ITEM 5.1 Riverwood Concept Plan0
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MINNESOTA V
DEPARTMENT INFORMATION
Request for
City Council Action
ORIGINATING DEPARTMENT:
REQUESTOR:
MEETING DATE:
Planning
City Planner Licht
28 November 2016
PRESENTER(s):
REVIEWED BY:
ITEM #:
City Planner Licht
Interim City Administrator Flaherty
5.1— Riverwood Concept Plan
AGENDA ITEM DETAILS
RECOMMENDATION:
City staff recommends support for a senior housing concept plan for rehabilitation/redevelopment of
Riverwood Inn and Conference Center.
ARE YOU SEEKING APPROVAL OF A CONTRACT? I IS A PUBLIC HEARING REQUIRED?
No
BACKGROUND/JUSTIFICATION:
Held by Planning Commission 21 November 2016
Riverwood Holdings LLC has acquired the Riverwood Inn and Conference Center property located north
of CSAH 39 at CSAH 19. The 33.49 acre property has been used as a conference center and restaurant
but those uses have recently ceased. The developer is proposing reuse of the property for senior
housing. The proposed use would involve a phased development for conversion of three existing
buildings and construction of a new assisted living multiple family building, an independent living
multiple family building, and nine detached townhomes. The proposed development is to be reviewed
as a Planned Unit Development (PUD) Concept Plan in accordance with Section 20-36-4.0 of the Zoning
Ordinance to provide comment to the developer as to the acceptability of the land use.
A public hearing to consider the proposed concept plan was held by the Planning Commission at their
meeting on 21 November 2016 at 7:0013M. Representatives of Riverwood Holdings LLC were present.
Mr. Stuart Turnquist, who owns the property to the east of the subject site, spoke in favor of the
proposed land use and said he thought an agreement could be reached between the developer and him
regarding the access. Mr. Turnquist also asked for clarification as to the planned use of the existing
building at the northeast corner of the site; the developer stated this building would be used only for
storage. Mr. Turnquist also requested that the developer provide a fence along the east property line
to screen the service drive from his properties. Mr. Paul Moriarty, the abutting property owner to the
northwest of the subject site, had questions regarding traffic, utilities, and setbacks from the bluff line.
City staff addressed these questions as outlined in the planning report.
The consensus of the Planning Commission was overall support for the proposed land use. The
Planning Commission questioned the extension of utilities only to serve the subject site. City staff
explained that this was the extent of capacity available in trunk sewer extended to service Riverwood
National and Grenins Mississippi Hills 2nd and that gravity sewer would ultimately be extended from the
southeast to serve this area. The Planning Commission also discussed the access and potential
improvements/traffic control at the CSAH 39 and CSAH 19 intersection. City staff said that the access to
CSAH 39 at CSAH 19 is subject to further review by Wright County, as well as the City, and this issue
would be addressed in relation to traffic generated by the proposed use.
The Planning Commission closed the public hearing and voted 6-0 to recommend City Council support
for the proposed concept plan. The Planning Commission added an additional stipulation regarding
provision of screening of the service drive from view along the east property line. This stipulation has
been added to the updated Planning Report attached hereto.
SUPPORTING DOCUMENTS: ❑ ATTACHED ❑ NONE
A. Planning Report dated 22 November 2016
POSSIBLE MOTION
Please word motion as you would like it to appear in the minutes.
Motion to provide the developer favorable comment regarding the proposed concept plan for
Riverwood Inn and Conference Center, subject to the stipulations of outlined in the Planning Report
dated November 22, 2016.
BUDGET INFORMATION
FUNDING: I BUDGETED: ❑ YES
NA ❑ NO
ACTION TAKEN
❑ APPROVED AS REQUESTED ❑ DENIED ❑ TABLED ❑ OTHER (List changes)
COMMENTS:
TPC3601 Thurston Avenue N, Suite 100
Anoka, MN 55303
Phone: 763.231 .6840
Facsimile: 763.427.0520
TPCg Planni ngCo. corn
PLANNING REPORT - updated
TO: Otsego Planning Commission
FROM: D. Daniel Licht, AICP
RE: Otsego — Riverwood Conference Center; Concept Plan
REPORT DATE: 22 November 2016
TPC FILE: 101.02
BACKGROUND
Riverwood Holdings LLC has acquired the Riverwood Inn and Conference Center property
located north of CSAH 39 at CSAH 19. The 33.49 acre property has been used as a conference
center and restaurant but those uses have recently ceased. The developer is proposing reuse
of the property for senior housing. The proposed use would involve a phased development for
conversion of three existing buildings and construction of a new assisted living multiple family
building, an independent living multiple family building, and nine detached townhomes. The
proposed development is to be reviewed as a Planned Unit Development (PUD) Concept Plan in
accordance with Section 20-36-4.0 of the Zoning Ordinance to provide comment to the
developer as to the acceptability of the land use. A public hearing to consider the proposed
concept plan has been noticed for the Planning Commission meeting on 21 November 2016 at
7:OOPM.
Exhibits:
A. Site Location
B. Developer narrative dated 11/08/2016
C. Concept Plan
ANALYSIS
Comprehensive Plan. The 2012 Otsego Comprehensive Plan guides the subject site for
commercial uses in recognition of the past use of the property as a conference center and
restaurant. The land use designation also reflects long-term opportunity for commercial uses at
this location in proximity to the intersection of two regional minor arterial roadways. However,
the area is still rural in character and the north portion of the property preserved in a natural
state in accordance with the Mississippi River Wild Scenic and Recreational River Management
Plan. The conference center and restaurant use has struggled to maintain financial viability in
recent years and the condition of the multiple principal buildings have deteriorated to the point
that substantial rehabilitation is required.
The developer is proposing a phased development of up to 149 memory care, assisted, and
independent senior housing dwelling units as a reuse of the three existing principal buildings,
construction of two multiple family buildings, and nine detached townhomes. Demand for
senior housing is strong within the Twin Cities Metropolitan Area and Otsego has identified
development of senior housing as an economic development and housing priority. The
property is a unique, scenic setting for a senior housing use within the City. Redevelopment of
the property as a senior housing use also presents an opportunity to address the viability of the
current development and resolve issues related to utilities and access effecting the property.
City staff supports development of the proposed senior housing use of the subject site as being
consistent with the goals and policies of the Comprehensive Plan.
Zoning. The subject site is zoned PUD, Planned Unit Development District as outlined in the
development agreement dated 7 January 1992. Paragraph 7 of the development agreement
included 31 stipulations regulating the use of the property as a conference center and
restaurant essentially defined by the character of the use existing at that time and planned
expansion. Paragraph 6 allows for future development or change in use subject to processing
of a development application subject to City Council approval. Pending this concept plan
review, the developer would be required to apply for a PUD Development Stage Plan as
outlined by Section 20-36-4.D of the Zoning Ordinance to obtain entitlements for the change in
land use, rehabilitation of the existing structures, and development of new structures upon the
subject site.
Surrounding Uses. The subject site is surrounded by the following existing and planned land
uses. The proposed senior housing land use would be a compatible land use within this unique
rural area of the City.
Direction
Land Use Plan
Zoning Map
Existing Use
North
--
--
Mississippi River
East
Commercial
A-1 District
Rural residential
South
Commercial
A-1District
Agriculture/Rural residential
West
Rural Residential
A-1 District
Rural residential
2
Building Materials. The three existing principal buildings on the property have wood siding as
the primary exterior material. The concept plan does not include plans for the exterior design
of the proposed multiple family buildings or the detached townhomes. The existing buildings
can be rehabilitated and converted to senior housing uses without being required to comply
with the exterior building material requirements of the Zoning Ordinance for multiple family
buildings. Any new principal structures will be required to comply with Section 20-17-4.G. of
the Zoning Ordinance establishes exterior material requirements for townhome and multiple
family uses. Building plans for each elevation of the proposed principal building that identify
the type and percentage of materials must be submitted with the PUD Development Stage Plan
application.
Floor Area Per Unit. Section 20-17-6.0 of the Zoning Ordinance establishes minimum floor area
per unit requirements for senior housing of 440 square feet for efficiency units and 560 square
feet for one bedroom (or larger) units. The minimum floor area requirement is typically only
applied to independent or assisted living dwelling units. No information has been provided
regarding the floor areas of the individual dwelling units within the existing buildings or two
multiple family building and these must comply with the minimum requirements of the Zoning
Ordinance. The detached town homes will also be required to comply with the minimum floor
area requirements for such dwellings established by Section 20-17-6.D of the Zoning Ordinance
requiring 600 square feet plus 100 square feet per bedroom.
Lot Requirements. Multiple family senior housing must provide a minimum lot area of 40,000
square feet and minimum of 1,000 square feet per unit and townhouses are required to
provide a minimum 5,000 square feet per dwelling unit. The 1,000 square foot per dwelling
unit requirement is typically only applied to independent or assisted living dwelling units, with
memory care not subject to a lot area standard. The area of the subject site exceeds the
minimum lot area requirement and there is 8,841 square feet of lot area per independent or
assisted living dwelling unit available.
Setbacks. Setback information is not indicated on the concept plan. City staff recommends a
minimum 65 foot setback from CSAH 39 and 30 foot setbacks from the east and west side lot
lines to maintain compatibility with adjacent uses. The north portion of the site is subject to
the requirements of the WS Overlay District along the Mississippi River. None of the proposed
structures may encroach into the WS District and new structures must maintain a 30 foot
setback from the defined bluff line. Three of the proposed detached townhouse buildings
shown on the concept plan appear to be located within the WS District and encroach over the
bluff line and must be revised. The setbacks for existing and proposed principal buildings and
all improvements must be shown drawn to scale on a PUD Development Stage Plan application.
Building Height. The PUD District does not establish a specific limit on building height for
structures on the subject site. The existing principal buildings are one and two story structures.
The height of the proposed assisted living multiple family building is to be three stories. The
height of the proposed independent living multiple family building is not specified. The
proposed three story height of the building allows for the number of proposed dwelling units
3
within a smaller footprint minimizing impervious surface and avoiding wetland impacts. City
staff considers the proposed building height to be appropriate for the subject site given the
area of the property and natural conditions.
Access. The subject site currently has one access to CSAH 39. This access is poorly located as
it is off -set west of the intersection of CSAH 39 and CSAH 19; the access is actually within the
bypass lane for westbound traffic on CSAH 39 creating a dangerous condition. City staff
recommends that a condition of approval for the change in use and development of additional
principal structures be that the site access be realigned to the north leg of the CSAH 39 and
CSAH 19 intersection to create a four-way condition. This will require the developer to acquire
property or easement from the abutting property to the east to allow for the construction of
the access as shown on the concept plan. Access spacing onto CSAH 39 is at intervals of one-
half mile for full intersections and one -quarter mile for intersections that will be limited to
right-in/right-out in the future. Based on the existing spacing along between CSAH 19 and
Kalenda Avenue, no additional accesses to the subject site are shown so as to comply with
these spacing requirements. The proposed access is also subject to review and approval of
Wright County.
Utilities. The subject site is currently served by on -site septic systems and private wells. The
septic systems were cited for causing an imminent public health threat and converted to
abandon the drainfields and utilize the septic tanks as holding tanks that are then pumped out.
The developer's narrative outlines three options regarding utilities to serve the proposed use.
City staff recommends that any redevelopment of the property be required to connect to City
sanitary sewer and water service to ensure public health and provide adequate fire protection
necessary for a senior housing use.
Sanitary sewer capacity is available by extending a forcemain from the subject site to the
existing lift station located just north of the Vintage Golf clubhouse building. This lift station
has capacity for an additional 24,500 gallons per day of flow or 140 Residential Equivalent
Connections (RECs). The number of Residential Equivalent Connection charges for senior
housing facilities are calculated in accordance with the Metropolitan Council Environmental
Services schedule as one REC per three residents estimated based on number of bedrooms for
each dwelling unit. The developer will need to adjust their phasing plan to conform the number
of proposed dwelling units within the first phase to equal that of the available sewer capacity.
There is an existing fire hydrant at the Riverwood National Golf Course that the developer could
connect to so as to access City water service. However, Riverwood National is currently on an
isolated water system without capacity to serve the proposed use. The City Council has
authorized the City Engineer to proceed with preparing plans and specifications for
construction of trunk water main along Kadler Avenue connecting the City's west water utility
system and Riverwood National. If construction of the Kadler Avenue trunk water main is
approved by the City Council, there will be adequate capacity to extend service to the subject
site.
S
The subject site is outside of the City's current West Sewer District and extension of utilities to
serve the proposed use of the subject site would typically not be consistent with the policies of
the Comprehensive Plan for growth management. However, the proposed use is a
rehabilitation/redevelopment of an existing commercial use with known environmental issues.
Based on these specific circumstances, the Planning Commission and City Council may allow for
the extension of utilities without creating a precedent for other development not within or
contiguous to the established sewer district boundaries. The developer would be responsible
for all costs in extending sanitary sewer forcemain and water main from Vintage Golf and
Riverwood National, respectively, to serve the subject site. These utilities would need to be
located within the CSAH 39 right-of-way and are therefore subject to Wright County approval as
well. The developer is also subject to payment of utility availability and connection charges for
City sanitary sewer and water based on the number of RECs for the proposed use.
Grading. The developer has not provided a grading plan with the concept plan application.
Portions of the subject site include large wetlands. The proposed improvements shown on the
concept plan generally avoid wetland impacts as required by the Wetland Conservation Act of
1991, except for a small area east of the parking area. There is wetland fill shown to
accommodate a service drive aisle parallel to the east property line. The concept plan
proposes replacement at a 1:1 ratio but replacement of purchase of wetland credits is required
at a 2:1 ratio for any impacts. The PUD Development Stage Plan must include a detailed
grading, drainage, and erosion control plan as required by the Zoning Ordinance. All grading
and wetland issues are subject to review and approval of the City Engineer.
Off -Street Parking. Section 20-21-9.E of the Zoning Ordinance requires senior housing uses to
provide one off-street parking stall per two dwelling units with proof -of -parking for one parking
stall per dwelling unit. This requirement is typically applied only to the independent and
assisted living dwelling units as memory care residents do not drive. The Institute of
Transportation Engineer's 3`d Edition Parking Generation Manual outlines the following off-
street parking recommendations for senior housing uses:
Type
ZO/ITE
Land Use
Category
Recommended
Parking Ratio
Stalls/Unit
Riverwood
DU
Parking
Stalls
Zoning Ordinance
Senior
Housing
1.00
140
140
TH
2.00
1 9
18
TOTAL
158
ITE Recommendations
Independent
252
0.50
20
10
Assisted Living
254
0.36
60
22
Memory Care
254
0.36
60
22
Townhouse
2.0
9
18
TOTAL
72
E
The concept plan illustrates 43 surface parking stalls, 20 underground parking stalls for the
independent living multiple family building and 18 garage stalls for the detached townhouse.
The detached townhouse dwellings are indicated to have an attached two -car garage. The
number of off-street parking stalls provided by the concept plan exceeds the parking required.
The design and construction of the off-street parking area must comply with the requirements
of Section 20-21-4.1-1 of the Zoning Ordinance and the area of the garage for the detached
townhouses must be at least 20 feet wide and 400 square feet in area.
Park and Trail Dedication. Park and trail dedication requirements for the existing conference
center were satisfied with the development agreement. No additional park and trail
dedication requirements would apply to rehabilitation of the existing principal structures. The
development of additional dwelling units within the two proposed multiple family buildings and
the detached townhouse units are an increase in intensity of the use of the property and
subject to park and trail dedication requirements in accordance with Section 21-7-18.13 of the
Subdivision Ordinance. The 2012 Future Parks and Trails plan does not identify the need to
acquire additional land for City park facilities in the area of the subject site. As such, park and
trail dedication requirements be satisfied as a cash fee in lieu of land at the time the PUD
Development Stage Plan is approved.
Exterior lighting. The submitted concept plan does not include details regarding exterior
lighting. A PUD Development Stage Plan application must include a photometric lighting plan
indicating the location of all exterior light fixtures and illustrating the intensity of the lighting
upon the site. All exterior lighting must comply with Section 20-16-6 of the Zoning Ordinance.
Signs. The concept plan identifies only the existing freestanding on the property. Any signs
that are to be located upon the subject site must be identified as part of the PUD Development
Stage Plan and be consistent with the allowances for the Otsego Waterfront East PUD District.
RECOMMENDATION
The subject site is a unique, scenic location for a senior housing use within the City that meets
economic development and housing goals for the community. Redevelopment of the property
as proposed also presents an opportunity to resolve issues related to environmental hazards
and poor access effecting the property. City staff supports development of the proposed
senior housing use of the subject site as being consistent with the goals and policies of the
Comprehensive Plan.
POSSIBLE ACTIONS
A. Motion to recommend City Council support of the proposed concept plan subject to the
following conditions:
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1. The developer shall apply for a PUD Development Stage Plan as outlined by
Section 20-36-4.D of the Zoning Ordinance to obtain entitlements for the change
in land use, rehabilitation of the existing structures, and development of new
structures upon the subject site, subject to City Council approval.
2. The exterior materials for any new principal structure shall comply with Section
20-17-4.G. of the Zoning Ordinance
3. The proposed dwelling units (other than memory care) shall comply with the
minimum floor area requirements established by Section 20-17-6.0 of the Zoning
Ordinance.
4. The PUD Development Stage Plan shall comply with the following setback
requirements:
a. Buildings/Structures:
(1) CSAH 39: 65ft.
(2) Other lot lines: 30ft.
(3) Bluff line: 30ft.
b. Parking/drive aisles: 15ft. from all lot lines.
5. No dwelling unit or portion thereof shall be located within the WS District
overlaying the subject site.
6. The maximum building height shall be three (3) stories.
7. The site access shall be relocated to align with the CSAH 39 and CSAH 19
intersection, subject to review and approval of the City Engineer and Wright
County.
8. The proposed development shall require connection to City stanitary sewer and
water utilities:
a. The phasing plan shall be revised to comply with available sanitary sewer
capacity of 24,500 gpd., subject to review and approval of the City
Engineer.
b. Capacity for water utilities to serve the proposed use shall be contingent
upon City Council awarding of a contract for construction of the Kadler
Avenue trunk water main.
7
C. The developer shall pay all utility availability and connection charges in
accordance with the City Code upon approval of a PUD Development
Stage Plan.
All costs for extension of sewer forcemain and trunk water to the subject
site shall be borne by the developer.
e. Use of right-of-way or drainage and utility easement for extension of
utilities shall be subject to review and approval of the City Engineer and
Wright County, as applicable.
9. The PUD Development Stage Plan shall include a detailed grading, drainage, and
erosion control plan as required by the Zoning Ordinance, which is subject to
review and approval of the City Engineer.
10. The design and construction of the off-street parking area must comply with the
requirements of Section 20-21-4.1-1 of the Zoning Ordinance and the area of the
garage for the detached townhouses must be at least 20 feet wide and 400
square feet in area.
11. Development of the assistant living multiple family building, independent living
multiple family building, and detached townhomes are subject to satisfaction of
park and trail dedication requirements as a cash fee in lieu of land at the time of
PUD Development Stage approval for each use.
12. The PUD Development Stage Plan application shall include a photometric lighting
plan indicating the location of all exterior light fixtures and illustrating the
intensity of the lighting upon the site in compliance with Section 20-16-6 of the
Zoning Ordinance.
13. All signs shall comply with Section 37 of the Zoning Ordinance.
14. The developer shall provide screening along the east property line to buffer the
service drive from view of the property to the east.
B. Motion to not support the request based on a finding that the application is not
consistent with the intent of the Comprehensive Plan.
C. Motion to table.
C. Adam Flaherty, Interim City Administrator
Tami Loff, City Clerk
Andy MacArthur, City Attorney
Ron Wagner, City Engineer
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CONTINUUM Livill�
Architecture
Riverwood Senior Living
Master Plan Narrative
11/08/2016
The former Riverwood Inn and Conference Center currently sits vacant on 33.5 acres of land located
at 10990 95th Street NE in Otsego, MN. A master plan for new senior living campus is proposed for
the site and would include reuse of existing buildings and construction of new buildings occurring in
phases.
Phase I would include conversion of three existing buildings and construction of a new assisted
living building. Phase II would include construction of a new independent living building that
would connect with the other buildings and detached villa homes.
CAMPUS BUILDINGS
Memory Care
• The existing "Courtyard Square" guest suite building and "Bluffhouse" guest suite
building will each be converted into 30 units of memory care resulting in 60 total.
• Remodeling of the existing rooms and baths will occur as required to ensure
compliance with accessibility codes, health department codes and building codes.
• Existing conference rooms, lounges and other large common areas will be
repurposed for areas commonly found in memory care facilities such as activity
rooms, lounges, dining rooms and nurse areas.
• The existing buildings will be linked together to create a cohesive building that
allows controlled circulation for residents and staff.
• The existing buildings will be linked to the existing production kitchen for
food can be delivery to a serving kitchen within the memory care building.
• Memory care residents will receive 24-hour supervised support services.
Assisted Living
• A new building comprised of 60 units of assisted living apartments
• The building will be connected to the existing pub, dining area and
kitchen to offer residents access to these amenities without
having to go outside of the building.
• The building will be connected to common areas that include
activity rooms, lounges and coffee shops, therapy and
fitness rooms and a chapel.
• The existing pool within the "Courtyard Square" an [I LJA. company
building will be available to assisted living 381 East Kellogg Boulevard
residents. saint Paul, MN 55101
651-227-0644
651-223-5092 Fax
Archilectine • Engineering • Consulting www.waicontinuum.com
Riverwood Senior Living Master Plan Narrative
11 /08/2016
p. 2
• Assisted living residents will be offered limited support services.
Independent Living (Future)
• A new building comprised of 20 units of independent living apartments with
underground parking
• The building will be connected to the assisted living building and commons areas in order
to offer the residents opportunities to use common areas such as the pub and pool
without having to travel outside the building.
• Detached Villa townhomes with garages will offer another choice for independent living
residents
SITE ACCESS and CIRCULATION
Driveway
• A new driveway is proposed on County Road 39 and would align with County Road 19 to
the south. Aligning the driveway will provide a safe and controlled means for vehicles
entering and exiting the site.
• Part of the property to the east would need to be purchased in order to construct the new
driveway and align it with County Road 19. Initial conversation with the neighbor
indicates that a purchase agreement can be made.
Circulation
• Circulation for vehicles within the site is proposed by constructing new asphalt roads and
will be designed to accommodate emergency vehicles.
• Walking paths for residents will be incorporated into the site
EXISTING WETLANDS
Disruption and displacement of existing wetlands on the site will be avoided as much as possible.
The master plan shows a proposed drive along the east passing through a small portion of an
existing wetland. The disturbed wetland will be replaced on the site at a 2:1 ratio.
SANITARY SEWER SERVICE and WATER SERVICE
There are three proposed options for sanitary sewer service and water service for the project.
Option 1 - Reuse of Existing Septic System and Wells
• The site's existing sanitary system consists of septic holding tanks that serve the
Bluffhouse on the northeast side of that building. The tanks are periodically pumped and
hauled. Septic tanks and a drainfield serve the Courtyard Square building and Restaurant
building and are located to the west. These septic systems would continue to serve these
buildings and be upsized as required to serve the proposed buildings. If required, all parts
of the existing septic systems would be modified/upgraded to be compliant with current
codes.
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Riverwood Senior Living Master Plan Narrative
11/08/2016
p. 3
The existing three buildings are currently served for potable water and a fire suppression
system by three existing wells
Building Name Well Capacity Pressure
"Bluffhouse" Building 8" @ 40 gpm 60 psi
"Courtyard" Building 4" @ 25 gpm 60 psi
Restaurant Building 4" @ 25 gpm 60 psi
It is anticipated that the existing wells will be able to accommodate both potable water
and a fire suppression system for new and existing buildings.
Option 2 - Connection to City Sanitary Sewer and Reuse of Existing Wells
• It is understood that the City lift station to the west is designed to accommodate 150 units
with 10 units currently using its capacity. A capacity for 140 units is available.
• The existing septic system currently serving the site will be abandoned in favor of
connecting to the existing City sanitary sewer system by the construction of lift stations
on the site and the construction of a forcemain route along County Road 39 westward
towards the City lift station. The forcemain would then travel north directly to the lift
station and connect.
• If required, a Supervisory Control and Data Acquisition system would be installed as part
of the new sewer connection for the proposed project.
• Abandonment of existing septic tanks and drain fields will comply with MN rule
7080.2500. Permitting and regulatory approval will be required by Wright County, City of
Otsego and Minnesota Pollution control Agency prior to construction of proposed sewer
improvements.
• A diagram showing the proposed force -main route s is attached.
• Reuse of the existing wells would occur as described in Option 1
Option 3 - Connection to City Sanitary Sewer and Connection to Citv Water Service
• Connection to the City sanitary sewer would occur as described in Option 2
• Connection to City water service would occur with the construction of anew 8" line from a
point approximately 1 /2 mile to the west along County road 39.
• A diagram showing the proposed water service route is attached.
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