Planning Commission - Regular Meeting

We would never start without you.

We were just discussing starting without you.

All right, we ready to call this meeting to order? Fantastic. We will call this planning commission regular meeting for Wednesday, September 9th to order and start with a roll call.

Commissioner Dukes?

Here.

Future Commissioner Adams? Here. You have to sit up and we have to hear you in your mic. I am here. Thank you. Commissioner Meyer?

Here.

Commissioner Kraft? Here. Commissioner Lazar? Here. Thank you.

Thank you. We will, Commissioner Kraft will lead us in a salute to the flag. All right, we're going to move to oath of office for our new commissioner. You can repeat after me. We're not getting married, though, don't worry. I, state your name, do solemnly affirm.

I will, Adam, do solemnly affirm.

That I will support and defend the Constitution of the United States.

That I will support and defend the Constitution of the United States.

And the Constitution of the State of California against all enemies, foreign and domestic.

And the Constitution of the State of California against all enemies, foreign and domestic.

That I will bear true faith and allegiance to the Constitution of the United States and the Constitution of the State of California.

That I will bear true faith and allegiance to the Constitution of the United States and the State of California.

And the Charter of the City of Eureka.

And the Charter of the City of Eureka.

That I take this obligation freely.

That I take this obligation freely.

Without any mental reservation.

Without any mental reservation.

Or purpose of evasion.

Or purpose of evasion.

And that I will well and faithfully discharge the duties.

And that I will well and faithfully discharge the duties.

Upon which I'm about to enter.

Upon which I'm about to enter.

In the capacity of Commissioner for the Planning Commission of the City of Eureka.

In the capacity of Commissioner for the Planning Commission of the City of Eureka.

Great job. Thanks.

Well that's nice, nice and rounded out.

Thank you. We can move to approval of minutes for August's meeting.

Move to approve.

Thank you.

I'll second that.

Fantastic. All in favor? Aye. We will open up oral communications. This will be an opportunity for anyone to speak on anything that is not on the agenda tonight. I don't see anyone on Zoom. Is that correct? I don't have anyone on Zoom. OK. And I don't see anyone in-house. So we'll close oral communications. And do I need to open public hearings since there's nothing on the agenda? No. Great. We'll skip to old business. Housing element update, regulatory constraints analysis.

Good evening, commissioners. As we've already talked about, but I put this in just because we have one new commissioner who also knows about it. But anyway, we are updating our housing element. And the new housing element will run from 2027 to 2035, and it will set the city's priorities and policies and actions that we're committing to that are housing related for the next eight years. And it's a big deal because whatever we put in there, we're committing to. And the housing elements result in tangible things like all of this housing on the screen, the Gateway Plan, the McKinleyville Town Center Plan. All of those came out of housing element update commitments. So getting involved right now and caring about what actions get put into the housing element is important because it will be something that will affect us for the next eight years. So housing element components. The one that people hear the most about is our regional housing needs accommodation and how we have to show that we are able to accommodate 1,740 net new housing units by 2035. But it's more than that. We're also required to have robust community outreach and engagement, and we have to do all these background analyses. The housing needs assessment looks at employment data and census data and housing data. And the fair housing assessment looks at the distribution of resources and lack of resources. Then there's a non-governmental constraints analysis that looks at, for instance, like the cost of building and other things that are non-governmental constraints on housing. And then what we're talking about tonight is the analysis of governmental constraints. We also look at our current housing element and look at what was effective and appropriate and what wasn't. And all of that plays into where we say we're going to develop more housing and into the housing element goals and policies, which are part of our general plan. So pretty much everything we do, we have to find general plan consistency. So these policies come up whenever we have a project or a citizen's initiative or whatever it is, county acquisition of property in Eureka, all of that, we have to consider a consistency with the policies of the housing element. And then there's a set of implementation programs, which is what the state is really focused on, is your implementation programs. And within them, you have to have these distinct actions with deliverables and deadlines. so you can't just say oh we're gonna try to explore relationships with affordable housing developers you have to say by 2028 we're going to amend the code to allow low barrier navigation centers by right in mixed use zones like it has to be very specific and and deliverable so um So what are government constraints? We're talking about not just regulations, but our permit review processes, our customer service, our fees, our on and off-site improvement requirements, which all can affect what type of housing can be built where, and also the cost, timing, predictability, and feasibility of housing development. And we're focused on what's within the city's control. So we aren't focused on things that we don't have control over, like state and federal regulations. And I think Eureka has removed a lot of major barriers since we adopted our last housing element. And so that's something I really want to celebrate to the state in the government constraints analysis. specifically our inland zoning code update and all the cleanup amendments that Planning Commission has helped us with since then including our 2026 amendment to remove discretionary design review Meaning that inland housing that's compliant with our zoning code can now be approved ministerially through the building permit process No sequa no public hearing no discretion So that's huge So the key opportunities kind of get broken up into regulations and process and cost. And I'm not going to go through all of them tonight. I'm going to just focus on ones that I'm most curious about your thoughts on. But definitely the first one up there, modernizing the coastal regulations, I would say is number one in terms of things that we need to do to reduce regulatory barriers and then just larger context the 2040 general plan which is the guiding document is really focused on infill development so that's why we're not exploring annexation or and we're focused on how do we get more housing within our currently developed areas. Also, the state is more so than when our last housing element was updated, is really focused on affirmatively furthering fair housing. So it's important to them that we create more economic diversity in our neighborhoods. So how do we bring resources to our lower income areas? How do we bring more housing options to our higher resource areas? That's something that they're really going to focus on. Also, now there's a state requirement that when you update your housing element, you need to update your safety element. And so there's a lot of the state really wants us to look at those together and to not cite housing where there's hazards. And so in the past, it's easiest to identify vacant sites and our vacant sites are all on our gulches and greenways. So that's where our past inventories have shown where we could accommodate housing. But we really don't want to do that. We want to focus on areas where there aren't natural resources. And then also there's just been more state legislation about focusing on wildlife and habitat connectivity. So that's another reason that we're trying to look at other options other than our Gulch Greenway areas. Although we still have some housing opportunities there that we are going to put in, but it's less of a focus this time. Also, Eureka lacks the type of market demand for housing that some other communities in California have. And so I think at this point, requiring more of developers isn't the solution. Like if you're a San Francisco and you say developer, you have to build affordable housing with your market rate housing and you have to do the X, Y and Z, it might be worth it to them to do all that and you'd still get housing. But in Eureka, because we're Not there yet, I feel like. If we impose more requirements, it's just going to mean less development. So one thing I want to highlight is that in our inland mixed-use districts, I think we're killing it in terms of being pro-housing. haven't seen it that like a developer wants to do more than what's allowed by our code since the 2019 update for inland mixed-use districts and not only can you do a mixed-use development by right but you could do a hundred percent residential project it doesn't have to be full residential units it could be micro shared housing and there's no max number of housing units per lot or per acre we don't have a maximum residential density there's no minimum lot area so you can subdivide in any way that makes the most sense there's no property line minimum setbacks typically no maximum site coverage no yard or open space requirements Typically no off-street parking required. In the coastal zone, we've prevented adaptive reuse of a number of vacant properties through yard and parking requirements. People want to add more units. There's per unit parking and yard requirements, and then they can't do it. And so not having those is huge for adaptive reuse. Also, we allow very tall buildings with a lot of floor area. And we have eight different ways that you can deviate from standards if you need to, beyond just variances. which are hard to make the findings for. And then, so where I think we have the most potential to improve is in our, other than the coastal zone, is in our inland residential districts. In the R2 and R3, this is showing where R2 and R3 are on the right. And then on the left, this is showing that our, R2 and R3, these are census tracts, but it shows kind of that they're higher percentage renter than owner. I just thought that was interesting. In R2 and R3, I think our most restrictive standard is the maximum dwelling units per acre standard. And so an idea to be more pro-housing would be to remove that dwelling unit per acre standard. and to regulate density instead just based on building massing, envelope, and design like we do in the mixed use zones. And so I looked at a bunch of projects that had been proposed. And for instance, this sevenplex on I Street, I think it's in the R2. Or was it H Street? It was H Street in the R2. It's nowhere close to the maximum height or far or site coverage for R2 or R3, but it's close to the maximum dwelling units per acre for R3, and it surpasses it for R2. Looking at a bunch of different projects that have come forward, they hit the maximum dwelling units per acre before they hit the other standard. So it's the limiting factor, I feel like. And it also is discouraging of smaller units, I think. Oh, you guys can stop me if you have thoughts on R2 and R3.

I have a question. What does FAR mean?

sorry, floor area ratio.

Thank you.

So it's how much you get a certain amount of building floor area based on how much square footage your lot has. So in downtown, it's the far of six means that for every one square foot of lot that you have, you get six square foot of building footprint. So if you have a 1,000 square foot lot, you get 6,000 square feet of building footprint.

Thank you. I know what that is. I just wasn't connecting FAR with floor area ratio. Sorry.

Yeah. So for multi-story buildings, you need a significant FAR floor area ratio. No, thank you. Tell me when I'm using acronyms that are not understandable.

OK, I'll keep going.

And then in the low density residential, a lot of our remaining developable area is in our R1, because a lot of our area is R1. A large percentage geographically of the city is zoned low density residential. It also includes our highest-resource census blocks. We don't have any highest-resource census blocks, according to the state, but we have a high-resource one around Mizzou and then a moderate-resource one on the east side. And so... Actually, can I interrupt you there?

Yeah. Could you go back to the other slide? So I was thinking about this when I was reading through the staff report and packet. I was trying to think of, like... It seems to me the zoning is one thing, but the actual land use development pattern is largely indifferentiable between the multifamily.

Yes. Yeah.

You would agree? Yes. Yeah. I mean, I figured I could do like a assessor use code query and see like what the proportions were within the R3 and R2 versus the R1. But I mean, as far as what the existing land uses were classified as. So it's like it's kind of weird that we have this sort of –

system differentiating between the southeast corner of the city and the northwest corner that's been the history of it is that we this yellow area happened after we got a zoning code in the 1950s so when we adopted our zoning code we were like any new area is going to be low density residential And then our existing neighborhoods we called like medium to high density residential, which is great because other cities down zoned their existing urban fabric and then basically prohibited missing middle housing, made it illegal. Whereas we've let our R2 and R3 evolve naturally into increased density with conversion of larger houses into multiple units and we haven't made that illegal but

I mean, I learned when I bought my home that it was R3, I think. But how many of the people that come in across the counter are aware that they're in a multifamily zoning district?

I don't think many people know what zoning district they're in. And you're right. The R2 and R3 neighborhoods don't look that much different at all, really, than the R1. They all look very similar. But developers know. When we updated our code in 2019 to reduce the minimum lot size in R2 and R3 to 2000 square feet, that got developers interested in purchasing R2 and R3 parcels and subdividing them. which is what is the idea for the R1 is to also reduce the minimum lot size to create more opportunities for smaller lots that could be sold separately because council really cares about creating more affordable home ownership opportunities. There's not that many 10,000 square feet lots that could be subdivided, but if based on the current minimum lot size of 5,000 square feet. But if we reduce the minimum lot size to 2,000 square feet, then that opens up most of the R1 to subdivision. And it would be really helpful to getting our housing element certified because HCD has given us direction that ADUs are not enough to promote fair housing in your single family residential districts. In the Bay Area, I've been told a lot of the jurisdictions were required to amend their code to allow for missing middle housing. They weren't allowed to just say, oh, in our single-family residential neighborhoods, we're going to allow ADUs, and that's going to affirmatively further fair housing. HCD didn't find that was adequate. So I feel like this would increase our maximum residential density to a density that HCD considers accommodating of affordable housing.

But with the SB9 provisions, you can go down to 1,200 square feet in R1 anyway, right?

Right, you can.

So we're just kind of shortening the gap between a conventional subdivision and an SB9 lot split?

SB9, you're only allowed to do one lot split once. And you have to live on the property for the next three years. So it's only of interest to a homeowner who wants to only split their lot once. It's not going to be interesting to... a developer who would wanna purchase a 6,000 square foot lot, turn it into three lots and build three units and sell them all to other people. um so this is an example from the r2 district where the beginning lot was 9 298 square feet so not quite large enough uh to get to for to qualify for subdivision currently in the r1 um but if we changed our r1 provisions then this could happen in the r1 too Any thoughts on that? Both those changes, the changes to the density in the residential zoning districts require also changing our general plan land use plan. So if we're going to do it, we need to do it during this general plan update when we adopt our housing element, safety element, and we'll adopt changes to the land use plan. Another opportunity that I'm interested in your feedback on is that if you look in our neighborhoods and you look for large lots, a lot of them are public facilities or zoning. And so an idea is to allow housing in the public facilities zone. And this is a The fire chief actually sent me this article today about how expensive it is to redevelop a fire station and how communities are paying for it through building housing on top of the fire stations. And so our fire chief is interested in this concept. He specifically mentioned Station 4, which is on Myrtle. It's the second picture that is desperately in need of being redeveloped. It's an aging building. And then talking with Heidi at the Jefferson Center, she had wanted, that's also a public facilities zone parcel, she had wanted to do a caretaker unit and couldn't because public facilities didn't allow housing. And so she's interested. Also, that Boys and Girls Club site next to the water tower, it seems to have maybe some potential space for housing. There's a number of Eureka City School properties that have space that's not being utilized, including this rectangle above the Eureka Mall. And then that last one is the Armory site, which is a state-owned site. But it's currently being used by the Conservation Corps, but they don't use that whole paved rectangle that I'm highlighting. All those would be opportunities for more housing, and we can't force other agencies to build housing, but if we allowed them in the code, then we're not holding them back from it. Also, I was thinking about religious institutions. They're definitely interested in the housing crisis and what to do about it. We've had meetings with them. This church on Hodgson in particular, their board voted to pursue affordable housing. They're really concerned about doing it in a way that's respectful of the neighbors. but they're interested. And so that got us thinking about large church sites in the R1 and how R1 density is dwelling units per lot. And so it really is not convenient. If you have a large lot, you don't get any more units. So changing those sites, upzoning them to like R2 or R3 or something is an idea.

Another maybe like...

Splitting the baby would be to just target sites with a history of like an institutional use and this giving them a specialized inclusionary provision for multifamily well We learned from HCD that there's been some case law development around like using overlays to up zone like you have to basically change the base zoning and land use designation of the property and If you want to go above your general plan density allowances.

The inclusionary or the combining zone or inclusionary zone approach has been challenged.

It's been challenged in the courts several that. Yeah. It has to be consistent with the density of your general plan.

I mean, on the same topic, like planned unit developments don't seem to be – I saw that you can create a specialized zoning district in the – It's a special considerations overlay.

Yeah. It's the same thing as a planned unit development. It allows you to basically deviate in any way you want from the zoning code, except that you still have to be consistent with the general plan. And our general plan says, you know, R1 is single family with ADUs.

Okay. Yeah. I mean, yeah.

There's also a state law that allows you to trump local zoning to build on properties owned by religious institutions. But there's all these caveats to it.

Yeah. Strings attached.

Strings attached.

Yeah. Like affordable or a fair wage or wage requirements.

Yeah. i just find it easier to i feel like it's easier for developers if instead of having all these like creative ways to deviate that are weird exceptions if we just like the base zone allows for it it's just like way more straightforward and clear signal do you think any of these church owners will bristle at getting up zoned uh good question i thought about that i thought about how they're tax exempt so it shouldn't be a problem but they are very concerned about not upsetting their neighbors so i don't know it would still preserve the use itself it would be a quasi public use or something like that that would be allowed that the religious institution wouldn't become non-conforming if it went to r3 or r2 Yeah, it's so interesting. Apparently, they didn't used to be allowed by our code because when we were researching these sites, we saw they all got variances in the 50s to be churches. But yeah, no, our code allows for civic institutions within all the residential zones. So it wouldn't make them nonconforming. And then, oh, go ahead.

The Seventh-day Adventist, or no, Christian Science Church on H Street, did they sell the parking lot that has been developed into apartments, or is that still part of their property? They sold it separately. Okay, thank you.

And then we got a comment from CRTP pushing us to remove minimum parking requirements, which is pretty much what we get every time we talk about the code. The thing is, with the new provision that the city cannot require parking within a half mile of a major transit stop, and then HCOG adopting so many major transit stops in Eureka, it begs the question of the fact that since we have so many exemptions and reductions already, should we just eliminate it for everybody to... altogether. That's, I guess, a question. And is this the... Do we put it in our housing element? Given that whatever we commit to in our housing element, we have to do. So I would recommend if we put it in our housing element, the action is not that we eliminate parking requirements, is that we take a vote to council on this provision. You know, like we... I don't want to commit to something I'm not sure will pass, basically, in a housing element. Because of all the implications of not getting your housing element stuff done, I think the action would be committing to taking an amendment to council to eliminate parking and then voting on it. Eliminating, sorry, not parking, eliminating minimum off-street parking requirements for development.

But that's limiting the requirement to have off-street parking.

Eliminating the requirement to have off-street parking. It's allowing the market to decide how much off-street parking developers will decide themselves how much they want. We've heard from developers that like high-end housing. parking is an amenity that they want to provide and there are studies that show that eliminating parking requirements doesn't necessarily mean that less parking will get built although our exemption for affordable housing is being used heavily currently and has been super helpful parking is especially tough Parking requirements are especially tough for small lots and spaces, and that's what we have left in Eureka is trying to develop on a smaller plot of land because it just takes up a lot of space. Unless you do structured parking or underground parking, but that's very expensive.

Can you explain the in-lieu fee? I always have to ask because it only comes up every now and then.

There's a $7,500 in lieu fee that you can pay instead of providing a parking space in the parking assessment district. But now the entire parking assessment district is within one half mile of a major transit stop. So there is no in lieu fee anymore. it's kind of been eliminated yes by virtue of the state yeah i do think in addition to i do think having especially in our central business district Public parking lots are huge. They're hugely important. They're hugely critical. We want people to share parking and use it efficiently. We don't want all these private individuals having their own parking lots that they only use when they're in their office or when they're at their residence. It's very inefficient. Public parking is what you want in your central business district. I don't know. So we need to manage our public parking better so that we don't get people developing private parking lots that just sit vacant when we have arts alive. And you're like, ah, man, that's such an underutilized parking lot.

I guess when I see this map, the thing that if we were to get rid of the parking requirements in the future,

That's kind of the last point of leverage that we have. It might go away in the years to come with subsequent state law changes. And I'm just wondering if it would be a place where, I mean, if they wanted to do another parking in Luffy for the remainder of the interior portions of the city that are not within a half a mile of a major transit stop, And I recognize that ADUs are already given a pass, right, in most cases. But could it finance some of the roadway infrastructure that is going to be needed? I guess, let me just connect the dots. I see us developing into a denser city. I mean, the 1,740 units are going to, you know.

And you're saying, how do we pay for public parking?

How do we pay for people to not drive cars?

Oh, that too.

How do we shift our roadways so that they're actually usable and functional so that someone might actually think of it as a viable means to commute within the city limits or connect to more regional transportation?

Luckily, the state is prioritizing bicycle and pedestrian improvements. So there is a lot of grant money out there for bicycle and pedestrian improvements.

Do you really think it's going to be enough? Because, I mean, we did the H&I Street stuff, but we kind of fumbled the ball as far as I'm concerned because we didn't actually create a barrier between the bike lane and the travel lanes. So it's not really what the full-blown version needs to be for it to be truly viable.

I know that the county has approached us about the idea of exploring a traffic impact fee. Again, apparently that might be something that's limiting their development south of Eureka because it was a requirement that they have a traffic impact fee to move forward with development that relies on the Martin Slough Interceptor Project. There's a possibility that we could do that and we can make it a multimodal impact fee. The problem is it's just politically not really a good time to adopt new impact fees. The state is now really focusing on those as something that's a barrier to development of housing. And everybody's dealing with really high costs of water and sewer impact fees right now. So layering another impact fee on to new development.

And it would conceivably be a constraint, right?

Exactly.

It's just I do have real concerns about that. It's like I'm all for growth, but I just feel like we're doing it without really planning for getting people out of their cars. And providing more parking and strategic locations is one part of the equation, but it's not for the residential area. Yeah. Yeah.

If I may add something. As a pedestrian, where I walk almost everywhere in town, the sidewalks are disasters. And if you're going to try and encourage more people to walk, you need to know you're not going to trip over unmaintained sidewalks. You're going to have to know that you don't have to go out into the street to avoid shrubbery that is completely covering the sidewalk. You're not going to have to go out in the street to avoid a home that's been there since the early 20th century and has never had sidewalks. There are a lot of issues. So I would just layer that on top of the bike lanes. And frequently, even on H&I, I have been overtaken as a pedestrian by someone on a bike

on the sidewalk who doesn't trust the bike lanes because there's not a yes a barrier yes so that's just yes i understand i understand that it's not what we're focused on tonight tonight we're focused on regulatory constraints and um permit processing and permit like development cost constraints uh definitely we have heard that Housing is tied to transportation. That's about investment in transportation infrastructure, and that's a separate thing. We're not talking about tonight what the city can invest in. We're talking about our regulations and what constraints we can remove from our regulatory processes.

And the only reason I bring it up, and I totally hear you, is just that if we remove that requirement, it may be silly to even think of that as a place to fund transportation infrastructure improvements. But I have to ask, because to me, I don't know where else we're going to locally generate it, you know, as a... Like a developer pays to put sidewalks in front of their place, but instead of you waive your parking requirements, you're going to contribute to a fund that will – it's like a mellow ruse for a park or a Quimby feed for a park. You're going to help invest in the next C Street bike network thing.

I think the larger point you're making is that if we remove all the regulatory constraints – then we lose any regulatory incentives that we can give people. Because if there are no constraints in the code that you need to try to get around, then there's no way to then negotiate for public benefits. And this is coming up with the infill incentive permit that we have. It allows regulatory deviations in exchange for increased density. And people haven't needed increased density in the inland portion of the city. And so it's gone unused because there's no, if you don't need the regulatory relief, then there's no need for the, but is that a bad thing? I, you know.

Yeah, I mean, if somebody comes in and saves the day, it's all who cares, right? But I just worry that there's nothing going to save the day. It's going to frustrate people to no end that we keep developing more density without actually trying to get people out of their cars.

I just don't think parking per site, private parking per site, requiring each site to have its own parking is the solution.

Agreed.

then the convoluted way to then like use that as a negotiating tool to get something else that if i was going to worry about getting money for parking i would i would just have a more general like just raise do some sort of like assessment district or something yeah i think that's it but if we do it in the only place we could do it well i guess we could do it across the city even where you're not required yeah you could that's a good point you could raise money for public improvements in a variety of ways.

So you could say all the areas in purple on there could be part of the assessment district, theoretically?

Right.

Okay. I'm done belaboring this. Thank you for... I just had to kind of ask. I felt a little concerned about that.

And then finally... It's not just about regulations. It's about the development process. And when we've interviewed developers, they talk just about how huge good or bad customer service is ultimately to whether they want to invest in a city or county. And I think some of our really good current best practices are that we have a free optional pre-application conference where we bring in building engineering and planning and fire ideally we have a planner on duty always to answer questions from the public we every time we answer a question we create a record and then we attach that to the property so that we because there's a lot of planner shopping and then there's a lot of inconsistency and responses We also problem solve code application questions as a group and then we make sure whenever there is an issue that we think about how we could amend the code to address that issue. in the past we never amended the code and we created all these like rules of thumb that were uncodified on how to interpret the code and now our philosophy is if something's unclear we just amend the code to make it clear and then i we do a good job of referring projects unfortunately we don't always get responses From people because the key I think with developers is is they want all of the information as soon as possible so it's like trying to get the other departments and the other agencies to really look at the proposal and give us their substantive feedback early on. And then. I'm really trying to get us to adhere to the Permit Streamlining Act, to accept the application, give them a full list of what's incomplete about it in 30 days, and then take it to hearing within 90 days. and not just indefinitely leave things. I want to keep them coming in and getting and moving through the cycle. And we have a lot of work to do still on that. But that's our philosophy. And I'm trying really hard to make it happen.

Can we go back to referrals for a minute? Yeah. If an agency does not respond, they have recourse to respond later.

It depends who they are. The Coastal Commission could not respond to our referral, but if they have appeal jurisdiction, they could still appeal the project later if they have an issue with it. So we'll pester departments and agencies if we think they will need to weigh in eventually. I think something we really struggle with is our silos and it shows on our website and in our permitting that everything's organized by department and that's not how the public is working and so it's hard for them to find stuff because we are so siloed and then also we have turnover of staff and that leads to inconsistency And we have a lack of checklists and other kinds of like self-help resources online. But I'm curious to what you all think we could do to improve our processes. And we're proposing housing element actions where we solicit feedback more regularly because i do um in interviewing developers for the housing element update i learned so much and i'm like man i need to do this more often so one thing that seemed like a good thing to do would be to do targeted interviews more often with people that participate in the development process and then also figuring out a way to have an optional survey built in because this last housing element cycle we did one survey and i sent out like 6,000 postcards and only like 60 people took the survey and then the responses were all really general like your process sucks you know and whereas I think right after you've filled out an application you can be like you asked this question that's not relevant and you can give us actual specific thing that I can then go and change And then I think we could do a better job of following up on stalled projects to see what happened. And then any other ideas would be great.

The reasonable and fair fees, is that a statement you feel you're reasonable or is that being worked on as part of the housing update is to make those fees more reasonable?

yeah that is definitely something we are hearing from developers is that our fees are not reasonable especially the sewer impact fee i don't think that is going to become more reasonable it's done through a study a rate study they're about to do a new rate study and i'm sure it's going to be even more because we are under a cease and desist order with our wastewater treated wastewater discharge and we have to do all these capital improvements to address that so The only ideas I had were like deferring the fees more So that you don't have to pay them all up front and They're pretty crazy. It's a lot of money.

I think the impact fees are huge, and any way you can control that or incentivize that. If the city's looking for denser housing, every time you add one of those impact fees or add another toilet onto it, it kind of defeats the purpose. Certainly deferring it over 10 years or something like that would probably be a huge help.

And I've seen that in other cities' deferral. You just have to bake in a way to get assurance that it'll eventually get paid off somehow.

What about prior to final or something like that?

We already do that.

This is not just a function of the city of Eureka, though. From what I understand, these sewer fees are pretty much statewide. Lots of different jurisdictions are having issues with deferred maintenance or any number of issues with their sewer treatment. So that's not unique to us, is it?

No, no. Impact fees are huge everywhere, and it's something that the state is now really honing in on. I feel like they've done everything they can with zoning legislation, and now they're thinking about the building permit process and the fees, the impact fees.

But that's another example of where it sets up this kind of impossible situation where, you know, they waive the parking requirement, they waive the can't require fundage improvements, can't require the impact fees are really reduced or nothing. But yet it doesn't change the capital improvement costs that are necessary, you know, in these communities and like these unfunded. infrastructure issues, like that's the kind of thing that I see coming to a head with all of the, you know, it's great for removing barriers for development, but it doesn't deal with this sort of like decaying infrastructure and needs of, you know, none of that's coming into backfill.

I know.

Easy to say. I just that's my real concern.

When our wastewater treatment plant was developed, it got a ton of money from the state and federal government. And there's so gosh, that would be great if somebody stepped in because that's not happening.

And so, yeah, more and more fees are going on development fees.

And that is chilling to development that you want. So it is definitely this whole thing.

It's probably acute in rural areas, too, because it's an economies of scale thing to some extent, you know, where you have an urban situation might be more diffuse. You don't think so?

I don't think so. Not based on what I've seen on impact fees in urban areas. They're just as big.

Any other – And I guess that speaks to your point earlier that, you know, where you have a greater market demand, people don't blink at it, you know.

Yes. How do we get the word out about – yeah, so I think – We've made so many changes in the last five and 10 years and people just don't know about them. And so we need to do a better job of getting the word out about all of the things that you can do that people don't realize they can do. Like you could have a boarding house and rent out rooms and they don't need to have their own kitchen and bathroom, anywhere in the city. You could have non-medical care housing anywhere. There's just, you can have, there's ADU, illegal ADU amnesty. There's the ability to condo-ize your ADU. There's all these things that people don't know about. So how do we get out the word about them? I know Brian Heaton, when he worked here, he was doing like a regular column in the Lost Coast Outpost. And that was really great where he would highlight something like affordable by design housing. So if there's anybody who likes to write for newspapers and highlight anything, that would be great. But yeah, any other thoughts on how we can get the word out?

I think I brought this up before, but I just – maybe I'll do it again. Or maybe tell me if I have. But what about a brokerage of some sort that the city administered that basically – you have these efforts to monitor vacant lands and – properties with development potential uh properties that are targeted for certain housing amounts like what if like there was like some kind of like you know somebody comes into the brokerage like i want to try to buy some property and split it off from an existing landowner but i don't own any property but if you could team me up with somebody who owns a parcel that has development potential i'll carry the water on moving it through the process and completing all the requirements. And then at the end of the day, I get a lot that I can develop. Is that something that could theoretically be a city-run thing?

Yeah, like connecting people who are interested in selling a portion of their parcel or partnering with a developer. And yes, and I think we could do that through I've seen Like on Santa Rosa's website, they have a housing opportunity mapping tool. And so I foresee us having something like this and we could have a layer where it's like known interested property owners and then somebody could go there. Because we do get calls from people who are interested in purchasing property. And if we knew more about who is interested in selling, I just don't know how much additional capacity we have as a city to be good at that. What I've learned from academic development department is like, don't do something if somebody else can do it better. But I think we could also, if we're not doing it, we could work with the real estate agents better and more closely to share information.

Right.

Yeah, I was on your previous thing, this whole thing. topic of getting the word out I mean it really depends on who the audiences are like some of them are networked together pretty nicely real estate agents have a place the builders have a place if you're talking about the wider public that's and you know people who might own a piece of property and might live here might not that's much more challenging But I think there's no substitute for getting in front of a bunch of eyeballs for those easy-to-target ones. And you might have, like, the top ten slides. I bet you didn't know you could condoize your ADU and hook people with some things like that. But the bigger public's hard, just hard.

What about through the first time home buyer program? Like if it was like, okay, you wanna buy a home and get financing to help with it, okay, we can maybe put you in touch with somebody who has vacant land or a property that could be split with a duplex or SB9 or something.

Yeah, through the programs that we administer for housing development or rehabilitation, we can use those as an opportunity to advertise things. So then the last thing is that we had a we're proposing to keep our current goal one from the housing element because I feel like it covers everything regulatory constraints related. And then we have some proposed policies. And I think it was unfair to give you just these and not all of the draft goals and policies. Because we have other ones on transit and parking and all the other things. These are just really focused on government constraints. So I can bring back the full list of draft goals and policies for us to look at at the same time. But if you have any thoughts on wording or anything.

I have a question about illegal unit amnesty. Is that just non-permitted or would it have to be brought up to code in order to have the amnesty?

Well, yeah, it would depend on what our provisions say. So our current ADU amnesty, you can get it as long as you meet basic health and safety requirements. So you don't have to be consistent with like zoning code property line setbacks or things that aren't really critical for health and safety requirements.

Are those basic health and safety requirements codified somewhere?

There's a list that we have online. Okay. it mostly is like you're wired right and you have the right uh um exhaust and things and yeah fire safety thank you how many illegal units do you think the city has in the city in in eureka i don't know is it a widespread thing or there's no estimate i don't i don't have an estimate i know I've heard of quite a few illegal ADUs. But yeah, I do not know. I do not have an estimate. We now have a really great inspector, Humble Bay Fire. I mean, not us. Humble Bay Fire now has a really great inspector, Hannah, who inspects three and more units. And she's slowly developing a list of all of our multifamily. But we don't have good record of... all of our addresses and where we have multifamily. We know where we have water meters, but sometimes people share water meters.

In the end with that Stanton vacation rental, did we determine that the four units in the house were lawfully converted to separate dwellings before they targeted it for short-term rentals?

In the house, those were all legal, yeah. That's R2 or R3, and so I do question. In those districts, I assume we don't have too many illegal units because we have been, people have been able to permit those conversions of space, but who knows? The reason we put that in there is that was something Planning Commission brought up last time. And that's it for my...

Can we go back to that slide about the historic? One thing, I don't know, I think I brought this up last time in relation to the conversion of single-family homes to multifamily and not getting kind of a clear, just like we don't know how many of them are illegal, we don't have any of them, how many units we're actually getting from our existing single-family dwelling housing stock. Does that make sense? In the sense that it's kind of evolved into multifamily housing, in some cases above board, but other cases maybe not.

Well, we know how many – the census data is what defines how many households we have in the city. So it's what people are reporting to the census.

So in that same vein, like, I guess with the historic – I was just trying to get us more credit as we struggle with the 1,740-unit thing, like, when we – When it comes to historic preservation, I thought it was interesting. I think it's a good idea. Correct me if I'm wrong, but what I read that goal to be basically was to, similar to designer view, create some objective standards that were codifying rules of the road that have been sort of informally used by the Historic Preservation Commission over the last decade. 30 years or whatever? Correct. Okay. So that's noble and great, but I do think we should get credit for the fact that we have a Historic Preservation Commission. It's looked at as an impediment to development, but the truth of it is that before we had it, everything had to go to Office of Historic Preservation, and the SHPO had to weigh in when it dealt with historical structures, and it was a pain in the ass. That was a huge step just to get the Historic Preservation Commission meant we were removing or streamlining the process for people, even though it sucks for... to negotiate these kind of questions about what's appropriate and all that.

So when would the SHPO have to weigh in?

Back before 30 years ago. I mean, we didn't have a historic, we weren't a certified local government with a historic preservation ordinance.

So if we weren't a certified local government and you wanted to remodel your house, and it's not on the national or state register.

Yeah, but there was a survey done in the early 70s that had certain weight, you know, because it was, you know.

I'm confused on what the trigger is for the SHPO. If you don't have a historic preservation commission, you have old houses, you want to change the siding. How does the SHPO get involved?

Probably on discretionary projects, maybe. That would be my guess.

Very few of our historic, actually none that we've done would ever, that have, the historic preservation review has been, no, that's not true. The Commissioner Adams project, that was a new, the third in G that needed historic preservation review. But typically it's just stuff that requires a building permit.

Yeah, that would otherwise be ministerial, I suppose.

It would not be stuff that, it's rarely anything that would come, would trigger CEQA.

I just know, I remember hearing that it wasn't like we wanted to go through all the trouble of creating a historic preservation ordinance and becoming a certified local government. It came with benefits of having local control over these decisions and not having to resort to Sacramento weighing in on these things.

So maybe in the CEQA process it helps us somehow?

Absolutely, yeah. I just think it's funny to look at it as an impediment when in many ways it was removing a kind of clunky, out-of-the-area kind of engagement process that was otherwise a little bit uncertain in the speak of those issues of like, I don't know, maybe the SHPO is going to say this is significant or something like that. I don't know. Yeah. Just a thought. But I do support the idea of codifying the objective standards that have been kind of rules of thumb. That seems like a good evolution.

A lot of cities are working on objective standards for historic preservation because affordable housing projects now you can't apply subjective standards to it. So they're doing it to protect historic preservation like San Francisco has adopted objective standards. because they're wanting to have a standard that applies. Because otherwise, you can't apply the subjective standards to affordable housing anymore. And because everything's ministerial now, there's no CEQA trigger. So without objective standards, you really have nothing.

Yeah, I guess in that context, it's a good point that it's really is additional stuff that would otherwise breeze through if it was just a purely ministerial without any discretionary.

I think it's still going to be trigger. Yeah, I don't know. We haven't approached it yet. It's going to be hard. In San Francisco, they've gotten all these reports over the years on properties with which character... What are the defining characteristics that make it historic? And so their regulations are really focused on that. They have already what the defining features are of a property, and then that's... The objective standards are built around those particular features, and we don't have as much... We talked to the... CLG, the state SHPO's office about it and they're thinking we first need to start with more analysis of what our features, historic features and defining characteristics are before we can get to objective standards. But because we are a certified local government, we qualify for grant funding for planning around historic preservation. It's just you have to submit your reporting, which we did this last year, but we have not heard back from them. And it's been months. But I think there's only one person in their office. But my goal is we can get money to do that.

What is the update on the coastal zone changes?

So when we go with the housing element, we'll also, when we do the, we have to do CEQA on all of the general plan amendments. So we're roping in the coastal element. So we'll do CEQA on the safety element update, the coastal element update, and the housing element update, plus any updates we have to make to the land use plan all together. So that's great. And then I will... work on our coastal zoning code and getting that done.

So you don't have a timeline?

No, because I'm working nights and weekends on like 50 other things. Like I just wrote a data center report yesterday. And I wrote the government constraints analysis for the housing element. So it's just I have to get the housing element done first.

Don't you think it should be part of the housing element? Because I think it's a missed opportunity for development in the coastal zone.

It was a commitment of our last housing element. We're behind on it. But if I don't get my housing element certified, there's all these repercussions. So I have to get it certified by the deadline. So it became the priority. Even though, yes, the coastal zoning code update is the number one thing we could do to remove regulatory barriers, I had to stop working on that to start working on the housing element update. And it is so much work. I cannot tell you how hard I work and how I work in my kids' room when they're falling asleep with a light. And I get really disheartened how much I get asked about the LCP update right after, like, I've worked so hard on something else. And I don't know what to do about it, because it is, I also want that the most. But I can't always set priorities for myself. They get set by the state and by council.

It just keeps getting pushed.

Correct.

Back.

Yeah.

Because it's been, I mean, I think I came on the planning commission in 2018.

It keeps getting pushed back by other priorities.

But it does seem like there's just a missed opportunity for development there that could help get to the goal.

Like the waterfront-specific plan, I had to turn to that because the grant deadline was due and we were going to owe back hundreds of thousands of dollars if we didn't adopt it. So I had to drop doing the coastal zoning code update to work on that waterfront-specific plan. And it's just like it keeps – those things keep coming up. And, yeah, but I have this goal that – After this housing element update, I don't foresee another thing. After this, I feel like the coastal zoning code could be next.

Don't say that.

And as we do the updates to the inland zoning code, all of that helps with the coastal zoning code update, too, because I can just translate that. And I have – Ben Noble worked on our inland zoning code update, and he just drafted Arcata's coastal zoning code, and it's very similar stylistically, so I can use – There's additional chapters that have to go in there on hazards and agricultural subdivisions and visual resources and archaeological resources. And so I can borrow from Arcata's, which is going to be helpful too. Or I could just quit and then it'll never get done.

You're the perfect woman for the job is all I can say. You have the unique skill set to really get over the hump.

For all the jobs.

Yeah, I don't want to give it to somebody else because I know what will get certified. I have the vision. And so it's a matter of getting people trained up to delegate the other stuff. And I have made huge improvements on that. I don't review permitting anymore. That's all Caitlin. I'm not a part of permit review and processing anymore. I'm just working on long-range planning. And I finally hired a long-range planning planner, Kelsey. So I'm trying to make changes to get to it.

And it was overdue long before you got here. I mean, it's not like it's all on your shoulders. Yeah, you're just the latest person struggling with it. But I feel much more optimistic with you at the helm than anyone else. Yeah.

We have the draft land use plan, the draft coastal element. We just need the draft coastal zoning code done. And I've drafted a lot of that. I just have a few more chapters to do, including hazards, which is just going to take me like two weeks of focused time, which I just haven't had in a couple of years.

But this housing element we're talking about tonight is a housing element for the entire city, both coastal and non-coastal, right?

Yeah, and in our last housing element, one of the key actions that HCD highlighted as a key action was the LCP update. And right now, our pro-housing designation is expiring. They only last for three years. And I can't apply for a pro-housing renewal because we don't have the LCP update done. So it's been flagged by HCD as well as, like, they are now saying we have to get that done ASAP.

But it didn't have a timeline, it sounded like.

They made me submit a timeline.

But the last housing element cycle.

We're getting in trouble for not having it done, and we're probably going to have to commit to getting it done immediately once we adopt the new housing element. But they understand that I'm busy now. Writing a new housing element. They understand that and I explained to them how We decided to go with the update to the inland code to remove discretionary design review first that was a choice because We knew we had the votes for that on City Council with our current council. So we went with that before I could have waited on that Amendment, but we chose to move forward with that. I ahead of the Coastal Zoning Code. And HCD, I think, somewhat supports that, although they haven't said that. But they haven't objected to that either.

But I'm sure they've heard of this thing called the Coastal Commission.

If you look at the Coastal Commission agendas, all their LCP amendments are triggered by HCD housing element requirements these days. That's like 90% of their LCP amendments are housing-related amendments required by HCD. That's the problem, is that the state has really, they have no requirement for you to update your LCP, but they have a requirement and a timeline for housing elements. So this happens, like, you know, the stuff that has a due date gets pushed ahead of the stuff that doesn't.

So you don't want us to ask about it anymore?

Is that what you're saying?

I mean, there's nothing we can do to help you, I don't think, right? I mean, to prioritize it or we are doing it.

No, and you're also not the one assigning me other stuff. So when you ask, I'm not mad at you. It's just if somebody is assigning me something else and then they immediately ask me afterwards where the LCP update is, it's frustrating.

I think we'd just like to see development down there. And also, I think it could help get us to the numbers that we need, right, to the 1,700. Yes. Yep. All right, well, good job.

So I took lots of notes. Are we at the point where general discussion and stuff is called for? Mind if I go?

Yeah.

So some of this is really general, some is just a few questions. When you say we're not looking at annexation, is that entirely financial? Is it, well, it doesn't solve the bigger housing issue where the city's borders are? What's the motivation for that?

We did an economic analysis of annexation when we did the general plan update in 2018. And the only one area that showed to pencil out was Brainerd. And that's why we annexed Brainerd and didn't annex other areas. I could see us doing another analysis of it at some point in the future. HCD has said that if we annex land, we can count that towards our current RHNA. So it would benefit us to achieve our current RHNA, but then we'll get a larger percentage of the county's RHNA in our next housing element cycle. So it'll benefit us for this housing element, but then it will just result in us getting a larger RHNA next time.

I just want to say that I think it's smart not to layer additional things on developers at this point, I do think. And I was heartened by how much of what you talked about tonight applies to all housing market, rate housing issues. I think some of these discussions go too quickly to the lower affordable housing levels and I do think that this is a kind of rising tide all boats and obviously that that Rena is allocated across housing levels I think the max units per acre increasing is a strong idea I write me down as a supporter of that a ditto with allowing public facilities and religious facilities to develop housing and I think communications there might be key to say we're not putting the screws to any of those folks to do it. We're making it possible for them to do it if they want to. I noticed that even a few weeks ago with what looked like a trial balloon, there were people saying And these were idiots on social media, but saying, you're going to make the church house your homeless? And it was just like, no, no, like three levels of no. But just something to be out in front of on that one. This is so general and threatens to be obvious, but I think anything that we can do to limit the uncertainty for developers up front and to help them cash flow, and that doesn't have to do with the level of fees as much in my mind. I'm realistic that I think we will continue to have impact fees that are substantial. But, you know, at cash out, over time for rentals, some mechanisms where it's not, you know, punching them up front and causing them capital carrying costs. And then something I threaten to be a broken record on is If there are ways that we can use these regulatory changes to allow for underutilized commercial spaces to be converted, I would continue to encourage us to do that.

Oh yeah, we didn't mention that tonight.

That's a question I had too. I didn't see converting commercial to residential.

Because it's allowed, I don't see a, what's the regulatory change we make to get more of that? I think you just added to the outreach. Yeah. Like, doing a good job. That's why at the next council meeting, I'm taking a vacancy registry ordinance so that we can at least... It's non-punitive. It's just so we can track vacancies. So that... Somehow we can do a better job of getting those reused. But that's the struggle. Yeah. We've definitely, in our site inventory analysis, have identified all of the underutilized sites or unutilized sites. But what to do with that information is the question.

I wasn't aware that those were being identified and called out. That's a useful step.

Yeah, we did a GIS. Our consultant did a spatial, like they did an analysis. And then it missed some stuff, which we basically went through the whole city visually and picked it all up. And we're going to be reaching out to people who own the properties to ask them if they're interested. And then we also did a, our consultant did an analysis of our two and our three properties that still have subdivision potential. And we're going to reach out to those property owners too.

Do we allow first floor residential conversions in commercial properties instead of storefronts? Or does the bottom floor have to or the ground floor have to remain storefront?

So in the coastal zone, in the commercial waterfront, it has to be a storefront because it's a visitor-serving priority use under the Coastal Act. In the rest of the city, it can be 100% residential. There are some streets that are designated pedestrian-focused frontages in the downtown and Henderson Center where you can only get 100% residential if you hit a certain density. So we allow the ground floor to be residential if they get enough units or beds.

Thank you.

Yes, from outreach we've heard everybody is hyperfixated on the vacant and underutilized properties because they're so visible and have all these negative impacts. And the question is, what do we do about that? We adopted this punitive ordinance that we aren't implementing because we're waiting on this court case.

But that kind of gets to the same point I was making earlier, which is if there was city acting and some brokerage capacity, if you're already going to reach out to these people to be like, hey, I just want to make sure. It looks like your property is vacant. Or did you know that you have development potential? Step one, check, right? So then it's just kind of like, would you be interested in developing it? No? What if someone else was interested?

That's what we're going to do.

So it seems like you're starting to work towards being in a position to broker those types of – transactions and i feel like it's something that we do around developing the site inventory every eight years um whether we could do it all the time i don't know we're just you know once it's been caught up here whatever formalized or made you know into a discrete list and it's like moving as you've got your housing element certified and you're moving into the next cycle throughout that cycle your your you're offering to kind of connect people to the set of other people that you've developed.

Yeah, I do think that could be layers on the GIS, housing opportunity GIS could be layers. Like, for instance, the analysis we did of subdividable properties, we could make that a layer that people can turn on and see.

Yeah, it just seems like, you know, for someone in the public, it can be a little intimidating to go, okay, well, I see this has got potential. I don't know who owns it. I guess I could go down to the recorder's office and find out, you know.

When we're trying to get property owners to say they're interested in housing, we want to give them something in return. And so that is what we are promising them, that we will help them and we will make their property visible to others and market it for them, basically, through our powers as when people are interested in developing, they contact us, we can...

So more than just the GIS layer?

right okay yeah we can look at the draft actions it's a lot of that it's a lot of us just communicating what's available and yeah anything else from commissioners

I want to thank you for an amazing set of presentations on this housing element I'm sorry that you're having to work in your kids bedrooms but I have learned a lot and it's clear that you've done a lot of work so thank you Kristen

Yeah, you streamed a lot. There's been so many changes over the past nine years that I've been on the commission, and I feel like you've made it a lot easier to understand for lay people and the community, and I recognize the hard work that you've done, so thank you for that.

And I couldn't do it without you guys. You're a great planning commission.

The love of balance. Okay, should we move on? We're moving on. It looks like no new business, and we do have a brief staff report.

Yeah, so there's a Planning Commissioners Academy coming up in Monterey March 10th through March 12th through Cal Cities. They switch off between it being in Southern California and Northern California. And this year, this upcoming year, it's going to be in Monterey.

That's north or south, the way they look at it. Yeah.

You're right. That's central, huh? You know how...

Forever debate.

Yeah. Nobody even recognizes anything north of Sonoma. They don't realize it's there.

Yeah.

So I have $1,000 a year in my budget for planning commissioners. I haven't training. I haven't used it in years. Unfortunately, I can't, like, go back and take the thousands that I missed out on. But... So I feel like I could send one or two of you to the training, depending on how much everything costs. And so I'm curious if you all are interested, and if so, if you could work it out amongst yourselves, who might be best to go, or if more than a couple of you are interested. I think it's really great opportunity not only to learn the basics about Brown Act and CEQA and all that, but also just to network with others from around the state.

Do you have information you can email out to us?

I just know it's happening because they're calling for proposals, but they haven't actually put out. Yeah, so they've told us it's at the Marriott in Monterey Wednesday, March 10th through Friday, March 12th, but they haven't told us anything else.

I was going to go, like, knives out to get it when it was Monterey with two R's on the agenda. Yeah, me too. Monterey, Mexico.

I really wanted it with two R's.

Monterey with one R. Still nice. Cow cities. Still a nice place. I think we collectively should take advantage of it. Somebody should go, and if anybody was wanting to arm wrestle, I'll concede, but if there is nobody else interested, I'll take the slot.

And I feel the same way. I'm not willing to get in an argument about it, but I'm certainly willing to go even if there is only one R.

And I guess, you know, I think you should weigh in in some way. I'll just say a couple of things that argue for and against me. For, I did just understand from Mayor Bergel that she plans to reappoint me for another four years, so... that would you know there would be time for it to pay off on the other hand I have been at this for a few years now so I the actual instruction in the room was maybe less relevant to me than it would be to Commissioner Duke or Commissioner Adams Meredith's been doing it forever and Steve's a professional so and there was something after I started or maybe was before but it was I

In Arcata, and it was put on by the FPPC. I just don't know. It's different from what you're talking about, probably. But it did cover some of the stuff that I benefited from.

And it was called a planning commissioner training?

I think so. I'm pretty sure. Yeah. I remember I saw Scott Davies was there.

I'll ask Jennifer Dart if she is.

So I don't feel like I need it because I got that.

Well, it sounds like there's interest. So I guess keep us abreast of information.

Yes. I'll bring it back when we get more information. And it's time to book it.

Great. Any other reports and communications?

That's it, except that, like I mentioned, at council on Tuesday, next Tuesday, the first reading of the rental registry will be on and a report on data center potential regulation. And then I was thinking I should bring that to you, that same report to you all as well, since if we do adopt data center regulations, it'll come through the planning commission. I Don't know I Don't think The coastal Part of it is gonna be part of the LCP update Because it needs to get certified by the Coastal Commission So I'm assuming we're gonna extend our moratorium for longer until the LCP gets certified In the Inland Code In the inland area of the city, there's just not that much industrial land at all. So I don't know with the inland code what will happen and when that will come. But that could come very quickly.

OK. Well, so that'll probably be on next month's agenda.

Yes. Great. And we have at least two other things due next month. So hopefully it can come.

Okay, great. We'll adjourn until then.

Awesome.

Can I just say one thing? I watched the appeal hearing at the council about the vacation round. I just wanted you to know that I thought you guys did a great job of encapsulating the discussion and the commission's deliberations on it. And even though they didn't uphold our decision, I don't think that there was anything to do with staff. I think staff did a great job. So just wanted to make sure you knew that.

Thanks. I'll pass that along. Yeah, I called my councilmen to tell them he was bullied, but yeah. So did I. Anyway, good job. We'll adjourn. Thank you.

Thanks.