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HEX Final Decision 2016-35 HEX NO. 2016 -35 HEARING EXAMINER DECISION PETITION DR — PL20130002268 — Petitioner, Wal-Mart Stores East, LP, requests approval of a site plan with deviations pursuant to LDC Section 10.02.03.F and seeks relief LDC Section 4.06.02 C.6, relating to buffer and screening standard requirements; from LDC Section 4.06.05 C., relating to foundation planting requirements along retail building facades; from LDC Section 5.05.08 C.2, relating to building design feature requirements for primary facades; from LDC Section 5.05.08 C.4, relating to variation in massing requirements for buildings 40,000 square feet or larger in gross building area; from LDC Section 5.05.08 C.5, relating to building design treatment requirements for all building facades; from LDC Section 5.05.08 C.8, relating to detail feature requirements for blank wall areas on a building; from LDC Section 5.05.08 C.10, relating to roof edge and parapet treatment requirements for buildings larger than 5,000 square feet in gross building area; from LDC Section 5.05.08 C.12, relating to entryway/customer entrance treatment requirements for single tenant buildings; from LDC Section 5.05.08 D.3, relating to design standard requirements for mercantile buildings; from LDC Section 5.05.08 E.3, relating to site design standard requirements for service function areas and facilities; and from LDC Section 5.05.08 E.6, relating to site design standard requirements for lighting, for a Wal- Mart expansion redevelopment project consisting of 17.21± acres of land, located on the north side of Tamiami Trail East (U.S. 41), approximately 1,000 feet east of Airport-Pulling Road, in Section 12, Township 50 South, Range 25 East, Collier County, Florida. DATE OF HEARING: August 25, 2016 STAFF RECOMMENDATION: Approval. FINDINGS: Based on the applicant's written petition, testimony at the hearing of the applicant and the public, and the recommendation of staff, the Hearing Examiner finds that the criteria set forth in Section 10.02.03.F.7 of the Land Development Code has been met and the petition should be approved. ANALYSIS: Two members of the public spoke in opposition to this application. Concerns were expressed involving lighting trespass onto adjoining properties after installation, landscaping, and the decision to hold this hearing while many residents of nearby neighborhoods were out of town. Additionally, there have been numerous letters of objection received. Those letters expressed concerns with increased traffic, noise, deliveries, lighting, perimeter fencing, location of truck delivery bays, flooding during excessive rains, removal of Banyan trees, need for a sound barrier, the parking lot entry way at Palm Drive, loss of natural barriers, expansion of existing development, fumes, new gas station location, and a saturation of food stores. [14-CPS-01388/1281522M65 Page 1 of 4 [ ] The issues for this hearing were limited to eleven deviations from the architectural code and one deviation from the landscape code. Not all of the concerns expressed by the public are related to the requested deviations. Site lighting was one element of objection and is addressed in one of the deviation requests. Currently parking lot lighting poles are approximately 42 feet high and lighting heads are traditional HID lighting. Wal-Mart is converting all existing poles to LED fixtures and any new poles will meet current Code, including a height limit of 25 feet. LED fixtures reduce glare, provide focused light, limit light trespass onto adjoining properties, and have less reflective light with higher poles. Documentation provided with this application show that the LED lighting provides a higher reduction in off-site glare and light trespass onto adjoining properties since the LEDs, as designed, are directionalized downward with a narrower angle of light distribution. Many concerns expressed by the public are related to issues that are typically addressed during site development plan review. DECISION: The Hearing Examiner hereby approves Petition Number DR-PL20130002268, filed by Jeffrey Satfield, P.E. of CPH, Inc., representing Wal-Mart Stores East, LP, for a site plan with deviations for redevelopment for the property described in Exhibit "A", also known as Walmart Store #1119, as follows: Deviation 1 seeks relief from LDC Section 4.06.05.C. relating to foundation planting requirements along retail building facades. Other requirements for landscaping meet Code. Due to existing conditions applicant is providing additional improvements in lieu of foundation plantings. Deviation 2 seeks relief from LDC Section 5.05.08.E.6 regarding site design standards for lighting. Site lighting height standards dictate that lighting fixtures within the parking lot are limited to a maximum height of 25 feet, and a maximum height of 15 feet in height for non- vehicular pedestrian areas. There are nineteen (19) existing 42 foot light poles, which exceed the 25-foot maximum. Instead of replacing the existing poles the applicant is requesting this deviation to allow the existing poles to be greater than 25 feet high, on the condition that they replace the existing light fixtures with directional LED lighting. Deviation 3 seeks relief from LDC Section 5.05.08.C.2.b relating to building design feature requirements on primary facades. Primary façades on the ground floor must have features along a minimum of 50 percent of their horizontal length. Alternative architectural design elements and landscaping are being utilized and are acceptable. Deviation 4 seeks relief from LDC Section 5.05.08.C.4.a.i relating to variation in massing requirements for buildings over 40,000 square feet or larger in gross building area. A maximum length, or uninterrupted curve of any facade, at any point, must be 150 linear feet. The applicant is removing an auto repair area and squaring off the East elevation, which is also screened from view by mature vegetation on the East elevation and the supplied design is acceptable. [14-CPS-01388/1281522/1]65 Page 2 of 4 Deviation 5 seeks relief from LDC Section 5.05.08.C.5.b which requires each building façade to have at least four (4) of the listed 22 design treatments on each façade and identified on drawings. The applicant is not providing listed design treatments, but is providing alternative enhancements to existing conditions. Deviation 6 seeks relief from LDC Section 5.05.08.C.6, Windows must not be false or applied. The applicant is utilizing applied fenestrations with Bahama shutters as alternative enhancements. Deviation 7 seeks relief from LDC Section 5.05.08.C.8.b, Blank Wall Areas. Blank, opaque wall areas must not exceed ten feet in vertical direction or 20 feet in the horizontal direction of any primary façade. For façades connected to a primary façade this applies to a minimum of 33 percent of the attached façades. Relief from this section is acceptable for existing walls only. Deviation 8 seeks relief from LDC Section 5.05.08.C.12.b. Entryway/Customer entrance treatment. Single-tenant buildings shall have clearly defined, highly visible, customer entrances that meet the standards set forth in the Code. The applicant proposed acceptable alternatives to these standards. Deviation 9 seeks relief from LDC Section 5.05.08.D.3.c, Mercantile — All areas with the building that can be accommodated within a space with a ceiling height of 16 feet or less must be designed and built within a single story envelope or a multiple of envelopes. These building envelopes must have a maximum eave height of 16 feet and must be expressed as single story elements in the architectural form of the building along the building edge or edges that front the public right of way. This limits any single wall plane from exceeding 60 percent of each façade. Due to existing conditions, not all provisions of this section can be met and the applicant is providing façade enhancements. Deviation 10 seeks relief from LDC Section LDC Section 5.05.08.E.3.f, which requires conduits and meters attached to the building or protruding from the roof to be screened or painted to match the surrounding building surfaces, and cannot be located on the primary façade of the building. Conditions make it impractical to apply this section to existing areas only. Deviation 11 seeks relief from LDC Section 5.05.08.E.3.g, which requires all rooftop mechanical equipment protruding from the roof to be screened from public view by integrating it into a building and roof design. Relief from this requirement applies to all existing or replacement units unless replacement or new units are added at heights higher than existing units or are located closer to the perimeter of the roof than existing units. Deviation 12 seeks relief from LDC Section 5.05.08.C.10.b.i, Roof Edge and Parapet Treatment, requiring that buildings larger than 5,000 square feet in gross building area have a minimum of two roof-edge or parapet line changes. Each vertical change from the dominant roof condition must be a minimum of ten percent of building height, but no less than three feet, and at least one such change must be located on a primary façade, as well as one additional roof change provided every 100 linear feet of the façade length. The building perimeter has more parapet line changes than required and those less than 3 feet are acceptable. [14-CPS-01388/1281522/1165 Page 3 of 4 These deviations are shown in the Deviations Detail attached as Exhibit "B," and are subject to the condition(s) set forth below. This decision does not constitute approval of the site plan. ATTACHMENTS: Exhibit A—Legal Description Exhibit B —Deviations Detail LEGAL DESCRIPTION: See Exhibit A. CONDITIONS: 1. All other applicable state or federal permits must be obtained before commencement of the development. DISCLAIMER: Pursuant to Section 125.022(5) F.S., issuance of a development permit by a county does not in any way create any rights on the part of the applicant to obtain a permit from a state or federal agency and does not create any liability on the part of the county for issuance of the permit if the applicant fails to obtain requisite approvals or fulfill the obligations imposed by a state or federal agency or undertakes actions that result in a violation of state or federal law. APPEALS: This decision becomes effective on the date it is rendered. Pursuant to Ordinance 2013-25, as amended, a Hearing Examiner Decision may be appealed to the Board of County Commissioners or the Board of Zoning Appeals, as appropriate. Appeals must be filed within 30 days of the date the Hearing Examiner Decision is rendered. RECORD OF PROCEEDINGS AND EXHIBITS: SEE CLERK OF COURT, MINUTES AND RECORDS DEPARTMENT. DECISIONS OF THE HEARING EXAMINER FOR VARIANCES, CONDITIONAL USES, AND BOAT DOCK EXTENSIONS SHALL BE NOTED ON THE ZONING MAP FOR INFORMATIONAL PURPOSES. i149.aas.L U/ Date Mark train, Hearing Examiner Appred as to iInn and legality: Scott tone Assistant County Attorney [14-CPS-01388/1281522/1]65 Page 4 of 4 *** OR: 4460 PG: 0551 *** Exhibit A Store#1119 Naples,FL Property Address: 3451 Tamiami Trail East A PARCEL OF LAND LYING IN SECTIONS 12 AND 13,TOWNSHIP 50 SOUTH,RANGE 25 EAST, COLLIER COUNTY,FLORIDA,BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGIN AT THE INTERSECTION OF THE EASTERLY RIGHT-OF-WAY LINE OF U.S.41(TAMIAMI TRAIL) WITH THE NORTHWESTERLY RIGHT-OF-WAY LINE OF PALM DRIVE AS SHOWN ON THE PLAT OF THE GLADES UNIT ONE,AS RECORDED IN PLAT BOOK 10,PAGE 82,PUBLIC RECORDS OF SAID COLLIER COUNTY;THENCE NORTH 39°05'20"WEST,ALONG SAID EASTERLY RIGHT-OF-WAY LINE OF U.S.41,A DISTANCE OF 901.47 FEET,TO A POINT ON THE ARC OF A NON-TANGENT CURVE; THENCE CONTINUE ALONG SAID NORTHEASTERLY RIGHT-OF-WAY LINE OF U.S.41 AND THE ARC OF SAID CURVE,CONCAVE SOUTHWESTERLY,HAVING FOR ITS ELEMENTS A RADIUS OF 5788.65 FEET,A CENTRAL ANGLE OF 03°39'32",AN ARC LENGTH OF 369.65 FEET,A CHORD BEARING OF NORTH 40°53'32"WEST,AND A CHORD DISTANCE OF 369.59 FEET,TO A POINT OF INTERSECTION WITH A NON-TANGENT LINE;THENCE LEAVING SAID NORTHEASTERLY RIGHT-OF-WAY LINE, NORTH 47°16'54"EAST,A DISTANCE OF 750.44 FEET,TO THE MOST WESTERLY CORNER OF LOT 3, BLOCK D,AS SHOWN ON SAID PLAT OF THE GLADES UNIT ONE;THENCE ALONG THE BOUNDARY OF SAID PLAT BY THE FOLLOWING SIX COURSES 1)SOUTH 42°43'06"EAST,A DISTANCE OF 400.00 FEET;2)THENCE SOUTH 07°26'14"EAST,A DISTANCE OF 611.35 FEET;3)THENCE SOUTH 88°07'42" EAST,A DISTANCE OF 195.12 FEET;4)THENCE SOUTH 02°02'25"EAST,A DISTANCE OF 94.73 FEET, TO A POINT OF CURVE;5)THENCE ALONG THE ARC OF SAID CURVE,CONCAVE NORTHWESTERLY, HAVING FOR ITS ELEMENTS A RADIUS OF 491.20 FEET,A CENTRAL ANGLE OF 52°57'12",AN ARC LENGTH OF 453.97 FEET,A CHORD BEARING OF S 24°26'11"WEST,AND A CHORD DISTANCE OF 437.99 FEET;6)THENCE SOUTH 50°54'48"WEST,A DISTANCE OF 140.04 FEET,TO THE POINT OF BEGINNING. TOGETHER WITH: ��------- �`� ' PARCEL B V ��l A PARCEL OF LAND LYING IN CT S 1-2,ti 4QI 3,TOWNSHIP SO TH,RANGE 25 EAST, COLLIER COUNTY,FLORIDA, ONG M P RTTIC„ lir DESC •1:E AS FOLLOWS: COMMENCE AT THE INTERS:CTI i IL AY.,INE OF U.S.41(TAMIAMI TRAIL)WITH THE SOUTHEA` Y to: OF M •Rf'E AS SHOWN ON THE PLAT OF THE GLADES UNIT•NA,, • ► s IF •,Pk6 82,PUBLIC RECORDS OF SAID COLLIER COUNTY;THE f?E ORTH 50°54'48"E �O G SOUTHEASTERLY RIGHT-OF- WAY LINE OF PALM DRIVE,A• ' • CE OF 140.03 FEET, A •OIt4T.,O CURVE;THENCE ALONG THE ARC OF SAID CURVE,CON. •" . ORTHWESTERLY, ,:•V" •TOOTS ELEMENTS A RADIUS OF 571.20 FEET,A CENTRAL ANGLE• 41' 0'27",AN ARC LENG 14„,4y7.12 FEET,A CHORD BEARING OF NORTH 29°59'34'EAST,AND A 07 I + STANCE OF 40 TO THE POINT OF BEGINNING; THENCE CONTINUE ALONG THE AR * S•dd+ "YE`•f�I 'kik° WESTERLY,HAVING FOR ITS ELEMENTS A RADIUS OF 571.20 FEET,A . 1�N'ii •' 11°06'45",AN ARC LENGTH OF 110.79 FEET,A CHORD BEARING OF NORTH 03°30'58"EAST;Ab A CHORD DISTANCE OF 110.61 FEET; THENCE NORTH 02°02'25"WEST,A DISTANCE OF 89.26 FEET,TO THE SOUTHWEST CORNER OF LOT 16,BLOCK A,OF SAID PLAT OF THE GLADES UNIT ONE;THENCE SOUTH 88°07'42"EAST,ALONG THE SOUTHERLY BOUNDARY OF SAID PLAT,A DISTANCE OF 200.47 FEET;THENCE DEPARTING SAID SOUTHERLY BOUNDARY SOUTH 38°24'48"EAST,A DISTANCE OF 175.84 FEET;THENCE SOUTH 50°55'55"WEST,A DISTANCE OF 100.00 FEET;THENCE NORTH 88°07'02"WEST,A DISTANCE OF 235.71 FEET,TO THE POINT OF BEGINNING. LESS AND EXCEPT THE FOLLOWING(SOUTH FLORIDA WATER MANAGEMENT DISTRICT PARCEL OFFICIAL RECORDS BOOK 1142,PAGE 1425) PARCEL I A PARCEL OF LAND IN SECTIONS 12 AND 13 TOWNSHIP 50 SOUTH,RANGE 25 EAST,BEING SPECIFICALLY DESCRIBED AS FOLLOWS: FROM A 4"x4"CONCRETE MONUMENT WITH A 3/4"PIPE MARKING THE SOUTHWEST(SW)CORNER OF SAID SECTION 12,BEAR NORTH 89°59'09"EAST,ALONG THE SOUTH LINE OF SAID SECTION 12,A DISTANCE OF 1216.63 FEET TO THE INTERSECTION THEREOF WITH THE NORTHEASTERLY RIGHT OF WAY LINE OF U.S.HIGHWAY 41(TAMIAMI TRAIL);THENCE,CONTINUE,NORTH 89°59'09"EAST ALONG SAID SOUTH LINE OF SECTION 12,A DISTANCE OF 75.00 FEET TO THE POINT OF BEGINNING; THENCE NORTH 24°00'00"EAST,A DISTANCE OF 45.00 FEET;THENCE,SOUTH 66°00'00"EAST,A DISTANCE OF 80.00 FEET;THENCE,SOUTH 24°00'00"WEST,A DISTANCE OF 9.36 FEET TO SAID SOUTH LINE OF SECTION 12,;THENCE CONTINUES SOUTH 24°00'00"WEST,A DISTANCE OF 35.64 FEET;THENCE NORTH 66°00'00"WEST,A DISTANCE OF 80.00 FEET TO THE POINT OF BEGINNING. Exhibit B DEVIATIONS DETAIL Wal-Mart was permitted at this location on February 11, 1993, with Site Development Plan (SDP) #92-06. The property is zoned C-5, heavy commercial. Currently Wal-Mart is requesting to amend the SDP in order to renovate the existing building that was built in 1994. The current building includes general merchandise, a garden center and a tire & lube center. The proposed changes include a 34,000 square foot expansion, much of which includes enclosing existing outdoor operations that are in closest proximity to adjoining residential. These existing operations include the Tire & Lube Center, the Garden Center, trash compactor and loading bays and docks. Part of the changes include moving the loading bays and docks to the rear facade and south of the current location, moving the trash compactor south of the new loading bay location, eliminating the Tire & Lube Center as well as the 6 service bays, and moving the unenclosed Garden Center to the opposite side of the building, along US 41. These changes either eliminate or relocate existing exterior impacts to the adjoining residential neighborhood. The area where the Tire & Lube Center, the Garden Center, trash compactor and loading bays and docks exist will be enclosed to become a new Grocery Center. To replace the existing two loading bays and one smaller dock, the new screened loading dock area will include 4 new loading docks. The current Tire & Lube Center will be eliminated along with the 6 roll up service bays. To accomplish the redevelopment noted above, the applicant is seeking deviations detailed as follows: Deviation 1 seeks relief from LDC Section 4.06.05.C. relating to foundation planting requirements along retail building facades. Other requirements for landscape meet code. Currently, 1,545 square feet of building foundation plantings are required along the primary facade facing Palm Ave. Due to existing conditions, additional improvements in lieu of plantings adjacent to the building foundation along Palm Drive facade include: 1. 1493.53 square feet of decorative pavement along the Palm Drive facade. 2. 250.45 square feet of additional parking island expansion near the Palm Drive facade. 3. Upgrade from the required 14' high trees to 16' clear trunk triple Foxtail Palms in the landscape parking islands closest to the Palm Drive building facade. 4. Exceed the overall building foundation tree requirement by 10 trees. 5. All outdoor storage/sales shall be removed from in front yards. Exhibit "B" Page 1 of 5 Deviation 2 seeks relief from LDC Section 5.05.08.E.6 regarding lighting. Site lighting height standards dictate that lighting fixtures within the parking lot must be a maximum of 25 feet in height, and 15 feet in height for non-vehicular pedestrian areas. There are nineteen (19) existing 42 foot light poles, which exceed the 25-foot maximum. The 19 existing 42 foot light poles are in good condition and would use a narrower LED light angle of distribution. This narrower angle will provide for safe even lighting on-site while reducing the potential for off-site glare and trespass. The request is limited to existing light poles in their current locations only. As a note, the light design engineer used by Walmart, Jeff Bays of HP Engineering, Inc., stated that for minimizing light trespass, it is better to have higher poles. With lower poles, more glare is created due to light reflection off the pavement. This deviation only applies to existing light poles. Deviation 3 seeks relief from LDC Section 5.05.08.C.2.b relating to building design feature requirements on primary facades. Primary facades on the ground floor must have features along a minimum of 50 percent of their horizontal length. Additional landscape is required and provides some support for this deviation along the rear elevation. However, the new addition on the rear elevation (protruding truck wells), will not have the benefit of the landscape buffer element due to the truck access onto Espinal Blvd. This deviation is supported with the applicant providing matching elements (eight (8) faux window fenestration, and Bahama shutters) along the protruding 50' addition. Deviation 4 seeks relief from LDC Section 5.05.08.C.4.a.i relating to variation in massing requirements for buildings over 40,000 square feet or larger in gross building area. A maximum length, or uninterrupted curve of any façade, at any point, must be 150 linear feet. The applicant is boxing in the existing right elevation which currently exceeds Code with four (4) breaks in massing (1 break required). The proposed elevation measures approximately 290 feet with no variations. This elevation does not meet the Code required 10 foot projection/recess along the façade. The proposed addition eliminates/encloses an auto repair area that was previously open and will provide an enhanced appearance to the right elevation; in addition, this façade is screened from view due to existing mature vegetation. Deviation 5 seeks relief from LDC Section 5.05.08.C.5.b. which requires each building facade to have at least four(4) of the listed 22 design treatments identified on drawings. The applicant is not providing listed design treatments, but is providing alternative enhancements to existing conditions. The applicant has provided cornice, canopy, additional roof articulation, pilasters, columns, projected/covered entry, and ornamental details along the front, right, and left elevations. The rear elevation, which is the most visible façade moving southbound on Tamiami Trail East, Espinal Boulevard, and the Collier County Complex, is providing larger trees (taller than code, 15-25') along the building foundation and perimeter buffer. In addition faux window fenestration and Bahama shutters are being added as a result of Deviation 3. Exhibit "B" Page 2 of 5 -Smote NJprod -Smooth!aeC panted tut -Smood'`aze N!pled fiurrand dumspadparted omttlagCrelSW*4 'DromedaryCrel'SW,fi4t / zy{ )om¢dary(mefSWGik 'DwmedrKamtfse694 Ok. Area of faux Windows w11-p Rear Devito `4etddo3rYdharoeparvc Deviation 6 seeks relief from LDC Section 5.05.08.C.6. Windows must not be false or applied. The applicant is adding applied windows using building material, shutters, and paint which do not meet code. This is still an improvement from the current blank walls, which were allowed before the revisions to the LDC. While the proposed enhancements do not fully meet current LDC standards, they do represent enhancements beyond those originally required. Deviation 7 seeks relief from LDC Section 5.05.08.C.8.b, Blank Wall Areas. Blank, opaque wall areas must not exceed ten feet in vertical direction or 20 feet in the horizontal direction of any primary façade. For façades connected to a primary façade this applies to a minimum of 33 percent of the attached façades. Relief from this section applies to existing walls only and new construction shall meet current standards. Deviation 8 seeks relief from LDC Section 5.05.08.C.12.b. Entryway/Customer entrance treatment. Single-tenant buildings shall have clearly defined, highly visible, customer entrances that meet the standards set forth in the Code. The applicant proposed acceptable alternatives to these standards. The customer entrance shall meet the following standards: an outdoor patio area must be provided adjacent to the customer entrance, with a minimum of 200 square feet in area. The patio area must incorporate specific features. The applicant shall provide patterned concrete and benches/trash cans at entryway/customer entrances. This deviation request is approved for the "Market" entrance since a structural area for seating is proposed. The request is due to existing conditions resulting from revisions to LDC requirements occurring after the development was originally constructed. The applicant intends to provide all the required enhancements of this LDC section except for the required 15-foot setback from the parking/drive isle and incorporating landscape areas. While the proposed enhancements do not fully meet current LDC standards, they do represent enhancements beyond those originally required. Exhibit "B" Page 3 of 5 Sp WSwt'd *II4e NV(Im5"gfxt(UUpxded -5 f4¢CMUpli u i ''9 5dmxtneirurn"$W6Ii3 "MkFdOdt�PS14;S71 tfflYlb`9! ,`pryn[dyyCsrA5WT 4 iMon (ml'4W7641 ', n91atFAY(�SN SuWrelGrYfWt569 j I Mil tf-TA 'Cabbie&avn"SW6+011 Deviation 9 seeks relief from LDC Section 5.05.08.D.3.c, Mercantile — All areas with the building that can be accommodated within a space with a ceiling height of 16 feet or less must be designed and built within a single story envelope or a multiple of envelopes. These building envelopes must have a maximum eave height of 16 feet and must be expressed as single story elements in the architectural form of the building along the building edge or edges that front the public right-of-way. The eave height is exceeded in all existing portions of the building. This deviation is approved due to existing conditions resulting from revisions to LDC requirements occurring after the development was originally constructed. The applicant intends to provide enhancements to the facades that were not required when originally permitted. While the proposed enhancements do not fully meet current LDC standards, they do represent enhancements beyond those originally required. Deviation 10 seeks relief from LDC Section LDC Section 5.05.08.E.3.f, which requires conduits and meters attached to the building or protruding from the roof to be screened or painted to match the surrounding building surfaces, and cannot be located on the primary façade of the building. Currently, there are existing "Conduits and Meters" on the primary façade not screened. This deviation is approved conditioned upon these elements being blended into the façade by using paint or some other application consistent with the existing façade. Any new "Conduits and Meters" shall be screened according to the LDC. Deviation 11 seeks relief from LDC Section 5.05.08.E.3.g, which requires all rooftop mechanical equipment protruding from the roof to be screened from public view by integrating it into a building and roof design. Deviation from this section applies to all existing or replacement units unless replacement or new units are added at heights higher than existing units or are located closer to the perimeter of the roof than existing units. Exhibit "B" Page 4 of 5 Deviation 12 seeks relief from LDC Section 5.05.08.C.10.b.i, Roof Edge and Parapet Treatment, requiring that buildings larger than 5,000 square feet in gross building area have a minimum of two roof-edge or parapet line changes. Each vertical change from the dominant roof condition must be a minimum of ten percent of building height, but no less than three feet, and at least one such change must be located on a primary façade, as well as one additional roof change provided every 100 linear feet of the façade length. The front elevation has the required parapet line changes. The building perimeter is approximately 1,180 linear feet and would require 12 parapet line changes. The building design proposes 26 parapet line changes, several of which are less than the required 3 foot height requirement. The building exceeds the minimum number of required parapet changes, and the additional changes are an alternative that is acceptable. Exhibit "B" Page 5 of 5