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Report to the Board of Supervisors Prepared by the Maricopa County Planning and Development Department Board Hearing Date: May 9, 2018 Case #/Title: Z2016091 – Yearling Behavioral Health Residential Facility Supervisor District: 3 Applicant/Owner: Daniel Istrate, Kontexture, LLC / Tariq Rana Request: Special Use Permit (SUP) to operate a Behavioral Health Residential Facility for up to 16 residents Site Location: 512 W. Yearling Rd., approximately 330’ east of 7th Ave. on the north side of Yearling Rd. Site Size: Approximately 1.23 acres County Island Status: Yes (Phoenix) Additional Comments: Staff has calculated the opposition received, and notes that a Super Majority Vote has been triggered. The trigger is when 20% or more of property owners within a 300’ radius of the subject site, by number and area register opposition to the case. The opposition received accounts for six (6) property owners with an area of 297,093.47 sq. ft. The calculations for Yearling Behavioral Health Residential Facility are as follows: 89.27% opposed by acreage 66.67% opposed by numbers Staff recommended denial of the SUP application to the Commission. A Group Home is a use as by right in a Rural-43 zoning district, Rural-43 is a rural single-family residential district with lots of one acre or greater. To qualify as a Group Home the residents must be no more than 10, must be of a certain classification (minors, disabled, over the age of 55) and they must live as a single housekeeping unit, thereby creating a family-like environment. Because the residents of a Group Home live in a family-like environment, it is very difficult to differentiate the operation of a Group Home from any other single-family residence. However, once residents fail to live as a single-housekeeping unit, and where treatment is given, the property loses the character of a single-family residence and takes on the character of a health care institution. Health care institutions are not permitted in the Rural-43 zoning district, hence the need for the SUP for a Group Care Facility. May 9, 2018 BOS Z2016091 Page 1 of 3 The property has been issued a license from Arizona Department of Health Services (AZDHS) to permit the operation of a Residential Behavioral Health Facility. The regulations covering such a facility define it as a health care institution. Residents are required to be given treatment as a condition of the operation of such a facility. Further, inspections of the on-going operation on the property have revealed that the residents do not live as a single-housekeeping unit. The area is strictly rural single-family residences. Services are limited. The home is located on a private road, restricting access by emergency vehicles. In the past, the facility has been used for meetings that included persons who do not work or reside at the facility, and if the SUP were approved, those kinds of meetings could continue. Staff believes such a facility in a single-family area is contrary to the intent and purpose of the Maricopa County Comprehensive Plan and zoning ordinance. The residence also does not meet the Rural-43 zoning district setbacks. A Variance was granted permitting the current setbacks (BA2003128), however this was for a single family residence and not a Group Care Facility. Currently the residence sets only 15’ from the north property line, where 30’ is the minimum in the Rural-43 zoning district; and 20’ from the west property line, where 40’ is the minimum in the Rural-43 zoning district. Both the north and west sides of the property are adjacent to single-family residences, hence locating the facility closer to neighboring property owners than the Rural-43 zoning district setbacks would normally allow for. This creates a burden to adjacent residences by putting a commercial-like Group Care Facility closer to neighboring properties. If the site was a new construction the existing setbacks would not be supported for the type of land use the SUP is requesting. Staff concludes that the operation of a health care institution at this location is an inappropriate land use for the area. One of the fundamental purpose of planning is to help ensure public health and safety. The Maricopa County Comprehensive Plan, Vision 2030 helps to meet this by supporting compatible land uses; environmental quality; and safe, efficient and practical development patterns. In addition, the County’s Land Use Goals are to achieve balanced and efficient development patterns and protect the public health, safety, and well-being. Staff believes a commercial-like Group Care Facility for Behavioral Health of up to 16 Residents in the Rural-43 zoning district, adjacent to single-family residences does not further these goals and will adversely impact the harmony of the residential neighborhood. Staff presented the Commission with a memo (attached) regarding 17 additional opposition letters staff received since the writing of the staff report. Staff also received three letters of support from facility staff. Staff received no letters of neighborhood support. The applicant provided the Commission handouts (attached) of businesses within the subject area located in the Rural-43 zoning district and spoke to the other commercial operations that may or may not be properly entitled. The applicant also spoke to three other SUPs for Group Care Facilities approved in recent years. Staff noted that each of the described SUPs for Group Care Facilities were approved based on the individual case merits, site aspects, and the furtherance of a preponderance of planning goals that indicates they were appropriate land uses for the respective sites. That is not the case with the subject SUP request. For reasons described above and outlined in the attached staff report, staff recommended denial of Z2016091. The Planning and Zoning Commission concurred with staff’s recommendation and voted unanimously to recommend Denial. May 9, 2018 BOS Z2016091 Page 2 of 3 Commission Recommendation: On 4/12/18, the Commission voted 6-0 to recommend Denial of Z2016091. Presented by: Jaclyn Sarnowski, Planner Reviewed by: Darren Gerard, AICP, Deputy Director Attachments: 4/12/18 Opposition Map for Super Majority (1 page) 4/12/18 P&Z Packet (79 pages) 4/12/18 P&Z Handout Memo by staff (38 pages) 4/12/18 P&Z Handout Memo by applicant (5 pages) 4/12/18 Additional Opposition e-mail/letter (3 pages) Note: 4/12/18 Draft P&Z Minutes are not available as of the writing of this report, but can be provided upon request later when available. May 9, 2018 BOS Z2016091 Page 3 of 3 Report to the Planning and Zoning Commission Prepared by the Maricopa County Planning and Development Department Case: Z2016091 – Yearling Behavioral Health Residential Facility Meeting Date: April 12, 2018 Supervisor District: 3 Applicant: Daniel Istrate, Kontexture, LLC Owner: Tariq Rana Request: Special Use Permit (SUP) to operate a Behavioral Health Residential Facility for up to 16 residents Site Location: 512 W. Yearling Rd., approximately 330’ east of 7th Ave. on the north side of Yearling Rd. Site Size: 1.23 acres Density: N/A County Island: Yes (Phoenix) County Plan: Rural Development Areas (0 – 1 d.u./ac.) Municipal Plan: City of Phoenix – Residential (0-1/1-2 d.u./ac.) Municipal Comments: City of Phoenix (attached) Support/Opposition: 16 letters/e-mails of opposition, including a petition letter signed by 63 residents of the Union Hills Estate Neighborhood Recommendation: Denial Z2016091 Page 1 of 10 Project Summary: 1. The applicant is requesting a Special Use Permit (SUP) to operate a Behavioral Health Residential Facility for up to 16 residents. The property is zoned Rural-43 and is located in the north Phoenix area at 512 W. Yearling Rd, 330’ east of 7th Ave on the north side of Yearling Rd. The property is approximately 1.23 acres. The site will operate as a 24-hour treatment facility with up to five (5) staff during the day and two (2) at night. The residence contains nine (9) bedrooms, eight (8) will be reserved for patient residents with double occupancy. One of the bedrooms will be utilized by staff. Per the applicant the driveway and parking areas will be paved with asphalt. No other upgrades or changes will be done to the physical site layout. 2. Previously, under LU20140044 a land use determination was sought to confirm a Group Home for up to 10 elderly residents, each over 55 years of age was permitted in the Rural-43 zoning district. The Department issued a Land Use letter, subject to conditions, confirming that a Group Home for up to 10 elderly, over 55 years of age was a permitted use on the property. 3. This application was initially filed as a SUP application to increase the size of a Group Home for up to 16 elderly residents (Z2016091). A complaint was filed with the Department alleging that the facility actually was for residents who had undergone drug rehabilitation (V201601836). Inspections revealed that the property was not operating as a Group Home as defined by the Maricopa County Zoning Ordinance (MCZO) and a notice of violation was issued. Prior to a hearing, a Compliance Agreement was entered into by the owner; as a result, a new land use was sought confirming a Group Home for up to 10 disabled and/or elderly, over 55 years of age residents in the Rural-43 zoning district. The Department issued a Land Use letter, subject to conditions, confirming that a Group Home for up to 10 disabled and/or elderly residents, (each over 55 of age) was a permitted use on the property (LU20170036). It was determined by staff through inspections that the site was not in compliance with the executed Compliance Agreement or the MCZO. 4. This application was then modified to a SUP for a Behavioral Health Residential Facility for up to 16 residents. The site currently holds a Behavioral Health Residential Facility License for up to 10 residents from the Arizona Department of Health Services (AZDHS), license number BH4897 (attached). Below is a more detailed account of the history of the case and site. Background: 5. December 10, 2003: A Variance was approved by the Board of Adjustment (BOA) (BA2003128) for a proposed single-family residence to setback 15’ from the side (north) property line, where 30’ is the minimum required; a proposed single-family residence to setback 20’ from the rear (west) property line, where 40’ is the minimum required; a proposed detached accessory structure to setback 40’ from the front (east) property line, where 73’ is the minimum required; and a proposed detached accessory structure to setback 47’5” from the street side (south) property line, where 60’ is the minimum required due to a mid-section line road alignment. Z2016091 Page 2 of 10 6. December 8, 2014: LU20140044 was issued confirming a Group Home for the elderly (each over age 55) for up to 10 residents is permitted in the Rural-43 zoning district. 7. October 25, 2016: A Pre-Application Meeting was held (PA2016168) to discuss converting the facility from 10 residents to 16. Staff noted a SUP would be needed, discussed the timeframe and the citizen participation process with the applicant and owner. 8. November 17, 2016: Staff received a SUP application (Z2016091) for a Group Care Facility for the elderly for up to 16 residents. 9. December 19, 2016: Code violation (V201601836) was initialized by staff after a complaint was filed with the Department alleging that the site was for residents who had undergone drug rehabilitation and/or other behavioral health treatment, not fitting the definition of a Group Home under the MCZO. 10. July 18, 2017: A Compliance Agreement was signed by the property owner. 11. July 24, 2017: LU20170036 was issued confirming a Group Home for the elderly (age 55 and older) and/or disabled for up to 10 residents is permitted in the Rural-43 zoning district. 12. August 18, 2017: A site visit was conducted by the Code Compliance Supervisor and the Deputy Director of Planning and Development as part of the Compliance Agreement conditions. At this visit staff documented noncompliance with the MCZO. 13. August 25, 2017: A letter was sent regarding the continued noncompliance of the site based on the site visit listed above. 14. March 16, 2018: Staff received a modified SUP application for Z2016091 for a Behavioral Health Residential Facility for up to 16 residents. There is no such category under the MCZO, therefore the actual land use category is a Group Care Facility for behavioral health residents. Existing On-Site and Adjacent Zoning / Land Use: 15. On-site: Rural-43 / Residential North: Rural-43 / Residential South: City of Phoenix jurisdiction / vacant, State Trust Land East: Rural-43 / Residential West: Rural-43 / Residential Z2016091 Page 3 of 10 Z2016091 Zoning Map Z20106091 Aerial Z2016091 Page 4 of 10 Z2016091 Site Plan (North to the right side of page) Z2016091 Page 5 of 10 Z2016091 Floor Plan (North to the right side of page) Z2016091 Page 6 of 10 Utilities and Services: 16. Water: Well Wastewater: Septic School District: Deer Valley Unified School District Fire: Rural Metro Corporation Police: Maricopa County Sherriff’s Office (MCSO) Right-of-Way: 17. Yearling Rd. is not a Maricopa County Department of Transportation (MCDOT) maintained roadway and is not classified in MCDOT’s Major Streets and Routes Plan. It is a private ingress/egress roadway, however it is located on a mid-section roadway alignment. Per the MCZO a 40’ R/W dedication is required for mid-section line roads. Under BA2003128 a variance was granted for the site to allow a detached accessory structure to setback 47’5” from the street side (south) property line, where 60’ is the minimum required due to a mid-section line road alignment. Adopted Plan: 18. Maricopa County Comprehensive Plan (Vision 2030): The Comprehensive Plan designates the land use of the subject site as Rural Development Areas (0 – 1 d.u./ac.). 19. Phoenix General Plan: The Phoenix General Plan designates this area as Residential 0 – 1/ 1-2 dwelling units per acre. Public Participation Summary: 20. The applicant has complied with the Maricopa County Citizen Review Process with the required posting of the site and notification by first class mail to adjacent property owners within 300’ of the subject parcels and interested parties. Staff has received numerous opposition letters (attached) regarding the site, including a petition signed by 63 neighborhood residents. Concerns include: facility resident related crime (MCSO reports); a facility treatment center operating in a rural residential neighborhood; proximity of neighborhood children, roadway maintenance, parking, environmental concerns, as well as others. Concerns from Reviewing Agencies: 21. As part of the SUP process, County agencies review the site plan for technical details associated with their discipline. With respect to the site plan the MCSO and Engineering had no comments or concerns regarding the site plan (attached). It was confirmed by Maricopa County Environmental Services Department (MCESD) that the septic tank is not in the correct location on the site plan. A revised site plan indicating the correct location of the septic tank will be needed (attached). Reviewing County agencies are not commenting on the land use. Z2016091 Page 7 of 10 Staff Analysis: 22. Staff recommends denial of the SUP application. A Group Home is a use as of right in a Rural-43 zoning district. Rural-43 is a rural single-family residential district with lots of one acre or greater. To qualify as a Group Home the residents must be no more than 10, must be of a certain classification (minors, disabled, over the age of 55) and they must live as a single housekeeping unit, thereby creating a family-like environment. Also, although on-site care, training or support is permitted, treatment is not. 23. Because the residents of a Group Home live in a family-like environment, it is very difficult to differentiate the operation of a Group Home from any other single-family residence. However, once residents fail to live as a single-housekeeping unit, and where treatment is given, the property loses the character of a single-family residence and takes on the character of a health care institution. Health care institutions are not permitted in the Rural-43 zoning district, hence the need for the SUP. 24. The property has been issued a license from ADHS to permit the operation of a Residential Behavioral Health Facility. The regulations covering such a facility define it as a health care institution. Residents are required to be given treatment as a condition of the operation of such a facility. Further, inspections of the on-going operation on the property have revealed that the residents do not live as a single-housekeeping unit. Staff concludes that the operation of a health care institution at this location is inappropriate land use planning. 25. The area is strictly rural single-family residences. Services are limited. The home is located on a private road, restricting access by emergency vehicles. In the past, the facility has been used for meetings that included persons who do not work or reside at the facility, and if the SUP were approved, those kinds of meetings could continue. Staff believes such a facility in a single-family area is contrary to the intent and purpose of the Maricopa County Comprehensive Plan and zoning ordinance. 26. The residence also does not meet the Rural-43 zoning district setbacks. A Variance was granted permitting the current setbacks (discussed above), however this was for a single family residence and not a Group Care Facility. Currently the residence sets only 15’ from the north property line, where 30’ is the minimum in the Rural-43 zoning district; and 20’ from the west property line, where 40’ is the minimum in the Rural-43 zoning district. Both the north and west sides of the property are adjacent to single-family residences, hence locating the facility closer to neighboring property owners than the Rural-43 zoning district setbacks would normally allow for. This creates a burden to adjacent residences by putting a commercial-like Group Care Facility closer to neighboring properties. If the site was a new construction (just being built) the existing setbacks would not be permitted for the type of land use the SUP is requesting. 27. The City of Phoenix sent a letter (attached) to staff stating that the area is designated Residential 0-1/1-2 du/ac in the City of Phoenix General Plan Planning Area; there is no other known group facility within 1,320’; and dust-free parking and maneuvering areas should be provided for employees and guests. Z2016091 Page 8 of 10 28. As mentioned above, staff has also received numerous opposition emails regarding the existing use and proposed SUP based on safety, environmental, land use, and access/roadway concerns associated with a behavioral health and treatment center operating in a rural residential neighborhood. Recommendation: 29. For reasons outlined in this report, staff recommends Denial of Z2016091. 30. However, if the Commission choses to recommend approval of the motion, staff offers the following conditions ‘a’ – ‘i’ for Commission consideration: a. Development of the site shall comply with the Site Plan entitled “Site Plan“, consisting of 1 full-size sheets, dated January 30, 2017, and stamped received February 9, 2017, except as modified by the following conditions. Within 30 days of Board of Supervisors approval, the applicant shall submit a revised site plan showing the correct location of the septic tank. b. Development of the site shall be in conformance with the Narrative Report entitled “Ascend Behavior Health and Wellness”, consisting of 2 pages, dated March 27, 2018, and stamped received March 27, 2018, except as modified by the following conditions. c. This Special Use Permit shall expire 20 years (May 9, 2038) from the date of approval by the Board of Supervisors or upon termination of the use, whichever occurs first. d. The applicant/land owner shall submit a written report to the Department outlining the status of the facility every five (5) years following approval of this request by the Board of Supervisors. The Department may accept this report, request additional reports, or take other action as deemed appropriate at that time. e. Parking, maneuvering areas, and driveways shall be paved. f. The following Engineering condition shall apply: 1. No new site disturbance (new buildings, additions, expanded parking, etc.) exceeding 1,500 sq. ft. is permitted. New site disturbance in excess of 1,500 sq. ft. shall require submission of an engineered grading and drainage plan for procurement of a building permit to the Maricopa County Planning & Development Department. g. Changes to this Special Use with regard to use and intensity must be processed as a revised application with approval by the Board of Supervisors upon recommendation of the Commission. Minor changes to the Special Use may be administratively approved by the Planning Division of the Department of Planning and Development. h. The applicant/owner shall submit a copy of the updated State of Arizona license to Maricopa County Planning and Development Department, indicating the increase in occupancy up to 16 residents prior to receiving an approval letter for this Special Z2016091 Page 9 of 10 Use Permit. The applicant/owner shall also provide the Department with a copy of the annual license issued by the State. i. Noncompliance with the conditions of approval will be treated as a violation. Further, noncompliance of the conditions of approval may be grounds for the Commission to take action. Presented by: Jaclyn Sarnowski, Planner Reviewed by: Matt Holm, AICP, Planning Supervisor Attachments: Case Map (1 page) Vicinity Map (1 page) Narrative Report (2 pages) Site Plan (reduced 8.5”x11”1 page) Floor Plan reduced (8.5”x11”1 page) Engineering comments (1 page) MCESD comments (3 page) MCSO comments (1 page) City of Phoenix letter (1 page) Rural Metro will serve letter (1 page) AZDHS Licensing Certificate (1 page) Letters of Opposition (58 pages) Z2016091 Page 10 of 10 Planning & Development Department DATE: April 12, 2018 TO: Planning & Zoning Commission FROM: Jaclyn Sarnowski, Planner SUBJECT: Z2016091 – Yearling Behavioral Health Residential Facility, Agenda Item #5 Since the writing of the staff report for the above case, staff has received 17 additional letters of opposition from neighboring properties (attached). One of the letters that was already included in the staff report; however enclosures to the letter were left out and are now included in this memo. Staff also received three letters of support from facility staff (attached). Staff would also like to add conditions ‘j’ and ‘k’ with the additional language shown in bold below. Staff inadvertently left out a building permit condition. Also, it was brought to staff’s attention that Rural Metro is no longer providing fire protection in this area. The applicant provided a Rural Metro “Will Serve” letter with their initial application. Staff would like to add conditions ‘j’ and ‘k’ if the Commission recommends approval of case Z2016091. j. Prior to occupying the residence as a Group Care Facility for 16 residents, or for any use associated with the Special Use Permit, the applicant shall obtain a Building Permit to retrofit the existing residence to meet current commercial building code requirements as applicable and shall obtain a Certificate of Occupancy for the retrofitted building prior to the occupancy of 16 residents. k. The applicant/property owner shall submit a ‘will serve’ letter for fire protection services for the project site. A copy of the ‘will serve’ letter shall be required as part of the initial building permit submittal. Enclosures 502 N. 44th Street, Suite 200 Phoenix, AZ 85008 (602) 506-8150 (602) 506-3711 fax Internet: www.maricopa.gov/planning From: flyersfan0126@yahoo.com To: Jaclyn Sarnowski - PLANDEVX Cc: District 3 Subject: Statement of Concern RE: 512 W. Yearling Property Date: Monday, April 9, 2018 7:30:40 AM Good Morning, I recently learned of the newest hearing regarding the above property. I had not heard anything for over a year since an initial meeting was held, a meeting for which I was advised not to attend. I have serious reservations regarding the intent of the permit being issued for this property. This area is a family-friendly environment and residents value the fact that this is a safe place to live. The owner of Ascend Behavioral Health has another such property in close proximity. She initially started that property as a home for troubled youth. However, it transitioned without the knowledge of residents and for the longest time there were 2 sex offenders residing in the property. Currently, I still see one residing at that property located at 27181 N 24th Ln. I find it very unsettling to this that, with the approval of this updated permit, there could potentially be 16 additional sex offenders coming to the area, or people with substance abuse and mental health disorders that may pose a threat to the children in the area. I am familiar with homes such as this as I work in the healthcare industry. The employees that manage the properties are paid very little and do not have a vested interest in the residents. Over at the property on 24th Lane, residents observe a lot of traffic in and out and speculate that employees have their friends over for visits as well. This property is much smaller than Yearling, so I would be concerned that this problem could potentially increase threefold if this current request was approved. I respectfully request that the current request from Ascend behavioral health is denied, both for the safety of our children and the sake of our property values in the area. Thank you for your consideration of this matter. Sincerely, Karen M. Hobbs 480.262.6748 From: nancy fouts To: Jaclyn Sarnowski - PLANDEVX Subject: Re: Z2016091 Date: Saturday, April 7, 2018 7:42:50 PM To Ms. Jaclyn Sarnowski M C C Planning and Development Dept. From Dave and Nancy Fouts 26310 N 7th Ave. Phx. Az. 85085 210-12-014C Re. Z2016091 Yearling Behavioral Health Faculty My objection of permitting a behavioral health, mental health, medical facility of any kind in this community. Mrs. Sarnowski, I have had the pleasure of living in this community for 20 years. In 1998 my wife and I found this area and built here so our 4 children could grow up in a quiet and safe neighborhood, where you knew all the kids and their parents. This area was built one home at a time by like minded families who respect their neighbor's privacy and safety. Its been a great life out here for all, I believe there is Apx. 100 homes West of central and 100+ East of Central Ave. North of Happy Vally up to Jomax Rd. The residential home at 512 W Yearling is smack in the middle of the area and can only be accessed from 7Th. Ave., Fire, Sheriff Dept., and Medical. So there's only one way in or out for this home. This is a rural neighborhood, not a commercial business area and needs to remain as residential only. I have read that only the homes within 300 Ft. of this business will have their wishes considered, if this is true may I point out that most of the lots out here are on 1+ acres and are over 300 Ft. apart and all the homes should be contacted by mail in the area so they can have ample opportunity to voice their opinion. I have never been contacted and only learned of this problem from driving by and seeing a sign facing Yearling that "nobody would see if not by driving past. All the residences in the area should be informed. My desire is not to let any type of mental / medical facility in our RESIDENTIAL neighborhood. Please if you haven't yet visited the area, take a drive out here and see what we have, prior to voting to let them stay and permitting a business to operate in the neighborhood. We highly oppose to this special use permit. Thank you for your consideration. Dave and Nancy Fouts From: Kristi Fouts To: Jaclyn Sarnowski - PLANDEVX Subject: Case # Z2016091-Yearling Behavioral Health Facility Date: Saturday, April 7, 2018 7:42:22 PM Ms. Sarnowaki, Thank you for taking the time to read this letter. I strongly oppose the Special Use Permit to operate a Behavioral Health Residential Facility in my neighborhood. Please do not approve this request. This neighborhood is zoned R43 and does not allow for such a business to be run in this type of neighborhood. I have many worries about this and why it would not be a good decision for my family and my neighborhood. But I also think about the families of the clientele in this facility. Do they understand that a rural area such as this does not have the conveniences of Phoenix emergency services? Fire, water, or paramedics? Please do not approve this request. Thank you for your time. Kristan Mills APN 210-13-005D 26310 N 7th Ave Phoenix 85085 From: Fred Ries To: Jaclyn Sarnowski - PLANDEVX Subject: case # Z2016091 Yearling Behavioral Health Facility Date: Thursday, April 5, 2018 1:37:22 PM TO JACLYN SARNOWSKI MY NAME IS FRED RIES AND I LIVE NEXT DOOR TO THE FACILITY ON THE EAST AT 25819 N. 5TH. AV. I OPPOSE THE FACILITY FOR THESE REASONS. # 1. THEIR OVERFLOWING TRASH DUMPSTER IS IN THE FRONT YARD AND JUST A FEW FEET FROM THE HOUSE ON THE WEST. # 2 THE LARGE CONCRETE DECORATIVE ITEMS ON EACH SIDE OF THE DRIVE- WAY ARE TIPPED OVER AND BROKEN. THEIR YARD SAND IS WASHED DOWN OVER THE PAVED ROAD FOR OVER A YEAR NOW. THESE ARE MAINTENANCE ITEMS THAT NEED TO BE FIXED IN ORDER TO BE A GOOD NEIGHBOR. # 3 THE WATER TABLE LEVEL IN OUR AREA IS STRESSED DUE TO THE DROUGHT. A FACILITY WITH 10 + PEOPLE WILL MOST CERTAINLY OVER TAX THE WATER SUPPLY. AND WHO KNOWS WHAT MEDICAL ITEMS AND MEDICINES ARE FLUSHED DOWN THE TOILET TO CONTAMINATE THE GROUND WATER. # 4 AT LEAST ONCE A MONTH AS MANY AS 35 VEHICLES ARE PARKED ALL OVER THEIR DRIVEWAY AND WHAT WOULD BE THE FRONT YARD. NEEDLESS TO SAY THAT THE FRONT YARD IS TRASHED. MOST DAYS 4 TO 8 VEHICLES ARE PARKED ALL ABOUT THE FRONT OF THE PROPERTY. A COMMERCIAL OPERATION SUCH AS THIS WOULD BE BETTER OFF ON A CITY WATER AND SEWER SYSTEM AND A LARGE PARKING LOT. THANK YOU . 4-5-2018 FRED RIES