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5. The Petitioner states that the configuration of Broad Street in this portion of the <br /> City results in its most frequent use by patients, visitors, and employees in a commute to <br /> Petitioner's main campus. <br /> 6. Since Petitioner is the sole property owner of each lot adjoining the portion of <br /> Broad Street at issue, the adjoining landowner's interests are not best served by keeping the <br /> current street open. <br /> 7. The part of Bates Street at issue adjoins Petitioner's main campus to the west, and <br /> the remaining three(3) sides of Petitioner's main campus are bound by immovable barriers <br /> prohibiting growth, including Fitzhugh Park and the City's Community Center and Aquatics <br /> Facility to the east,historic Oaklawn Cemetery to the south, and Harrison Street, one of the <br /> City's two(2)busiest thoroughfares, to the north. Creation of a contiguous campus dictates that <br /> growth on the north side of Harrison Street would be unsafe for patients, visitors, and staff <br /> needing to travel between buildings on the main campus. <br /> 8. Petitioner seeks abandonment of the part of Broad Street between 15th Street and <br /> Sidney Street to create space allowing for construction of a new medical facility which will <br /> expand and enhance health care access for the community. <br /> 9. Closure of said part of Broad Street will save the City of Batesville maintenance <br /> costs associated with its upkeep, and it will remove intersections which provide opportunities for <br /> motor vehicle accidents, as set out in Exhibit B, Affidavit of Damon Johnson, City Engineer. <br /> 10. Closure of said part of Broad Street will not have any negative impact on law <br /> enforcement function, fire department function, or other emergency services, as reflected in <br /> Exhibits C through E, Affidavits of Alan Cockrill, Batesville Chief of Police, Brent Gleghorn, <br /> Batesville Fire Chief, and Karen Ryan, CEO of Vital Link, the community's ambulance <br /> 2 <br />