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05.'11/9S 15:31 nO.St.2 POO?LINDQUIST & VENNUM p.l.l.p. <br />statements concerning other types of future use of the Woodhill Avenue access. <br />Woodhill did not use the Woodhill Avenue access for construction machinery and <br />trucks then and does not propose to do so today. As set forth in the application, all <br />commercial and delivery vehicles will be required to use the Woodhill Road <br />entrance. <br />7. Woodfaiirs reservation of its rights to use Woodhill Avenue have been clear <br />and have been acknowledged by the City of Orono. As quoted in Woodhill’s <br />initial application. Woodhill wrote to the City of Orono, advising the City of its <br />decision to limit regular vehicular traffic.on Woodhill Avenue. In doing so, the <br />Club expressly reserved its right to reopen the access anytime it decided to do so. <br />(Morrison letter, dated June 23, 1980) Seven years after having sent that letter, the <br />city administrator wrote a memo to the city council stating that, indeed, Woodhill <br />could open the road at any time it elected to do so. (Bemhardson memo, dated <br />October 6, 1987). <br />IV. WoodhiU's Application is Consistent with the City of Orono's Comprehensive Plan <br />1. Woodhill is a recreational property, not a commercial property. <br />No one has questioned that the existence of Woodhill Country Club is included in and <br />consistent with the City of Orono ’s Community Management Plan (“CMP"). In 1968, no one <br />suggested that Woodhill Country Club was in any way inconsistent with the then-newly <br />conceived zoning districting plan (Scarlcs Deposition testimony). The subsequently adopted <br />CMP also embraces Woodhill Country Club’s use of its property as consistent with and part of <br />the overall city plan. <br />Contrary to Mr. Malkcrson’s reference to Woodhill Country Club and its traffic as <br />“commercial" or "business,” the CMP does not categonze Woodhill as either "commerciar or <br />“business.” Table 2 of the CMP lists five types of land use: <br />(i) Urban residential; <br />(ii) Commercial; <br />(iii) Industrial; <br />(iv) Rural residential; and <br />(v) Recreation open space. <br />Doc»f I i IV304\|