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Ordinance No. 92-07 i CITY OF TIGARD, OREGON ORDINANCE NO. 92-0"T AN ORDINANCE AMENDING ORDINANCE 91-22 AND APPROVING AN AMENDMENT TO THE.: TIGARD COMPREHENSIVE PLAN TRANSPORTATION MAP BY CHANGING =DESIGNATION Ox NAEVE STREET FROM MINOR COLLECTOR TO LOCAL AND BY ADDING A,MINOR COLLECTOR CONNECTION[S I FROM � 109TH AVENUE AT MURDOCK STREET TO PACIFIC HIGHWAY OPPOSITE ROYALTY PARKWAY AND ! LOCAL STREET CONNECTION BETWEEN 100TH AND 109TH AVENUES NORTH OF HOODVIEW DRIVE AND DECLARING AN EMERGENCY (CPA 91-0002) REQUESTED BY NPO #6, WHEREAS, the request is to amend the Comprehensive Plan Transportation Map as follows: 1) Change the designation of Naeve Street from minor collector to local. 2) Add an extension of 109th Avenue between Murdock Street and Pacific Highway and designate 109th Avenue between Canterbury Lane and Pacific Highway as a minor collector. 3) Add a local street [minor collector] connection between 100th and 109th Avenues at a location north of Hoodview Drive. 9 WHEREAS, on December 17, 1990 the City Council authorized NPO JJ6 to initiate consideration of a Comprehensive Plan amendment focused on transportation issues in the area of 109th Avenue and Naeve Street. WHEREAS, NPO #6 has developed a proposal to address traffic concerns in the Little Bull Mountain area. WHEREAS, the Planning Commission heard the CPA 91-0002 proposal at its regular meeting on July 22, 1991 and recommend[s]ed approval and also recommend[s]ed deleting the last sentence of note 10. WHEREAS. the City Council adopted Ordinance 91-2.2 on August 13. 1991, approving CPA 91-0002. WHEREAS the Comprehensive Plan Transportation MaF amendment was annealed to the Oregon Land Use Board of Anneals (LUBA) ` LUBA Nos 91-133 and 91-137. ' WHEREAS. LUBA remanded the decision: to the City for reconsideration on January , 28. 1992, NOW THEREFORE, THE CITY OF TIGARD ORDAINS AS FOLLOWS: SECTION 1: The proposal is consistent with all relevant criteria as noted below The relevant criteria in this case are Statewide Planning Goals 1, 2, 5. 9 Economic Implementation Strategy 19. 12, and Tigard Comprehensive Plan policies j 1.1.1 a., 2.1.1, [and] 8.1.1, 8.1.2._ and applicable Community Development Code sections related to legislative plan amendments. The proposal is consistent with the applicable Statewide Goals based on the following findings: 1. Goal 1, Citizen Involvement, is met because the City has an adopted citizen involvement program which includes review of land use applications by ORDINANCE Nu. 92-D7 ,kk t a neighborhood planning organizations. in addition, this proposal has been reviewed in public hearings by the Planning Commission and by the City Council for which the public has been properly notified. 2. Goal 2, Land Use Planning, is met because the City has applied all relevant Statewide Planning Goals, City Comprehensive Plan policies, and Community Development Code requirements in the review of this proposal. In addition. as exRlained with reference to Comprehensive Plan policy 8-1.2, the City has coordinated its plan_with the vlanz- of potentially affected governmental units by soliciting from those governmental units comments on the proposed amendment and considering, any comments received. 3y Goal 5, Oven Spaces Scenic and Historic Areas and natural Resources is met because a. Pursuant to the reouirements of Statewide Planning Goal 5. the Citv o£ Tigard has inventoried Goal 5 resources and designated in its Comprehensive Plan those Goal 5-resources that it has determined to be significant (Comprehensive Plan Vol I pp, 94-109.) The City's Comprehensive Plan including its Goal 5 provisions were acknowledged by the Land Conservation and Development Commission on October 11 1984. b. There are two designated Goal 5 resources that are within the vicinity of the streets that are the subject of the proposed comprehensive plan amendment: the Little Bull Mountain Natural Forest and the Kall.strom Fir Grove aerial photograph Exhibit A) The precise locations of these resources were confirmed by the city's planning staff by comparing the descriptions of the resources in the comprehensive plan with aerial Photographs and observations from the ground. No other designated Goal 5 resources are potentially affected by the Posal._ The "summit of Little Bull Mountain" is mentioned as a "special area" and an area of scenic value in the city's natural Features and Open Space Comprehensive Plan Report (See Comprehensive Plan Vol. I. P. 42) The summit area of Little Bull Mountain. however. was not identified as a significant Coal 5 resource with the exception of those resources included within the designation of the Little Bull Mountain Natural Forest Therefore Goal 5 is not applicable to the general discussion of the Summit area in the natural Features and Open Space Comvrehensive Plan Report Moreover, even were Goal 5 applicable there is no credible evidence that any of the asserted Goal 5 resources of the summit of Little Bull Mountain would be adversely affected by the_proposed plan amendment. c. The Comvrehensive Plan identifies the Little Bull Mountain Natural Forest as an area of mature coniferous trees on the west side of Little Bull Mountain (Comprehensive Plan Vol. I. P. 96.) The forest was designated as a Goal 5 resource because it was determined to be "an outstanding scenic site." (Id ) The Comprehensive Plan explains that the scenic value of the site stems from the visual landmark provided by the large stand of mature coniferous trees at an elevated location within the City. d. The prop sed comprehensive plan amendments do not adversely affect the Little Bull Mountain Natural Forest. The forest is located on the west side of Little Bull Mountain As shown by Exhibit A and the relevant -planning maps and the documents descr'.b1"K'g the proposed street alignments the proposed local street connection between 109th ORDINANCE No. 92- U-J Avenue and 100th Aye mg lies entirely oji the east side of Littl2 Bull Mountain, Thus theproposed c pnection would not travel through the forgst or impact the integrity of the forest. Moreover, because the f orest is elevated, because of the topography_of the area, because o the low relief of the connection. and because few if any trees will be removed the connection would not interfere with any scenic views of the forest. A. Similarly, as shown by the relevant planning maps and the documents describing the proposed street alignments, the proposed extension and realigMent of 109th Avenue lies entirely to the east and south of the forest Moreover at its northern end in the vicinity of the forest., theRroposed location of 109th Avenue is within its existing night-of- way, Thus. the extension and realignment would not travel through the _forest or otherwise impact the character of the forest. And. again. because of topography and the low relief of the street facilities constructed as a result of the extension and realignment, the extended and realigned street would not interfere with any scenic views of the forest For the same reasons, My change in traffic patterns or volume caused by the proposal. including street reclassification, would not interfere with the views of the forest f. The little Bull Mountain Natural Forest is designated as a Goal 5 { resource solely for the scenic values provided by the mature coniferous trees within the forest. The forest is relatively small ? and isolated: is adjacent to a major four-lane arterial. Highway 99W: { and is surrounded by extensive urban areas that the Comprehensive Plan has designated for more intensive development in the future. The Little Bull Mountain Natural Forest is not designated as a significant wildlife habitat area and wildlife within the forest was found to be limited to small birds and animals (Comprehensive Plan. Vol. 1. p.96). n h� s gz The Kallstrom Fir Grove is a row of mature Douglas fir trees located adjacent to 100th Avenue in an existing residential neighborhood. The ,grove is designated as "a significant Visual and Natural resource. (Comprehensive Plan Vol. 1. p. 106.) These resources stem from the visual landmark provided by the Douglas fir trees, which are described as "the only major stand of Douglas Firs on the south side of Little Bull Mountain.- The only potential conflict that the Plan identifies with surrounding land uses is the possibility that the trees might be cut down to make way for future development. (Id.) h. The proposed comprehensive plan amendment could only have an adverse effect on the scenic and natural values of the Kallstrom Fir Grove if the proposed east-west connection between 109th Avenue and 100th Avenue reguired the trees to be cutdown or otherwise damaged the trees As shown on aerial photographs and by testimony at the hearing the grove is an east-west row of trees that would parallel the proposed connection Although the proposed plan amendment does not specify the precise location of the future connection. Exhibits A and C. as well as testimony at the hearing. demonstrate that the future connection will lie within an area entirely outside the grove and that the future connection can be located so as not to require cutting or damaging_the Grove. There is ample room to place the proposed connection up to several hundred feet from the grove and at a sufficient distance to prevent damage to the trees or interference with their scenic value. No other natural or artificial features would constrain the location of the proposed connection within the ORDINANCE No. 92-0'7 r } area designated, i, Finally, even if, contrary to these fir�dinEs ttae propos®d ramendmgnts to the transportat on plan were in conflict with the Little Bull Mountain Natural Forest or the Kjllstrom Fir Grove the conflict would have been anticipated and resolved by existing provisions of the Comprehensive Plan. All of the meas included in the Little Bull kjountain Natural Forest and the Kallstrom Fir Grove are designated b the Comprehensive Plan for future residential develo ment -Viae Plan's Goal 5 analysis notes that future development may create conflicts with these designated Goal 5 resources, (see Comprehensive Plan Vol 1. pp. 96-97. 106-107) and resolves the conflict as follows: "The significant wooded areas are identified and mapped. The Rolicy of the City's comprehensive plan is that these areas will be preserved in a natural state as much as possible or integrated into the design of any development-� i.e. , parking lot island. building setbacks, street rights- of-way and landscaping areas whenever possible. If it is necessary to remove a Rortion or all of the trees, the replacement landscape features shall be subject to approval by the applicable approval authority." [Comprehensive Plan. , Vol. 1, p. 95.E The Plan expressly requires that "development proposals in designated timbered or tree areas be reviewed through the planned development process to minimize the number of trees removed." (Plan Policy 3.4.2.b.) Moreover, even with respect to devel2nment proposals that are not in designated timber or tree areas. the Tigard Community Development Code (TCDC) requires all new developments and major modifications of } existing developments to undergo site development review. See TCDC 18.120.180.A.1.1. These provisions require, among other things, that the tree removal be necessary and that the tree removal will not adversely affect the aesthetic character of the area. See TCDC § 18.150.030.A. S k The City's acknowledged Comprehensive Plan thus expressly anticipates that development, and in particular residential development and associated roadways, may create conflicts with the designated Goal 5 resources in the Little Bull Mountain natural Area and the Kallstrom Fir Grove. Foliowina the required Goal 5 analvsis. however. the Plan chose not to absolutely protect these resources but to conditionally protect them by requiring scrutipy of development proposals to ensure that the number of trees lost through development was minimized. For these reasons even if contrary* to the findings above the proposed amendment adversely affected designated Goal 5 resources, the existing Comprehensive Plan has anticipated and resolved any such conflicts through the Plan and TCDC provisions regulating tree removal. 4 Goal 9 Economic DeveloRment, Implementation Strategy 19 is satisfied because: a. The plan provides alternative and enhanced access for commercial pro ep rties along the east side of 99W south of Naeve Street. ORDINANCE No. 92-0 f Cu a tl these properties which are the only commerci.A g i�dustpial areas directly affected by the plan amendment. have unsignalizgd. access to 49W The Oregon Department of Transportatign's 12011ey is to restrict direct access to 99W froom individual properties r. Under the Dlan t properties can be developed with access to 99W via the realignment and extended_109th Avenue, which wilja - ma use o the existing signalized intersection at 99W and Rovalty Par' _ ay. p� 'rhe 0raeon Department of Transportation and Metropolitan Service D strict have been notified of the ro osed amendment and have had the opo tp uni to provide input No comments were received from the Metropolitan Service District or the Oregon Department of Tra s ortatODOT) ODOT had previously contributed however, by assisting the City-in reviewing various access options in.this ares I act ODOT st ff ori inall su gated th t the Cit ex lore the option of providing access to 99W at the existing signalized intersection with Ro alt Parkwa This su estion was Ultimately incorporated into the proposed amendment. 5[3] Goal 12, Transportation, is met because the City has adopted policies related to improving the transportation network and continuing coordination of transportation improvements with other involved agencies. Furthermore the Goal is met for reasons discussed in conjunction with Economic Implementation Strategy 16 and Policy 8.1.1. g The proposal is consistent with the City's acknowledged Comprehensive Plan based on the following findings: 1. Policy 1.1.1 a. is satisfied because the proposed amendment to the 3 ect compliance of the City's acknowledged Comprehensive Plan will not aff Plan with the Statewide Goals. 2, policy 2.1.1 is satisfied because Neighborhood Planning Organization #6 and #3 have been notified of the hearing and have commented on the proposal and a public notice has been published including the date, time and place of the hearing. 3. Policy 8.1.1 is satisfied because the proposed amendments to the t Comprehensive Plan Transportation Map plan for a safe and efficient street and roadway system that meets current and future needs. A safe and efficient transportation system'is provided because: provides for current needs and is also planned A. The. ro osed amendment to accommodate traffic growth anticipated as a result of future in the Ian amendment the develo meat in the area. In develo NPO relied on traffic ro'ections based on full develo merit of the area in accordance with existing zoning_ b. The l_an provides for access to the arterial street s stem for both existin and future devela meat. It also provides for circulation within the neighborhood without using the arterial street system. c. The tan was coordinated with the Fire District and the Police Department to assure that the plan provides adequately £or ewer eg ncv_ vehicle access routes d. The plan eliminates the need for left turns at the existing intersection of Naeve Street and Hi hwa 99W therebv reducing the ORDINANCE No. 92-b7 i f safety concerns associated with the existing_ unsienalized intersection. The plan also eliminates the future need fora traffic signal on 99W at Naeve Street Reduction in the need for signalized intersection on 9gW is consistent with ODOT's standards for improyine and Rrotecting the efficient movement of traffic on 99W as an Access Oregon Hi� away; e. Other locations were explored _in coordination with the Oregon Department Of Transportation (ODOT) for access from the study area to 99W. The Royalty Parkway connection shown in the plan which was originally suggested by ODOT and which is already a signalized intersection, appears to have the fewest traffic safety_ and traffic operations concerns of all available locations. j f Concerns were expressed at the hearing regarding the suitability of soils alone the planned street routes. The Comprehensive Plan j designates this area for residential development including roads to serve the development The Comprehensive Plan does not suggest that the soils of this area are incapable of supporting roadways intended 1h for residential traffic because of soils ^sones or other conditions The Council-does not find that the concerns which were unsupported by any expert testimony or documents are warranted and concludes that the proposed streets can be constructed in accordance with the proposed Dlan amendment. Moreover, thee concerns are addressed at the development stage through the street standards of the comprehensive plan and community development code Z, The plan provides alternative access for commercial properties along the east side of 99W south of Naeve Street which presently have access only to 99W. Reduction in the need for direct driveway access to 99W is consistent with ODOT's standards for improving and protecting the efficient movement of traffic on 99W as an Access Oregon Highway. h. The plan reduces the potential for through traffic in existing residential neighborhoods. i. The Transportation Map does not address the schedule for construction of the various improvements indicated on the map Implementation will depend on where and when land development occurs and on the availability of public funding for capital improvements Off-site roadway improvements are considered as part of the development review process for land development projects and appropriate conditions of development are ordered for each project Public review and appeal processes have been established as part of the development review process in the City._ Priorities for funding of public projects are established annually by the City Council based on recommendations of the Budget Committee and the Transportation Advisory Committee. Moreover. the Council finds from the evidence Dresented that the timing concerns are unwarranted The proposed plan amendment does not generate or introduce any new traffic within the area: it simply reroutes traffic within the area. The proDosed future connection between 100th and 109th will provide an additional route for traffic that would otherwise use parallel local streets that already connect or are planned to connect 100th and 109th Similarly, the extension and realignment of 109th will redirect_traffic from existing and planned residential developments along 109th away from adjacent residential neighborhoods and onto 99W. ORDINANCE No. 92-017 Udings for a llocgl stree connection between 109th and 100th: J. $a futur.2 developmeng w th 4-1— street street connection is needed between 100th Avenue and 109t16 Air, to ' minimize the tXaffic i_mnactson existing east-west_residential streets. The projected traffic volume of the proposed street connection is in the middle of the range for local streets- as suggested by the backkgjoun jdocuments o£ the Comnrehe siyg Flan (700 vehicle trips nex dgv projected- ranine is 0 to 1500 trips per day) The proposed street cQnnection is intended only to relieve traffic volumes on adjacent local streets. The proposed street connection will not generate or introduce additional traffic within the area. 1 The general location shown on the plan is the only location available using undeveloped properties m,- To minimize traffic safety and operations concerns along S.W. 100th Avenue the City Engineer has recommended that the intersection of LX1 new street with 100th Avenue be aligped with existing Sattler Street or, alternatively that the intersection be located at least 100 feet from the existing intersection with Sattler Street, 4 Policy 8.1.2 is satisfied because: a, The Oregon Department Of Transportation and Washington County were notified of the proposed Comprehensive Plan Transportation Map Amendment in June 1991 The City received no formal response from either agency_ Washington County's Dolicy is not to comment on street issues in this area of the City, The City however, has gorked with ODOT to coordinate the plan amendment with ODOT's standards and policies for Highway 99W. In original deliberations for a development in the vicinity. ODOT suggested moving the connection with Highway 99W from near Beef Bend Road to the existing signalized intersection at Royalty Parkway. The Metropolitan Service District was also notified of the eroposed amendment. The director of the Metro Transportation Department has responded by telephone that Metro is concerned with issues of regional significance and since this amendment involves only minor collectors Metro has no objection King City has reviewed tha plan amendment and has notified the City that it supports the amendment. SECTION 2: Certain procedural objections were raised at the March 10 he-Axing- First, earingFirst there was an objection that the proposed elan amendment had been revised following the remand from LuBA, and that revised proposals are required to be reviewed by the Planning Commission prior to action by the Council The Council denies this obiection. Under Tigard Community Development Code section 18.3.0.130.D the Council has the authority_to adopt modifications to legislative proposals approved by the Planning Commission Moreover, the objector did not specify in what way the objector was prejudiced by any failure to rerand the plan amendment to the Planning commission. b. Second there was an obiection that inadequate notice was provided of Cf changes in the Droposed plan amendment and of the map showing designated Goal 5 resources The Council denies this objection. The. y ORDINANCE No. 92-07 Council finds that a good faith attem t was made to notify all persons entitled to notice. In addition, t e Council speci£icall finds that ..__ .. : M ... ones vvLi .�cto.rwas notified uo later tan Pobruar 5 of t e c an es in the Rropasad plan amendment following the ram-and.. from LUBA. n Furthermore, the objector did not specify in what respect it was � pre udiced by any inadequate notice or otherwise justify the need for a continuance. CTION 3: The City Council hereby amends the Comprehensive Plan Transportation Map by 1) designating Naeve Street a local street, 2) establishing a new extension for 109th Avenue from its current terminus south of Murdock Street to Pacific Highway; the extension would curve across the south slope of Little Bull Mountain, crossing Naeve Street west of The Fountains condominiums and meeting Pacific Highway opposite the existing intersection of Royalty Parkway, 3) designating 109th Avenue as a minor collector between Canterbury Lane and Pacific Highway, [and] 4) establishing a logal rnew minor collector street, to connect between 100th and 109th Avenues at a location north of Hoodview Drive,. and 5) add Comnrehansive Plan Transportation May Notes #9 and #10. as shown in Exhibit h i� _s SECTION 4i„ AAnemergencyemergency ++ctnby declared. to exist inasmuch as it is necessary for the health, safety and welfare of the City that this ordinance be enacted a soon as possible; therefore, this ordinance shall become effective upon its signing by appropriate authority. PASSED: By U Oa- ttMDAID vote of all Council members present after being read by number and title only, this LI:L-14 day of 1992. Catherine Wheatley, City Reco6der APPROVED: This a day of �-m��' 1992. Mayorv AR as 'to fo C rovedty Atto COuncit 1AJ5id-en+ JA/CPA91-02.OAD ORDINANCE No. 92-Di- X '•7` 1+ ' �r 1 µl., y. y; ',�!�. C.'�?. �r.'a, � t ,.��,�y�.' :�� ��' �.. y tgM ��•'4 �' fY k t1 7t i,..,# ��r r ,�a�ip' �y`��yr d , ! ';- '�ti�Stil(�i��.�+ �- � ti!F li���ll%.;�' �• '. � '�. �is•j,"� 3'E � .}`',iry' *",rk Y° � •kt°1ih�.+ .�°� t\'a E" •.1 `tT" �4��y'«t'I �, � i� �,,��r���4 a ��t y* _� j _ .. + >' * '7 e .. "fit • - '.`a •4 :s� as `k`s "��• �. Q} { .4 .iT`.- +n �S�R"c+ �.ad � � :�s*"-w�� jj'���j$j�.�' a. ,t ��� �. 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'S` i .' �` � � y„ ��.Nyyta_t®r.".'"fit «,i f !t•'r�i � 5,:•'�•„al _ J�..+�"r83F,� � c A -� r - A All" �.:_ •I -r C CO E-+ Q4 I c; 1 1 Ii1, 1 97TH AVE Cy s _-_-----_ -------- o o CY rn LLJ LL C� Z 4 1 COMPREHENSIVE PLAN TRANSPORTATION MAP NOTES 1. Scholls Ferry Road to be realigned to connect with Davies Road. 2. Study area to determine a future connection between the Walnut/132nd intersection and the Gaarde/'121 st intersection. A major collector extension of Gaarde Street has been recommended by the Northeast Bull Mountain Transportation Study Report. An indirect connection of minor collectors has been recommended by NPO #3. 3. Approximate alignments are shown for the extensions of 132nd Avenue south of Benchview Terrace, 135th Avenue south of Walnut Street, and Benchview Terrace west of 132nd Avenue. These streets are to be designed as minor collectors with a design speed of 25 m.p.h.. 4. Study area to determine the configuration of a new connection between southbound Pacific Highway and Main Street. 5. Study area to determine the alignment of a minor collector street connecting 68th Parkway near Red Rack Creek with the Dartmouth Street extension; and with Hampton Street at 72nd Avenue with the Dartmouth Street extension within the westerly portion of the Tigard Triangle. E. Study area to determine the alignment of connections between Highway 217, Kruse Way, 1-5 and the Tigard Triangle. 7. Connections between Hunziker Street, Hall Boulevard at O'Mara Street (generally) and Bonita Road. 8. Study area to consider extension of Hall Boulevard southward to connect with Boones Ferry Road in Tualatin for either pedestrian.or vehicular access. 9. (Deleted) 10. An extension of Sattler Street from 100th Avenue to 109th Avenue intersecting 100th Avenue at a point approximately 200 feet north of the existing Sattler Street intersection. An extension and realignment of 109th Avenue south of the Sattler Street extension, to intersect Pacific Highway at Royalty Parkway. The realigned 109th Avenue shall intersect Naeve Street at a point approximately 250 feet to 450 feet east of Pacific Highway. The design of the Sattler Street extension may vary from the adopted City standards for minor collectors. MP1091ST.PER k © � COS '� Cif ti=• .,.s .A p . � " h�+®1 pa n> a. On C a i 9TH AVE i (� LAJ r n <, mLi LLJ Z i I � Q /r � C i C i 4 4 4 4 f 4 f �r i COMPREHENSIVE PLAN TRANSPORTATION IMAP NOTES _ { ;l 1 Scholls Ferry Road to be realigned to connect with Davies Road. a future 2. Study area to a'etaro�io��¢ A .�...... connection between the Walnut/132nd - intersection and the Gaardel121 st intersection. A major collector extension of Gaarde Street has been recommended by the Northeast Bull Mountain Transportation Study.Report. An indirect.connection of,minor collectors has been recommended by NPO #3. 3. Approximate alignments are shown for the extensions of 132nd Avenue south of Benchview Terrace, 135th Avenue south of Walnut Street, and Benchview Terrace west of 132nd Avenue. These streets are to be designed as minor ' collectors with a design speed of 25 m.p.h.. 4 Study area to determine the configuration of a new connection between southbound Pacific Highway and Main Street. 5 Study area to determine the alignment of a minor collector street connecting 68th Parkway near Red Rock Creek with the Dartmouth Street extension; and f with Hampton Street at 72nd Avenue with the Dartmouth Street extension within the westerly portion of the Tigard Triangle. 6. Study area to determine the alignment of connections between Highway 217, Kruse Way, 1-5 and the Tigard Triangle. 7. Connections between Hunziker Street, Hall Boulevard at O'Mara Street (generally) and Bonita Road. ._ i 8. Study area to consider extension of Hall Boulevard southward to connect with Boones Ferry Road in Tualatin for either pedestrian or vehicular access. # 9. A local street connection from 100th Avenue to 109th Avenue intersecting 100th i Avenue either at Sattler Street,or at a point at least 100 feet from the existing i Sattler Street intersection. 10. An extension and realignment of 109th Avenue south of the Sattler Street extension, to intersect Pacific Highway at Royalty Parkway. The realigned 109th Avenue shall`intersect Naeve Street at a point approximately 250 feet to 450 feet east of Pacific Highway. t mp109.per z