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MIXING FACTS WITH SUBJECTIVE INFORMATION ~',Aany staff reports share the common prob-- lem of mixing factual information with sub- jective information. ]'he excerpt below, taken From the findings section of a staff report, illustrates this shortcoming typical of many reports: the report drafter has intermingled statements of fact with subjec- tive assessments, analysis, and common- taw that seems to contain recommended conditions for approval. Taken on its face, such language would make it difficult for both the applicant and the commissioner to know what action he ar she could or should take. Fha property is designated SRt sing(e-famd¥ development in the 2. OLD Plan but there is no opportunity for a roaq connection tn either INesbittl or [Maple Avenue]. There nave been several non-residential development inouiries for this site but no application for these has even been submitted. The proposed condo- minium deve~qpment could be aa acceptable use if the proper protections for adiacent prop- arty are incorporated and if hi§h-quality devel- opment standards are met. In this example, the fact presented is: "The property is designated SRz sin§lo-family development in the 2OlD Plan ..." The analysis presented is: "no opportu- pity for a road connection." And the language that could constitute either analysis or a recommendation, includes: "condominium development could be ~n acceptable use," "proper protections for adiacent property," and "if hi§h-quality devel- opment standards are met." It would take the reader several passes at the text to separate these elements. The upshot is that findings of facts, staff analysis, and recommendations should each be pre- sented in separate sections of the report, with each highlighted by a heading. EXCESSIVE DETAIL OR INADEQUATE DETAIL Planners who prepare staff reports often unwittin§ly provide excessive information in an attempt to §ear the report :o all audi- em:es and to ,:over all bases of potential inquiries from commissioners, applicants, and other users. Too much detail makes ,'.he report, Which the members of the decision- makin§ body often read :-hortly before the ,)u0lic mae[in§, hard to fathom. Far axam- i)i~::, ,n JOlne 5toff .'eoor[s Ala~ reviewed. Ne ~olinn ha[ ..)Die.C ,)1 e~lSlefeu 1]ali receipts were included, when simply a list- in§ of the addresses from which receipts had been returned (or not returned) would have sufficed. In contrast, many reports'bften leave out vital information that c'outd.have a bearin§ on a planning commissioner's d(~ci- sion to approve, deny, or conditionally approve a development project. This was the case where either a particular reviewing agency, such as the engineering depart- ment, had not provided comments, or a particular requirement of the application had yet to be completed (e.g., "Petitioner must provide a Master Drainage Plan."). With the former, such omissions make it difficult for the reader to discern if a Ideally, any standard requirements to which the developer will need to adhere should be addressed in a preapplication conference. reviewing agency had indeed ~eviewed the proposal and determined it to have r{o effect on'its interests [e.g., school district) or if they had reviewed it but had yet to provide comments for inclusion in the staff report. Thus, inadequate detail leaves questions hanging that may delay resolution of the approval or suggest that local government agencies are failing to complete timely and thorough reviews. UNCLE. AR LANGUAGE Staff reports sometimes contain unclear lan- 3ua§e that makes it difficult for the applicant or the reviewing body to decipher exactly what standard is being applied or what action will be necessary to address the concerns raised in the report. The recommendations must provide dear guidance on wi~at aspects of the proposai need to be revised, .]nd bV what date, for the proposal to ne considered for approval. In the example be'iow, the unclear tan§uage appears ;n italics, iust what exactlv is expected of the ioDlicanr in ;his .:3se." Landscapin§: No'preliminary landscaping plan has been pro- vided with the Communib/Conference applica- tion. It is li~ely that the plant materials chosen will be those that blend and complement those used with the ~aple Street t 8uiidin§ (Phase ~). Along the south side of the parcel is a Lineal planting strip comprised of coniferous trees (pines and cedars) and some deciduous trees mixed in .... Care should be taken to see what could be done to preserve this lineal groupin§ of trees. A fair amount of existing landscapin§ in north and south parking- lots will be eliminated tn order to construct the new office building and parking structure. Perhaps some of the landscaping that is currently in place c¢n be reused or salvaged. [emphasis suppliedl Many staff reports intermingle or in some cases confuse standard requirements, as con- tained in the development code, with com- ments or conditions for approval. Ideally, any standard requirements to which the developer will need to adhere should be addressed in a p~'eapplication conference. Thus, if one of the conditions of approval in the staff report is the submission ora specific pian (e.g., a drainage plan), document, or other needed drawing or data that technically should have been included as pad: of the initial application but was not, then the application is in effect incomplete and is not ready for review by the planning commission. One could argue that 'inclusion of language describing such boiler- plate requirements in the staff report serves simply as a reminder to the applicant that additional pape~vork is stiil needed and to the commission that the requirement has ,not been overlooked by planning staff. The problem, however, is that the planning commission is perhaps being asked to make a decision on an application with vital information still pending. In the 'staff report excerpt below, items ~., fl, and 8 are clearly standard requirements that should have been addressed by the applicant prior to the staff report's comple- tion. One wonders how the application got this far into public review without the require- ments having been satisfied. Item 7 might be an initial submission requirement, or it might be Ieft to ~.he developer's [ater discretion. Comments on a PUD application by Public 'Norks Department t. A ;ire ,Jrainag'e plan is required. z. A: ft. no-access easement witl be required ainu8r iLove!¥ Lakes Road! and [P/anatown ,.ekes Parkwavi 5inca ail direct access nontd :nme ¢rom the new ouqlic cui-de- ZONING PRACTICE *¢/,ERIC.~N PL~.N NING ASSOC~ATIO N