STAFF BRIEF. Valerio Dewalt Train Associates Paradise Investment Properties Kairori Residential

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1 Cmmunity Planning and Develpment Denver Landmark Preservatin 201 West Clfax, Dept. 205 Denver, CO p: f: STAFF BRIEF This dcument is the staff s cmparisn f the Secretary f the Interirs Standards fr Rehabilitatin, Design Guidelines fr Denver Landmark Structures and Districts, the Landmark Preservatin Ordinance (Chapter 30, Revised Municipal Cde) and ther applicable adpted area guidelines as applied t the prpsed applicatin. It is intended t prvide guidance during the cmmissin s deliberatin f the prpsed applicatin. Guidelines are available at Prject: Bell Twer Develpment LDDRB Meeting: February 7, 2019 Address: 1300 Walnut Street Staff: Brittany Bryant Year structure built: n/a vacant lt (Perid f Significance: ) Applicant: Valeri Dewalt Train Assciates Paradise Investment Prperties Kairri Residential Prject Scpe Under Review: Discussin Item Mass, Frm, & Cntext discussin fr a new 375 residential twer Staff summary: The prpsed infill building will be lcated n the triangle parcel defined by Cherry Creek, Speer Bulevard, and Market Street at the edge f the Lwer Dwntwn Histric District. The parcel is within the 4 th Special Review District (SRD) sub area 01 and is defined as an Histric Urban Edge District (HUED). Develpment within the 4 th SRD is intended t serve as a gateway, transitin, and cnnectin t Lwer Dwntwn, Cherry Creek, Speer Bulevard, and the Auraria Campus. Within the 4 th SRD, this blck is unique as the nly site bisected by Cherry Creek, ver-laid by the Muntain View Crridr, the site f Denver s Old City Hall, and adjacent t Larimer Square. Only the Bell Mnument, at the crner f 14 th Street and Larimer Street, remains f Denver s Old City Hall, prviding the namesake fr the site. Due t the unique circumstances f the site, a Planned Unit Develpment (PUD) and guidelines specific t the 4 th SRD were develped in 2006 t guide develpment n the site. Per the PUD, the site may be develped via tw distinct ptins: Optin 1 allws fr a tall twer with limited ft print n sub area 01 and a smaller, lwer scale cnnecting/transitinal building n sub area 02. The applicant is pursuing this ptin. Optin 2 allws fr develpment that fllws the requirements f Lwer Dwntwn Histric District. The 4 th Special Review District Graphic Guidelines: Histric Urban Edge District in the Lwer Dwntwn Histric District (2006) states that the Lwer Dwntwn Design Guidelines shuld nt be used fr the twer typlgy, therefre the LDDRB will need t evaluate the Twer develpment n sub area 01 with cmpliance t the fllwing dcuments: Planned Unit Develpment #597 Bell Twer (2006), and 4 th Special Review District Graphic Guidelines: Histric Urban Edge District in the Lwer Dwntwn Histric District (2006). Within the 4 th Special Review District Graphic Guidelines: Histric Urban Edge District in the Lwer Dwntwn Histric District (2006) the fllwing Design Principals have been identified fr the site: Recgnize the respnsibility f develping the site t take advantage f its unique characteristics: Its lcatin as an imprtant gateway t Dwntwn and LD and as a western terminus t Furteenth Street. Its prximity t bth Larimer Square and the histrically redevelped LDHD acrss Furteenth Street

2 Its diagnal bisectin by Cherry Creek (the nly such site) Its histric significance as the site f Denver s Old City Hall and lcatin n Cherry Creek and the Old City Hall View Plane Its presence n histric Speer Bulevard Expand the cncept f Bell Park as a unique urban pen space pprtunity by extending the existing pen space f Larimer Square dwn t Cherry Creek, thus creating a majr public creekside place cnnected t the existing park t the east f Larimer Street and ultimately t a new Auraria campus space and cnnectin t the suth. Maximize the pprtunities fr visual and pedestrian cnnectins between the site and Dwntwn, sites within the LDHD, Larimer Square and the Auraria facilities n bth sides f Speer Bulevard and Cherry Creek. Prvide pprtunity fr develpment f the site by alternative means: Sub Area 1 By wrking with new special review district guidelines which permit a single building f greater height, limited ftprint and specific lcatin, all as defined in the prpsed PUD. The design f this building shall minimize visual bstructin tward the suth, west, and nrthwest and shall include substantial landscaped pen space as defined in the guidelines belw. Sub Area 2 Prvide a cnnecting building with active street level and pen space frntage at the crner n 14 th Street and Larimer Street New develpment in Subareas 1 and 2 shuld maximize reciprcal architectural and design pprtunities at the pedestrian, vehicular, and urban scales t mark and emphasize the site s imprtance as a gateway int Lwer Dwntwn and a transitin frm brad landscape f the Auraria Parkway and Speer Bulevard int the mre urban streetscape f Lwer Dwntwn The lwer level f the building, at a pedestrian scale, shuld maximize transparency. Visual cnnectins thrugh the building t the pen space, the creek and lwer dwntwn are encuraged. In 2008, a prpsal fr a twer and lwer scale cnnecting building n the site was reviewed by the Lwer Dwntwn Design Review Bard. The Bard asked fr a restudy f the twer massing and frm, althugh the verall scale was apprved. The 2019 prpsal fr sub area 01 has substantially different massing frm the prir submittal and therefre will be reviewed as a new submittal. On January 10, 2019, a Cncept meeting was held with the City s Develpment Services team, and listed belw were sme f the fremst cmments discussed with the applicant in regard t the prpsed design. The applicant will be required t mdify the submittal prir t resubmitting the plans fr anther Cncept review. Only ne driveway curb cut n Market St. serving the residential twer is apprved. The prte-cchere is nt permissible as it results in a secnd curb-cut and is gemetrically nn-cmpliant with CCD driveway standards (driveways must be within 10 degrees f perpendicular alignment t the street, and must include 20 feet f tangency). In additin, the curb-cut must be aligned (r sufficiently ffset) frm the 14th Curt alignment n the west side f Market St., in accrdance with CCD Std. Drawing 6.3. All curb cuts must cmply with that standard. Additinal crdinatin is required with the city t determine the impacts f the Cnnecting Auraria bnd prject, which includes replacement and widening f the Larimer Bridge ver Cherry Creek. This prject may result in right-f-way (ROW) dedicatin alng the Larimer frntage fr bth the residential (twer) and ffice parcels, and may have ther impacts n the streetscape design. Any abve grade r subsurface encrachment int the ROW is subject t the Public Wrks encrachment rules. The subsurface parking structure is a Tier 3 encrachment requiring City Cuncil apprval. Bth the City s Transprtatin and Frestry Departments d nt supprt the subsurface encrachment t the extent prpsed within the ROW. Varius technical requirements infrm the allwable encrachment, including the need t ensure the successful planting f street trees, and knw existing r future utility needs, r ther ROW requirements. A minimum 8-ft wide detached sidewalk and 8-ft wide tree lawn per CCD Std. 5.0 are required alng each f the fur street frntages f this prject. All lading shall be shwn n the Zne Lt and prvide fr an area f means f adequate maneuvering fr ingress and egress entirely within the zne lt bundaries. Backing t r frm a public ROW fr lading maneuvering is prhibited.

3 All existing public right f way trees in Speer, 14th, and Larimer ROW s are under the jurisdictin f Frestry Operatins. The Office f the City Frester requires preservatin f existing trees within all public rights f way. The applicant shuld assume trees in these lcatins will be required t be retained and prtected thrugh the entire duratin f the prject unless authrized remval is granted by this ffice. The LDDRB shuld prvide feedback n the preliminary design f the massing, frm, and cntext specifically regarding: Setbacks Open space Building ftprint Height Flr-t-flr heights Variatins in height and flr massing at the amenities level The design f the grund flr alng Market Street Cnnectin t Cherry Creek, Speer Bulevard, and the wider cntext Excerpted frm PUD 597 Bell Twer (2006) PUD Language Cmments 1. Intent Statement: This PUD permits tw distinct develpment ptins t ccur. The purpse f the tw ptins is t prvide assurance that if the prperty develps in any way ther than that described in Optin 1, then the develpment under Optin 2 is gverned by the B-5 zning district and DRMC Sectins thrugh (Lwer Dwntwn Histric District requirements. The applicant is pursuing Optin 1 utlined in the PUD. 2. Requirements Applicable t either ptin: The Cherry Creek Channel shall nt be cnsidered a break in the cntiguity f the zne lt fr these parcels. Develpment under either Optin may prceed as ne zne lt including bth parcels. Develpment under either ptin shall nt use the area f the Cherry Creek Channel t calculate density fr the flr area rati if applicable. The Old City Hall view plane shall remain in full frce and effect. If there is any cnflict r discrepancy between the prvisins f this PUD and any ther rdinance, regulatin, rule r guideline, the prvisins f this PUD shall cntrl. The PUD requires that bth structures n Sub Areas 01 and 02 be built in clse successin. The twer site may be develped first, hwever, n later than 6 mnths frm the issuance f a Certificate f Occupancy (CO) by the City fr the develpment as described abve, as Optin 1, Sub Area 01 the develper shall submit plans fr develpment f Sub Area 02 als as described in Optin 1 t the City fr review. A PUD is a custm zne district t address unique sites, r a unique prpsed develpment when standard zne districts are nt applicable, such as the Bell Twer and Bell Park site. The Bell Twer PUD is the base zning fr site. In additin t the PUD, the 4th Special Review District Graphic Guidelines: Histric Urban Edge District in the Lwer Dwntwn Histric District (2006) apply t the site. The hierarchy f dcuments fr sub area 01 is as fllws: 1. The PUD 2. The 4 th SRD guidelines

4 3. Optin 1: Sub Area 01: This ptin permits the develpment n Parcel A f a single structure (the Twer) with a maximum building height nt t exceed 375 feet excluding mechanical and architectural allwances up t 25 feet and a maximum flr plate f 7,500 square feet (exclusive f balcnies, terraces, decks, as well as ther similar exterir features alng with utdr sitting, seating and eating areas) t be cntained in the area shwn n the District Plan. The apprximate lcatin and maximum flr plate f that structure are described n the District Plan page cntained in this PUD applicatin. A single structure will be develped. The structure is prpsed t max ut the allwable building height f 375 feet. Staff are cncerned that the max flr plate f 7,500 square feet may have been exceeded. On level 1 and 2, areas f the building ft print have nt been included in the flr plate calculatin. These areas appear t be service areas; hwever, the max flr plate is inclusive f all interir enclsed spaces, Levels 1 and 2 may be beynd the buildable area as defined in the District Plan. On Level 1, prtins f the building at the suth end f the site are beynd the buildable area. It is unclear what the entire functin f these space will be, a prtin f it is identified as unenclsed utility zne and the unenclsed ramp dwn t parking level ne. On Level 2, the private terrace is als beynd the buildable area. The private terrace is lcated n a plinth, the height f which is unknwn. Hwever, staff are cncerned that these unenclsed and enclsed spaces beynd the buildable area are exceeding the intended placement f the twer n the site and disrupting the balance between building and pen space. The residential flrs abve Levels 1 and 2 are shwn t be within the buildable area and meeting the 7,500 square feet flr plate. Hwever, interir balcnies will cunt tward the FAR and shuld be included in the calculatin f flr plate. 6. Maximum Heights f Structures Optin 1: Sub Area 01: The intent f this sectin is t assure that the maximum building height shall be n mre than 375 feet f usable structure plus a maximum f 25 feet additin fr a tapered r stepped structure which may enclse mechanical equipment and acts as an identifying decrative feature. The height is further described as fllws: The maximum height f structures shall nt exceed a ttal f 375 feet. Nte: The height f a building shall be determined by the vertical distance frm the highest pint f the rf t the highest pint f elevatin measured frm either The prpsal is t develp a twer t the max building height f 375 feet. The actual height f the building, as measured frm the highest pint f elevatin t the highest pint f the rf, has nt been clearly defined and is unknwn at this time. The highest pint f the rf shuld nt exceed 375 feet frm the measuring datum line. The measuring datum line is, , measured frm the site f the Bell Mnument lcated in Sub Area 02. An additinal 25 feet is prpsed fr a mechanical penthuse. The PUD allws fr rftp features t exceed the maximum height by 15 feet.

5 Sub Area 01 f Sub Area 02, excluding any parapets, crnices, elevatr verruns, stair twers extending nt the rf, mechanical equipment r mechanical penthuses, certain architectural rftp elements r similar elements. Rftp features (such as slar cllectrs, antennas, chimneys, elevatr stack(s) flues, vents and air cnditining equipment) may exceed the maximum height f structures by 15 feet maximum. Architectural features may exceed the height by 25 feet. Staff are cncerned that the current mechanical screen is nt an architectural feature and therefre shuld be limited t 15 feet in height. It may be pssible t integrate the mechanical screen int an architectural feature, allwing it t be 25 feet in height. Additinal justificatin fr the current height shuld be prvided. Architectural features, such as a spire r ther such feature, may exceed the maximum height f structures by 25 feet maximum. Objective 3: Caring Cmmunities The Bell Park prject is charged with the demands f standing up t the legacy f the larger urban envirnment, as well as the necessity f furthering histric preservatin Instead f seeking t blend the new develpment with the ld, which cannt be replicated, the intent f the prject is t cmplement the histric neighbrhd with thughtfully cntrasting develpment strng enugh t stand separately frm the existing rich Dwntwn urban fabric. The Bell Twer site is intended t serve as a gateway t and frm Lwer Dwntwn and t the wider cntext f Cherry Creek, Speer Bulevard, and the Auraria Campus. The Bell Twer will nt replicate the massing r material cnstructin f Lwer Dwntwn; hwever, the Bell Twer shuld cmplement the Lwer Dwntwn Histric District thrugh thughtful design. Excerpted frm 4 th Special Review District Graphic Guidelines: Histric Urban Edge District in the Lwer Dwntwn Histric District (2006) Guidelines Cmments Intrductin The 4 th SRD Design guidelines mdify and expand upn existing LDHD Design Guidelines by defining parameters specifically respnsive t unique cnditins present within the 4 th SRD. Designs fr additins r new cnstructin prpsed fr parcels within the 4 th SRD shall be reviewed using these supplementary design guidelines with all cmplementary existing LDHD Design Guidelines that are nt mdified herein.prvisins verriding [LDHD] guidelines, specifically respnsive t the 4 th SRD edge cnditin, are prvided in the 4 th SRD Guidelines. Where guidelines are less specific, the Review Bard is intended t utilize greater discretin in reviewing the prpsed develpment.the 4 th SRD prvisins shall cntrl in the event f any cnflict with prvisins f the LDHD Design Guidelines and ther applicable design guidelines. Except as mdified herein, the LDHD Design Guidelines shall be in full frce and effect within the 4 th SRD. The 4th Special Review District Graphic Guidelines: Histric Urban Edge District in the Lwer Dwntwn Histric District (2006) were develped t ensure that all develpment within the 4 th SRD respnds t the unique cntext f each parcel with the HUED. The guidelines fr sub area 01 and 02 als reinfrce the requirements f PUD #597 and mdify the existing Lwer Dwntwn Design Guidelines t allw fr the twer Develpment with a limited ftprint t maximize public views, pen space, and access t address the unique circumstances f the site. The 4 th SRD guidelines n page 11 state the Lwer Dwntwn Design Guidelines shuld nt be used fr the twer typlgy

6 Mass and Scale The building mass f additins r new cnstructin shall fllw the 4 th SRD Design Guidelines specific t each Sub Area The building mass f additins and new cnstructin shall supprt the values and pririties f the LDHD in a manner cnsistent with the Visin Statement and intent f the 4 th SRD. The expressin f the verall mass frm the street shuld acknwledge and reflect significant histric characteristics as they are present within the existing LDHD. These design elements may be interpreted in a cntemprary manner. The Twer Develpment is intending t max ut the allwable height f 375 feet. Fr additinal infrmatin n hw the building mass fllws the 4 th SRD Design Guidelines specific t Sub Area 01, see cmments belw under Design Guidelines fr the Bell Park Site Optin 1. The massing f the Twer is intended t be limited t prvide maximum views, pen space, enhance the pedestrian experience and cnnectin t the Creek, Dwntwn, Larimer Square, Speer Bulevard, and the Auraria Campus. Staff are cncerned whether the fllwing elements f the design successfully achieve the gals utlined in the visin statement: The pedestrian experience n Market Street at the building entrance with the private drive aisle and recessed building entrance. The cnnectin f the building and site t Cherry Creek and the integratin f the required prmenades. The visin statement encurages building design alng these prmenades shuld weave tgether the urban cntext f pedestrian riented Lwer Dwntwn and the spatial qualities f the creek amenity, thereby making the creek integral t the experience f the histric LDHD. The slid massing f the private terrace and placement f the service/utility areas n the site, adjacent t the space required fr a prmenade. The placement f the building n the site and the disruptin f the pen space with the private terrace n a plinth, the ramping dwn int the undergrund parking, and the undefined building ft print beynd the buildable area defined in the PUD. Staff are als cncerned abut the verall expressin f the building massing, particularly viewed frm Lwer Dwntwn. Histric buildings within the District are cmpsed f a base, middle tp. The Twer massing, viewed frm Lwer Dwntwn, reads as a base, middle, tp, base, middle, tp.

7 Frm and Articulatin Additins r new cnstructin shuld be recgnized as prducts f their wn time. Scaling elements and articulatin shall relate t the typical scale and prprtins f adjacent cntributing buildings and site elements. Rf frms n additin r new cnstructin shall be cnsistent with typical rf frms f existing structures in the LDHD in terms f rf pitch, rientatin, and cmplexity. Appearance f height in stries f structures lcated within the 4 th SRD may reflect actual number f stries behind the façade. Façade articulatin and materials fr structures lcated with the 4 th SRD shall be affrded special cnsideratin relative t assciated 4 th SRD cntext. This shall include cnsideratin fr permissible departure frm traditinal LDHD cntext requirements gverning chice f primary and secndary materials; depth f recess r prjecting f windws and balcnies; prvisins f windw sills; windws prprtins; balcny size, lcatins and prprtins; and railing articulatin. The Twer has been designed t be f its wn time. It has a mdern design and will be cnstructed f mdern materials. The appearance f the height in stries will reflect the actual number f stries with the grund flr duble height. Additinal scaling elements culd be incrprated int the design, particularly at the grund flr and amenity level t relate t the scale fund within the Lwer Dwntwn Histric District. Althugh materials are nt cnfirmed at this time, the Twer will be cnstructed f mdern materials that are a departure frm the traditinal masnry materials f Lwer Dwntwn. The Twer will als have nntraditinal massing and will use balcnies t enfrce the massing. Balcnies will be interir and prjecting. The Twer will have flat rf. Additinal Cnsideratins f Building Typlgies Unique t the 4 th SRD The Lwer Dwntwn Design Guidelines shuld nt be used fr the twer typlgy recmmended in Optin 1. Building massing and prfile shuld supprt the ntin f the building as an imprtant urban crssrads and gateway marker. In rder t supprt the vertical twer as a type, the building prprtins r prprtinal system f elevatins shuld be vertical and slender. View crridrs frm Speer int the city and view crridrs frm the city t the west shuld be maximized. A twer typlgy that serves as a gateway marker shuld have a distinct figural quality. The prfile f the building shuld be cnsidered within the cntext f the surrunding buildings that make up the view crridr frm Auraria Parkway. Rf appurtenances shuld be cnsidered and cmpsed as an extensin f the elevatin and massing and shuld reinfrce the figural quality f the building rather than appearance as unrelated additins. The Lwer Dwntwn Design Guidelines will nt be used t evaluate the apprpriateness f the Twer Develpment, hwever, the visin statement fr the 4 th SRD states the built envirnment is als intended t respnd t the cntext f the bard urban frm as a transitinal and cmplementary edge t the Lwer Dwntwn District. The Twer can have a greater level f verticality in its massing and scale t reinfrce its psitin as a gateway market. Hwever, the figural quality f the prfile f the building n the surrunding cntext shuld als be cnsidered. Staff have the fllwing cncerns regarding the prfile f the building: The amenity zne between the lwer twer apartments and the higher twer apartments. The massing f the building is cantilevered and supprted by piers n this level facing tward the Lwer Dwntwn Histric District. A dramatic shift in massing f this nature that creates a significant vid with slid massing abve is nt a design element fund in Lwer Dwntwn Histric District. This mdern design feature may

8 Fenestratins systems shuld reinfrce the cncept f a gateway marker. Cnsideratin shuld be given t the qualities f the fenestratin during the day and night. The scale f fenestratin, the materiality and the level f detail shuld acknwledge the unique ways in which the building is perceived especially as it relates t vehicular traffic. be mre apprpriately riented away frm the district. The recessed building entrance behind a private drive aisle n Market Street is nt an element fund within the Lwer Dwntwn Histric District nr the surrunding cntext. Buildings within Lwer Dwntwn have a strng street presence, built at the prperty line. Buildings n the Auraria campus als have a strng grundlevel presence with minimal setbacks frm the prperty line. N private drives are seen in the surrunding cntext at the primary entrance. The flr-t-flr heights are nt prprtinate t what is fund in Lwer Dwntwn. The lwer twer apartments will have 9-8 flr-t-flr heights and the higher twer apartments will have 10-8 flr-t-flr heights. Within Lwer Dwntwn, the preference is fr the street level t be feet and the upper levels t be feet. It is als atypical t have taller flr-t-flr heights at the grund level and lwer flr-t-flr heights abve. Staff are cncerned that the prpsed mechanical penthuse will nt reinfrce the figural quality f the building design. The screen is shwn n Market Street, Speer Bulevard, and Larimer Street; the design is nt cntinued t the Cherry Creek elevatin. Additinally, per the PUD, the screen needs t be an architectural feature f the building t be 25 feet in height. Design Guidelines fr the Bell Park Site Optin 1 Sub Area 1 Highrise building design parameters: Building placement shall be limited as shwn n site plans. Additinal view plane angle beynd Old City View Plane 15 degrees minimum Building flr plate shall be limited t a maximum f 7,500 square feet exclusive f balcnies and terraces Building height shall nt exceed 375 feet with additinal 25 feet allwed fr architectural features Minimum setbacks shall be as fllws: 16 feet alng Cherry Creek wall shall be reserved fr public use as a prmenade Levels 1 and 2 may be beynd the buildable area as defined in the District Plan f the PUD and the site plan prvide n page 16 f the 4 th SRD guidelines. On Level 1, prtins f the building at the suth end f the site are beynd the buildable area. It is unclear what the functin f these space will be, a prtin f it is identified as unclsed utility zne and the unenclsed ramp dwn t parking level ne. On Level 2, the private terrace is als beynd the buildable area. The private terrace is lcated n a plinth, the height f which is unknwn. Staff are cncerned that these unenclsed spaces beynd the buildable area are exceeding the intended placement f the twer n the site and

9 Walnut Street [Market] frntage 5 feet Speer Bulevard frntage 12 feet disrupting the balance between building and pen space. The private terrace is ttally within the additinal view plane required beynd the Old City Hall View plane. City rdinances prhibit any structure frm exceeding an elevatin f plus ne ft fr every sixty feet that the structure is hrizntally spaced frm the reference pint. The elevatin f the private terrace is at , belw the required view plane. A 16-ft setback is prpsed frm the Cherry Creek wall t the unenclsed utility zne alng the Nrtheast edge f the prperty. On renderings this space is shwn t be paved public walk, hwever, the site plans d nt clearly express this intent. The setback frm the Market Street frntage t the building façade is unknwn, hwever, it exceeds 5 feet. Additinally, the grund flr is recessed further frm Market Street than the flrs abve, this dimensin is als unknwn. The entrance canpy des encrach int this 5-ft setback requirement and extends beynd the prperty line t partially cver prtins f the sidewalk/new drive aisle. A 12-ft setback is prpsed frm the prperty line n Speer Bulevard t the building façade. Sub Area 1 and 2 Open space develped in Sub Areas 01 and 02 shall be prvided and maintained in accrdance with the fllwing prvisins: Sub Area 01 Open space shall be privately wned, but shall be develped and maintained in a manner cnsistent with r exceed that f existing Denver city parks. Open space may be cnfigured in such a manner as t encurage utdr art. Sub Area 01 pen space may be secure private space, but shall be visually accessible t the public in such a manner as t permit visual cntinuity between this pen space, Speer Bulevard and pen space lcated n Sub Area 02, including the creek. Visual accessibility shall nt preclude inclusin f a fence as described under the general guidelines and such fence shall be permitted t be placed upn a structure at r within the setback line. Privately wned pen space is prvide n the Bell Twer site. The space is a mixture f a park-like space and a private terrace with a pl. Open space within this area can be secure, but it shuld maintain a visual cnnectin t the creek. The park-like space has a strng visual cnnectin t the creek. Staff are cncerned abut the private terrace. It is riented in a manner that maintains a visual cnnectin t Speer Bulevard, hwever, with its raised plinth design, creates slid massing alng the Creek edge. Staff are cncerned that visual cnnectin, t and frm, the Creek is lst. END