HomeMy WebLinkAboutItem IV PLAN COMMISSION STAFF REPORT NOVEMBER 17,2020
ITEM IV: PUBLIC HEARING: CONDITIONAL USE PERMIT REQUEST FOR A
NONRESIDENTIAL ACCESSORY STRUCTURE EXCEEDING 10,000
SQUARE FEET AT 2676 S. OAKWOOD ROAD
GENERAL INFORMATION
Applicant: McMahon Associates, Inc.
Owner: Muza Sheet Metal Co.,LLC.
Action(s) Requested:
The petitioner requests a Conditional Use Permit for a nonresidential accessory structure
exceeding 10,000 square feet at 2676 S. Oakwood Road.
Applicable Ordinance Provisions:
Non-residential accessory structures exceeding 10,000 square feet are permitted only through a
conditional use permit per Section 30-86(J)(2) of the zoning ordinance. Criteria used for
Conditional Use Permits are located in Section 30-382 of the Zoning Ordinance.
Property Location and Background Information:
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2018 aerial image of the subject site (outlined in red)
The 718,354 sq. ft. (16.49 acre) site is located off of S. Oakwood Road and Badger Avenue and is
accessed via an entrance/exit from S. Oakwood Road. The site contains a 71,150 square foot
industrial building and associated parking area. It previously served as a Dynamic Drinkware
facility. The Muza Sheet Metal Company now plans to operate the property as a contractor
office, shop and outdoor storage area. The property is located within the Southwest Industrial
Park and the surrounding area consists predominately of industrial uses. The site currently
consists of three adjacent parcels which the owner will combine into a single parcel.
Muza Sheet Metal Co. plans to relocate its existing business from the current locations at 51 W.
Fernau Avenue and 3200 N. Main Street to the subject site at 2676 S. Oakwood Road. Muza will
remodel the existing building to accommodate its operations. Muza does not currently have
plans to add onto the existing building. They plan to add an outdoor storage area to the east of
the existing building. Muza will use this area to store different types of raw materials used in
the production of sheet metal products. The storage area will also accommodate the parking of
their various fleet vehicles used for the delivery and installation of their sheet metal products.
The combined subject site will house Muza's office operations, the production and storage of
sheet metal products, and the hub of Muza's sheet metal installation operations including the
storage of Muza's vehicle fleet. The office and industrial land uses are compatible and
consistent with the 2040 Comprehensive Plan land use recommendation and with the Heavy
Industrial (HI) zoning for the area. The Plan Commission recommended approval of a
Conditional Use Permit (CUP) for the outdoor storage land use at the May 19, 2020 Plan
Commission meeting and the Common Council approved the CUP at the May 26, 2020 Council
meeting.
Muza has since decided that they would like to add a large accessory storage building to the site
on the east side of the proposed outdoor storage area. The proposed accessory building is a
30,000 square foot building for the storage of materials. Since the proposed accessory building
is greater than 10,000 square feet in area, it requires a Conditional Use Permit.
Subject Site:
Existing Land Use Zoning
Industrial—Proposed contractor office, shop, and storage
yard HI
Adjacent Land Use and Zoning:
Existing Uses Zoning
Industrial—manufacturing/service—electric
North motors HI
South Industrial—beverage distribution company HI
West Industrial—door manufacturer/distributor HI
East Industrial—trucking/freight handling company HI
Comprehensive Plan Land Use Recommendation Land Use
2040 Land Use Recommendation Industrial
Item IV—CUP/Accessory Storage Building—2676 S.Oakwood Rd. 2
Page 2
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The above plan shows the previously approved plan of the subject site. The existing building is located on
the southwest portion of the site and the outdoor storage area to the east of the building. Additional
parking is to the north of the existing parking. This plan was approved at the May 261h Common Council
meeting. The proposed storage building would be located immediately adjacent to the outdoor storage lot
(see plan below).
Item IV—CUP/Accessory Storage Building—2676 S.Oakwood Rd. 3
Page 3
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The proposed site plan above shows the outdoor storage area in gray and proposed footprint of the
accessory storage building(rectangle to the east of the outdoor storage area).
ANALYSIS
The petitioner is requesting approval of a Conditional Use Permit(CUP) to construct an
accessory storage building for materials storage on the subject parcel (see plan above). The
scope of work proposed for the site includes the following:
Construction of a 30,000 square foot detached accessory building for materials storage
on the site.
Muza intends to construct a detached accessory building for the storage of raw materials used
for the production of sheet steel products. The storage building as proposed will include
approximately 30,000 sq. ft. (.69 acres) of enclosed area. Nonresidential accessory structures
exceeding 10,000 sq. ft. in area require a CUP. The impervious surface additions proposed for
the site are as follows:
NEW IMPERVIOUS AREA - OAKWOOD SITE
New Accessory Building 30,000 sq. ft.
Total New Impervious Area 30,000 sq. ft.
Item IV—CUP/Accessory Storage Building—2676 S.Oakwood Rd. 4
Page 4
The storage lot expansions and new parking lot(previously approved) along with the proposed
storage building will increase the amount of impervious surface area on the site to
approximately 42.27% of the lot area. The proposed impervious surface coverage falls below
the 70%maximum impervious surface ratio permitted by the zoning ordinance for Heavy
Industrial (HI) zoned parcels. The proposed impervious surface ratio also falls below the 60%
maximum impervious ratio permitted under the Industrial Park Covenants. Muza will not
make any changes to the existing principal building's footprint at this time.
The petitioner has stated in the narrative that accompanied the CUP application that the
materials stored in the proposed outdoor storage area will not be hazardous materials. The new
storage building will not have an impact on vehicle or pedestrian circulation within the site.
Manufacturing at the S. Oakwood Road facility would occur indoors. Activities that occur
outdoors would be limited to shipping and receiving and everyday business and maintenance
activities. Muza would use the proposed storage building for material storage. Due to this,
Muza has stated in their narrative that the outdoor storage area approved previously would
only be used for fleet vehicle and trailer storage/parking. The industrial park where the facility
is located contains trucking/freight companies and manufacturing facilities with similar hours
of operation to the Muza facility. The noise produced at the Muza site will not be atypical of
other uses within the industrial park and will not result in abnormal noise pollution.
Screening
Since the proposed accessory building is the focus of this CUP no screening is required beyond
what was stipulated in the original CUP for outdoor storage.
Access/TrafficNehicle Circulation
The accessory building will not greatly affect vehicle circulation for the publically-accessed
areas of the site as the accessory building is proposed adjacent to the outdoor storage area.
Access to the building would be through the outdoor storage area. Therefore, the new
accessory building will not obstruct access to the existing parking areas. The locations of the S.
Oakwood Road and Badger Avenue access drives will stay the same and Muza does not have
plans to alter the access drives, employee parking, or outdoor storage beyond what was
originally approved.
Landscaping
2676 S. OAKWOOD LANDSCAPING CALCULATIONS
Building Foundations - No Additional Landscaping Required
Paved Areas - Addressed in original CUP
Island Plantings-Addressed in original CUP
Street Frontages -Addressed in original CUP
Yards - 10 points per 1,000 sq. ft. of buildings/storage area
proposed for the lot (30,000 sq. ft. /1000 = 30 x 10 = 300 points)
Bufferyards - None required
Item IV—CUP/Accessory Storage Building—2676 S.Oakwood Rd. 5
Page 5
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Overall landscaping plan proposed by the petitioner(above).
Additional landscaping is required for the addition of the accessory building as part of this CUP
request (see table above). The addition of building area on the site is considered an addition to
the site under the Landscaping Requirements in the zoning ordinance. For every 1,000 square
feet of building or impervious surface area added, the petitioner must add 10 points of yard
landscaping to a Heavy Industrial-zoned site. With the addition of 30,000 square feet of
building area, 300 points of yard landscaping are required. The petitioner submitted a
landscaping plan for the site as part of the CUP application. Staff reviewed the landscaping
plan and found that the petitioner has proposed additional landscaping adjacent to the
accessory building's foundation (see plan above)- A prairie area is proposed to the east and
northeast of the accessory building. The petitioners have provided point totals for the
landscaping proposed as part of this CUP request. The point totals provided by the petitioner
ascribe 1 point for each square foot of perennial plantings. Staff ascribes 1 point per every 20
square feet of perennials. Staff will require updated point totals. The petitioner will have to
show on the site plan which landscaping points will be ascribed specifically for the accessory
building. Staff will require code compliant point totals for Department of Community
Development review during the Site Plan Review process.
Lighting
The original CUP request addressed lighting. The petitioner submitted a photometric plan as
part of this CUP request. Enclosed outdoor storage areas are not subject to the same lighting
standards as parking areas and drive aisles. Based on the plan provided the point values meet
code.
Item IV—CUP/Accessory Storage Building—2676 S.Oakwood Rd. 6
Page 6
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A portion of the photometric plan provided by the petitioner is above. This shows the outdoor storage area
which will be fenced in and not subject to ordinance lighting standards. Based on the information
provided the photometric plan is code compliant.
Signage
No sign plans were submitted and the petitioner is not proposing any changes to the on-site
signage.
Building Facades
No changes are proposed to the existing principal building facades as part of this Conditional
Use Permit. The petitioner provided building elevations for the proposed accessory building.
The accessory building will be clad in steel paneling. The Industrial Design Standards do not
apply to accessory buildings. The proposed elevations are below-
Item IV—CUP/Accessory Storage Building—2676 S.Oakwood Rd. 7
Page 7
SOUTH EXTERIOR ELEVATION NORTH EXTERIOR ELE'V;:710'J
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EAST EXTERIOR ELEVATION
The elevations of the proposed accessory building are shown above.
Storm Water Management/Utilities
The petitioner has submitted erosion control, grading, storm water management plans, and an
operation and maintenance plan. Since the petitioner is planning to add significant areas of
impervious surfacing to the site the Department of Public Works will require a full storm water
review through the Site Plan Review process. The petitioner stated during the original CUP
request that the scope of work will include the construction of storm water management devices
to treat storm water runoff for sediment and phosphorus runoff. The storm water management
devices installed as part of the project will treat the runoff from the outdoor storage and
accessory building.
Conclusion
Staff is in support of the proposed accessory building as the use will not be detrimental to the
surrounding area, provided that the required landscaping and storm water management are
provided for the site.
RECOMMENDATION/CONDITIONS
In its review and recommendation to the Common Council on an application for a Conditional
Use Permit, staff recommends the Plan Commission make the following findings based on the
criteria established by Chapter 30-382 (F)(3):
(1) Is in harmony with the Comprehensive Plan.
(2) Would not result in a substantial or undue adverse impact on nearby property, the
character of the neighborhood, environmental factors, traffic factors, parking, public
improvements, public property or rights-of-way, or other matters affecting the public
health, safety, or general welfare.
Item IV—CUP/Accessary Storage Building—2676 S.Oakwood Rd. 8
Page 8
(3) Maintains the desired consistency of land uses, land use intensities, and land use
impacts as related to the environs of the subject property.
(4) The conditional use is located in an area that will be adequately served by, and will not
impose an undue burden on, any of the improvements, facilities, utilities or services
provided by public or private agencies serving the subject property.
(5) The potential public benefits outweigh any potential adverse impacts of the proposed
conditional use, after taking into consideration the applicant's proposal and any
requirements recommended by the applicant to ameliorate such impacts.
Staff recommends approval of the proposed Conditional Use Permit for a nonresidential
accessory structure exceeding 10,000 square feet at 2676 S. Oakwood Road with the findings
listed above and the following conditions:
1. Petitioner shall submit a revised landscaping plan and landscaping schedule with code-
compliant species and code-compliant landscaping point totals for Department of
Community Development review. The plan and landscaping schedule shall illustrate
which plants and point totals will be added specifically as part of this CUP request.
2. Petitioner shall provide at least 300 points of yard landscaping for the proposed storage
building.
Item IV—CUP/Accessory Storage Building—2676 S.Oakwood Rd. 9
Page 9
SUBMIT TO:
City Of Oshkosh Application Dept.of Community Development
City 215 Church Ave.,P.O.Box 1130
of Conditional Use Permit Oshkosh,Wisconsin54903-1130
Oshkosh PHONE:(920)236-5059
—PLEASE TYPE OR PRINT USING BLACK INK*
APPLICANT INFORMATION
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Petitioner: McMahon Associates, Inc . Date: -442.9 t@
Petitioner's Address: 1445 McMahon Drive City: Neenah State: WI Zip: 54956
Telephone #: (920) 751 -4200 Email:dgruber@mcmgrp.corn Contact preference: ❑ Phone M Email
Status of Petitioner(Please Check): ❑Owner X Representative ❑Tenant ❑ Prospective Buyer
I U%I-1120
Petitioner's Signature (required): &—Atvl Date: 44Le4-2-G-
OWNER INFORMATION
Owner(s): Muza Sheet Metal Co. , LLC. Date:24-mL&�-o
Owner(s) Address: 51 W. Fernau Ave . City: Oshkosh State: WI Zip: 54901
CarvenB@muzasheetmetal.com
Telephone#: (9 2 0) 2 3 5-4 9 6 0 Email: Contact preference: ❑ Phone M Email
Ownership Status (Please Check): ❑Individual ❑Trust X Partnership ❑Corporation
Property Owner Consent:(required)
By signature hereon, I/We acknowledge that City officials and/or employees may,in the performance of their functions,
enter upon the property to inspect or gather other information necessary to process this application. I also understand
that all meeting dates are tentative and may be postponed by the Planning Services Division for incomplete submissions
or other administrative reasons.
C21�LCI�i ���� -/- a/2-C7
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Property Owner's Signature: Date: 4�2 6/2�fl
SITE INFORMATION
2676 S . Oakwood Road, parcel 1329100200 and
Address/Location of Proposed Project: parcel 1329100102 /��l r /j
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Proposed Project Type: Contractor office, shop,
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Current Use of Property: Vacant . Former Dynamic Drinkware facility. Zoning: Heavy Industrial
Land Uses Surrounding Your Site: North:HI, manufacturer/service for electric motors
South: HI, beverage distribution company
East: HI, manufacturer/distributor of doors
West: HI, trucking/freight handling company
"*Please note that a meeting notice will be mailed to all abutting property owners regarding your request.
➢ It is recommended that the applicant meet with Planning Services staff prior to submittal to discuss the proposal.
➢ Application fees are due at time of submittal. Make check payable to City of Oshkosh.
➢ Please refer to the fee schedule for appropriate fee. FEE IS NON-REFUNDABLE
For more information please the City's website at www.ci.oshkosh.wi.us/Community_Development/Planning,htm
Staff Date Rec'd
Page 10
Briefly explain how the proposed conditional use will not have a negative effect on the issues below.
1. Health,safety, and general welfare of occupants of surrounding lands.
See attached narrative .
2. Pedestrian and vehicular circulation and safety.
See attached narrative .
3. Noise,air,water,or other forms of environmental pollution.
See attached narrative .
4. The demand for and availability of public services and facilities.
See attached narrative .
5. Character and future development of the area.
See attached narrative .
SUBMITTAL REQUIREMENTS-Must accompany the application to be complete.
(Submit only digital files. Please note at the discretion of Community Development staff may request a hard copy)
➢ A narrative of the proposed conditional use and project including:
❑ Proposed use of the property
❑ Existing use of the property
❑ Identification of structures on the property and discussion of their relation to the project
❑ Projected number of residents,employees, and/or daily customers
❑ Proposed amount of dwelling units,floor area,landscape area,and parking area expressed in square feet and
acreage to the nearest one-hundredth of an acre
❑ Effects on adjoining properties to include:noise,hours of operation,glare,odor,fumes,vibration,etc.
❑ Surrounding land uses
❑ Compatibility of the proposed use with adjacent and other properties in the area.
❑ Traffic generation
❑ Any other information pertinent to adequate understanding of the intended use and its relation to nearby properties
➢ A complete site plan including:
❑ Digital plans and drawings of the project
❑ Title block that provides all contact information for the petitioner and/or owner,if different
❑ Full name and contact information of petitioner's engineers/surveyors/architects,or other design professionals used in
the plan preparation
❑ The date of the original plan and latest date of revision to the plan
❑ A north arrow and graphic scale. Said scale is not to be smaller than one inch equals sixty feet (1"=60') unless
otherwise approved by the Department of Community Development prior to submittal
❑ All property lines and existing and proposed right-of-way lines with bearings and dimensions clearly labeled
❑ All required building setback and offset lines
❑ All existing and proposed buildings,structures,and paved areas,including building entrances,walks,drives,decks,
patios,fences,walls
❑ Location of all outdoor storage and refuse disposal areas and the design and materials used for construction
❑ Location and dimension of all on-site parking (and off-site parking provisions if they are to be employed),including a
summary of the number of parking stalls provided per the requirements of Section 30-175 City of Oshkosh Zoning
Ordinance
❑ Location and dimension of all loading and service areas on the subject property
❑ Location,height,design,illumination power and orientation of all exterior lighting on the property including a
photometrics plan
❑ Location of all exterior mechanical equipment and utilities and elevations of proposed screening devices where
applicable (i.e.visible from a public street or residential use or district). Mechanical equipment includes,but is not
limited to; HVAC equipment,electrical transformers and boxes,exhaust flues,plumbing vents, gas regulators,
generators
2
Page 11
Conditional Use Permit Application for Muza Sheet Metal Co., LLC.
Narrative of the proposed conditional use and project:
Muza Sheet Metal Company is a business that specializes in the production and installation of sheet
metal products used primarily in the building construction industry. Muza Sheet Metal Company is
currently located at 51 W. Fernau Avenue and 3200 N. Main Street in the City of Oshkosh.
Muza Sheet Metal Company (Muza) has recently purchased the former Dynamic Drinkware facility
located at 2676 S. Oakwood Road, parcel 1329100000, and is planning to relocate their existing business
to this location. Prior to the relocation, Muza will be remodeling/retrofitting the existing 71,150 S.F.
building to make building modifications required for their operations. Muza will not be adding on to
the existing building at this time. In addition to required building modifications, Muza also needs to add
additional employee parking spaces, an area for additional outdoor storage and an accessory storage
building. To accommodate these additional outdoor areas, Muza has purchased two parcels that are
adjacent to parcel 132910000, parcels 1329100102 and 1329100200. Muza will be requesting that the
three parcels be combined through the City's "Request to Combine Tax Parcels". Please refer to the
included preliminary site plan which depicts the existing improvements on parcel 1329100000 as well as
the proposed site improvements on all three parcels.
The purpose of this Conditional Use Permit Application is to address the City's limitations on outdoor
storage areas that are accessory to the principal land use. As part of the proposed project Muza is
proposing to construct an outdoor storage area that will exceed 500 square feet and a storage building
that exceeds 10,OOOsf. The proposed outdoor storage area will be for the storage of different types of
raw materials that Muza uses in their production of sheet metal products. In addition to the storage of
these materials, Muza will also require an outdoor storage area for the parking of their various fleet
vehicles used for the delivery/installation of their sheet metal products, and a 30,O00sf building for
material storage.
The three parcels that Muza has purchased are currently zoned Heavy Industrial and are surrounded by
parcels that are also zoned Heavy Industrial. The former Dynamic Drinkware facility (parcel
1329100000) is currently vacant/idle. The two additional parcels that Muza purchased, parcels
1329100102 and 1329100200, are undeveloped parcels. Parcel 1329100102 is currently used for
agricultural crop farming and parcel 1329100200 is currently wooded idle land. The proposed use for
the three parcels will be for Muza's office operations, the production and storage of sheet metal
products, and the hub for Muza's sheet metal installation operations including the storage of Muza's
fleet of vehicles. Muza's proposed use on the three parcels is, in our opinion, compatible with uses on
adjacent properties and other properties in the area. The existing land uses are all heavy industrial uses
and consist of; facility for the distribution and service of electrical motors, door manufacturing facility,
freight handling and trucking facility, beverage distribution/warehousing facility, heavy truck
manufacturing facility, and several metal fabrication businesses.
Page 12
The proposed use will not be a significant generator of traffic within the industrial park. Muza employs a
total of approximately 100 people all of which will travel to and from the facility daily.Traffic that will be
generated by the facility will include daily employee commutes to and from the facility, incoming daily
deliveries of raw metal product, outgoing shipments of product and trips of fleet vehicles traveling to
and from off-site job sites. The number of trips that are anticipated are as follows:
• Trips for 100 employees traveling to/from the facility= 200 trips per day
• Trips for the delivery of raw materials=4 trips (2 incoming shipments a day)
• Trips for the shipment of product= 16 trips (8 outgoing shipments a day)
• Trips for employees traveling to/from construction sites =80 trips per day(40 vehicles)
Briefly Explain how the proposed conditional use will not have a negative effect on the issues below.
1. Health, safety, and general welfare of occupants of surrounding lands.
The proposed conditional use is for an outdoor storage area that exceeds 500 square feet and
an accessory building that exceeds 10,OOOsf. Muza Sheet Metal Company is proposing an
outdoor storage area that is larger than 500 square feet for the storage of fleet vehicles, and a
30,000SF material storage building. The approximate area of the proposed outdoor storage
area is 10,800 SF. The materials that will stored within the outdoor storage areas will not be
hazardous materials. The proposed conditional use will not have a negative effect on the
health, safety and general welfare of the occupants of surrounding lands. Outdoor storage is
reserved for the sole purpose of fleet vehicle and trailer storage/parking.
2. Pedestrian and vehicular circulation and safety.
The proposed conditional use is for an outdoor storage area that exceeds 500 square feet and
an accessory building that exceeds 10,OOOsf. The proposed outdoor storage area will be in a
secure fenced in area located in the rear yard area of the existing building. The outdoor storage
area will have no impact on the amount of vehicular traffic and will have no effect on vehicular
circulation and safety. The industrial park that the subject parcels are located within does not
have provisions for pedestrians, i.e. sidewalks or trails.The outdoor storage area will have no
impact pedestrian circulation and safety.
3. Noise, air, water, or other forms of environmental pollution.
The proposed conditional use is for an outdoor storage area that exceeds 500 square feet and
an accessory building that exceeds 10,OOOsf. The conditional use will not have a negative effect
on noise. Muza Sheet Metal's hours of operation are between the hours of 5:30am and
10:OOpm Monday through Friday.
• The office hours are from 7:OOam to 3:30pm.
Page 13
• The first shift of the production area is from 7:00am to 3:30pm
• The second shift of the production area is from 5:00pm to 10:00pm.
• Employees that work at off-site job sites will arrive at Muza at 5:30am and leave to job
sites shortly thereafter. These employees will return to Muza at 5:00pm.
Manufacturing at the proposed Muza facility will occur indoors. Activities that occur outdoors
will be limited to shipping and receiving and everyday business and maintenance activities. The
proposed use is in an industrial park and heavy industrial zoning district. The industrial park
contains trucking/freight companies and manufacturing facilities that have similar hours of
operation. The noise that will be produced from the proposed use will not be atypical of other
uses within the industrial park and will not result in abnormal noise pollution.
The proposed conditional use is for an outdoor storage area that exceeds 500 square feet and
an accessory building that exceeds 10,000sf. This will not contribute to air or groundwater
pollution. The proposed use is the relocation of an existing business into an existing building.
The relocation of the business and the construction of the new parking lots and storage area
outlined earlier will not contribute to additional air or groundwater pollution.
The proposed project will include the construction of stormwater management devices to treat
stormwater runoff for sediment and phosphorous runoff. Runoff from the outdoor storage area
will be treated by the stormwater management devices. Therefore,the proposed conditional
use will not contribute to surface water pollution.
4. The demand for and availability of public services and facilities.
The proposed conditional use is for an outdoor storage area that exceeds 500 square feet and
an accessory building that exceeds 10,000sf. The larger outdoor storage area, anticipated to be
approximately 10,800 SF, will have no effect on the demand for and availability of public
services and facilities.
5. Character and future development of the area.
The proposed conditional use is for an outdoor storage area that exceeds 500 square feet and
an accessory building that exceeds 10,000sf. The proposed conditional use is located within an
industrial park and is surrounded by parcels that are zoned heavy industrial and that have uses
that are compatible with Muza's proposed use. Several of the businesses that are located
within the industrial park have large outdoor storage areas for the storage of their materials.
The proposed conditional use will not have a negative effect on the character and future
development of the area.
Page 14
CUP SHILO PROPERTIES LLC 2855 SOUTH OAKWOOD ROAD LLC
2676 S OAKWOOD RD 2850 S OAKWOOD RD PO BOX 689
PC: 11-17-20 OSHKOSH WI 54904 NEENAH WI 54957
DOUGHERTY REAL ESTATE LLC HUSZAR ENTERPRISES LLC W&W HOLDINGS LLC
2701 S OAKWOOD RD PO BOX 2465 PO BOX 2405
OSHKOSH WI54904 OSHKOSH WI54903 OSHKOSH WI54903
MUZA SHEET METAL CO MCMAHON ASSOCIATES INC
51 W FERNAU AVE 1445 MCMAHON DR
OSHKOSH WI54901 NEENAH WI54956
Page 15
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