Planning Commission - Regular Meeting

the Thursday. February 26, 2026 meeting of the Brisbane Planning Commission will now come to order. Staff, please call the role. Commissioner Funka here. Commissioner Gooding here. Commissioner Saiasan here. Commissioner Wadziaak here. Let the record show Commissioner Laauo is absent. May I have a motion to adopt the agenda, please? So moved. All in favor? I I

I. Motion is unanimous. Next is a consent calendar. If there is any member of the public who would like to remove an item from the consent calendar, please do so now. Uh is there anyone in the audience? I see no one. Staff, can you set a 30 second timer? And while we're waiting to see if anyone calls in, does any commissioner uh would any commissioner like to remove an item? No.

Okay. 5 seconds. All right, 30 seconds has elapsed. No one's raised their hand. Thank you. May I have a motion to adopt the consent calendar? I move to adopt it. Second. All in favor? I.

Okay. Next is oral communications. If anyone wishes to address the commission concerning items not on tonight's agenda, you may do so now. Anyone in the audience? Okay. Staff, can you set a one minute timer for folks at home? 15 seconds. All right, 60 seconds has elapsed. No one's raised their hand.

Okay, thank you. Next is written communications. We have none for tonight and there's no old business, so we will move on to new business. Tonight we have a Tonight we have a public hearing regarding 320 Mendescino Street 2025-UP-01-PE is an R-1 zoning district. This is for a use permit authorizing a parking modification reducing the required off- streetet parking from four to three spaces and covered parking spaces from 2 to one. This would allow for an approximate 73 square foot addition to an existing family single family dwelling. Joe Koul is the applicant. Staff, may we have the presentation? Thank you, chair. As introduced, this agenda item is for a use permit authorizing a modification to parking regulations of the Brisbane Municipal Code to reduce both the required number of off- streetet parking and covered uh parking spaces for an existing single family dwelling to allow an approximately 73 foot addition. The planning commission has the authority to allow any modification of parking regulations within chapter 17.34 of the Brisbane Municipal Code via a use permit. The approximately 4,800 foot lot is located in the R1 district of central Brisbane about halfway between Visitation and San Bruno Avenue and is developed with a three-level single family dwelling and a detached onecar garage. The home was previously expanded in 2015 when a 335 ft third-story addition was approved. At the time, the property was determined to have two off- streetet parking spaces, one covered and one off- streetet parking on Mendescino for a total of three parking spaces. This was compliant at the time. In April 2025, a building permit application was

submitted to the community development department for a 73 foot addition. As part of the plan check for conformance with the zoning ordinance, staff reviews parking compliance. The zoning ordinance prescribes minimum parking requirements generally based on the floor area of single family homes, but it also allows property owners to cumulatively expand homes up to 400 ft without triggering parking compliance. The 335t addition approved in 2015 combined with the current proposed addition is more than the 400t exception allows. Accordingly, per the zoning ordinance, two covered parking spaces and two more on or off streetet parking spaces would be required to approve the building permit. As shown on the applicant site plan, the garage is located towards the rear of the property with the driveway more than 70 feet long providing access from Mendescino Street. Due to the configuration of the lot, uh the location of the home and detached garage, and the location of a street tree, just three on or off streetet parking spaces can be recognized under the municipal code. One covered space in the garage, one uncovered parking space in tandem with the garage space, and one on street parking space within the frontage. No additional parking spaces in the driveway may be counted since tandem parking may only be counted when no more than one space needs to be vacant to access another. So even though the driveway can accommodate up to three more parking spaces that would comply with the design requirements for parking, we can't count them. Excuse me. Because the zoning ordinance only counts two tandem parking spaces and two covered parking spaces are required where the garage only provides one, a modification to reduce both the required number of off- streetet parking spaces

from four to three and the required number of covered parking spaces from 2 to one is necessary for the applicant to proceed with the building permit application without additional modifications to the site to provide compliant parking. To approve the use permit, the commission must make the findings contained within Bridgebane Municipal Code section 17.40 40.060 and 17.34.050. There are five findings uh abbreviated on the screen. Uh detailed findings are included in exhibit A of the draft resolution, but in summary, the request complies with all findings. One, the subject property is located within the R1 residential zoning district uh and is developed with a single family dwelling and adjacent uses on Menoscina Street are similarly lowdensity residential uses. Two, the proposed project does not increase the footprint of the home nor change or intensify the existing use. Three, the proposed project will not change the present traffic and or circulation conditions. Four, the subject property contains enough space within the long driveway to accommodate four parking spaces. The minimum requirement under the Brisbane Municipal Code for a similarly sized home. And these four spaces are in addition to the garage and existing on street parking space that will not be removed or altered. And five, due to the location of the home and garage, substantial alterations would be required to both structures to accommodate code compliant parking. This concludes staff's uh presentation with a recommendation of approval of use permit 2025-UP-1-PE via adoption of the attached resolution. This application was reviewed by the city's public works building and fire departments and any applicable conditions of approval have been incorporated into the resolution. Any questions at this time?

Okay, thank you Jeremiah. Um let's start with Commissioner Funka. Any questions? Um yeah just uh just a couple for uh clarification. So um the uh like if it's strictly per requirement the total number of spaces require would be six. Is that right? No four. Four. Okay. And the total available now is three. Right. To be code compliant. Yes. There will be three.

Okay. Uh that's one. And I just wanted to get a an idea of the difference between u what would be required and what is available now. Um and I'm just curious about what the second uh finding that you needed to have. Strict enforcement is not required and I wonder uh what does that mean under what conditions is strict enforcement required or are there some codes that do require strict I just wonder if you give an example. This is clearly one where it's not strictly required. So the the strict enforcement is I think getting to it's not creating an impact without the enforcement. So you know if if it's creating an impact then we do want to have that enforced right to make sure there's compliance. But in this case strict enforcement is not necessary because of some of the other findings there is no impact to the traffic or circulation.

Yeah. Yeah. And I would add I think the way I think of that finding is also does it would approving it require on like human behavior being a certain way. Okay. You know in terms of is it you know I think the findings you guys are making is is this um you know something that isn't easily accommodated by the site or something that's you know kind of relies on an extra element. All right. All right. And my last one is just is more observation part question is clearly that this addition that uh that is being proposed it's not like it would accommodate a whole new family that would create need for more cars, right? It's just expanding a bedroom basically.

It it's enclosing a deck. Um I guess technically under the code there's a there's a threshold. It's kind of a bright line between three spaces or four spaces and it's just going over that. But uh the actual addition, yeah, it's 73 foot small bedroom, right? Technicality is I guess what it is. Okay. All right. That's all I have. Okay. Thank you. Uh Commissioner Woodak, no questions right now. Okay. Commissioner Gooding, thank you. Um, a couple my understanding is that that we're here because the the small amount of enlarged, pardon me, the small amount of space on the deck proposed it to be enlarged barely kicked it over the 400 yes

square foot increment from the original floor plan. Um, so I get it that it seems, you know, minimal.

Um, my other my larger concern is that it's not just this property, but the next one, the next one, the next one. Um, is this manipulatable by people to to enlarge your house in increments and try to tuck themselves into, well, this is just one small increment, one more small increment and not have to deal with the parking issues that those create. Is there any mechanism in in how you guys review or how we respond to it to deal with that? Well, the if I understand that the mechanism is you you get to the 400 and then we say you do have to comply, but there is the the alternative path to request this modification,

right? But but let me phrase it with better articulation, which is it seems like um this is sort of open to people increasing their their interior sizes in chunks and not have to deal with the parking issue because each little incremental chunk just like just looks like one small incremental chunk, not the net result being a significantly larger house. Um, do we have any way to sort of prevent that from happening or or I'm a little bit troubled by your the statement of strict enforcement is not required. There's a certain point where it is, right? That's that's rhetorical, but um, and I think I I have the answer. Um, do we

I I think I understand I'm sorry to interrupt. No, go ahead. I think I understand where you're going. It kind of depends on maybe the baseline here. It's here's it's the increments of 400 that triggers the requirement. Is that right? It there's not increments of 400. It's just one one 400 cumulatively. So if you did 50 50 all the way up to 400, then when you get to the 400, we're looking at the parking.

Gotcha. That's the baseline from which the 400 is calculated. that that's the standard in the municipal code and it's it's based off of the the pre-existing floor area. Um so we're looking at when the building permit comes in, what is the current floor area and we look back at our records of additions that have occurred and we're calculating any addition any added floor area and if you get to the 400 now we're looking at parking compliance and we're looking at the total floor area of the home and how that matches up with the minimum parking standards in the parking chapter. Okay. And just to press the point a little bit more, let's say four years from now, another 400 ft or 399 square foot addition is asked for after this 400's already been done.

Yeah. I mean, again, we're looking at parking compliance, but I guess in this particular case, four four parking spaces is sort of the the maximum a single family home would need under the municipal code. So any further addition, it's still the four parking spaces. And I guess in this case, if granted, it's already been allowed that three would be required. But if they weren't compliant, it would be let's get the four parking spaces. And they once they go over the four 400 foot, they need four parking spaces. And if they do another 399, they're already at they've already provided the four parking spaces. They're already providing the minimum required. No additional no additional would be needed.

That's a very helpful clarification. I think I understand it better now. Yeah. Okay, I have a couple questions of the applicant, but um thank you. Okay, thank you. Um I have no questions, so I will now open the public hearing. Um may we uh hear from the applicant.

Hello. Hi. Is there anything you would like to say um through the chair? I'm sorry. Could you introduce yourself?

Sorry. I'm uh Joe Cool. I'm the designer and applicant for the project. Um the only clarification I would make is that um the motivation for the project in the first place is that the current roof deck that they're enclosing is on a particularly dark corner of the building. And um the overall motivation for the project is to prevent the mold growth that has occurred in that corner due to the lack of sunlight there. and with this addition kind of make the intended design of the existing building more usable for its intended purpose.

Okay. Thank you. Any questions for the applicant? Commissioner Gooding. So, you're the designer, not not the homeowner, correct? Correct. In that case, I I have no no questions on you. Thank you. Okay. Any questions? Okay. None. Okay. Thank you. Um, does anyone else have uh any comments? Okay, no one here. Um, staff, can you set a one minute timer for folks to call in if they would like?

We do have someone uh with their hand raised. Okay, Emily, you should be able to speak now.

Uh, thank you. Uh, I think it's Jeremiah who's talking. Uh, good evening, commissioners. This is Emily Warwick. I am a resident on Mendescino, but I'm also the chair of the complete streets and safety committee. Uh I would like to uh request that the commission um considers not allowing any uh reduction in parking. As you all may well know, we have a parking uh issue in our town. uh and I don't want the commission to be setting a precedent um that others can also request reductions in parking and they will be accepted. Um, this particular neighbor has four to five vehicles and I I would like, you know, when the commission is uh considering parking variances that they seek out assistance with the police department to perhaps do a klutz or to confirm number of registered vehicles with a resident. I think that would help you in making your decisions. Um, you know, the chair did mention briefly the behavior, human behavior. Um, this particular resident does not use the long driveway. Um, strictly parks his boat on the driveway and doesn't use the rest of it for the rest of his cars that he then takes up street parking for. While I do understand what the applicant's designer is talking about, no one wants mold in their home. My hope is that the commission can come up or staff can come up with a different way to accommodate the fourth parking perhaps with a different variance and putting a parking pad on the front where their grass is or something to that effect. Um, but I do request that the committee commission really strictly

consider not allowing uh eliminating any parking spaces in general as a policy for our residents in town, but also for this particular applicant. Thank you. Okay. Thank you. Anyone else? Jeremiah. No. Okay. Uh then may I have a motion to close the public hearing? So moved. Second. Okay. All in favor? I I Okay. Let's deliberate. Uh anyone want to start? Commissioner Gooding.

I'll start. Thank you. and and the the caller actually voiced um really well one of my concerns about this and I'm not uh I drove by there today and I did confirm that there's a boat on a trailer parked in the driveway and there were no other and there was a vehicle parked in the uh I'm not sure what to call it. It's not street. It's off streetet. It's parallel to the street which is one one of the the we call it on street parking.

Yeah. um that I inferred would was the homeowner's vehicle. The fact there's a boat on a trailer parked in the driveway strongly suggests that the enclosed garage is not used for car parking. Um and there were no other vehicles. It was daytime. Maybe they're at work that there were no other vehicles parked in the driveway, which is consistent with what Emily called and told us. So, um, this goes to, you know, everyone's concern about street parking in downtown Brisbane and that it's difficult and when people don't use the parking um, spaces that they have, um, I'm I'm a little troubled by decreasing the requirement for having spaces to begin with, not just for this homeowner, but the next homeowner. Um, so those are my comments. I haven't really decided yet, but if the applicant were here, it would be nice to get from them, pardon me, if the homeowner were here, it would be nice to get from them how many cars do you have and where do you put them? Um, are you, you know, are you using your your parking spaces responsibly for the neighborhood? It's to me those are important issues that that um, can you can you put back up on the screen at some point the the five findings that we have to sort of sign off on to approve this? And again, these are just abbreviated for the findings.

Sure. Understood. Understood that they're they're well summarized and I just wanted to recall them. I forgot to bring my pad today. Um, okay. I'll I'll stop for now. Let somebody else talk while I look at this. Commissioner Woodsak. And in this case, the spot four, five, and six don't count because of the two cars in rows that because of how we define tandem parking. Yeah. So, yes, four, five, and six, we would not count under the code because I also noticed there's a boat in number two, which suggests that the garage is not being used. And yeah, interesting. Okay. Uh, Commissioner um Funka, anything?

Uh, just a point of clarification there. There's no reduction in parking being proposed here, right? It's just that the requirement to increase the parking we're proposing that it not kick in because it's barely over the limit. Right. I I think what if I understand you? Yes. We're not eliminating any space where vehicles can park, but we are requesting that how they're counted is being reduced so that we can count it and be compliant with the code. And Jeremiah, can you clarify? So if they if the applicant changed the plans and reduced it, you know, and kept it under 400 square foot, they wouldn't need to come before us. Correct.

That that is one possible avenue. Yes. if if it was reduced so that we're only getting uh and I don't recall if it's less than 400 or exactly 400, but if they got it right at that threshold, then yes, we would not need a request because we would not even be looking at uh the parking compliance. But the boat would still be in the driveway and the neighbor's concern would still be the same. Just want to be clear about that. Yeah.

Yeah. That's Yeah. So that's my dilemma because granted I'm concerned about the boat and I'm concerned that they're not practically probably using their garage space but at the same time I mean we are talking they're here because of eight square feet right so I mean we want them to create more parking spaces but they don't necessarily have to if they if they change their plan slightly. So, do we force them to do that? You know, and and we still don't get the parking is what I'm saying.

Um I I guess I have an opinion which can change depending on what the other commissioners say, but I think that it's such a small amount over the threshold. It's not it's not an addition that's going to increase occupancy in the house to the point to where more cars are required. So, I think it's totally reasonable to um to not have the the requirement to make more parking spaces kick in in this situation. I think it's just kind of a common sense thing. I think the behavior of the occupant is to me a separate matter that should be addressed somewhere else. We should probably have parking permits in this city. you should probably be required to get a permit and pay to put your cars on the street. But I think I don't think that we should try and modify the applicant's behavior about parking boats in the driveway and use this particular exemption as a tool to do that. It just doesn't, you know, it requires a systemic solution in my opinion.

Yeah, I'm I'm glad you put it that way. Um because I I I can't disagree with the way you put it. um we aren't here and don't have the power to um compel this homeowner to um be more neighborly about where he puts his cars. Um it's a systemic problem in the city um that uh this particular application in this particular um factual situation is not not going to fix. So I would just want to convey to the caller who called in and that we are you know sensitive to that issue. Um but that I think we have to agree that that's not not u not the kind of human behavior that we have the power tonight to do anything about.

Yeah. I would love to see sort of a study of that. What what communities like Brisbane do have a parking permit system? When when does it when do we reach this stress point where that becomes like, yeah, we're going to do it. I'm sure it's been discussed and I should probably know more about it, but um you know, that's not I don't think that's on the agenda tonight. Yeah. Okay. Any more discussions? No. Okay, then. May I have a motion, please?

All right, I'll do it. I'll move to with our comments taken into account, I'd like to move to um approve the the existing application and to uh confirm the findings attached. There are two um I'll second that. Okay. Uh all in favor? I

I Okay. Motion is approved and um I will now read the appeal process. Anyone may appeal the action of the planning commission to the city council except where specified otherwise. Appeal shall be filed with the city clerk no later than 15 calendar days following the commission's decision. Exceptions include appeals for use permits and variances which are six days and tentative maps and advertising sign applications which are 10. There is an application form and fee. You may contact the city clerk for any help at 415-508-211. Okay. Next is items initiated by staff. Staff, I believe you have a SQA training for us tonight. Yes, thank you. Good evening, chair and commission. Um, yeah, tonight we have a SQA training and I'm very excited to introduce Mark Teague of Place Works. Um Mark is going to lead the training and go ahead and step up to the podium. Um Mark has over 40 years of experience in public sector planning as well as SQA work. Um he has worked in California agencies both large and small as well as the private sector. Um he regular regularly presents to the League of California Cities as well as the planning commissioners academy. And I'm not sure if you'll see him Darius at the March Academy. Um you will. Um, so we are just really excited to have Mark with us tonight and I will kick it off to him.

Thank you. Can you hear me? I don't want to get in trouble. All right. Thank you for having me and uh above all, thank you for being commissioners. It can sometimes be a thankless job and uh I respect the fact that you have taken the job upon you. Tonight we're going to talk about SQA, which is Latin for delays project. We're going to go through a few of the pieces here. I'm a little irreverent with this particular code having lived with it for so long, but the issue here is not to explain to you how to do SQA, but from your perspective as a recipient of the information and some tips and tricks along the way. So, without further ado, and I promise I did not do a 200 slide uh presentation, but it'd be nice if the slide moved. Next slide. Sorry, Vanna. We're going to go through the purpose of SQA. We're going to talk about uh who participates in the process, some key concepts that are important for you to understand, and then what do you do if you uh have impacts that you can't deal with. Um, and please don't wait till the end to ask your questions. If you have a question, this is a study session. Just speak up. And if I use an acronym such as SQA, which I don't define, California Environmental Quality Act, please call me on it. I don't like acronyms very much because it tends to isolate people from the information. It's handy when you're writing. It's not so handy when you're presenting. So, next slide, please. Got to be a reason this is Oh, such is life. Whoa. Now, it decided to move. There we go. The hundreds and hundreds of pages of information that you're going to receive, all of the technical studies, all of the all of the information

presented in oral testimony and written testimony before you is headed toward disclosure. The intent of SQA is to disclose the potential or probable impacts associated with a project. Now projects are defined many different ways. An entire or the the whole of the project is the phrase used in the code. So it's not only what's being applied for, but anything associated with needing the success of that project. So if you have a subdivision, for example, but you need to extend a water line or a sewer line, those extensions also need to be covered in the environmental document. So, if you get a document that stops at the property line and the analysis stops at the property line, that may not be adequate. And adequacy, not perfection, is what you're looking for. Do you have enough information to make a decision? Perfection costs too much and is impossible to obtain. One of the reasons that we use probable and possible effects is that just about everything in your document is based on an assumption. Sometimes the assumptions run to four or five decimal places. Doesn't make them any more accurate. It just means that somebody used a spreadsheet to calculate the number and gave you four decimal points. Just because a piece of information has that kind of assumed accuracy doesn't excuse the fact that it's based on an assumption. So when you're looking at a document, you need to first understand what the assumptions behind the analysis are. And they should be stated in the analysis. We refer to it as methodology. How did you go about evaluating this impact? Should be a brief statement ahead of the impact statements themselves. And it should explain to you, oh, we looked at this. We took traffic counts. We went out and looked for bugs and bunnies. We did this on a day when school was in session. We did this when it wasn't raining. We measured noise. Those things are important to provide you with the

assumptions that the analysis was based on because if those assumptions are flawed, the analysis is flawed and you're being led down a pathway that you might not enjoy. So, SQA at its heart evaluates change. It's pretty rare nowadays uh at least in this part of the world to have what we call a green field where no development has ever occurred. happens, but it's rare. Uh, in the central valley or in other parts of California where I work, green fields do happen. But usually, we're looking at what we call a baseline because if you're going to measure change, you have to first find out where you are, right? You have to have one end of the tape. So, you have to know what that is. Now, a baseline is an important consideration. It's a term used in SQA. It's defined by the agency themselves. And when I say agency, most likely your staff is going to be telling the the person preparing the document what baseline to use. Most of the time, baseline is existing condition. What's on the ground today? Okay. Um doesn't always have to be that way. If it was a shopping center and it just recently closed, you could use that. This was more important in the days when we were evaluating level of service for traffic than today when we're using vehicle miles travel VMT. But it's still essential. This used to be a noisy, busy, vibrant shopping center and now it isn't. Do you evaluate a green field, which it isn't, or you look at the shopping center baselines can vary, but inevitably there should be an analysis to existing conditions. Now that in that includes things you can see and things you can't see like any kind of contamination, anything below the soil, any improvements that may have been buried for whatever reason, power lines, water lines, those sorts of things. So change is what you're looking at. The first thing would be a baseline.

Uh you can also look at indirect changes, indirect and and global baselines. The baseline is often correlated to the impact being evaluated because some projects have impacts that cannot be contained within their property lines and some analysis goes beyond your city. Regional impacts such as traffic or regional impacts such as air quality or greenhouse gases. Those are, you know, regional or global in nature. And so you're just looking at your small corner of it. All of those things are defined within the document for the topics being talked about or should be. Lots of people are going to come to your microphone when you have a an environmental document. And I like to include this slide because it explains who's doing what. Uh the applicant is typically going on the hook for the cost of everything. Although not always. Sometimes there's evaluation and analysis that is being shouldered by the city. Uh your staff uh is sort of the hub of the wheel. All the information goes through them and the city as a lead agency. You're the one with the primary discretion over the project. Now there are also responsible agencies and that would be you know for example an agency like a sewer district that's responsible for sewer lines. They may have a small part of the project, but they're not responsible for the overall project. When the document comes to you, it you will be the lead agency. That means you have the primary responsibility for ensuring that the document and the process is adequate, meaning that we've followed all the laws. Um, you're also the ones that get yelled at if nobody likes the the uh the decision, but uh you already know that part. Consultants are interesting. We we are often in the shadows. I prefer to have

the staff present on projects and be there for questions because it's not my document. It's your document. And when we write these things, we write it through the lens and with the cloak of the community. Uh not all consultants do that. That's my preference because I grew up as a staff person and believe very strongly that if the city's going to present things, the city's going to be responsible. Not that you don't bring in technical consultants along the way to explain things and to help augment your staff services, but ultimately it's your document and we'll talk about that a little later because you're the ones that have to recommend certification or that it's adequate. And so you have to be comfortable with the people in front of you explaining things. The applicant will also have consultants. often they get paid more than I do and they'll have attorneys and those attorneys will have attorneys and it becomes this really lovefest of really highly paid people being paid to listen and respond to everything that you have. Um it's it's really important that you keep straight who's on which side separating the goats from the sheep because you need to understand the perspective of the bias that's being given to you. It's not overly complicated. Your staff will help you with that. But just remember, sometimes the highest paid, most wonderful flowing description coming at you may not necessarily be with your best interest in mind. Um, it just is the nature of how we do things. And, uh, refer to staff when you have a question. And that's a recurring theme that you'll hear from me, which is if you have a question, call your staff. Don't email, don't text. actually use the telephone to call and ask the question. Now, if you have a question about something you're reading or something you don't understand, calling staff puts them on deck to be able to have the answer for you if you want to ask the question at

the hearing. Not saying don't ask the question. What I'm saying is as soon as you put something in writing, it's part of the administrative record of decision. staff has to respond to it in writing to make sure that that is an is not an unanswered question and that it's all discoverable in the middle of a lawsuit. Not that you're going to ask or say anything improper, but for heaven's sakes, you have the telephone, you have the access to the staff. Skip that step. And then if you want to put it in writing, knowing both sides the answer and the question, knock yourself out. But at least at that point, call with your staff. Context is everything. Uh, not all agencies have the same standards. You've run into that, I'm sure. Not all agencies have the same issues and not all agencies solve things the same way. Um, so when you talk to your colleagues, such as at the planning commissioners academy, which I encourage you to do, you're going to discover some very interesting things. Like for example, in some communities, I can get a Starbucks with a drive-thru approved at the counter, no use permit, nothing. SQA, it's exempt from SQA because it's a small project. That's that community's understanding and context. Other communities, I've had to do an EIR for that same project. So while we all use the same standards, the California Environmental Equality Act, not all communities use the same approach. So it's not necessarily fair when somebody says, "Well, in such and such city, daily city, I don't have to do this." Great. Go build in Daily City. Don't build here. Here we have our standards. It's how we follow things. I think you can understand that, but SQL really reinforces that as you go through the process.

Now I almost deleted this slide in the next one because honestly in an EIR you this is tucked in an appendix somewhere if it's there at all but this is an example of the checklist. You'll hear the checklist for a lot of projects. Appendix G is where it's found in the guidelines. It's literally a list of things to think about. They are not environmental thresholds. not specifically says in the guidelines they're not thresholds. However, planners being lazy have used them as thresholds because communities don't want to spend the time and money to adopt their own. So many communities will just use the checklist and they will call this a threshold and use this. In reality, it's just a checklist just like bread, milk, donuts, the grocery store. This is aesthetics, biological resources, cultural and it helps us go through in a methodical way determine what impacts are. The point of the checklist 22 pages in, it's not a short checklist, is to come to this conclusion to determine whether or not you need an IR. For most of the things that you'll see, this has been determined before you get there. Right? This is something done at the staff level and the people have gone on their merry way and you end up with the final product. I put it here because you will hear and see this in excuse me in conversation with other commissioners and I wanted you to have some basis there and if I forgot about it somebody would yell at me. So we talked a little bit about the baseline. We're going to talk about thresholds of significance. So we have one end which is the measurement right the beginning of the baseline we're going to draw the tape and we're going to measure. Well information without analysis is useless. So what we need to

know is how far in that tape do we go before there's an impact. What are we looking for? Is it a problem if it's this big? Is it a problem if it's this big? Right? And because everybody's slightly different this has to be unique to your community. Now you can adopt your own thresholds of significance. In fact, the secret guidelines implore you to do so because remember the checklist is not guidel thresholds. But in reality, there's a point at which you care. There's a point at which the community cares whether this impact is is here or not. The conversation that you had just in the item just before you danced around the issue of the threshold. At what point do you need to do this? At what point is this important? That's the threshold. So, we talked about the baseline. There's my tape measure. It's defined by the agency stated in the document. The reason I keep hammering this point home, this is significant because if you're going to measure change, you have to have an unfixed mark to measure it from thresholds. It's a quantitative or qualitative determination of the end of the line. Right? This is above this we care it's a significant impact below this it's acceptable and that needs to be looked at both from the individual impact associated with the project itself and cumulative impacts a collection of projects as you were discussing earlier that was a wonderful explanation of cumulative if we do this for everyone that's an issue and so it's important when you look at the threshold to determine what it is for your community now they can be low, such as requiring an EIR for a drive-thru at a Starbucks, or they can be high, meaning you can approve them at the counter because you don't care about the noise. You don't care about those things. Um, there are certain things within the

code, within secret guidelines we call exemptions, which is where the legislature has stepped in and said, "Yes, there are impacts, but we don't care. Building a single family home, for example, it's typically doesn't trigger an environmental analysis. Thresholds can be found at all sorts of places, not just in the public resources code. They can also be found in your general plan uh and in development standards. So, for example, in your own code, it talks about construction activities and when they can occur. Now what's interesting about this particular code is it ignores by and large how big things are constructed and it assumes at a certain level that everything can be done very quietly. Uh I once did a project in Southern California for Amazon Amazon fulfillment center. 3 million square feet of warehouse under one roof. It's a big building. Even in my world that's a big building. So 3 million square feet monolithic pore. That means that the floor of that three million square feet is one slab of concrete. Mindboggles at that point, right? In the code for the city of East Veil, there's a provision that says construction can only occur between 7 and 7 weekdays, no holidays, no weekends. And so that's what we wrote into the mitigation strategy and the requirements for the project. So about six months and now in my defense, I did ask the applicant, "Is this okay? Can you do this?" So about six months after the project was finally permitted and we're getting ready to break ground, a fellow comes with a tool belt, a faded vest, a hard hat, work truck, and he comes to the counter and he wants to know what idiot put this provision in

the conditions of approval. It's me, sir. I took care of it. So, I come to the counter and I'm talking to this fellow and he said, "Son," which was funny because it was only about 10 years ago and people hadn't called me son a while. Said, "Son, let me explain to you how I build things." So, they start pouring 3 million square feet of building day one and they don't stop 247 all the way until all three million square feet is poured. Right. Well, obviously if you have a provision like this in your code, that doesn't work. Can't do that. So, what do we do? Well, some codes have an out. Thankfully, ours did. Building official was allowed to say, "Yeah, my planner's been an idiot. We'll fix this." Um, but if you're going through an environmental process and you're going to exceed a threshold for a reason, you write that down and that becomes a statement of overriding considerations. We're going to do this because we have to because this is how it works. Don't get buried in the code thinking you get out of jail free. I've seen some zoning codes that says, "Well, if you don't build on the weekends and you don't build after or after 7 o'clock, you have no noise impact." Wrong. There is a noise impact whether it's significant or not or whether you care bases based on the amount of noise that's generated, not when it's generated. So there are lots of little nuancy things to bring into. The point of this slide is to suggest to you that thresholds for your community can be found in different places uh such as your own development code just fall on the ground.

I wonder I I have a question. You did say it's okay to absolutely go. All right. So these are um you know pretty objective measures. You've got light and you've got noise. You can stop a project. You can fix it in a day. How about threshold when it comes to environmental impacts? Let's say species diversity or something like that. That's something clearly once a project's done all you have I guess all you have at the beginning is estimated projected impacts.

Correct. And well, it's kind of too late once the project is done. But I just wonder how how do you estimate effects there? Do you basically go with the assumption there's going to be a 25% reduction in species diversity and this city the codes are going to say, "Yep, that's too much. That meets our threshold." So you have to believe the assumption and something like that.

That's the dirty little secret of SQA. We're disclosing what we can disclose, but there for some there are no absolutes. Uh, how how far do you go with that? H how far do you establish a threshold? And I'll even do you one better. We're going to lose deer and bunnies. Deer and bunnies aren't a protected species. And if you go through the the law as it's established for that particular impact, you're stuck with the species list, the endangered and threatened species. I won't get into the difference between the feds and the state right now. That's in disarray. But let's go with the state. They have a long list. Studies will look at what's on that list and make a determination whether that individual species is there or if there's habitat that would have that species. On the federal side, the habitat is alone alone is enough for you to assume a species could be there. That could be frustrating because you know it's it's a bull wall. How do you know it's a vernal pool? And their response would be how do you know it's not? Right? And there's a protocol for for studying it. So, you're 100% on point. Uh, sometimes you have to make a decision with the information you have in front of you, and it's both frustrating and gling. Uh, but you have to lean a little bit into regional plans, into statewide plans for certain things to decide whether or not a property is there. So, it's really popular in some areas to do things called habitat conservation plans. The concept behind them is really cool. Let's take a look at an entire region, map out the species of concern, endangered or rare, uh, and make sure that we're maintaining habitats and wildlife corridors for those species. It sounds awesome until you get all of the agencies involved and then it becomes a work by committee and it becomes such an ownorous regulatory process where the cities don't know what they're supposed to do, the applicants

don't know, and the property owners are suddenly pretty frustrated. it it it's it's much more complex. That's why you shouldn't rely entirely on the the checklist. You should have these discussions before projects in front of you because once once it's gone down the channel based on your current standards and your current approach, it's almost impossible to make significant changes or just deny the project. Okay. Um, and so if these things are of concern to your community, wildlife corridors between preserved open space, you put those in your general plan, they become a threshold and we're we're gold. Did that answer the question?

Yep. Outstanding. And thank you for asking it.

So, I like this graphic because it shows what's happening. When you say proposed action, it's planner speak for proposed project, which is planner speak for what's before you. Um, and then you can see with and without mitigation, and we'll talk about that in a moment. But you'll see the pink line there is threshold of significance, and that becomes important when we're talking about mitigation. That is the level to which we mitigate. Zero is not the level. And I have to say that and I put a little asterisk unless we're talking GHG, which nobody really understands. Um, at the local level, globally it's important, but at the local level, it's hard. Greenhouse gases. Thank you. Called me on it. Mitigation measures. Now, this is where the teeth of SQA come into play. Mitigation measures are conditions of approval placed on a project to reduce or eliminate an environmental impact. It's pretty simple when you say it that way, but they also have to meet the constitutional standards brought to you by Nolan and Dolan. You don't need to know that, but brought to you by the Supreme Court that says that has to be roughly proportional to the impact. So, if this is your project, this can't be the mitigation measure, right? You can't make a 7-Eleven put in a freeway overpass. Just doesn't fit. Um, they also have to be they have to answer the question, right? You can't require a mitigation measure over there for an impact happening here unless you have pretty good evidence to suggest that that matters. So there are bumpers on these mitigation measures. The mitigation measure, now this is Teague talking, must be measurable. Has to be objectively measurable. You have to know when you've done it and the public needs to know when you've done it because otherwise it's an idea. It's a hope. It isn't

something useful. Now, mitigation measures unlike conditions of approval have to be based on a significant impact discovered in the environmental document. So if we go back to this little graphic, if your project without mitigation is that gray box, you have no authority to establish a mitigation measure because nothing exceeds the threshold. It's a really important concept here because occasionally planning commissions and councils get all excited when they get a big project and they just want to keep throwing mitigation measures at it. That isn't legit. Now, in order for it to come before you, it's discretionary and you have other powers. Make them conditions of approval. What's the difference? One of them's negotiable. Conditions of approval are negotiated with the applicant. Mitigation measures, that's pretty much a cut and dry. Remember, it's got to be measured. It's got to get there. Now, occasionally, mitigation measures also have their own environmental impacts. If that's the case, then they need to be evaluated in the environmental document, at least in a cursory fashion. And the last thing I'll tell you is SQA doesn't give you a cloak. You can't jump buildings in a single bound. Gives you no powers you don't already have. So what that means in a practical sense is if you want the state of California to do something with their property or fix a road or you have no way to compel that and therefore it's not adequate mitigation. You can still require it. You can say mitigation, but you have no way to compel it to happen. And at that point, we have an unmititigated significant environmental effect. That requires you to do some findings. And if you still want to act on the project, that's a big deal. And a lot of cities get in trouble because they try to establish mitigation outside their

jurisdictional boundaries where you have no authority or on property, state, federal, tribal, where you have no authority. And that becomes a problem. We don't just jump into mitigation measures. Maybe 40 years ago, you had, you know, Ace, the developer who decided that he was just going to pave the planet. Nowadays, most developers are pretty enlightened. Uh it's easier to avoid an impact than it is to mitigate it or to address it. So, they build these into design. It's a way if you have a wetland here and you can build your project without messing with this wetland, you do it. It's faster, better, cheaper. And if you're in a profit motive, you don't want to pave the wetland. They try to minimize the amount of permitting they need to do. If those don't work, they have to do something on the site. Then we can rectify it, reduce, eliminate. The last one is to pay a fee or compensate because it's very complicated to make that happen. So for example, wetland. You want to take out a wetland If you want to replace that wetland, you not only have to find a spot that isn't wet and create a wetland. Remember, you're creating something you're destroying, it's usually done at a larger than one to one ratio. So often it's three or more to one depending on the value of that wetland. And here's the fun part. You have to establish an endowment that ensures its maintenance in perpetuity. That can be a lot of money, hundreds of thousands of dollars depending on the size of the wetland. if you can even get there from here. So, we try really hard not to mess with things that we have to compensate for. Sometimes you can't get out of it and you have to and then that's where the real tears start on everybody's side. When you're looking at a mitigation measure, I want you to remember T exacum. Can an independent person measure it? Is it objectively

measurable? Can we do it? Is the mitigation measure feasible? Uh years ago it was really popular for people to propose greenhouse gas mitigation credits. You write a check, you plant a tree in Brazil, right? Um but then they run into somebody like me who says, "Well, how do I verify that that tree got planted? How do I know it's still there?" And the part that drove my technical team absolutely nuts is if this is my impact, how many trees must I plant to demonstrate that I've mitigated for that impact? And can I have the substantial evidence to get there? Substantial evidence meaning enough studies that I could tell the judge, well, based on these studies, no. And the reason the development community loved the idea of planting trees in Brazil is it's cheap, right? and you write a check and that isn't adequate under SQA and it isn't adequate with the agencies we work for because while you all are the intended audience, I have to stand in front of a judge or an attorney does. I don't have to do that. Um, but they yell at me if they can't get this stuff right. So, you also want to know who's paying the freight. Now, obviously, most of the times it should be the developer, right? They're getting the benefit, but not always. Sometimes the agency has a horse in this fight and they have to do something in there. You need to know who's doing it. Timing. When will that thing that you've said be done? Now, timing usually has one of four times. Before you approve it. In other words, I want to see the study before we take it to the planning commission. After you approve it, but before permit issuance, which means if we told you to do something, we want to make it happen. during construction, which is after the permit is issued to construct. These are things like making sure we don't have

erosion. And then during operation now, I don't like the operational ones because you lose all your leverage once you give them a certificate of occupancy. You lose all the leverage. Um, but sometimes you have to do things. And then lastly, of course, are there any impacts of that mitigation? If I have to build that freeway overpass, yeah, there's impacts, right? And just plop one down. So those all have to be addressed before you have an adequate document. I know I realize I'm making this sound much more complicated than it really is. U this is pretty lineal in most cases because we haven't we're paving a site. The site has storm water runoff because it rains regularly and we have to figure out what happens to that. In most instances you have a process in place already to address those right. You have storm water uh pollution prevention permit, right? SWIP, and it has requirements for erosion control and keeping things on site. You have low impact design standards for storm drainage. The environmental document will tell you what these are and that it solves the problem, right? So, you don't have to make this stuff up. It should all be in a story told to you in the environmental document. If you're not comfortable, then somebody needs to explain that to you. And then I think at that point, we as planners, authors have failed because we're supposed to be writing this for the public, not for the judge. Judge gets his piece a little later on. So, we talked about this. There's your mitigation target. It is the threshold. It is not zero. There are exceptions to this, but we are not going to talk about them because life is too short and it's too complicated. If there is an exception, it'll be brought up in your environmental document. Usually the exceptions are because the state has adopted some law or a judge somewhere

has made some sort of court decision. Um, a few years ago, uh, there was Newh Hall Ranch. I don't know if you heard that name. uh that literally shook the snow globe through the entire environmental community because they decided to mitigate to zero and then that got grabbed on to by state agencies and now that's often a request. So not only are we going backwards to 1990 on some of these thresholds, they wanted to go to zero. I just I don't I don't know how you reconcile that. Let's talk about public comments. Now, I am not one of those to tell you that the public is bad and that's it's the most ownorous part of the process. Uh I am relatively unique because I used to be a planner uh that had to answer questions at the counter. I like the public process. I think this perhaps or arguably is the best part of SQA because as I've mentioned, every community is different. Your thresholds are different. Your your context, your your tolerance for things are different. Why not let the community say something? Could it be done a little differently and a little better? Absolutely. I like the way NEPA does it a lot better uh in terms of how you do your public comment, but that's not important for what we're doing here. What I want you to know about the public is often they're passionate and they'll get up here and they'll call you all sorts of names and they'll pound on the podium and they'll say how bad you are and people will clap and all of those things. If you're not passionate about where you live, you're probably living in the wrong spot, right? So don't react to that passion. Listen instead for anything that they've said that is gerine to what you're talking about. Right? I have to answer a lot of comments or respond to a lot of comments in the environmental process where they question whether my parents were married, whether I have, you know, enough brain cells to function. I mean, some of the comments get pretty rude,

but every now and then they bring up something. Oh, that's an issue I should think about. and will change something in the document or will you know even I've even gone so far as says I'm sorry this was unclear here's a better explanation of this again my audience is the public I would suggest to you too that not everybody who is opposed to the project will show up not everybody in favor of the project will show up this is a small small sample size for your community make sure you're looking at all the information not just the folks that are in here yelling at you. Late hits or what we talk about as like a a driveby, a document dump. It's when usually an attorney, okay, always an attorney walks in with a couple hundred pages and sets it on the clerk's desk and says, "These are my comments." Now, it's totally legit. There's nothing wrong with it. It's what happens. It's frustrating to those people that don't do this on a regular basis, but I would caution you, take a break, right? Let your staff take a look at it. Uh, take a look at what's in there. Most of the time, it's repeating what was put in during the public comment period. I'd say about 85 to 90% of the time, we already know what's in there, but that 10 to 15% may be worth continuing the meeting for. and your staff will be the ones to help you with that piece of it. But just don't don't get in a hurry. Don't say, "Well, we've been doing this for three years. We need to decide tonight." I mean, the applicant will tell you they'll be crying and renting of teeth. But often a small delay to resolve an issue is better than hurrying up and missing something that you'll lose in court because then you got to go all the way back to zero, all the way back to start. You don't get to don't get to pass go.

You don't get your $200. It's pretty awful. Um, staff can guide you on all of those. Embrace the passion of your community. I mean, there's these are the folks that are most impacted. This is often a common question that commissioners have. It's done by the time I get it. No, it's not. If it was, you wouldn't be getting it. We don't tend to bring things to you that you don't have a decision-making ability on. It's not written in stone. If you see something you don't like, call your staff. If you've read something you don't like, call your staff. You are literally the last stop before it starts to go down the process where the only other people to weigh in will, you know, be the judge. So, I would suggest to you that if you have a question, call your staff. Um, I don't know if you do this here, but in many communities, we do one-on-one briefings with the commission for big projects because we live with a project. I have a project in Southern California right now. The EIR is 16,000 pages. The attachments are another 40,000 pages. So, I'm going to give it to you on Thursday. We have a planning commission meeting next Tuesday. Hope you have a nice weekend. But what we're doing instead is we're summarizing the key points of that document and we're having one-on- ones with the planning commission. We don't want to know how you're going to vote. We want to explain the project, the information you have before you, and we'll let you let the commissioners know. So, if it's a big gnarly project, you might want to talk to folks about what the findings of the EI are on are because remember, it's your EIR, it's your staff, you have the ability to ask questions and then if you want to repeat them in public, absolutely do that. Absolutely. Once I get chasened by planning commissioner says, I want the public to know what I'm doing. Not telling you not to do that. I'm saying that it's more effective if you've given your staff a heads up and

they have the answer for you. So, hello. Maybe please help me out here, brother.

Bless you. Final ER. Now, the final EIR is where we tie up all this into nice little bows. We have all the comments. We have all the responses to those comments. We have the IRATA, which is changes to the EIR. Sometimes the changes are because we find typos, believe it or not. Um, sometimes it's changes because the project has changed slightly. It's a new graphic or whatever. And sometimes we change them because of the comment. Right? I told you I've I've changed the EIR in response to comments. I like doing that and and I don't like doing but I mean if I do that I say uh this was change was made in response to comment such and such because that way you can demonstrate to anybody looking over your shoulder that you paid attention to the public and you made a change in the document. Um there's a response to every commenter. I like to be polite. Not everybody is. Uh, and I like to answer the question if it's at all humanly possible. Even if it isn't on the project, that changes for other people. Uh, you know, all you're required to do is provide a well-reasoned response to the comment. Part of the final EI process is to get you here. Now, as I remember, we have mitigation. We have impacts places where there's no impacts. We have mitigation measures that have reduced impacts below the threshold of significance and this is unique to ERS. We have impacts that we cannot reduce to a level below the level of significance not below the threshold. What do you do? We don't stop. You can make a statement of overriding considerations. Now these are the most interesting parts of the document. And I I scratched my head a little bit because for two to six years I'm being objective. The environmental consultant has to be entirely objective. I don't care whether the projects approve or not. What are the impacts? If I don't

have that objectivity, I'm leading you astray and things go bad. And then the last five pages of the findings is usually where the statement overrided consideration. They asked me to write them like even though you found all these impacts, isn't it still a great project? Wouldn't you like to do this? I don't know. And I would suggest to you, and we'll get to this in a second, that you should really pay close attention to the statement of overriding considerations because what it what you're doing there is saying, "Yes, there are going to be impacts in my community. However, the benefits of these impacts outweigh the environments of the project outweigh these environmental impacts." That's a that's a balance. So, SQA does not stop projects. The environmental impact report is designed to allow you to decide on a project even if there are significant impacts. It is unique in all of the documentation we have and it's something that folks opposed to projects never seem to really understand. If they you must do an EIR, okay, it's costly. It takes a little time, but once they've done that, once they've done that EIR, they can say yes. You can't do that with with anything else. You can't do with an exemption. You can't do with a mitigated negative declaration. You can't do it with anything other than an EIR. So, that's the part of the findings. Now, the findings are essentially the EIR without the pictures. So, it's reorganized for attorneys. This is really where I said the rest of it is designed for the public. the findings really start to weigh in on the first brief uh that we'll go to the because it says here are the impacts, here's the solution, and it's just matter of fact. There's no in between text. Um and then the statement of override. Uh when I was talking to your staff before we uh we decided to let me come

and bore you this evening, um I put this slide up. It's how to read an EIR. And except for 16,000 page documents, this is how a consultant reads an EIR. And this happens more often than you'd think. Somebody else is working on a project and somebody's daughter has a dance recital uh on the night the hearing or they get sick or whatever. You got to stand in and it's Monday, hearing's Tuesday afternoon. How you going to read that EIR and be competent that evening? So, no, I don't sit down and write page one. This is not a novel. No ER will ever make the New York bestseller move ever. You do not need to read it cover to cover. It's unnecessary. Most of it is regulations, thresholds, stuff that is pertaining to the analysis that's there to demonstrate for people to be there, but it isn't going to tell you anything. Skip all that. Assuming you know a little bit about the project, set it aside and pick up the final EIR. Yes, that means you skipped all the way to the end of the book to see how it turned out. You know how it turns out. It's going to come in front of you. The final is going to tell you several things that you don't know when you first start out. First of all, it's going to tell you what changed, right? Okay, there's an arata section, right? It's going to tell you what changed. So, if you read the project description, it may not be right. And in fact, there may be new mitigation measures and new impacts and new information come out in the final IR that you wouldn't know about if you started at the project description. It's also going to tell you who's annoyed about this project. Lots of people get annoyed. Some of them hire very expensive and very talented legal firms to tear apart the EIR. I know this because I get to work with them. They're going to tell you what's wrong

with your document and why you shouldn't even have let us in the building. Then there's a response to those comments. Remember, all of those comments have to have a reasoned response. We'll tell you how we addressed it. We either said, you know, you're wrong. Uh, go pound sand or oh, we've changed the document here and the change isn't significant. So by reading what's changed in theata and by reading the final IR and I would I would prioritize the length of your attorney letters not because your public isn't important but because those folks are going to cover soup to nuts and if you read a 20page letter you're going to get the gist of what the impacts are from their perspective. Then I would read the findings. Remember I told you the findings is the EI without the project. It's going to tell you now the findings will be accurate because we base the findings on the ARATA. We've changed a mitigation measure, it will be in the findings. If we've changed some analysis, it's in the findings. And so that skips most of the bulk of the document. Then read the staff report. I know it's a concept and I shouldn't tell you have to tell you this. Uh some commissioners don't read the staff report and we take great pains to put in the staff report the things we think are important. And I know that all of you read the staff report. So, it's not that big of a deal, but that's just cut you down to a few hundred pages right there. And that will tell you 99% of everything you need to know about that project's environmental process. The last thing I'm going to tell you about that is even though it's big, even though it's ugly, even though a lot of people will be in the room, the EIR is not the project. It's not the reason you're here. It's only part of the process, only part of the information before you. So, focus on the project and your staff and everybody else will catch up with the rest of it. Now, if there are environmental impacts

of the project that you are concerned about, absolutely bring those up. But you're not here to approve the EIR. You're here to approve the project or consider the project. And if you focus only on the EIR, I think you miss the entire process of it. And that gets to be a little ugly. So that's it. I mean this is my entire presentation on one slide. Uh this is all you do. Uh you have to consider changes before you act. This is all required. And then lastly uh I like to put in my presentations where you can get additional information. If you're truly curious, you're a new commissioner or you've not uh done this in a while. The planning commission handbook was woefully out of date for decades. And there was a consortium led by ILG. A lot of us got involved and we rewrote it. I am particularly proud of the stuff that I put in there. Um and I like to incite it as a reference. But all of these are publicly available. Yes, all are publicly available to you. Uh probably the biggest single resource you have is your staff. I may have said that once or twice. Uh there's another plug for the uh handbook. if you've not just and it's designed to be online although you can print it. Uh it's designed for you is to be a reference to you be able to go in and find things and that's it and that is my contact information. If you have questions or want additional information or want to hear how the 16,000 page EI goes

well thank you very much. That was an excellent presentation. Thank you. Thank you very um does anybody have questions for Mr. Teik? Nope. Should we give the public an opportunity to ask any questions? No. Okay. Okay. Well, thank you. And so we will now move on to um items initiated by the commission. Is there anything any commissioner would like to address? Nope. Not for me.

Okay. Next is selection of planning commission officers. Okay. First is the next chair and I would like to nominate vice chair uh gooding for a chair. Uh do I have a nomination or a second? I will second that. Okay. And all in favor? I I Okay. Next is the vice chair. Nominations nominate uh Mr. Funka. I'll second that. Yes. All in favor? Hi. Hi. Okay, we are done with that and congratulations to you both. Oh, thank you.

Um, I guess that's all there is. Uh, I guess we will now adjourn to the next regular meeting of March 12, 2026. Thank you everyone.