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agenda.drac.19981008
AGENDA DESIGN REVIEW APPEALS COMMITTEE October 8,1998 4:00 p.m. Thursday Special Meeting City Council Chambers, City Hall 4:00 I. Roll Call II. Minutes (07/09/98, 09/10/98, 9/17/98) III. Comments (Committee, Staff and Public) 4:05 IV.A. Appeal -Colas Condominiums, 341-351 Park ~PP2a,~~3 _~ Avenue OO Volume Standard -glazing 9'- 12' above floor (continued from 9/10/98) IV.B. Nevin -Lot #2, SilverLode OO Volume Standard -glazing 9'- 12' above floor, OO Building Orientation parallel to street (continued from 9/19/98) ~~/~ 3-~ V. Adjourn Memorandum TO: Design Review Appeal Committee FROM: Julie Ann Woods, Deputy Director = r DATE: September 10, 1998 RE: Colas Condominiums, 341-351 Pazk Ave..--Reconsideration of Appeal from Design Standazds relating to orthogonal windows and volume standazds SUMMARY: At their July 9, 1998 meeting, the DRAC voted 2 to 2 on the proposed appeal. The motion failed; there was no other action taken on the petition. The applicant subsequently met with the city attorney regazding the action of the committee, and it was determined that they could return to the next DRAC meeting and request reconsideration. The DRAC approved a reconsideration request at the last meeting on August 13, 1998. However, the city attorney advised the DRAC that a hearing for this case would require the reposting of the property before a hearing could be held. Staff has attached the previous memo for your reconsideration and review, as well as a letter from the applicant making the reconsideration request. As attachments to this memo is "Exhibit B" which aze the same elevations previously submitted as well as a site plan. Please note that no changes have been made to the application. Staff still does not support the variance requests. The applicant has indicated that he will have more photographs of the surrounding azea at the meeting for your consideration. Memorandum TO: Design Review Appeal Committee THRU: Stan Clauson, Community Development Director FROM: Julie Ann Woods, Deputy Director ~` DATE: July 9, 1998 RE: Colas Condominiums, 341-351 Pazk Ave..--Appeal from Design Standazds relating to orthogonal windows and volume standazds SUMMARY: The applicant requests a waiver of the Residential Design Standazds related to FAR increase due to volume for glazing in the "no window" zone, for the placement ofnon-orthogonal windows between 9' and 15' above the floor plate (Standard 12). APPLICANT: Colas Investments, LLC, represented by Jan Derrington of Chazles Cunniffe Architects. LOCATION: 341-351 Park Ave. ZONING: R-6 (PUD) PROJECT REVIEW PROCESS AND STAFF EVALUATION Background: The proposed project is currently under construction and is in the process of being condominiumized. Site Description: The structures azelocated adjacent to the Roaring Fork River. Waiver Requested: Standard: "All areas with an exterior expression of a plate height greater than ten (10) feet, shall be counted as two (2) square feet for each one (1) square foot offloor area. Exterior expression shall be defined as facade penetrations between nine (9) and twelve (12) feet above the level of the finished floor, and circular, semi-circular or non-orthogonal fenestration between nine (9) feet and fifteen (I S) feet above the level of the finished floor. " Staff Evaluation: The Committee may grant an exception to the design standards if the project as proposed is found to meet one of the following criteria: a) yields greater compliance with the goals of the Aspen Area Community Plan: Staff Response: The project does not further any goals of the AACP. b) more effectively addresses the issue or problem a given standard or provision responds to; Staff Response: The waiver request does not address this criteria. c) be clearly necessary for reason of fairness related to unusual site specific constraints. Staff Response: The property is located adjacent to the Roaring Fork River, at an elevation lower than the street elevation. It is immediately adjacent to the Bibbig residence to the east and Garrish pazk to the west. The units have been sited to take advantage of the south solar aspect, and to face the river. The non-orthogonal windows aze located in the south elevation of Unit 2. The doors for each unit aze 9' tall. The applicant is also proposing non-orthogonal windows above the upper French doors that serve the ADU on the south elevation (please refer to the south elevations of Units 1 and 2). The applicant is also proposing high windows within the 9'-12' azea above plate height for Unit 1. Staff does not believe that there aze unusual site constraints that should allow these windows "for reasons of fairness." Staff does believe that the location of the site will minimize the impact of the windows, should the committee approve the variance request. Staff does not support the requested variances. Recommendation: Staff recommends that the Design Review Appeal Committee deny the waiver request, and that the FAR be calculated at 2 square feet for the azeas in the 9' to 12' "no window" zone, or that the project be redesigned to conform with the standard. attachments: Exhibit A--Original application with drawings Exhibit B--Revised drawings w~d.~a~m~.~ ~~ September 8, 1998 Julie Anne Woods Aspen Planning Department Community Development 130 South Galena Street Aspen, Colorado 81611 Re: D.R.A.C. Review of Colas Investment Protect 2 Detached Single Family Residences 341-351 Park Avenue Aspen, Colorado Dear Julie Anne, ARCHITECTUI•.. PLANNING INTERIORS As you know, we are asking for a variance to the Aspen Residential Design Standards (Ordinance 30) on behalf of the Applicant regarding some high windows in the living room of both residences. The specific regulation, number 72, ostensibly attempts to regulate volume by prohibiting the placement of non-orthogonal windows between 9ft. and 15ff. above finish floor and prohibiting windows of any sort between 9ff. and 12ff. The walls of the living rooms of these residences face south, overlooking the Roaring Fork Rives and are approximately 250ff away from the facade of a condominium complex on the other side, which is well screened by trees. The window restriction does nothing to affect the volume of these residences, but does adversely affect the ability to take advantage of the view over the top of the condominiums to Aspen Mountain, as well as passive solar considerations. Since these windows are not near to any other residences or facing a street, we do not believe the regulation is relevant to this project and its application should be waived under D.R.A.C. Standard C. In view of the fact that a similar amendment to this regulation has been recommended by the planning staff and will soon be considered by council, we respectfully request a variance be granted by the D. R.A.C. and wish to have a hearing at their next meeting on September 10, 1998, to present our case. Thank you for your cooperation in this matter. Sinc y, ~^ Ja er Derringtc Pr ect Architec nclosures w. ,~.. CHARLES CUNNIFFE ARCHITECTS 520 EAST HYMAN •_SUITE 301 • ASPEN, COLORADO 81611 • 970/925.5590 FAX 970/925-5076 -` z L 1, s ~Z 0 n "a ~v ~` a~ i, i 1-------- ~ ~ - -- I; i V ~ ~ ' l I l l I W ~ E° ~ ;'ll ;Ill ' = 3~ ;l I'll, II, '. II I ll~l'~' U ~ F ~, i i ~ , I , ~ Q '~ IIII ill I ~i' I~',i ',; ill W ~ F c I~ I Ii~I~I~ ~ 1 '@ 8 _ ~ I I I~ i 1 ~~ ~ ~ I~ I j I I i 'l I I I I!' ~ ~ I ~ ~ ~ ~ L -~ l ~ ', i '' ~ I I'~ 'I l ~ I i r--..-~-~~~ V Y~ R ~ I l l I I' i `~ it l ~l ~ ~ Ii~' y ~ ~~ < l l l i t ~ ~I I I ~. I I I I ~' i, II I 1 I ~ ~ l ~ O = 3J I I I ~~ L_______J I 1 j i I I ~i i I I I ____J I i ~ F U : A !~ ~ I ~ I ~I i II ~~ I I I ~I ~.~ ll I! W i I I I I I I W O . i ~ ?E / _ C ~_ I I I ~I I ~ ao ? sz L a I I L ~ s ~-----~ O I I I , __., F-- -~ I ' V~~_~ ~~ I ? .I ~ _~___~ _ IIIIII Bill II II _ - ~ ~~ o° w ~, _ r ~~ J M1- . 0. ~~= ~ i ~' F~ ~ ~§ V ~s ~ 9 Z ~8 ~ "s U ~ W ~~ C J U °s~ 1U ~[ ~ o°.z 0.. 0 Z }= ti W ~ o I~ w (~ ~ c ZO ~ QO 2 U ~ Y rA C Z v! d N a 0 V -. g€ v a ~~ T ~~ U s Q ~ ~a - 'A t Z ~s L , ~ i V R __ ~ ~F~ ~ ~i W ~~ ~--------'~ ~ C ~ ~~ ~ Q ~ 2 ~ o ~ w.°< ~ ~z j >o U ~ Y C Z ~ iN a O U w,,~,- O I'~ V~' ~ ~~ fl W~ a ~0 0 ~ z 1= J W v c Q 2 v W V Q S Z I1 yJ O U R ~` ~~ y s; ~~ ~~ ggJ i~ !. 0 W C ~ C < U C Z Q W aN a ~"'~ r- __ _ _. _ W_ 3 _ F ~~ W 6 9 4a~ ~ ~;~ ~~ .4 -~° ~ Vii.: ~.p y ~ ~~ a .` ~: ~ ~' 'F s ^Q 4+ • y ~ t. ~ A. sly` ~ _ ® ~\ ~. ~ ~~ ~' ,. ~ • ~ 5 ~ / z.,,, • ~ <:~,. (r1 / ,., ~ ~gig c`' ~ \ / , `...• ... _.. ~~~ :i.. ~---~ - " SSE `\I 9 / O ~ V / \ .:~ ~ { ` d ~. 0 ~ _ CS ~ SC : d° ~ 3 \~~1 Y3 ~ ~_ ~ T __ _. V• \ ` ,.. ,_ ~$ ' _..• 4 e `' _ _ ~ M,, ~ .. ~ -...., ._._. t __ ._ re_• yy ~ S 1 „_. _ .... _.__ ~.. ~~ ., ~...... ,~ ~ ,~d~ ` ~~ °~'H i~{ \\ o` 1 ~~ $_: ~rr m '~Ir himm ~m ~~ Q. E ~ b~g,'O ~,~, ~ c: ~ ~~ro _o ® ~ N ~.~ o ^ ' .4 ' ~_ n ~ ~ ~> .•> N ~ c ~ 11 ~ , ~ W ~~ ~. x a ~ .> i. ~ ~ U ~ ~ - ° W1 ~. -~ s L z J o ~, ~,~. n, ~ W .~ ~ ,~ N ~ ~ >' W ~ ~. 3 a "D T W ~ °- _ > ,y ~ a LAW OFFICES OF PAUL J. TADDUNE, P.C. 323 WEST MAIN $AEET, SUITE 301 ASPEN, COLORADO 81611 PAUL J. TADDUNE, P.C. WILLIAM K. GUEST, P. C., OF COUNSEL ANDREW H. BUSCHER, OF COUNSEL September 15, 1998 Ms. Jackie Lothian City of Aspen, City Clerk's Office 130 S. Galena Street Aspen, CO 81611 Re: Colas/DRAC/September 17 meeting Dear Jackie: TELEPHONE (970) 925-9190 FA6IA1ILE (970) 925-9199 This letter is to formally request that the DRAC postpone consideration of the Colas application until sometime after October 1, 1998. As you know, Mr. Tabet was in town for the DRAG meeting that was to occur on September 1 Q but failed to occur for lack of a quorum. Mr. Tabet is now in California and is scheduled to be out of the country until October 1. ` I have your telephone message concerning the October 8 date. I do not know at this point whether or not Mr. Tabet will be available on this date, but I will try to reach him to ascertain if he can attend the meeting. Thank you in advance for your attention to this matter. Very tmly yours, PAUL J. TAI;D1Jl~lE, P.C. Paul J. Taddune PJT/som cc: Sylvio Tabet Jan Derrington Attachment 8 County of Pitkin } AFFIDAVIT OF NOTICE PURSUANT } ss. TO ASPEN LAND USE REGULATIONS State of Colorado } SECTION 26.52.060(E) I, dr ~ U ~ ,being or representing an Applicant to the City of Aspen, personally certify that I have complied with the public notice requirements pursuant to Section 26.52.060(E) of the Aspen Municipal Code in the following manner: ~~ 1. By mailing of notice, a copy of which is attached hereto, by first-class postage prepaid U.S. Mail to all owners of property within three hundred (~00) (cct ~~1~ the subject property, as indicated on the attached list, on the ays prior to the public hearing date of 2. By posting a sign in a conspicuous place on the subject property (as it could be seen from the nearest public way) and that the said sign was posted and visible continuously from the~dday of , 199., to the ay of , 199. (Must be posted for at least 11 days before the hearing date). A photograph of the posted sign is attached hereto. -t >ed befor ~~ ~' . by /, ~~~i' ofd C t"C~ ~~t'v'~ 1 WITNESS MY HAND AND OFFICIAL SEAL My Co Notary ~pTARI -0-o- n ~.~~- - , ~v ~pMMISSION EXPIRES. ~eav 22 ?001 .. 'fi~jJ.S(~ .. County of Pitkin State of Colorado } AFFIDAVIT OF NOTICE PURSUANT } ss. TO ASPEN LAND USE REGULATION } SECTION 2652.060 (E) 1, ~~~~ C.UN N l ~F ~ ,~iP-C.t-Ii.1~CT5, being or representing an Applicant to the City of Aspen, personally certify chaz I have complied with the public notice requirements pursuant to Section 26.2.060 (~ of the Aspen Land Use Regulations in the following manner. r(l~ 1. By mailing of notice, a copy of which is attached hereto, by first-class, postage prepaid U.S. itiiaii to all owners of property within three hundred (300) feet of the subject property, as indicated on the attached list, on the day of l99_ (which is _ days prior to the public hearing date of ) 2. By posting a sign in a conspicuous place on the subject property (as it could be seen from the nearest public way) and that the said sign was posted and visidle continu usly from the _~day of SE!'T• .1998 (yiust be posted for ~;,~c5~ at least i~-(~6') full days before the hearin; date). A photo~aph of the aosted sib is attached hereto. ', ~ -~, ~ tint.. ~- Si ~ re ../ ~} ~ ) Signed before me this ~~% day ,199 by . ~1/1 ~ l -FE',~ Ca ~Q-~ WITNESS MY H?u~+"D A:vD OFFICIAL SE.1L tiIy cornrnission expires :1`~~ 2 ~ i-~~~'C~ I ~~~~~~c-~.~ ~ ~~ l I ~Y~ ~ Not Public ((// ,~,~~~~~~~~„~~,, . ~fias ~ ~. Signature ~~ ~~ SAY COMMISSION EXPIRES ~AAY 22. 20~' ~ a .w,,,.L, ..:,.,r~~nh hP.Y°~ ~~ County of Pitkin State of Colorado } } ss. } CHARLES CUNNIFFE ARCHITECTS ~F'FID A VIT O F N OTICE PL~RSt; ~u~IT TO :~,SPEN LAND LSE REGL'L~TION SECTION ? 6.5 2.060 (~ ~ ,being or representing an ~ppiicant to the City or :;pen, personally certify that I have complied with tfie public notice requirements pursuant to Section ?6.2.060 (E) or the aspen Land Use Regularions in the following manner 1. By mailing or notice. a copy of which is '1TT'1C;led hereto, by hzst~iass, aost~ge prepaid U.S. tifail to ail owner or oroverry ~>vith three hundred i.~00) feet or the subiect property. as indicated on the attached !ist. un he _ da;% of , iyu_ ;vhich is ._ days Drier to ~he public hea.rng date ~f ?. By posting a sign in a conspicuous place on the subiect property {as it could be seen Tom the nearest public ~vay) and that he said sign .vas posted and visible continuoust~~ 4th September ~ ~ from the day or , t 9g~ {Must ce posted for at least yei1~~ full days be:ore the hearing date)- .~ photograph of he posted sign is attached '~ereto- . n _ ~ Sign~re ,// ~'-~ Signed be:ore me this~~;~ day __~~iyn/~~.t ~ _ ,199~y WITNESS ti1Y HAND .~vD O>;FI SEAL. qty commission expires: w /` ~ / -~ ~`~ Y Notary Public's sign ,.. Memorandum s TO: Design Review Appeal Committee THRU: Julie Ann Woods, Interim Community Development Director FROM: Amy Guthrie, Historic Preservation Officer DATE: September 10, 1998 RE: Nevin, Lot #2, Silverlode- Appeal from Design Standazds relating to Building Orientation and Volume SUMMARY: The applicant requests a waiver of the Residential Design Standazds related to building orientation and to an FAR increase due to volume for glazing in the "no window" zone. APPLICANT: Joe Nevin, represented by Charles Cunniffe Architects. LOCATION: Lot #2, Silverlode Subdivision. ZONING: PUD PROiFCT REVIEW PROCESS AND STAFF EVALUATION Background: The proposed project is a new house on a vacant pazcel. Site Description: The structure is to be located in the Silverlode Subdivision at the base of Smuggler Mountain. 1. Waiver Requested: Standard: "The orientation of the principal mass of all building must be parallel to the streets they face. " Staff Evaluafion: The Committee may grant an exception to the design standazds if the project as proposed is found to meet one of the following criteria: a) yields greater compliance with the goals of the Aspen Area Community Plan: Staff Response: The project does not further any goals of the AACP. b) more effectively addresses the issue or problem a given standard or provision responds to; ~. ~ Staff Response: The waiver request does not address this criteria. c) be clearly necessary for reason of fairness related to unusual site specific constraints. Staff Response: The property is located at the base of Smuggler Mountain, and therefore the development is influenced by topographical constraints. The proposed building runs with the natural fall line on the site, rather than against it, which would be required if the building orientation standazd were to be met. Additionally, this skewed orientation allows the project to meet another important goal of Ordinance #30, tucking the gazage behind the house, off of the street, which has been problematic on most other sites in this neighborhood. Staff recommends the variance be granted based on unusual site specific constraints. 2. Waiver Requested: Standard: "All areas with an exterior expression of a plate height greater than ten (1 D) feet, shall be counted as two (2) square feet for each one (1) square foot of floor area. Exterior expression shall be defined as facade penetrations between nine (9) and rtivelve (12) feet above the level of the finished floor, and circular, semi-circular or non-orthogonal fenestration between nine (9) feet and fifteen (1 S) feet above the level of the finished floor. " Staff Evaluation: The Committee may grant an exception to the design standazds if the project as proposed is found to meet one of the following criteria: a) yields greater compliance with the goals of the Aspen Area Community Plan: Staff Response: The project does not further any goals of the AACP. b) more effectively addresses the issue or problem a given standard or provision responds to; Staff Response: The attached drawings indicate those azeas which violate the volume standazd. Staff finds that the intent of the standard is met in that no windows aze two story in height or express large, vaulted interior spaces. The slight azch over the front windows gives the building additional chazacter. The side window is a bathroom window which has a high placement for privacy concerns. Again, none of the windows give the building an overscaled appearance. c) be clearly necessary for reason of fairness related to unusual site specific constraints. Staff Response: This standard is not met. Recommendation: Staff recommends that the Design Review Appeal Committee ~ approve the requested variances for Nevin, Lot #2, Silverlode. r r, ©^ August 14, 1998 ~~ City of Aspen Design Review Appeal Committee Aspen, COIOIadO ARCHITECTURE PLANNING Re: Lot #2, Silverlode Subdivision INTERIORS Members of the Committee: Our proposal for a new single-family residence in the Silverlode Subdivision has been designed to meet the essential goals of the Ordinance 30 Design Standards. The building sites in this location aze unique, and they have distinct physical characteristics that differ from typical lots in the City of Aspen grid. In previous reviews of othec new residences in this subdivision, you have determined that some flexibility in the application of the Ordinance 30 Standazds is acceptable due to the special qualities of these sites. The proposed design succeeds in satisfying the Ordinance 30 goals of providing appropriate mass, scale and relationship to the streetscape in the following ways: • Street-oriented entrance and street-facing principal window. • One-story street-facing element at least 20% of building width. • The garage is not visible from the street. Unlike other Silverlode properties, this proposal complies with this Ordinance 30 requirement. • The use and location of stone and wood finishes enhances the human scale of the proposed design. • Building massing and form enhances the human scale of the proposed design. This submittal requests two variances regarding the Street Orientation requirement and the Volume Standazd. We believe the flexibility in the Ordinance 30 Design Standazds that is appropriate for this location can be the basis for determining that these requests aze acceptable. STREET ORIENTATION Ordinance 30 is intended to address the pedestrian's visual perception of our built environment. We believe that a vaziance to the Street Orientation requirement, based on reasons of fairness related to unusual site specific constraints, meets this aesthetic goal ,and that it would be consistent with previous approvals granted for this neighborhood by the Committee. Our proposal satisfies the intent of the Ordinance for the following reasons: • The Silverlode neighborhood is located at the foot of Smuggler Mountain. It relates directly to the existing topographic features of the land rather than the typical City of Aspen grid. • Silverlode drive conforms to a curvilinear configuration defined by the natural topography. +; • The natural fall line of the proposed building site is not perpendicular to the street. CHARLES CUNNIFFE ARCHITECTS_• 520 EAST HYMAN SUITE 301 • ASPEN, COLORADO 81611 970/925-5590 FAX 970/925-5076 • The proposed residence is sited to fit naturally and sensitively on the topographic contour of the property. Strict conformance to the ordinance would result in a building orients. ` that visibly conflicts with the natural terrain. ~.- • The street orientation requirement is intended to maintain and enhance the street frontage presentation of Aspen's more typical gridded neighborhoods. Since the physical configuration of the adjacent Silverlode sites along the curvilinear street do not create a perceptible line of street frontage, this situation does not exist. • The proposed design does provide a strong street presence -including entrance and principal window- in spite of a modest adjustment to the street orientation requirement. • The proposed orientation would result in a consistent relationship among the entrances for Lots #1, 2 and 3. • Lot #2 is unique to the Silverlode subdivision in having natural, existing Aspen groves on the property. Our proposed building siting allows the maximum number of trees to be retained. VOLUIVIE STANDARD Our proposal includes 4 windows which do not conform to the Volume Standard. We aze requesting a variance to allow some glazing in the so-called "no window" zone, and we believe this request is consistent with previous approvals granted by the Committee for this neighborhood. The proposed design is intended to provide a compromise between the Owner's desire to maximize available light and views and the requirements of Ordinance 30. The project will serve as successful transition between the kind of expansive glazed openings evident in completed Silverlode Residences and tti'"°"~ goals of the Design Standards now in effect. We believe our proposal successfully and sensitivel addresses the issue of presenting glazed openings that relate to human scale for the following reasons: • Glazed openings have been configured with mullions and muntins to eliminate areas of uninterrupted glass. • Principal windows are emphasized. • The window sills in the Master Bathroom on the east elevation are located 6'-8" AFF above the lavatories and wall-mounted mirrors. They are modestly sized and would conform to the Ordinance if located in a lower position. • The potential glazing in the south-facing Living Room gable end has been reduced to allow for a high separate square window above the arch-top, mullioned view window. • The proposal satisfies the goals of the Volume Standard and maintains a contextual relationship to adjacent Silverlode properties which do not conform to this requirement. Sincerely, Chazles L. Cunmffe, AIA Principal ~, ,. - _ ,:- . '~ ._ 1. Project name 2. Project locati~ ATTACHMENT 1 LAND USE APPLICATION FORM (indicate streei address, !ot and black number or metes and bounds description) 3. Present zoning ~•U•~ 4. Lot size Io43~~ 5F 5. Applicant's name, address and phone number ~°~ ki/V/N I~ 4 ~~~-Sa,~c2 t.~l . RSPB Co S r~ r i ~~~ I~l ~- l 4-4 I 6. Representative's name, address, and phone number CF~Pmi.£~ GdEU~%b~ , 5~u ~. El~u~v3N 14SPEN ~o ~(ioll a1n q~s- X590 7. Type of application (check ail that apply): Conditicnai Use _ Special Review _ _ 8040 Greenline _ Stream i~targin Subdivision _ _ GMQS allotment _ _ View Plane _ _ Lot SplitlLot Line Adjustment Conceptual SPA _ Final SP,4 _ Conceptual PUD _ Final PUD _ TextlMap Amend. GMCS exemption Condominiumization~ Conceptual HPC Finai HPC Minor HFC Relccation HPC Historic Landmark Demo/Partial Demo Design Review Appeal Committee 8. Description of existing uses (number and type of existing structures, approximate sq. ft., number of bedrooms, any previous approvals granted to the property) SI,T~ I% UNaGt,uFif~ W~ f~ {4LbP(wl1~i/~CiS 9. Description of development application 10. Have you completed and attached the following? _ Attachment 1-Land use application farm Response to Attachment 2 _ Response to Attachment 3 (-~ APPLICANT: Joe Nevin, represented by Charles Cunniffe Architects LOCATION: Lot #2, Silverlode Subd. RE: Appeal From Design Standards relating to building orientation and volume. Two waivers are requested: 1. Standard: The orientation of the principal mass of all building must be parallel to the streets they face. Must meet one of the following criteria for an exception: a. Yields greater compliance with the goals of the AACP. b. More effectively addresses the issue or problem a given standard or provision responds to. c. Be clearly necessary for reason of fairness related to unusual site specific constraints. 2. Standard: All areas with an exterior expression of a plate height greater than ten feet, shall be counted as two square feet for each one square foot of floor area. Exterior expression shall be defined as facade penetrations between nine and twelve feet above the level of the finished floor, and circular, semi-circular or non-orthogonal fenestration between nine feet and fifteen feet above the level of the finished floor. Must meet one of the following criteria for an exception: a. Yields greater compliance with the goals of the AACP. b. 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