterns in the corridor through the subarea planning process. The land use projections used in the Plan were drawn from the individual community's plans, zoning and development approvals. There is no evidence that the Plan will increase development activity in the corridor more than what is already planned, predicted and being promoted (by some jurisdictions). The Conceptual Transportation Plan improves mobility along I-25 and along the major north -south and east -west roadways. It is true that 1-25 will be more congested than it is now; but it will not be failing (level of service F) as the traffic model indicates it will be if the recommended transportation improvements are not. implemented. The improved roadway network allows 1-25 to serve regional and interstate travel, while supporting connectivity and mobility within and between planned centers along the Corridor. 26. How will the Plan affect air quality in the region? Response: A regional air quality analysis was performed for the 1-25 Corridor Plan. The air quality analysis for this project was regional in its scope and was performed 2[Revised sues and Answers September 10, 2001 www.i25comdor.com NOP,Tt4f% N GOl-OPrADO Oil' 1=25 CORRIDOR '- PLAN PtGG10NAL /g1.�Mt,iNY(�9 22.Why does the Regional Plan unfairly place the cost of the transportation infrastructure on citizens and not on those who most directly benefit? Response: Participating communities in the 1-25 Regional Communities Corridor Plan agree that development must be accountable for its fair -share of impacts and costs. The plan specifically states that "...development -induced demand for transportation facilities should be funded from development activities, rather than local residents." Larger communities such as Fort Collins and Loveland already have enacted and implemented development impact fees and adequate public facilities ordinances that require development to pay for its proportionate impactsand to ensure that the proper infrastructure be in place concurrent with development. Loveland and Windsor have even gone beyond this level and have identified subarea -specific funding strategies for the Crossroads Area's transportation and infrastructure needs. The /-25 Regional Communities Corridor Plan recommends this type of subarea -specific analysis be performed in other parts of the 1-25 Corridor as well. 23. What are the cost estimates for the 1-25 Plan road improvements? Response: Page 41 of the Plan provides "sketch plan -level" cost estimates for the arterial ($125 million) and interchange ($175) improvements, a total of $300 million. These costs do not include increased regional and feeder bus service or the commuter rail. The tricky part of the cost estimates is to separate the "new" transportation improvements recommended in the Plan from other needed network transportation improvements that are already part of some other current regional or jurisdiction's transportation plan. For instance, a large portion of the recommended arterial network in the Plan is already included in the Loveland, Windsor and/or Larimer County master street plans. The commuter rail system is part of TAFS. Staff is reasonably comfortable with the $125 million cost estimate for the arterial improvements because these include some new N-S arterials and upgrading of some E- W roads not currently included in another jurisdictions plan. However, most of the recommended interchange improvements are already or soon to be needed due to growth in the entire region and therefore are not so directly tied. to just the Plan. But we included them in the Plan cost estimates anyway because they were not showing up on any other jurisdiction's plan. 24.The Transportation Element in the Regional Plan does not provide enough detail. Why? Response: The 1-25 Regional Communities Corridor Plan represents a shared vision for the future of the 1-25 Corridor in Northern Colorado. This vision was crafted with 1 Issues and Answers Revised September 10, 2001 www.05comdorcom NOPi'ri-FP�WJ G�PSA.DO 1=23 . CORRIDOR PLAN rsr'4 L- &' 1 "UN17C_FJ planned for the area, the impact would be significant without updating the master street plans within this corridor for future improvement of the major arterial roadways that run east -west and north -south. The Transportation Element of the I-25 Regional Communities Corridor Plan also pulls together the transit, rail and bicycle plans for the corridor in one document. An important aspect of this plan is to enable communities and counties to preserve right-of-way for future roadway infrastructure to be funded by and to service anticipated corridor —specific development. This Plan allows for intergovernmental master street and transportation plan for future development that provides for good multimodal circulation and connectivity both within and between focused centers of activity along the 1-25 corridor planning area. 20. "Mass transit was an afterthought... the Plan was designed to be a road plan that will divert public financing from rail to subsidizing roads ... lets focus on mass transit." Response: Alternative modes were not an "afterthought" in the Plan. It was always an important issue. The 1-25 builds upon previous work for the corridor including the North Front Range Transportation Alternatives Feasibility Study. The Plan includes new recommendations for transit and alternative mode improvements. And, the recommended design standards are directed at creating more transit -friendly development. The misperception that alternative modes was not given as much priority as cars/roads was fostered by the greater public attention to the issue of roadway improvements given the very poor level of service that was depicted in the consultant's studies. 21.The Regional Plan seems to only address cars and not other transportation modes. Why? Response: The Transportation Element of the I-25 Regional Communities Corridor Plan is built on a foundation stressing true, balanced multi -modal transportation alternatives. Multi -modal transportation elements from the North Front Range Transportation Alternatives Study (NFRTAFS) adopted in 1999 form the backbone for the recommended 1-25 Corridor transportation system. This includes regionally focused Commuter Rail supported by feeder bus transit servicing inter -regional and local needs. Local and regional plans for bicycle and pedestrian trails were also incorporated into the recommended transportation element. In many ways, the I-25 Regional Communities Corridor Plan lays the groundwork for the most comprehensive multi -modal transportation network ever envisioned for Northern Colorado. o Issues and Answers Revised September 10, 2001 www.i25comdor.com WCIPr7;-� coy ovvo ode CP ARNRIpOR =u �Gr10hWli GONIP-tCJd�M'f�h TRANSPORTATION 17. Can you counter the claim that the I-25 Regional Corridor plan will/is intended to subsidize state and federal widening of 1-25? Response: First, the widening of 1-25 is not anticipated nor planned for in the /-25 Regional Communities Corridor Plan, TAFS Study, or the draft North Front Range 2025 Fiscally Constrained Regional Transportation Plan. Therefore, the issue of subsidization is a moot question. Second, and more importantly, the purpose of the 1-25 regional plan. is to recommend a regionally coordinated and interconnected local transportation system network (for all modes) in response to the plans and zoning that communities have approved (and are promoting) along the corridor. The recommended local network will provide an alternative to 1-25 for local trips (2 to 5 miles long), maintaining 1-25's integrity for region -wide and interstate travel trips. Staff believes this is responsible transportation planning on the part of the local jurisdictions and not a case of shifting the responsibility from the state or federal governments to widen the interstate. This local network is essential in order to provide for transportation needs in this two-mile wide corridor, and will be needed whether or not the state and federal government choose to widen 1-25 at some point in the future. 18. How does the 1-25 Regional Communities Corridor Plan road plan differ from the plans for road development that is part of the MPO's 2025 plan? Response: The MPO's "road" plans cover a much larger geographic area than the 1-25 Corridor Plan. And, the roads the MPO is interested in are much more "region -serving" than the 1-25 Corridor Plan; the 1-25 Corridor Plan includes the MPO's region -serving roads plus a local road network. The MPO's 2025 Transportation plan is 'fiscally restrained"; the Corridor Plan is not. And finally, the time horizon for the MPO's plan is 20 years; the Corridor Plan is longer. 19. How can the 1-25 Regional Communities Corridor Plan make transportation recommendations without a land use plan? Response: The sense that no land use thought went into preparing the Transportation Element of the 1-25 Regional Communities Corridor Plan is not accurate. The premise for establishing the need for infrastructure as future development occurs within the 1-25 Corridor came directly from established, adopted community and county land use plans that are now in force in the northern front range area. These plans, combined with new development that either currently exists or has been approved for construction, were compiled by the project team and the policy committee and looked at from a comprehensive, corridor -wide perspective. It became very apparent that if each of these land use master plans are realized, and no additional transportation service is 9 F sues and Answers evised September 10, 2001 www.i25corridor.com r.iov,?rtGww eoLo+2�vo rip. I=ZS CORRIDOR PLAN The 1-25 Plan does not propose any "new" roads in these community separators. Rather, the 1-25 Corridor Plan's Open Lands policies are supportive of the Study. For instance, the 1-25 Plan recommends establishment of a "Regional Open Space Task Force"; establishment of TDU programs; and, creating development funding resource protection programs, which could stimulate 'more regional discussion and implementation of community separators in the 1-25 Corridor. "The North Front Range MPO has a long range -range regional transportation plan that promotes passenger rail and inter -city transit. This Plan will divert scarce transportation dollars from mass transit solutions to more roads and congestion. " Response: Nothing in the Plan suggests diverting transportation funds.from transit to roads. Quite the contrary; the Regional 1-25 Plan has been carefully coordinated with, is supportive of, promotes,'and expands upon the alternative mode policies of the MPO's various regional transportation plans, including the North Front Range Transportation Alternatives Feasibility Study. The 1-25 Planning process has in fact increased awareness of and support for transit in the corridor. The North Front Range Transportation Planning and Air Quality Council has recommended that the Transportation Element of the 1-25 Regional Plan be adopted by the participating jurisdictions. Funding for future regional roads and transit will be decided by the MPO and/or individual jurisdictions. 16. "Clarify for me, once again: When we (City Council) vote on the 1-25 Corridor Plan, are we voting to accept JUST the road plan, or does it include the design elements and the open space commitment? When other cities, such as Berthoud, vote on this, are they voting on just the roads portion. I read in the Loveland paper that Berthoud will be discussing the design part sometime in August, so it appears that they only voted on the roads." Response: The Council will be considering a resolution for adoption of the entire Regional Corridor Plan document, including the transportation, design, natural areas/open lands, and the implementation elements. This is what. each of the communities is doing too. Berthoud adopted the entire plan a few weeks ago. This Fall, Berthoud will be considering adoption of the Design Standards (which is another document; not part of the Regional Corridor Plan). This is similar to the process that Fort Collins is following e.g. Council will adopt the Regional Plan in November and later, as part of the adoption process for the Subarea Plan, Council will be considering adoption of the 1-25 design standards. Generally, most of the communities will adopt the Plan and design standards under separate processes e.g. present the vision first, then later the detail and implementing ordinances. 8 [Revised sues and Answers September 10, 2001 www.i25comdor.com WaRT�-� ooL-o+&PN vo HP HIm23 CCOARNRIDOR '" ` PiGC:dOhlA.l� G01��MCINITN h that regional, communities could draw upon to fund improvements. The 1-25 Plan leaves the choice of funding mechanisms to the individual communities and the MPO to decide. " Fort Collins economic development policy discourages government sponsored growth incentives. This Plan is a major incentive for new growth by attracting new development with promises of new roads." Response: The 1-25 Plan is consistent with City Policy regarding providing quality services to encourage and support economic development. There is no mention in the Plan of any "economic incentives". "City Plan supports the concept of a compact city that grows from the center outward. This Plan facilitates the opposite; sprawling development in a 60 mile square linear corridor, distant from central cities, services, and residential communities." Response: The 1-25 Corridor Plan was never intended to and does not force the policies of the Fort Collins' City Plan on the participating jurisdictions. Rather, staff was directed to be sure that the 1-25 Plan was compatible with and honored the comprehensive plans of the participating jurisdictions. "City Plan supports growth locating near adequate public facilities. There are little or no public infrastructure or facilities in the corridor; e.g. parks, fire stations, sewer, water, etc." Response: The Plan was never intended to and does not address public infrastructure except for the local transportation network. Rather, each of the jurisdictions has their own policies and standards for public facilities. The City's Adequate Public Facilities requirements will apply to development within our segment of 1-25 that is annexed into the City. "The City supports the Northern Colorado Community Separator Plan that identifies the location of separators between communities. New roads in the corridor will attract even more growth, eliminating even the opportunity to conserve agriculture in the separator area." Response: The only two "viable" community separators left in the 1-25 Corridor are the Windsor/Timnath/Fort Collins and Wellington/Fort Collins separators. An implementation study is underway for the Windsor/Timnath/Fort Collins separator; a similar study is contemplated, but not underway for the Fort Collins/Wellington Study. 7 Issues and Answers Revised September 10, 2001 www.i25comdor.com N f% -F ?" GOL OFyA.DO �'-za CORRIDOR JU- �,GGIONP.L GOh�MUNITp'ifj 13. If we do not expand the GMA, what affect will this have on the 1-25 Regional Corridor Plan?, Response: The policies of the 1-25 Regional Communities Corridor Plan are independent of whose jurisdiction's growth management boundary a property in the corridor lies within. However, implementation the Plan is likely to be more successful if the subarea were within the City's GMA, under City control. 14. What happens if some of the communities don't adopt the Regional`Plan? Is it an all or none proposition? Response: The possibility that one or more jurisdictions might not participate or agree to implement a plan was considered early on in the planning process. Regardless, all the participating jurisdictions agreed that it was important to proceed with the preparation of the Plan. Obviously, the Staff Technical Team and Policy Committee hopes that all of the participating communities will adopt the Plan; and early indications are that most if not all of the jurisdictions will eventually adopt the plan. If this is not possible, the jurisdictions have informally agreed that it is important to pursue implementation with as many jurisdictions as possible adopting the Plan with the faith that the few, remaining jurisdictions will soon follow. 15."This particular Plan conflicts with many of our local policies about planning and growth" for instance: "Growth should pay its own way. This Plan never even suggests this principle and lists regional taxation, special taxing districts, and paying developers from sales taxes as funding mechanisms for development related roads" Response: This is not correct. Page 41, Section "Funding", 2nd paragraph of the Plan, states that funding will be through both local and regional sources and through both public and private sector funding mechanisms. The next sentence states that "Inherent in these assumptions is the principle of development paying its "fair share" meaning that development induced demands for transportation facilities should be funded by the development activities, rather than by local residents". This statement is completely consistent with City Plan policy GM-6 which states that "Development will pays its "fair share" of the cost of providing needed facilities and services". The funding mechanisms that Ms. Janett mentions in her letter are correct. However, she failed to note that the Plan also mentions local impact fees as a primary source of revenue. Furthermore, the funding mechanisms that she describes are those that is currently being discussed as part of the Crossroads Boulevard Subarea Study and/or the MPO's regional funding study. These are simply examples of potential mechanisms b F sues and Answers evised September 10, 2001 www.i25comdor.com Kwrin-t P" GOL.OP),C�DO rn Im25 :.a IDOR PLAN FjGGIOtJP.L GOMMUhII'(Y 4 design standards. Timnath, Johnstown and Weld County have not yet. scheduled meetings to consider adoption. The NFRAQPC has recommended adoption of the Plan. 11. What are the consequences of not adopting the Plan? Response: Development activities along the corridor will continue at the same level of activity anticipated, since much of the land has already been annexed, planned,. and zoned. But this will occur without the regional context provided by this Plan. Some transportation activities along the corridor will still be coordinated through the regional MPO, but as part of a broader, regional effort. Most importantly, the momentum started by this planning effort for the communities to work together in the corridor will be lost if the Plan is not adopted after almost two years of effort on the part of staff, elected officials and citizens in the region. 12. What is the relationship between the 1-25 Regional Communities Corridor Plan and the subarea plan? When and by what mechanism (resolution; Study Session discussion and direction; etc.) did the previous Council request that the Council act on these two studies separately and that the Corridor plan be considered first, followed by consideration of the subarea plan. Response: The Regional Plan provides an overall vision for the 30-mile corridor in regards to transportation, open lands, and development quality. It is general in scope and broadly grained; it purposely refrains from issues of local concern like land use on individual parcels or urban growth boundaries. It is intended to serve as the basis for an agreement between the communities along the corridor for their individual actions in support of a regional vision. On the other hand, the subarea plan is specific to Fort Collins' portion of the corridor. It provides a fine grain analysis and recommendations within the broader vision of the regional plan. The subarea plan will offer specific land use, road network and open lands recommendations on a parcel by parcel basis. While the regional plan provides overall direction for the Subarea Plan, they are independent efforts and address quite different levels of detail. There was no "direction" from Council that the regional plan and subarea plan be separately brought forward for Council approval. However, staff has been saying that the subarea plan would follow the regional plan because it was important to establish the region -wide vision first; and the details of the subarea plan would shortly follow (2-3 months later). It is.fair to say that the original direction from the Council(s) was to come up with a framework that all jurisdictions could adopt, and THEN modify it at the local (subarea) level to reflect local conditions and tastes. It is also important for Fort Collins, which has always been seen as a leader in the region for good planning, to set an example by being among the first communities to adopt the regional vision. 5 Issues and Answers Revised September 10, 2001 w J25comdor.com NOP1T1-�riWJ GOIOP�A.DO I-ss E CORRIDOR -u PLAN P,GGrIONAL GOMMCJIJI'1•�ih 7. Will the Regional Corridor Plan just encourage more sprawl? Response: The Plan is in response to growth that is already underway or will be shortly. The Plan was never about limiting growth. And, contrary to opinion expressed in some of the comments received, the 1-25 Regional Communities Corridor Plan does not seek to "stimulate" corridor development. The premise for establishing the need for infrastructure as future development occurs within the 1-25 .Corridor came directly from established, adopted community and county land use plans that are now in force (and being promoted) in the northern front range area. 8. "There's no teeth in the Plan; an absence of regulation! Response: The Plan is a voluntary, cooperative, regional planning effort among the eight participating jurisdictions (Berthoud, Johnstown, Loveland, Windsor, Fort Collins, Timnath and Weld and Larimer counties). The primary objective was to establish a ,'vision" for the corridor. The Plan is non -binding; it's a beginning, on a long arduous effort of course correction: The regulation (teeth) will be provided by the adopting jurisdictions. For instance, in Fort Collins, the design standards will be incorporated in the City's Land Use Code and enforced as new development occurs in the corridor. 9. "Costs to taxpayers ... no dollar estimates for open space or mass transit... who pays and who benefit?" Response: The direction from the Policy Committee was to focus the 1-25 planning effort on creating a vision for quality development, open lands preservation, and alternative modes in the Corridor. Furthermore, the Plan recommends that "next steps" in the process be identifying funding mechanisms for open space and transportation. Regarding transportation, the Plan recommends a framework of "regional partnership areas" be created wherein the jurisdictions of each of these areas work together in a manner similar to the Crossroads Study effort, conducting a detailed transportation evaluation, examining funding opportunities, and defining prioritization and phasing of improvements in response to the local areas growth and development. And, regarding open lands, the Plan recommends establishment of a Regional Open Space Task Force for the 1-25 Corridor as a means of addressing the preservation priorities and required resources in the Corridor. 10. What actions have communities taken on the Plan to date? Response: The Towns of Windsor and Berthoud, and Larimer County, and City of Loveland, have adopted the Plan (by unanimous approval of both Planning Commissions and town/county/city elected boards). Windsor has also adopted the 4 F sues and Answers evised September 10, 2001 www.i25comdor.com niv�Ti-fct� co�or�eo I -SS EC IDOR .., �Y PIGin10NP.1� GOMMUIJI'(GiJ While most communities are excited about the economic benefits that growth brings, they are also realizing that without careful planning and coordination on a regional basis, it brings other costs and unanticipated consequences. These include the potential for unattractive, strip development, inadequate transportation systems, impact on future transit opportunities, and loss of our unique regional character and qualities. We only need to look just south of our region to see what can occur without sound planning. Because of the significance of the 1-25 corridor for both residents and travelers throughout the Northern Colorado region, the communities of the region joined together to establish a vision and framework to ensure compatible, coordinated development. Continuous, unattractive development without adequate provision for a well -planned, multi -modal transportation will likely occur if this plan is not adopted. and implemented. 5. What are the benefits to Fort Collins from adoption of the Plan? Response: The benefits to Fort Collins from adopting the plan are numerous. First, as the largest community in the region, it is essential that Fort Collins participate as a leader in the regional arena, working with others to address critical issues in the corridor. By adopting the Plan, the City will be seen as endorsing a regional approach to problem solving in the corridor. Second, adoption of the Plan will result in numerous transportation benefits to the City. These include congestion relief through implementation of ._the roadway recommendations, and enhanced opportunities for implementing transit on a city and regional basis. One of the actions that need to be taken is to begin preserving the necessary ROW for future transportation corridors as development occurs. Third, by embracing the recommendation for a task force to focus on implementing a regional approach to open lands and natural areas in the corridor, the City will be in a position of forging new partnerships with communities in the region. 6. Are there any negative consequences to the City from adoption of the Plan? Response: No. The City will continue to implement its policies and standards towards land use patterns, development cost recovery, open lands, and transportation in the same manner in which it currently operates. The primary difference is that it will do so with some assurance that it will share some of the same values with other communities in the region, even if they may not choose to embrace the same policy approaches as Fort Collins in all cases. 3 Issues and Answers Revised September 10, 2001 www.125corddor.com NOP�T�-FC�PYJ GOl�OF5A.D0 w.. 0 111-sa PCO�RRIpOR P1GG�ONAI� GOMMUr.NTGh GENERAL 2. Why do we need the Plan? Response: The face of northern Colorado is changing rapidly. Over the next 10-20 years, the 1-25 Corridor is likely to experience more changes than any other part of our region. Communities have annexed and zoned thousands of acres for development along the corridor, and, each community already has or is in the process of establishing their own land use and development plans for these areas. This is causing a strong emotional response for some of our residents, who are experiencing a sense of loss over the change in our region's character. In order to be effective, we must get past the emotional reaction to these changes, and take a hard, objective look at the current situation and the future. Quite simply, what is needed is to deal prudently with the reality of the situation. Yet we are lacking a regional context for decision -making and coordination amongst the communities along the corridor. This Plan, if embraced regionally, establishes a framework for the communities to work together on issues of regional significance such as transportation and open lands preservation. Within that regional context, there should be room for each community to establish its own standards and approaches that best fit their own "culture" and approach towards development. 3. What are the objectives of the Plan? Response: From its inception, the objective of the planning effort for the I-25 corridor has always been clear: Establish a regional vision that addresses development quality, open lands and natural areas policies, and a multi -modal transportation framework. The participating communities agreed to these objectives, and all endorsed a resolution that established their commitment to this effort. It was also agreed by all that the Plan would not seek to address land use patterns on a local or regional scale; those decisions should be left to each individual community. Fort Collins is currently addressing land use patterns in the corridor through the subarea planning process. 4. What is the purpose of the 1-25 Regional Communities Corridor Plan; how is it an example of good/wise planning; why do we need such a plan for the "corridor"? And, if we don't do some planning in the corridor, what can we expect... sprawl, strip development, other? Response: It's clear that the corridor will be subject to considerable development activity over the coming years as evidenced by the amount of land that communities along the corridor have annexed and zoned for development in the past several years. 2 Issues and Answers Revised September 10, 2001 www.i25comdor.com NOFSTrtGPxJ GOL-OP,P.170 Im23 :., CORRIDOR F'1GGIONC.L GOMMUIJP(Gh Issues and Answers 1-25 Regional Communities Corridor Plan Revised September 10, 2001 Over the past 3-4 months, a variety of "questions" have been asked of and by the Fort Collins City Council and City staff about the 1-25 Regional Communities Corridor Plan. The policy of the City Council and City staff has been to respond of these questions as quickly and as fully as possible. The following is a compilation of many of these "questions" and the City staff "response" to them. We hope this information will be useful for you in learning more about the 1-25 Corridor Plan. You can download a copy of this document at www.fcgov.com/advancenlannina. A hard copy is also available from the City of Fort Collins Advance Planning Department at 281 North College Avenue, (970-221-6376). More information about the 1-25 Regional Communities Corridor Plan is available at the project website at www.i25corridor.com. NEXT STEPS 1,. When will the City Council consider the Plan? Response: The City Council postponed discussion of the 1-25 Corridor Plan at their Council Meeting on August 21 to allow additional time to consider input that was provided at the public forum on August 8 and to further study the Plan. In general, the direction was that City staff would carefully review the Plan and identify objectionable parts that could be cut from the Plan without significantly affecting its overall vision and integrity. Two issues in particular were identified for dissection: Funding of transportation improvements; and, certain phrases in the Plan that appear to overly "promote" or "encourage" urban development in the corridor. The recommended deletions could be brought forward in the form of "conditions" to be included in the adopting Resolution of City Council. Furthermore, staff was directed to seek the input and advice of the City's Natural Resources Advisory Board, Transportation Board, Air Quality Advisory Board, and Planning and Zoning Board, of any recommendations they may have for eliminating parts of the Plan in regards to the above issues. The findings of staff and the recommendations of the City boards will be presented to and discussed by City Council at their Study Session on October 23. Council will consider adoption of the Plan with the proposed changes at their regular meeting on November 6. Issues and Answers Revised September 10, 2001 www.125corridor.com Ted Shepard CCSS082702 Staff R _port.doc — —__v_ the I-25/Mulberry and/or the I-25/Prospect "activity centers" as mixed -use housing, i.e., housing located on the 2"" floors of office/retail commercial uses. Since the I- 25/Mulberry activity center is basically totally developed, the only potential for additional affordable housing would be at the I-25/Prospect activity center. Ted Shepard_„CCSS082702 Staff Report. doc _ _ m_ Page 3 of the I-25/Mulberry interchange and the other at the northeast quadrant of the I- 25/Prospect interchange (see attached Comparison Matrix). Staff believes the northeast I- 25 Prospect site is better suited for regional/community shopping uses for the following reasons: at a minimum of 60 acres, it offers greater flexibility as to size (the Mulberry site is a maximum of 50 acres); the Prospect site is already annexed into the city (the Mulberry site is not eligible for annexation); most of the Prospect site is already zoned C, Commercial and the property -owner would be willing to rezone for a larger area (the Mulberry site is mostly zoned I, Industrial in the County and the property -owner is undecided if the property should be rezoned); the Prospect site offers greater flexibility for potential access to adjacent residential areas (the Mulberry site is constrained by existing development). Both locations would require improvements to the interstate interchanges. There is a plan for improvement of the Mulberry interchange (there is no plan for the Prospect interchange). The Regional Transportation Plan indicates improvements to the prospect interchange would cost about $19 million, while improvements to the Mulberry interchange would cost about $30 million. Both sites are also located in the Boxelder Creek floodplain. Affordable Housin Citizens expressed concerns that the Regional I-25 Corridor Plan did not adequately deal with the issue of affordable housing. Encouraging the development of affordable housing in the I-25 Subarea Plan's study area will be difficult if residential development is restricted to a density of less than 2 units per acre as directed by the Council. Densities at around 12 units per acre, or more, are typically needed for the development of affordable units. Staff has been working with the Affordable Housing Board in developing potential mitigation methods. One possible solution is to allow a density bonus for affordable housing proposals in urban estate areas similar to the density bonus to 12 units/acre in low density mixed use neighborhoods. While this solution seems simple on the surface, it would create compatibility issues if an affordable project at 12 units per acre were to be proposed adjacent to residential areas developed at less than 2 units per acre. Section 3.5.1 of the City's Land Use Code requires new development to be designed to be compatible with existing development. Thus, staff does not believe a density bonus will work in urban estate areas because of the compatibility requirements. East of I-25, there are only two undeveloped properties planned to be included in the low density mixed use neighborhood classification (that would allow for an affordable housing density bonus). One property, located north of Mulberry (approximately 27 acres) is considering developing as an extension of the Cloverleaf Mobile Home Park, if the development plan can overcome significant Boxelder Creek floodplain issues and neighborhood concerns from the Vista Bonita Subdivision. The other property (approximately 47 acres) is located south of Mulberry. This property -owner is considering developing some multi -family units (not necessarily affordable units) as part of the housing mix for the property. The only other potential locations for the development of affordable housing would be in Ted Shepard CCSS082702 Staff Report.doc� Page 2] 50% building frontage is a new standard designed to prohibit the development of what could appear to be a continuous line of buildings adjacent to the highway. By limiting building frontage to no more than 50% of a lot's frontage, open areas will remain between buildings. Eventual Access from Parallel Road System: Traffic modeling has shown that the interstate highway cannot function as a both a highway and a local arterial for development in the I-25 corridor. Therefore, the parallel road system is designed to provide the necessary local access and movement through the corridor. Requiring development to be designed in a manner to eventually take future access from the parallel road system will only enhance its functional usefulness to provide for the local access and corridor movement. Resource Recovery Farm At the last Council study session on the I-25 Subarea Plan, Council directed staff to investigate what it would take to preserve most of the Resource Recovery Farm as open lands. The matter involves both legal and financial issues. Council has received a memorandum (May 16, 2002) from the City Attorney's Office detailing the legal aspects of preservation. Essentially, the property will need to be purchased from the Utilities Department at fair market value. An appraisal of the property will need to be completed to establish its value. The Utilities Department will commission the appraisal. The southwest corner of the I-25 and Prospect Road interchange (approximately 50 acres) will be retained by the Utilities Department for future sale. This area is currently zoned C, Commercial. The extreme southern portion of the property will be donated to the Parks and Recreation Department in fulfillment of previous agreements. The balance of the area, approximately 150 acres currently zoned E, Employment will need to be purchased. The City's Engineering Department has completed legal descriptions for the various portions of the property. As indicated, an appraisal will need to be completed to establish value. Then, all information will be forwarded to the Council, and the Council will determine the final cost of the property and identify a funding source for the purchase of the property. Reeional/Community ShonoinR Area There have been discussions in the past as to the appropriate location(s) for regional/community shopping centers within the I-25 corridor. The potential locations included the I-25/Mulberry interchange activity center, the I-25/Prospect interchange activity center, or outside the I-25 corridor along East Mulberry Street, west of the interstate highway. The East Mulberry Corridor Plan has basically concluded there is not an appropriate location for a regional/community scale shopping center within its study area, so that leaves the two interstate highway activity centers as potential locations. Staff has completed a comparison of two potential locations, one at the northeast quadrant ETed Shepard~CCSS082702 Staff Report.doc —�� Pegg gill Update on the I-25 Subarea Plan The purpose of this report is to present the City Council an update on the process to develop the I-25 Subarea Plan. Discussed below are summaries of the major areas currently being worked on by staff. Design Standards The Regional I-25 Corridor Plan, adopted by the Council last year, contained a listing of suggested design standards for development within the highway corridor. Staff has completed an exhaustive review of the suggested standards in comparison to standards contained within the City's Land Use Code. Generally, many of the City's existing standards were equal to, or better than, the suggested standards. Staff is drafting code language for the small amount of standards that will need to be added to the Land Use Code (see attached Draft Regulations). Basically, the new standards will deal with land use setbacks, building setbacks and spacing, architectural standards, and standards for the activity centers at the Prospect/I-25 and Mulberry/I-25 highway interchanges. Listed below are the key components of the new standards: • Requirement that "secondary uses" allowed in the I, Industrial, and E, Employment, Zoning Districts be setback at least '/a mile from I-25. • Prohibition of single-family residential development within '/a mile of I-25. • Requirement that single-family residential development more than '/a mile, but less than '/2 mile from I-25, be clustered. • Minimum building setback of 80 feet from I-25 right-of-way — Maximum 50% building frontage. • Development designed to (eventually) take access from the secondary (parallel) road system and not frontage roads whenever possible. Setback of Secondary Uses: Secondary uses in the E, Employment, and I, Industrial; Zoning districts include such uses as hotels, restaurants, convenience shopping, child care, and housing. The policy requiring secondary uses in the E and I Zones to be setback at least '/a mile from I-25 was initially developed in the Mountain Vista Subarea Plan and implemented through Division 4.22 (D) of the City's Land Use Code. The standards of the I-25 Subarea Plan will extend the policy and requirements to the east side of the highway. The policy and Code requirement is designed to prohibit a commercial strip from developing adjacent to the highway. Setback of Single -Family Housing: This policy and requirement is derived from the Regional I-25 Corridor Plan. Single-family residential development is deemed to be inappropriate in close proximity to the highway. Minimum 80' Setback — Maximum 50% of BuildingFrontage: rontage: The 80' setback requirement was initially developed in the Harmony Corridor Plan. The maximum Ted Shepard CCSS082702 Cover Page doc Page 1, SUBJECT FOR DISCUSSION: The I-25 Subarea Plan GENERAL DIRECTION AND SPECIFIC QUESTIONS TO BE ANSWERED: • Does Council have any questions or concerns regarding the proposed key elements of the design standards for the I-25 corridor? • Should staff continue to pursue the preservation of the Resource Recovery Farm as open lands through purchase from the Utilities Department? • Should the I-25/Prospect activity center continue to be shown as a potential location for regional/community shopping uses, or should the I-25/Mulberry activity center replace it, or should both locations be shown for regional/community shopping uses? • Is Council comfortable with the limited opportunities for additional affordable housing development in the I-25 corridor, or should more land be made available for such development? LIST OF ATTACHMENTS: Staff Report I-25 Subarea Development Standards — Draft Regulations Regional/Community Shopping Comparison Matrix I-25 Subarea Plan - Summary Listed below are the key points, conclusions, and policies of the I-25 Subarea Plan: • Due to the recent adoption of the Mountain Vista Subarea Plan, the Fossil Creek Reservoir Area Plan, and the East Mulberry Corridor Plan, the 1-25 Subarea Plan mainly deals with the area located east of I-25 from around the Prospect Road interchange on the south, to County Road 52 on the north, and County Road 5 on the east. • No change to the City's Growth Management Area (GMA) boundary is proposed as a result of the plan. • Two mixed -use activity centers are identified for the planning area, one at the I-25/Mulberry Street interchange and the other at the I-25/Prospect Road interchange. The northeast quadrant of the I- 25/Mulberry Street interchange is also planned for the potential location of a regional/community shopping center. • Employment and industrial districts adjacent to I-25 are to be designed in such a manner as to maintain a perception of openness through the corridor. This will be achieved through the use of design standards, including setback requirements and maximum building frontage allowances, and the proper management of floodplain areas. • Secondary uses (retail and highway oriented commercial uses) typically permitted in industrial and employment districts will be required to be set back at least 1/4 mile form I-25 in order to avoid the development of a "commercial strip" appearance along the highway. • Low -density, single-family residential development is to be prohibited within one -quarter (1/4) mile of 1-25 through various means, including zoning patterns and land use restrictions. Development that creates new single-family lots located between one -quarter (1/4) and one-half (1/2) mile from the I-25 right-of-way shall utilize a clustering technique to concentrate densities away from the I-25 right-of- way, and to maximize views, and preserve landscape features or open space. • Low -density, mixed -use neighborhoods are to be concentrated within one-half (1/2) mile on either side of Mulberry Street east of 1-25. These neighborhoods could have densities as high as eight (8) dwelling units per acre, with affordable housing projects obtaining a density of 12 dwelling units per acre. • The balance of the areas planned for residential uses are to be urban estate developments with a maximum density of two (2) dwelling units per acre. • The City's Resource Recovery Farm is to be preserved as open lands. • The study area is planned to eventually be served with multi -modal transportation options, including mass transit, bicycle and pedestrian connections. A supplemental street system (sometimes referred to as a parallel street system) is planned to be the major facilities allowing movement within the corridor, thus, diminishing the need to utilize the interstate highway for short length trips. The employment and industrial districts adjacent to 1-25 will be designed in such a manner that they eventually obtain their access from the supplemental street system, thus, minimizing the need to use the frontage roads adjacent to I-25. developed for the I-25 Regional Corridor Plan. • Dependent on the establishment of an Integrated transportation network that focuses travel within the corridor away from I-25 onto a north/south local street system. • Land uses cover the full range of urban uses, intensities and densities, Including, Industrial and employment uses; regional, community, and neighborhood retail; and multi -family and single-family residential development at a variety of densities. • The activity centers are mixed -use areas that help promote the utilization of alternative modes of transportation within and between the centers, as well as within the regional corridor. • Land uses west of I-25 remain unchanged from existing plans in the region. (City Plan, Mt. Vista Subarea Plan, Fossll Creek Area Plan) • Areas within the Study Area Boundary, but outside the GMA Boundary would remain under County FA-1, Farming and 0, Open Zoning. , `� O UnSIX rn�cr INSME md[c'r �ar� ngEA Commercial Corridor Neighborhood Commercial District Community Commercial District Employment District Industrial District Medium Density Mixed -Use Neighborhood ((12+ units/acre) Low Density Mixed -Use Neighborhood ((5-8 units/acre) Urban Estate (2 du/acre) Rural Subdivision River and Stream Corridors Proposed Open Space County Agricultural 100 Year Flood Plain Rural/Open Lands (County FA-1, _ Farming and 0, Open Zoning) City -Owned Natural Areas © Transit Center/Park and Ride Conceptual Roadway Network ••••a Activity Center Boundary Study Area Boundary Proposed Urban Growth Area (GMA) Timnath City Limits R. Collins City Limits v fw.s msw or.a�x. uc+mwr a.�a • t • • , •w mm 9 County Rd.32