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Each member of the Common Council shall have the opportunity to comment before a motion of <br />disposition on the appeal is accepted by the Chairperson and a roll call vote is taken. <br />III. Issues <br />The Petitioner asserts two issues as the bases of its appeal in its Position Statement Related <br />to Denial of Certificate of Appropriateness No.2020-0302: <br />A. The HPC's decision to deny COA#2020-0302 was arbitrary, capricious and <br />contrary to law; and <br />B. The HPC's decision to deny COA#2020-0302 was unsupported by substantial <br />evidence. <br />IV. Facts <br />A. The Pierre Navarre Cabin located in East Leeper Park, South Bend, Indiana <br />Pierre Navarre was the first settler of European descent to reside permanently in St. Joseph <br />County. He built a cabin in 1820, which is now known as the Navarre Cabin, along the St. Joseph <br />River to aid in his fur trading business with the American Fur Company. In 1895, the Navarre <br />Cabin was donated to the Northern Indiana Historical Society, now known as The History <br />Museum, and was moved to the newly established Leeper Park in 1904. The Navarre Cabin moved <br />again in 1916 and 1954, but it has remained in the same general area of Leeper Park since 1904, <br />preserving its close proximity to the river. In November 1996, Leeper Park was designated as an <br />Historic Landmark pursuant to Ordinance No. 8734-96, which included, as part of the Common <br />Council's consideration, a copy of the Standards and Criteria for Leeper Park in a form <br />substantially similar to today's iteration of them; Ordinance No. 8734-96 and its attachments are <br />attached hereto as Exhibit C. Additionally, in June 2000, Leeper Park was entered into the <br />4 <br />