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Code recital and commentary: EMC 15.03.060 C. General Criteria. In considering any request for modification of standards in this title, the following criteria need to be met: 1. The request for modif►cation would result in development that is equivalent or superior to what would likely result from compliance with the development standards which are proposed to be modified. The proposed landscape plan includes landscaping in all areas that are not porch, stairs, or ADA ramps. We believe this to be equivalent to the intent of the code. If the entire setback area is to be landscaped, then where are the porch and ramps to go? 2. 'Che request for modification meets the intent of the standards being modified. We believe they meet the intent. 3. The request for modification does not create any impacts or nuisances that cannot be mitigated, such as access points which are unsafe, noise, dust, odor, glare, visual blight or other undesirable environmental impacts. We believe this is the best way to landscape the project's street frontage while still providing pathways to the front entrance of the building. 4. The request for modification meets any additional modification criteria in the respective chapter. (Ord. 3771-20 §3 (Exh. 2),2020.) The next section addresses this point. EMC 19.35.190 Administrative Modification of Landscaping Requirements A. The planning director may authorize a reduced width of planting or waive sonic or all of the landscaping requirements in the following instances: 1. When existing conditions on or adjacent to the site, including, but not limited to, differences in elevation, existing vegetation, or location of buildings or utilities would render the requirements of this section ineffective. This does not apply. 2. When Type I visual screening is required, an applicant may request to use plantings that can be expected to form a healthy sight-obscuring evergreen hedge within three years 21 Page Its Rockefeller Square