Agenda 07/09/2019 Item #16K 5 (Staff's Official Interpretation Old Groves Road) Proposed Agenda Changes
Board of County Commissioners Meeting
July 9,2019
Add-On Item 16.12: To record in the minutes of the Board of County Commissioners,the check
number(or other payment method),amount, payee,and purpose for which the referenced
disbursements were drawn for the periods between June 13,2019 and June 26,2019 pursuant to
Florida Statute 136. (Clerk's office request)
Add-On Item 16J3: Request that the Board approve and determine valid public purpose for
invoices payable and purchasing card transactions as of July 3,2019. (Clerk's office request)
Move Item 16K5 to Item 12A: Recommendation to affirm Staffs Official Interpretation and
reject the appeal therefrom concerning Old Groves Road in the Vineyards Planned Unit
Development which will allow the entities to go directly to court to address their dispute.
(Commissioner Solis' request)
Note:
Item 16K7-The expiration date for the new term is June 30,2022, not October 20,2022. (County
Attorney's request)
Time Certain Items:
Item 11D to be heard at 10:45 a.m.
7/9/2019 8:43 AM
07/09/2019
EXECUTIVE SUMMARY
Recommendation to affirm Staff’s Official Interpretation and reject the appeal therefrom
concerning Old Groves Road in the Vineyards Planned Unit Development which will allow the
entities to go directly to court to address their dispute.
OBJECTIVE: To affirm Staff’s Official Interpretation and reject the appeal therefrom (ADA-
PL20190001155) concerning Old Groves Road in the Vineyards Planned Unit Development, and refund
the application fee.
CONSIDERATIONS: The below map will help explain this issue:
The Orchards is the community to the right of the photo. Piper’s Grove is the community to the left.
Piper’s Grove has access to both Airport Road and Vanderbilt Beach Road. The Orchards has access to
Vanderbilt Beach Road but is blocked from access (through the Piper’s Grove community) by a gate
indicated by the red arrow. The gate has been there for over 14 years. For many years, off and on, the
Orchards has been attempting to get the County to force open the gate to all ow them access onto Airport
Road, using Code Enforcement as the crowbar, claiming that access to Airport Road was required by the
PUD. As (1) both staff and the County Attorney are of the opinion that the PUD says no such thing; and
(2) all of the interior roads to both developments are private roads, it has been the County’s position that
this is a private dispute, and no action has ever been undertaken by the County.
Presumably in an attempt to force the issue, on January 8, 2019, The Orchards Community
Association filed a request for an official interpretation that the Vineyards Planned Unit Development
requires that the Orchards Community be provided access through Old Groves Road to Airport -Pulling
Road. The Zoning Director determined that neither the LDC nor the Vineyards Planned Unit
Development require that the Orchards Community be provided access through Old Groves Road to
Airport-Pulling Road. A copy of this opinion is included as back-up. On May 13, 2019, The Orchards
Community Association appealed the Official Interpretation.
16.K.5
Packet Pg. 2429
07/09/2019
It is the opinion of the County Attorney that this is now and has always been a private dispute. It is the
further opinion of the County Attorney that the appropriate venue for this dispute is and has always been
the Circuit Court of Collier County, and that once in Court, the interpretation of an Ordinance is subject
to de novo review by the Court anyway, leaving any prior interpretation by staff or the Board of County
Commissioners at best non-binding.
Note that unlike other similar appeals to the Board, there is no underlying development action pending.
In all other like appeals, the Board has been asked to interpret and apply the questioned LDC or
Ordinance provision in the context of a requested development order (such as a site development plan
contingent on whether a proposed hotel was limited by a FAR requirement, or a Request for an Official
Interpretation of a zoning provision concerning whether a particular use at a particular location was
authorized, in which the Board would look at compatibility as part of its review). Here, the appellant is
asking the Board for its interpretation of a PUD provision in order to compel the County to utilize Code
Enforcement to force open a gate on private property through the threat and imposition of fines. Put
another way, the relief sought simply does not fall within the typical parameters of a quasi -judicial review
(which is a Board function), but instead seeks a legal interpretation of an ordinance (wh ich is a Court’s
function).
With that noted, it is the recommendation of the County Attorney that the Board simply affirm Staff’s
Official Interpretation without formal review or opinion, deny the appeal, and leave the Orchards
Community to seek whatever legal remedies may be available to them in the Courts. Should the Board
wish to hear this matter it will need to be advertised and brought back for a Public Hearing.
FISCAL IMPACT: None; the application fee will be refunded to appellant.
GROWTH MANAGEMENT IMPACT: None.
RECOMMENDATION: That the Board of County Commissioners affirms Staff’s Official
Interpretation and rejects the appeal therefrom (ADA-PL20190001155) concerning Old Groves Road in
the Vineyards Planned Unit Development, and refund the application fee.
PREPARED BY: Jeffrey A. Klatzkow, County Attorney.
ATTACHMENT(S)
1. Request for OI (PDF)
2. Signed-OI-PL20190062 (PDF)
3. The Orchards Appeal of OI_Entire Submission Pt 1 (PDF)
4. The Orchards Appeal of OI_Entire Submission Pt. 2 (PDF)
16.K.5
Packet Pg. 2430
07/09/2019
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.K.5
Doc ID: 9516
Item Summary: Recommendation to affirm Staff’s Official Interpretation and reject the appeal
therefrom concerning Old Groves Road in the Vineyards Planned Unit Development which will allow the
entities to go directly to court to address their dispute.
Meeting Date: 07/09/2019
Prepared by:
Title: Legal Assistant/Paralegal – County Attorney's Office
Name: Virginia Neet
07/01/2019 2:31 PM
Submitted by:
Title: County Attorney – County Attorney's Office
Name: Jeffrey A. Klatzkow
07/01/2019 2:31 PM
Approved By:
Review:
Office of Management and Budget MaryJo Brock Level 3 OMB Gatekeeper Review Skipped 07/01/2019 2:13 PM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 07/01/2019 3:05 PM
County Manager's Office Leo E. Ochs Level 4 County Manager Review Completed 07/02/2019 8:46 AM
Board of County Commissioners MaryJo Brock Meeting Pending 07/09/2019 9:00 AM
16.K.5
Packet Pg. 2431
TO:
FROM:
DATE:
RE:
ADAMCZYK LAW FIRM PLLC
REAL ESTATE. CONDO/HOA & BUSINESS L W
Michael Bosi, Director, Planning and Zoning Division
Mark E. Adamczyk, Esq.
lamtary 2,2019
Official Interpretation of The Vineyards PUD
The Orchards Community Association, Inc.
Dear Mr. Bosi:
This Firm represents The Orchards Community Association, Inc. ("The Orchards").
Pursuant to section 1.06.01 ofthe Collier County Land Development Code ("LDC"), please accept
this submittal as a request for an Official Interpretation of PUD Ordinance 85-15, as amended
("The Vineyards PUD").
The problern is as follows. The Orchards residents have only one point ofaccess for their
community. That access point is Groves Road, which connects to Vanderbilt Beach Road (see
Exhibit I enclosed). We believe this is inconsistent with The Vineyards PUD and subdivision
plats (which is explained further below). By contrast, the residents in Piper's Grove and North
Groves have multiple points of access. There is access from Airport-Pulling Road through Old
Groves Road. There is also access to Vanderbilt Beach Road through the Groves Road entrance
shared with The Orchards (see Exhibit 2 enclosed). We believe The Orchards should also have
access to Airport-Pulling Road through Old Groves Road, but there are gates blocking access.
Groves Resident's Association, Inc. (the "Groves") is the entity that owns and maintains
Old Groves Road and the aforernentioned gates. The Orchards through our offtce has requested
that Groves provide access to Old Groves Road so that The Orchards residents can have the same
access enjoyed by Piper's Grove and North Groves. Despite several requests and dernands, Groves
has refused to provide access. For reasons explained below, we believe this is a violation of The
Vineyards PUD.
Viner ards PUD
The Vineyards PUD govems the property in question. The original ordinance is 85-15,
and it has been amended several times. There was a substantial PUD amendment approved by the
BOCC in 1991. Ordinance 9l-75 states the following on page 46, Miscellaneous: "Access to the
16.K.5.a
Packet Pg. 2432 Attachment: Request for OI (9516 : Appeal - Old Groves Road Official Interpretation)
project shall be restricted to those access points shown on Exhibits A-1 and A-2 hereto, provided
that the location of the access to commercial parcels shall be approved by the County Engineer."
The only PUD amendment subsequent to ordinance 9l -75 was approved as ordinance 95-
62. The only change involved the PUD master plan. The required interconnection discussed above
was not removed or changed. Further, the BOCC meeting minutes for (approval o0 both 9l-75
and 95-62 show za discussion about removing the requirement for multiple access points.
Piper's Grove S ite Development Plan
To ensure the validity ofour position regarding the PUD, we requested copies ofplanning
records for the approval of the Piper's Grove site development plan. Enclosed herein are copies
of a Planning Services memorandum dated June 26, 1992 Exhibit 4 and the pre-application
meeting notes dated MaY 27 , 1992 Exhibit 5 ) for review of the Piper's Grove site development
plans.
In the pre-application meeting, the applicants (i.e. the Groves developers) stipulated that
the access gates at the erltralrce ppil1; would provide the residents to the east ofthe project with
thru access to the commercial site. Per the Vineyards PUD, the project to the east is The Orchards.
The commercial site, ofcourse, is the Publix shopping center at the comer of Airport-Pulling and
Vanderbilt Beach.
A month later, the Planning Services Division issued a memorandum addressing
transportation planning in the Piper's Grove planned subdivision. That mernorandum states that
the subdivision site plan provides interconnection to the adjacent tract to the east (i.e. The
Orchards), which is "consistent with the approved PUD Master Plan".
The Orchard s Site Devel op ment Nlaster Plan
We were also able to obtain records for the approval of The Orchards Site Development
Master Plan (originally named Stoneybrook Estates by U.S. Home Corp.). Enclosed herein is a
copy of a memorandum to the Planning Commission from Community Development Services
dated August 7, 1990 Exhibit 6 In the analysis, the CDS division stated that the project is to
have access from Vanderbilt Beach Road an d Airport-Pulling Road.
Exhibits A-1 and A-2 fiom Ordinance 9l-75 are enclosed as Exhibit 3. Those exhibits
clearly show that all communities west of Livingston Road are supposed to have access to both
Vanderbilt Beach Road and Airport-Pulling Road.
16.K.5.a
Packet Pg. 2433 Attachment: Request for OI (9516 : Appeal - Old Groves Road Official Interpretation)
App roved Subdivision Plats
"Old Groves Road is subject to an easement in favor olProcacci Bros. Sales Corporation,
a Pennsylvania corporation, their successors and assigns, an owner of a contiguous tract
consisting of approximately 84 acres to the east of Piper's Grove for vehicular and
pedestrian access and egress, pursuant to a Declaration of Restrictions recorded at O.R.
Book 1898, Pages 2308-23 I 8, of the Public Records of Collier County, Florida'"
An ingress/egress easement is referenced on Old Groves Road on all pages of the plats,
which is clearly a reference to the Declaration of Easements. The pertinent pages fiom the plats
are attached as Exhibit 7. The Orchards is the community developed on the 84 acres to the east of
Piper's Grove, and the plats provide further evidence that Groves is required to provide access to
Airport-Pulling Road though Old Groves Road.
We have attached as Exhibit 8 the Declaration of Easements discussed above. That
document was recorded December 29, 1993 at O.R. Book 1898, Page 2308, Collier County,
Florida Public Records (the "Easemenf'). This Easement was created and recorded precisely when
phases one and two olPiper's Grove were being platted and developed.
Procacci Bros. (hereafter "Procacci") was the owner ofTracts A, C and D as shown on the
conceptual site plan attached to the Easement. Tract D is The Orchards. The Groves developer
owned Tract B (now Piper's Grove, Phase One), and had an option to acquire Tract C (now Piper's
Grove, Phase Two). Tract A is the commercial parcel where the Publix shopping center was
developed.
The Easement shows that Procacci gtanted access to Vanderbilt Beach Road in favor of
Tracts B, C & D, via "Groves Road", which again now serves as the only entrance to The Orchards
from Vanderbilt Beach Road. In tum, Groves granted access to Airport-Pulling Road through
"Old Groves Road" in favor ofTracts B, C and D for passenger vehicle traffic.
As a whole, it is clear that the main purpose of the Easement was to ensure that both Piper's
Grove and The Orchards had multiple access points at Vanderbilt Beach and Airport-Pulling,
which is consistent with the PUD and site development plans.
The plats for Piper's Grove and North Groves are consistent with the above analysis ofthe
PUD and site development plans. In fact, a Declaration of Easements is expressly referenced on
the first pages of the plats for Piper's Grove Phase One and Phase Two. Under the "General
Notes", the plats state:
Declaration of Easements
16.K.5.a
Packet Pg. 2434 Attachment: Request for OI (9516 : Appeal - Old Groves Road Official Interpretation)
Conclusion and Request
We believe that the Vineyards PUD and the planning approvals for Groves and The
Orchards clearly require multiple access points at Vanderbilt Beach Road and Airport-Pulling
Road. Groves currently enjoys the required access, but Groves has blocked the required
interconnection and second access point for The Orchards. The Orchards requests an interpretation
consistent with the above analysis and that this matter be refened to Code Enforcement and the
County Attomey's Office for enforcement if Croves continues to refuse access.
Thank you for your assistance in this matter.
/ .) U(Nl
Ultt(fi4,t nwru
$Mark czyk, Esq.
For the Firm
16.K.5.a
Packet Pg. 2435 Attachment: Request for OI (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.b
Packet Pg. 2436 Attachment: Signed-OI-PL20190062 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.b
Packet Pg. 2437 Attachment: Signed-OI-PL20190062 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2438 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2439 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2440 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2441 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2442 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2443 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2444 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2445 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2446 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2447 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2448 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2449 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2450 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2451 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2452 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2453 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2454 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2455 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2456 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2457 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2458 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2459 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2460 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2461 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2462 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2463 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2464 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2465 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2466 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2467 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2468 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2469 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2470 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2471 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2472 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2473 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2474 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2475 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2476 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2477 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2478 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2479 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2480 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2481 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2482 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2483 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2484 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2485 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2486 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2487 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2488 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2489 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2490 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2491 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2492 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2493 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2494 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2495 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2496 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2497 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2498 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2499 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2500 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2501 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2502 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2503 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2504 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2505 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2506 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2507 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2508 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2509 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2510 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2511 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.c
Packet Pg. 2512 Attachment: The Orchards Appeal of OI_Entire Submission Pt 1 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2513 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2514 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2515 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2516 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2517 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2518 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2519 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2520 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2521 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2522 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2523 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2524 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2525 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2526 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2527 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2528 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2529 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2530 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2531 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2532 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2533 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2534 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2535 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2536 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2537 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2538 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2539 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2540 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2541 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2542 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2543 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2544 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2545 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2546 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2547 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2548 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2549 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2550 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2551 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2552 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2553 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2554 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2555 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2556 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2557 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2558 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2559 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2560 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2561 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2562 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2563 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2564 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2565 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2566 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2567 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2568 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2569 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2570 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2571 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2572 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2573 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2574 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2575 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2576 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2577 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2578 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2579 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2580 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2581 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2582 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2583 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2584 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2585 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2586 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2587 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2588 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2589 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2590 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2591 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2592 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2593 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2594 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)
16.K.5.d
Packet Pg. 2595 Attachment: The Orchards Appeal of OI_Entire Submission Pt. 2 (9516 : Appeal - Old Groves Road Official Interpretation)