HomeMy WebLinkAboutLetter to ask for construction discontinuation 1999 GG-
Mrs. H. A. Luther
614 Welsh Ave.
College Station, TX 77840
Bobby Mirza.
612 Welsh Ave.
College Station, TX 77840
Helen Pugh
601 Fairview
College Station, TX 77840
October 4, 1999
City of College Station In re: Construction project either side
Tom Brymer, Acting City Manager of 600 Welsh Ave. and;
The Zoning Board of Adjustment 614 Welsh Ave.; 612 Welsh Ave.;
The Historic Preservation Committee 601 Fairview;
Box 9960
College Station, TX 77840
Mr. Nelson Nagle
510 Dennis Drive
Round Rock, TX 78664
Stylecraft Builders, Inc.
Randy French, President
4112 State Highway 6 South
College Station, TX 77840
Gentlemen:
This is a. formal request for full near -term abandonment of the current
construction of two additional single family dwellings on either side of 600
Welsh Ave. We believe the city erred in issuance of construction permits
for this work in many ways. This letter specifically addresses just one of
them which is very important to us. It also addresses a staff management
viewpoint which we think some staff personnel are using which is very bad
for all of the city; it produces these problems and citizen -staff flare ups.
We tried to fix this problem verbally, as cheaply and as fast as we became
aware of it. However, there was no notice to us at all, so we could begin
working with this issue in the some six months it took the developer, the
contractor and city staff to orchestrate this project! Our to-be -filed
written request was deemed to be meaningless. Thus, it is now necessary to
present our problem for board level decision. In considering this, it
should be apparent that Council and board level action must *AGAIN* be
taken, to prevent future similar flare ups. Some of city staff are still
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not listening to either the majority of the citizens, nor to Council, as we
think this complaint illustrates. The guidelines are clear, as we see it.
As the last verbal interface at this, Jeff Tondre saw a less strongly worded
draft of this request. He was asked for guidance for the final document, so
as to minimize the time and expense needed to bring the hest case forward to
the city, both as to the complaint and any proposed solution. He verbally
acknowledged that there is a problem with this construction and our plight.
He noted he could not advise us on how hest to write the formal letter,
which he said should he written, until he checked with the city legal
department. His answer, on checking with the city legal staff, was the city
has no legal obligation to consider our position, at all, - relative to this
construction for protection of our property! We disagree with that.
Additionally, it has come to our attention that there is a feeling that
absent of a 'specific ordinance' which addresses the general policy toward
additional development and construction in historic neighborhoods, such as
this, city staff has no obligation to consider anything on how construction
will impact a. neighborhood such as this! They are free to do as they please
in exercising their own view of these things. They may act as they want and
need not consider the thousands of hours of citizen -city previous work.
They are not bound by any directive of Council here.
We believe this perception in error.
We believe staff has failed to take into account existing city ordinances,
together with specific policy applicability to our property. You may affirm
this with inspection on the ground and reasonable engineering study, current
law noted and a simple review of the July 23, 1998, City Council meeting
minutes. It's all there for anyone whom wants to do a little study.
We think you may determine, if you review the City Council's minutes, in
action on general policy as applicable to Neighborhood Preservation, that
the all but item six of the Neighborhood Preservation Council, was ACCEPTED,
in its entirety, as general policy and guidelines for the future development
in the area of study for the Southside area and other older neighborhoods
like this. There now ARE general staff guidelines which have been formally
ACCEPTED as a. matter of policy to protect property owners like us. They are
a. directive which has been ACCEPTED for city staff. Thus staff has failed
to act on the generally adopted directive on policy towards us, even under a
most widely interpreted perspective of a modified Carver's Governance model
for staff performance, as we see it. Something is badly wrong here.
First, we address the technical problem and current ordinance protection
that is afforded to us which has been violated. There is no ability, at
all, for the immediate downstream property to handle any additional water
runoff, let alone construction waste water. There is no way to provide for
it, given the current civil engineering foundation for this neighborhood,
nor any near -term future engineering solution for it.
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This neighborhood was designed, for drainage purposes among others, with
alleyways at the rear of many of the houses. As designed, a formal alleyway
here and both Welsh and Fairview street were lower than the property level
of all of the houses in this block. The street AND the alley were both the
required drain ways for water runoff, in protection to the property. The
formal alley, in theory, designated for this property, behind it, is common
to all houses in the block which hack it on both Fairview and Welsh Ave. By
ordinance, at the time this property was frozen into the current engineering
template, this alley must continue to provide several utility service
requirements. Per our recall, these include that it must remain no less
than 20 feet in width, and is to be paved. The original improved paving for
this alley was in a. non-hard surfaced, improved gravel -like material,
similar to the original street paving on Welsh. It originally had not only
the required paving needed, but was the garbage pickup route for the houses.
The original wood garbage can rack is still there at 614 Welsh Ave!
This alleyway also contains sewer service for the houses in question in this
block, most of which are still connected to it. The original sanitary
service in the neighborhood was in septic tanks. The sewer supplementing
them was constructed in this alley years ago as many of the houses were
built. This alley also contains water and gas service for many of the
houses. It, further, contains the full 6900 volt primary electrical
distribution service for all of the houses in the block. That service,
alone, has to be protected for access for full truck and lift operations on
the ground by the city, even if there were no issue on the drainage for us.
This alley, by ordinance, must not be fenced or obstructed by any property
owner, and as a drainage way, no property owner is permitted to interfere
with the drainage it must continue to afford. Further, in that it is longer
than 100 feet in length, it must, by ordinance, remain open at both ends of
the alley! That means, full city access, irrespective of what may or may
not have appropriately been done with the other end of the block, the
extension of Fidelity street, legally has to be maintained at the subject
property end on the 600 Welsh project. None of this was addressed in the
action taken together by the developer, the contractor, nor the city. As an
inspection on the ground, together with applicable ordinance requirements
will easily determine, none of this can be satisfied under the present
construction plans. There is no easy adequate engineering solution for new
construction here, as is common to many of these older neighborhoods.
Specifically, the current property flooding conditions immediately down
stream from these locations are already well known to City engineering. The
issue is so severe for the corner area around the intersections of Welsh and
Park Place, that there is no ability for that segment of the City to handle
*ANY* additional water flow from major construction upstream, of *ANY* kind,
which will add to the run -off.
The property on which construction is to he done is already, now, slightly
below street grade level for Welsh. Not a full block down stream toward
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Park Place, the land property level decreases to what is already now nearly
nine inches below current street grade level. The civil engineering
foundation upon which this neighborhood was based, coupled with the fifty
succeeding years in which what little drainage protection there once was,
has long since been neglected and /or abandoned by the City - to the expense
of the individual property owners down stream of this development. As a.
matter of fact, the entire recent street overlay work that proceeded, under
protest, on Welsh, has only added to the problem.
The proper street level is clearly evident from the original drive way
levels still in existence. The abandonment is photographically provable.
The intended original below -grade full curb, gutter and sewer plans had to
be abandoned more than forty years ago; the 'storm sewer' preparation, even
then, overflowed into the property! It took removal of the original 'pre -
storm drain facilities, coupled with private property owner paving and
driveway maintenance, to even keep adequate access to their property on
Welsh. This situation has remained for at least forty years now. It grows
steadily worse with each additional square foot of ground either paved, or
built -over, upstream. Any further major construction upstream of this area,
like this, will even more seriously endanger the property of those below it.
There is no realistic frontal civil engineering solution for Welsh, which
will now provide drainage for this development. Significantly, the major
trees below it, cannot be preserved, if any major Welsh Street work is done
to alleviate the problem. The entire rear drainage for this property in the
alley way behind the property, which was the actual allowable exit for all
this runoff water below the development property, must be re- addressed by
the City as well. It is now over -level in respect to the downstream
properties as well. The City having realistically lost any ability to cure
this over forty years running, cannot technically, therefore, permit further
construction like this, without liability for the consequences, unless a
demonstrable and satisfactory engineering solution for the problem is on
hand, contemporaneous with the new construction, as we see it.
Until all of you can settle this issue alone, such that no additional runoff
of any kind from this major construction will reach those of us below the
property, to add to our current woes, please withdraw forward work on this
project. It's either that or consider the possibility that the only action
we might take to gain relief, would he in the form of injunctive relief,
pending litigation over the issue. That's expensive for all concerned,
perhaps significantly so for you, should you lose the case.
In summation, this neighborhood is a classic, historic, fragile area of the
City. The guidelines for City future property development in this
particular historic neighborhood are well established. They have been
developed formally over many hundreds hours of public work toward guidelines
for further development of neighborhoods, while preserving these fragile
areas of the City. The basic policy of caution and concern for this,
already has College Station City Council past approval. The focus of this
near complete inability to solve this problem, in and around this particular
downstream intersection and area has, on dozens of occasions, been the
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subject of City - citizen conference, with no real solution, as well. The
houses of concern are headed toward historic registry.
All of this would have been easily discovered had city staff simply followed
the already issued guidelines set forth in the Neighborhood Preservation
Committees' report to Council and the formal adoption of that report as
guidelines for future property development in this Historic Neighborhood.
There is a sign demarking this property as being in this neighborhood
directly in front of the development.
We believe, for these permits for such new major construction, to have even
been issued, for such construction, without addressing this problem, as well
as other neighborhood issues, in advance, including an impact notice to the
public, would be far beyond what any reasonable and prudent person would
have done. Further, we don't believe that any knowledgeable and capable
City staff person, given their presence at Council meetings, could have
issued or permitted the issuance of any building permit for this work,
absent of protection arrangements for the downstream citizens. We believe
any reasonably aware such person had to have known, or should have known,
that the protection of downstream residents was necessary. Gee, even the
current rules force the erection of temporary plastic barriers to protect
the neighbors on a temporary basis! There is *NO* form of temporary
protection for construction runoff that can be made in *ANY* form for the
downstream residents of this project!
Sincerely yours,
Mrs. H. A. Luther ichael Luther, P%
6141-lshAv-.. ,/
Bobby 'rza.
612 Wel, Ave.
Helen Pugh
601 y Fairview
Attachments:
Minutes transcription July 23, 1998, Council Meeting.
Neighborhood Preservation Committee report submission to Council.
Alley Ordinance continuing duties December 1997.
Copies of water load photographs on downstream properties.
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Attachment to letter of October 4, 1999 to various parites. Partial
transcription of City of College Council meeting minutes for July 23, 1998:
Hickson:
"I would like to move that we accept 1, 2, 3 and 5 of staff
recommendations.." He is interrupted, "Could you go the two hour deal
instead of one hour ?" He continued, "Yeah, eh, .. two hour parking.
Mmm, .. my prob .., I don't necessarily agree right now that we need an on-
street parking system. I'd like to see how these things work, before we
really consider moving in that direction, to see what the impact... To me
these are some things that will definitely help in that area. I agree with
Jerry at this time that going to an on- street parking, parking permit
with .. is maybe a little bit premature."
Marr iot :
"I second that."
Mcilhaney:
"OK, we have a motion to approve staff recommendation 1, 2 and 3 which is
removing the on- street parking on George Bush; establishing a two -hour
parking, uh, .. eight through five on, uh, .. Fairview and George Bush to
Kerry; install no parking from here to corner signs on Fairview and then to
accept the staff's proposed actions for recommendations for on, uh, .. the
Committees report, items one through five and seven through thirteen.
Motion by Councilman Hickson; second by Councilman Marriott. Further
discussion by the Council ?" She paused, then continued, "Seeing none, I'll
call for the vote. Those in favor say 'Aye'." Voices heard. "Those
opposed, say 'No'." There is no sound. Whereupon she continues, "Motion
carries unanimously."
Look *CAREFULLY* at item number four of the Committee's recommendations.
Note that this project is *NOT* a reconstruction of an old house for student
use. It is *NEW* construction. Accepted Committee Item number four says:
4.) Land Use Restrictions
RESOLVED, that no upcoding of structure category shall be
permitted in this area. Property shall not be re- platted in
this area to achieve a. higher structural density than
is currently of record.
So noted, staff has violated both the wishes of the people of College
Station whom employ them, and the directive of the City Council, when
approval of this project was given. Moreover, if you listen carefully to
the Council meeting tapes, staff was expected to get back to the City
Council to implement these acceptances; to our knowledge, they have never
done so. In order to prevent future flareups like this, we think failure to
accept the will of the people relative to issues like this must cease.
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7/14/98
Southside / Southgate Neighborhood Preservation Report , '
Recommendations #1 - 5 NIP
1. Student Housing (Nevada & Welsh).
RESOLVED, that no further changes in any property use from single-family residence
or up- coding of any property in the Neighborhood Preservation Area of College
Station should be permitted and are the position taken in the report.
2. Develop Themes.
RESOLVED, that the theme of the Neighborhood Preservation Area addressed by the
Committee shall not change from the present mixture of single-family residential
dwellings and zoning in any way.
3. Opportunities For Small Business Development.
RESOLVED, that the present language used by the City of College Station to describe
opportunities for small business development at home is satisfactory.
4. Land Use Restrictions.
RESOLVED, that no upcoding of structure category shall be permitted in this area.
Property shall not be re platted in this area to achieve a higher structural density than
is currently of record.
5. Zoning Changes.
RESOLVED, that it would be contrary to the Public Interest, cause unnecessary
hardship and substantial injustice would be done, if the zoning were changed and up-
zoning of property in this area should occur.
In regard to Recommendations 1, 2, 4, & 5:
This issue has been largely addressed by past City Council and staff action. The
City has included comments in the current Comprehensive Plan to not increase
density in the Southside /Southgate area. State law prohibits a City Council from
restricting future City Councils from considering zoning requests. Also, the City
cannot prohibit developers from submitting zoning requests. The Council has
previously voted to not require amendments to the Comprehensive Plan prior to
consideration of re - zoning requests that are not in accordance with the Plan. If
Council wishes, it could reconsider this option. As with any such consideration,
there are pros and cons. When Council Last considered this issue, the fact that
such a step would increase development review time seemed to be a major factor
in Council's decision not to make this a requirement.
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7/14/98
In regard to Recommendation 3:
L ,, In accordance with the recommendation by the Southside/Southgate
Neighborhood Preservation Committee, there are no plans to change the
ordinances describing small business development (i.e., home occupations).
Southside / Southgate Neighborhood Preservation Report
Recommendation #6
6. Housing Renovation.
RESOLVED, that the Committee recommend that a regulatory authority be established
in the City of College Station to regulate non owner - occupied rental property in the
Neighborhood Preservation Study area. Occupancy rate for unrelated adults in any
such single-family residence shall not exceed the number of bedrooms and shall not
exceed four such occupants in any such dwelling. The number of improved parking
spaces which must be provided on the properly shall equal the number of unrelated
adults permitted for any given single-family residence used as rental ro er The
adoption of such an ordinance shall be requested in a timely fashion, so as to bring the
Neighborhood Preservation Area under its protection as soon as it is practically
possible to do so, preferably in time for the fall semester.
In regard to Recommendation 6:
At the City Council workshop in January, the Council directed staff to review the
Southside /Southgate Preservation Committee's recommendations. Council
discussed the various aspects of Recommendation #6, and asked staff to look at
options other than the regulation, or permitting, of non -owner occupied rental
property.
In light of the direction given by Council, City staff has studied the symptoms
created by non -owner occupied rental property. One of the p rima
caused by both the rental housing as well as the proximity of the Texas rA &M problems
University campus, is an overflow of on- street parking in the Southside /Southgate
neighborhoods. City staff has reviewed the on- street parking situation and
developed the following options to deal with the problem in this neighborhood:
1. Remove all on- street parking in the entire study area.
2. Remove on- street parking in the entire study area from one side of every
street, leaving on- street parking on the other side of every street.
3. Permanently remove on- street parking on every street in the study area that is
currently restricted by Special Event Parking.
4. No on- street parking during certain hours of the day, such as from 8:00 a.m.
to 5:00 p.m.
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7/14/98
40 .
5. Identify blocks with majority of rental units and restrict parking only on
those blocks. A potential impact of this is the possibility that is parking may
spill over into the blocks marked owner- occupied.
6. Use of a permit, or hangtag, method to allow on- street parking by the
residents of the study area. This option also addresses the situation in
Committee Recommendation #8b.
Staff has also evaluated the concerns associated with the off - street parking
situation. Current ordinance states that a single family residence dwelling unit
will have a minimum of two off - street parking spaces. Staff has investigated the
possibility of enforcing the required two off - street parking spaces for non-
conforming residences built before the standard was put into effect. Staff has
determined that legal restrictions facing the City prohibit this action. However,
the options presented regarding restricting on- street parking could have the
effect of encouraging the construction of off - street parking. With limited or no
on- street parking available, property owners and residents may have an incentive
to create off - street parking spaces if they do not already exist.
After the options regarding the on- street parking situation were developed as an
indirect method to deal with Recommendation #6, staff met with the
Southside /Southgate Neighborhood Preservation Committee on May 7. The
Committee asked to have the options presented to a forum of
Southside /Southgate residents and property owners, and have this group reach a
consensus on which option to support.
Over 2,000 invitations were sent out to those who reside in the
Southside /Southgate area and those who own property in this area but live
elsewhere. On June 4, a neighborhood forum was held in the College Station
Conference Center for the residents and property owners in the
Southside /Southgate neighborhoods. The options to deal with on- street parking
were presented to approximately 70 citizens in attendance, followed by a
discussion period and a survey on the options. The survey was taken by ballot,
and resulted in the permit system receiving the largest amount of votes. Of the 28
votes cast for this option, twelve votes asked to combine the permit system with
other options. The survey results are attached for your consideration.
Using these survey results and staff's analysis of the problem, staff recommends
the following actions to deal with the on- street parking situation created by the
proximity of Texas A &M University to this neighborhood:
1. Remove on- street parking presently along the north side of George Bush
Drive from Timber to Texas Avenue. If this is done before the fall semester,
staff can track where Texas A &M University commuters migrate to in search
of free parking.
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7/14/98
l / 41 D
2. Establish `'On -Hour Parking" from 8:OOAM to 5:OOPM Monday through
Friday in t e areas on Fairview Avenue and Montclair Street, from George
Bush Drive to Kerry Street.
3. Install "No Parking From Here To Corner" signs on Fairview Avenue to help
reduce the sight distance problems created by parked vehicles.
These recommendations would be a first step, and staff can watch the area to see
• if the problem moves further south. If the commuter parking moves further south,
the City can increase the area for restricted one hour on- street parking. One of the
attached maps shows the area and volume of the Southside /Southgate
Neighborhoods in which commuter parking is occurring.
Staff's recommendation to deal with the problems caused by residential on- street
parking is to create an on- street permit parking system. The concept is based on
similar programs in cities such as Lubbock, Dallas, Austin, and San Marcos. The
permit system restricts on- street parking to residents and their guests.
Under such a system, residents would be able to limit non - residents from parking
in front of their homes without losing valuable parking area. Using other cities'
models as examples, the permit system would be based on street -by- street basis.
Residents would apply for a permit through a petition and pay for the application
fee, signs, and permits. Staff recommends an application /petition system of some
type which would require the signature of a certain percentage of owners and /or
residents adjacent to street in question. This places the responsibility for
initiating such a system to the residents of a particular street while allowing the
City the final authority for approving it. Information on Lubbock's residential
parking program is attached for your review. It should be noted that while other
Texas cities have such programs, from a legal standpoint, there are issues to
consider. The streets and roadways are held in trust by the City for public usage.
The cities that have established limited use of public streets have no clear
statutory authority to limit the public access to the public streets. It is likely that
only in extraordinary circumstances will Limited use of public roads be allowed.
It is also possible that limited use of public roads may be held to be invalid.
Staff is recommending implementing an application /petition based permit system
on a pilot basis in a small trial area to test the system's effectiveness. If this pilot
program has a positive impact, staff can implement this system in other
neighborhoods as needed. Staff advises making the area bordered by George
Bush Avenue to the North, Dexter to the East, Park Place to the South, and
Wellborn Road to the West as the targeted trial area for the permit system.
Further details of such a system would have to be worked out if Council directs
staff to move forward with this recommendation.
1
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7/14/98
ate 4I
Southside /South
Southgate Neighborhood Preservation Report M1
Recommendation #7
7. Restoration of the Neighborhood
RESOLVED, that the Committee recommends;
a. The City create a reinvestment positive climate in the area through economic
means which is restricted to single-family owner - occupied homes. It is suggested
that the time period for this should not exceed beyond the year 2040 and that
abatement on a given individual 's property should not exceed 20 years.
b. The City should tie the above point together with some form of tax abatement
and/or some kind of program of low interest subsidized loans which will increase
the value of non - conformance property, as well, in order to make the overall effects
revenue positive for the City as time goes forward in the area.
In regard to Recommendation 7:
Staffs research has found the City cannot legally offer abatements of ad
valorem taxes for residential property owners. However, there are existing
Community Development programs which can be utilized in this neighborhood
on a voluntary basis:
•
• If a family is low- income (less than 80% of area's median adjusted for
family size) and owns their home (or purchasing it), then they can apply for
owner - occupied rehabilitation assistance and Optional Relocation Program
(if house is beyond repair, Community Development tears it down and
rebuilds). These programs are grant programs for persons below 60% of
median income, and those between 60 % -80% pay a small portion of their
project cost. Community Development does not do any kind of loan for
their share.
• The Rental Rehabilitation Program is available for landlords of rental
property on a dollar- for - dollar match, with a ceiling amount based on
number of bedrooms, i.e., on a 2- bedroom Community Development loans
up to $7,500. These are deferred, forgivable Loans for a 10 -year period.
The landlord has to bring the property up to code and make it available for
rent to low to moderate income (LMI) tenants.
• . Also, the Downpayment Assistance Program is available for LMI
homebuyers who might wish to purchase a home in that area (actually
available city- wide). Community Development can pay up to $4,000 in
down payment and closing costs. Also, they can apply for rehabilitation
assistance in conjunction with this.
6 •
7/14/98
• Other assistance would be to make available painting supplies and
materials to a LMI homeowner who might wish to paint the exterior of his
home. Community Development has also done some relatively minor
drainage projects. Community Development can also do "emergency
repairs" if the health and safety of occupants is involved.
While Community Development offers a variety of programs to this area, it
may be that there is not a high awareness of these programs by residents
and /or property owners. If Council so directed, Community Development and
the City could begin a targeted marketing project to the residents and property
owners in the Southside /Southgate study area. This would include workshops,
flyers, and other possible informational material to get the information out to
those who need it.
7
30/09 '99 08:18 FAX 403 693 4243 M D G
002
1
8-G_11 Street Names
New streets shall not only be named so as to provide continuity of existing streets, but
shall be named to prevent conflict with identical or similar names in other parts of the
City. New streets shall not be named after any living person_
8�H Allevs
8-H.1 Alleys may be required at the rear of all lots intended to be used for business purposes
and may be provided in residential areas.
8-H.2 Alleys shall generally be parallel to the street, shall be not less than twenty feet (20)
wide and shall be paved under City Engineering standards. The right -of -way for alleys
shall be dedicated to the public.
&H.3 Where two (2) alleys intersect, or where an alley turns, additional width may be required
to allow tuming of vehicles or guying of utility poles.
8-H.4 Dead -end alleys shall not be permitted, except where the alley is one hundred feet (100
or less in le th, 1
8-H•5 In
each side all alleys, overhead easements of at least four feet (4) in width shall be provided on
of
must hang. the his alley
easement is not over required when the elec�ncca and communication lines
nd communication lines
are placed underground.
8.1 Easements
8-1.1 Drainage Easements
Where a subdivision is traversed by a watercourse, drainage way, natural channel or
stream, there may be required a drainage easement or right -of -way conforming sub-
stantially to the limits of such watercourse, plus additional width to accommodate future
needs as determined by the City Engineer. No construction, including fences, shall Im-
pede, constrict, or block the flow of water in any easement or natural watercourse. Such
easement shall not be considered a part of the lot area for purposes of minimum lot size
requirements of the zoning ordinance. Drainage easements may be used for utilities.
8=1 2 Utility Easements
8-1.2.1 Each block that does not contain an alley as provided in 8-H above, shall have a utility
easement at the rear of all lots, reserved for the use of alt utility lines, conduit, and
equipment These utility easements shall be twenty feet (20') in width, taken ten feet
(10) from each lot where the rear of the lots abut each other, and shall be continuous for
the entire length of a block These easements shall be parallel as closely as possible to
the street line frontage of the block
8 -1.2.2 Normal curb section shall be required where utility easements intersect streets.
8 -12.3 Where utility easements are not themselves straight within each block, or if the sart7e do
not connect on a straight course with utility easements of adjoining blocks, then an
additional easement shall be provided for the placement of guy wires on lot division lines
in order to support poles set on curving or deviating rights - of-way or easements.
8-12.4 Utility easements may be required across parts of Tots other than as described above 1
upon recommendation of the City Engineer. Where the proposed subdivision adjoins an
unplatted area, the full twenty foot (27) width of easement may be required along the
rear of lots adjoining the unplatted area.
g
Rev- 12/97
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