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� 8s in part: "The minimum lot dimensions in subdivisions designed for single-family � sg detached dwelling developments shall be...85 feet wide. .." Clearly the present proposal � so involves lots for single-family, detached dwellings. But if seven lots fronting existing � s � streets constitute a"development," which is a reasonable conclusion, one needs to �s2 assume that the creation of even one new lot constitutes a"development" since the � s3 Subdivision Code doesn't provide any more specific parameters. That is, the logical � s4 conclusion of this interpretation is that every newly-created lot for development of �s5 single-family, detached dwelling units is subject to the Subdivision Code's lot size � s6 requirements for single-family detached dwelling units. 197 6.7 198 199 200 201 20� 20� 204 205 206 207 2oa 209 21G 211 212 There are two compelling examples, however, that suggest the above, strict reading of the Subdivision Code is not representative of the City Council's interpretation of the provision. a. First, when the existing Zoning Code was being drafted in 2010, Planning Division staff had proposed smaller minimum lot size requirements for the LDR-1 district. This proposal was ultimately rejected for the time being, in no small part because smaller LDR-1 lot sizes in the Zoning Code would have conflicted with the provisions of § 1103.06. But, while the adoption of the current Zoning Code in December 2010 kept the LDR-1 lot size standards consistent with the standards of the Subdivision Code, the updated Zoning Code established standards for lots intended for development of single-family, detached dwellings in the LDR-2 and MDR districts which are smaller than the standards of § 1103.06. The fact that smaller lot size standards were created for development of one-family, detached dwellings in LDR-2 and MDR districts leads one to the conclusion that the lot size standards of the Subdivision Code were understood to relate only to the LDR-1 district—and not to apply to single-family development lots in other districts. 2� � b. Second, on April 21, 2014, the City Council approved the preliminary plat for the 2�4 Roseville Housing and Redevelopment Authority/Greater Metropolitan Housing 2� 5 Corporation joint redevelopment of the former fire station site on Dale Street. In 2� 6 addition to creating 24 lots for one-family, attached dwellings in townhome/row 2� � house formats, this plat creates 11 lots designed for development of single-family, 2� 8 detached dwellings which confarm to the MDR district's minimum lot standards for 2� g such units but which are substandard to the requirements in § 1103.06. Here again, the 22o action of the City Council leads to the conclusion that the provisions of § 1103.06 do 22 � not apply to all lots intended for development of single-family, detached homes. 222 While this most recent action by itself does not confirm that the minimum lot size 22s standards of the Subdivision Code only apply to the LDR-1 district, this City Council 224 action does depend on a nuanced interpretation of the intent of the subdivision text 225 rather than a strict reading of the text as written. 226 227 228 229 230 231 232 233 r �� 6.8 Based on the above examples, Planning Division staff believes there is an ability for the City Council to approve the original proposal for the creation of single-family lots that are smaller than the standards identified in § 1103.06 of the City Code but exceed the minimum requirements for single-family lots in the LDR-2 district. Rezoning to LDR-2 notwithstanding, however, the applicant has followed the guidance of the City Council and prepared a quick revision of the proposed plat with seven lots that conform to the current LDR-1 requirements; the revised preliminary plat is included with this RCA as Attachment H. Given the constraints of limited time and significant expense, the engineering details (e.g., grading, storm water, etc.) have not yet been prepared. Even if PF14-002 Prelim RCA 051514.doc Page 6 of 8