Zoning Board of Appeals - Regular Meeting

It is now 6.32. We're calling to order the Zoning Board of Appeals special meeting for June 6th. Hey, Michaela. And present we have... Russell Fogg. Nancy Hutchinson. Michaela Pearson.

Patricia Forsmeyer.

Sylvia Rakowska-Counsel. Stephanie Beckel.

Eric Gapolin is coordinating.

And I think we're still expecting Kip. And Nick's not coming.

So I think we're, and Kathleen has just stepped out for a moment. All right. Did you just say her name? Kathleen, Tracy, sorry.

All right. So there's only one thing on the agenda that's to continue our discussion of potential CBA input into the zoning for the zoning commission update to the part two of the zoning regulations. And last time we spoke, mostly about this chapter on the zoning board of appeals and um and also some definitions and so i tried to incorporate that into the updated zoning regulations effective april 1st and eric has it on his computer so he's going to show it to us so what do you want this is the regs and i have the document that has all the comments to it.

Let me pull up something. Okay. You've got Shore Mirage. You've got FEMA summary excerpt. You know that one you had there.

Go back to the one you just had before.

Hang on.

Let's see what we've got here. The title says, Z-Day Suggestions May 30th. That's it.

This is that document, right?

So then you need to go to review the venue review next right now in view. OK, review review. This is an email you sent to us. Yeah, and then you can see it says next. OK, here.

Where are you trying to go here? See this is next OK. Next.

It takes us, this takes us one by one through the changes. Hey, Kip's here as well. Kip Cotsen. All right. So I thought the way to do this is first, we're going to start off, I think, going to Chapter 22. That's the Zoning Board of Appeals Chapter 22. We made the most changes on this.

Chapter 22?

Chapter 22. Chapter 22. Can you zoom down to Chapter 22? A second.

A second.

Yeah, that's one we were looking on already.

I just want to make sure that we're all on the same page that I incorporated everybody's feedback as appropriate. And we did have one question for staff that now that Eric's here, we can ask him some questions.

I'm sorry, I wasn't here last time.

No problem, no problem. 22.

Yeah, we're getting there. So this is the old email that you gave us that we're going back to. This is not a new email, or is it?

I sent one out on Saturday.

Oh, Saturday.

I just pull it up. I have so many pieces.

Yeah. I just have been kind of crazy.

So I got it.

So, so I said, um, we're going to try to review what we did last time, make sure I incorporated correctly. And then we're going to focus on the chapters that we didn't get to yet. And, uh, that was the flood zone, the coastal site, the coastal site plan review area, and the nonconformities. Okay. Okay. So you're in Chapter 22.

Hey, you deleted B, right? And renumbered? Is that what you did here?

Right. So can you make it so that you can see the comments? I know how to do that.

Here, I'll go over and click on the comments.

I'm saying...

There's a way to do it, you can see both at the same time okay I I zoomed in because I wanted to be readable give me a second I will reduce the size. Down to 100 here, and hopefully that will you okay.

Yes, very good okay I can't read them that's that's why I zoomed in yeah well I I can. I can see it. I can see it. Okay.

Are you going to have it up too?

So basically, currently there are no special permits designated to be reviewed by the ZJ. Should this be removed throughout or retain cases on commission slides in future to give us a special permit, which is unlikely because they haven't done it ever before. So I guess I just want to make sure that we're all on the same page that we just want to delete it. Oh, I also wanted to say, start off, is that These suggestions are not meant to be verbatim. They're meant to be more highlighting to the zoning commission, things that may need clarity or updating, or we can give an example of something that may, it may not be what they intend to do. So, but it's not to be that exactly that wording. I think that we don't need the, and I think I talked about this as sort of, she was okay with deleting that entirely. And then I think it's easier if I just point to it up there.

Okay, I will handle it however you want to handle it.

So we talked about this. We want this to be considerations for granting of variance. We talked about that. It was still there last time. And then we're just, it's not a policy. It's just, it's only where it appeals. And this would try to update this to make sure it's updated with the current case law. So for example, And we tried to separate what was the considerations from what are the cost procedures, which is later.

Can you read that? Does it say the red part, the blue and the red?

It says considerations, policies, considerations for granting of variances.

Policy considerations for granting of variances.

The policy I thought was taken out.

Well, you still show it in there.

Okay.

I still have it in my notes.

Okay. To me, it looks crossed out. Okay.

It is crossed out. It says deleted. Okay. So I'm hovering over it. I say I see deleted.

Okay. So basically, this is just basically what we discussed last time. Describe fully the findings as part of the procedure. We'll try to make this streamlined and simple. The evidence has provided that an unusual hardship, exceptional difficulty, is not used anymore, or that the evidence has provided that an olding or an unusual hardship exists. Because when these zoning regulations were written, they didn't have the case law that now we know about from Sylvia that says you can sort of course trade many ways. Yeah. And then also minimum to be a chemical client.

Is that in your comments that this was like legal advice or something along those lines?

It's not in the comments.

I can't read that at all. I can make it in the comments. I would put that. what I'm thinking is if we agree to this, I'll do like a summary memo to put in front of it and say, based on revisions to the case law, we suggest these changes. And, you know, for example, these are based on interpretation of your definitions. These are cases we've seen that is not fulfilled. All right. So basically this, this tries to capture simplifying this, making it, Actual case law. This is redundant. This is, again, separating procedures from the process. So basically, this turns into the things that we always say at the beginning of our meeting. What is your unusual hardship or legal alternative to unusual hardship? Are these the minimum variances necessary to leave the unusual hardship and allow reason to use the property? Variances in property, pretend, purpose, unregulated, and the comprehensive plan of zoning. And then And then this is the added weather. The variance constitutes a reasonable accommodation for the names of the stated persons that transpond. So that's basically the heart of, and this is for information only, because this is the law, basically. We're just putting it in here, Sylvia mentioned, so that applicants can look to see what the ZPA does.

Can we get rid of that middle column and maybe make it bigger?

Not easily, because that's the margin there.

Let it go. Okay. And then the next section, we decided... You deleted it entirely. Yeah, because if I recall... You asked...

It says, why is section 22.3 needed? Historical exceptions are already in section 13. Um... So here, you can read the whole thing here. And the proposed consideration section seems more appropriate in Section 13 and or for CSPR application, Section 12. Later section seems more appropriate for enforcement section, Section 21. That's the end of it.

This is the whole section on granting variances to FEMA. And they said what you should consider, but that should go into FEMA regulations. And if there's something that the zoning enforcement officer needs to do, that's going to the zoning enforcement section, I thought. So I think the point is, and then they have conditions for variances. This shouldn't change. It's the same conditions for variances that we do for everything. But the thing is, if they think some of these things need to be considered, then they should put this in the purpose of these FEMA regulations.

Nancy or Eric, I think if, Eric, can you go to the review tab up on top? You know how you're in the review tab? Go into review. And then if you, in that comment section where you would add a new comment, you see how there's a drop bar where it says show comment? It's back in the middle of the top bar. Click on the drop down. If you put it into list format as opposed to contextual, hit the drop down, put it into list. It'll let you expand the document without removing the comments. It should. It does on my screen anyway.

Okay, well, can you grab that and spread it?

I think it's okay.

Because before, it had the comment tied to the text that it's changing. I don't think that's more helpful. Well, you can see them side by side. It's Yeah, but it doesn't say what you're referring to.

That it's just a list, it's not next to the comment?

The other one has it next to it. So what it'll do is it'll show you the document that you can expand and contract, and if you hit on the little bullet, whatever, the little text box or the comment box, it'll show you to the comments. for it.

Oh, and now it's bigger.

I mean, I expanded this to 150%. So that should be that should help. Okay.

2230.

But anyway, to contextual still out of the screen, if I move it to list, it's on the side, but it's, it's not. It's not aligned with the comments.

Yeah. But if you click on that little bubble, Within the document, that little, you know, old school where people talk, the little dialogue, that thing, it'll take you to the specific comment.

Oh, there it is, the box then.

Ah, okay.

Okay.

Thank you, Sylvia.

It's all about education.

But basically, the whole point of this section is it's unnecessary to convey to applicants the role of the ZVA and what we do. And if there's certain things, so there's certain things that they had in here that they wanted us to consider. And I went back and I checked to see under FEMA regulations that they say that the purpose and intent of the FEMA regulations are. And if they're missing something there, then we should put this there and not here. So the point is, our job is to say, is very in alignment with intent and purpose zoning regulations. So if that's the intent and purpose zoning regulations, those texts should be in the regulation essential purpose of the zoning regulations. So anyway, so that basically, I think we can remove this entire section.

Okay. And you're just saying it's sort of massively redundant. Massively redundant. Tidy things up a bit.

And if there was something here that was not listed under the FEMA regulations, I added it to the FEMA regulations.

It can't be a government document unless it is massively redundant.

But I think the point is. And it's also the point that I don't really want you varying the FEMA regulations anyway.

And we never have. So I think the point is, what I felt going through this is a lot of redundancy. things that are said in multiple places but to make it streamlined so people can understand it should be if there's some intent to the zoning regulation it should be in the 10 purposes of that zoning regulation right not under zva so anyway so this whole section i think we can take out okay that's 2.

2.3.

We don't have the authority to take that out. We're just suggesting. You are suggesting this directly to the suggestion.

And then we'll put a document, a memo.

If some contrasting lawyer says, no, you should let it.

As I said before, we're making suggestions to either streamline, prevent redundancy, to make it clearer, to help understand things that we've seen over the last few years that shows that the regulations are not being interpreted in what they mean.

I'm sure the legal parts are being upheld.

And also updated the legal parts because ZBA now has case law that says there's other things besides straightforward hardship. So then we said that gets down to procedures. So then we talked about by leaves. So this is... So the board shall hold a public hearing. And this is a procedure. We have it in our room. The point is, it says prescribed by these regulations. There's nothing in the regulations that prescribes anything other than what the general statute says. We don't need that. But then this is where I said the board shall hold. So I just basically just took the procedures and put them in slightly different order. But basically everything that needs to be here and everything that was in the redundant section before is put in here. So basically, in part, the public hearing, the sound reporting, we can ask for them to have, let's say, health department approval. But I also thought, now that the sewer's coming in, and or ethical water pollution control authority, because there's going to be a limitation in that the sewage output that a home can have. And if you change it, if you change bedrooms, then- Is that purview of zoning? No, that's purview of the water pollution control authority. That's my understanding. So I think since sewers are in town and are coming to town more, it's not just the legislative health system because they only really oversee septic systems. But if somebody goes from a two-bedroom house to a four-bedroom house, that's going to increase their use of sewer. That needs to be reviewed and approved by the Water Pollution Authority. And they either need to approve it and say, but even if they approve it, they need to say, you might need to pay more. So we shouldn't be approving something that they don't have. It's just like if you don't have a septic system.

And the language in that is fine where it says authority and or.

Again, I'm not saying this is verbatim what they put in there, but I'm saying that they need to have some review by the Water Pollution Control Authority. So I'm saying none of this is verbatim, but it's just the concept.

So again, these explanations you're giving to us, are they in your comments?

Now that the community sewers are being installed, probably need to require that proposed increase in sewage influence is approved by the local WPCA.

So yes, yes.

Thank you. I try to. OK, so then zooming down a little farther. This is where it comes to. Make the following findings to discuss this last time, so we don't need to say it. Also another part of the document. We just need to say it once under procedures, right? And then the purpose is an intense and the comprehensive When the variance constitutes reasonable combination, it is the table person. Basically, it's the things that we always do.

And then this is what we talked about with Sylvia.

Any variance granted by the board shall not become effective until placed upon the land records by reporting. I'm zooming a little ahead.

Okay, I'll keep zooming.

There's no exception. We don't do special permits. Now, this is the question that we had. We wanted to discuss with staff. Okay. This is, I never stamp or sign MILRs. We usually just ask for, we just usually ask for them to send us final plans. I stamp and sign final plans. So do we need to say something about final plans or do we need to say?

I would just delete the words on MILR because you say final plans right in there.

Yes.

So why don't we just delete the words on MILR?

I'm fine with that. I just wanted to ask you. If that's the procedure. Because it's on laser fees. We don't put all the plans on the land use records.

No, not all plans do not get recorded on the land use records.

Because it says for any grants with plans that are final plans on the land records. But we don't usually say as a condition on the land records.

We usually just say submit. The variance itself does need to be recorded. And the variance report should trigger someone to go take a look at what we have up there.

of the final plans.

Well, just here, where filing of plans is a condition of such variance. So you can make that a condition of the variance, right?

To be on the land records. What I'm saying is, no, let me just say to the land records office.

I understand, but it just says, for any variance where that has been made a condition of the variance.

Okay.

So I think you should probably leave it in there. Okay. Because it's just saying... If you were to make that a condition of the variance.

I don't understand it. So my question to you is, should we be making that a condition of variance? Usually we just say that we submit it and I stamp and sign it.

If you find that the variance is so tied to the map that it doesn't make sense without the map, you can also require them to submit the map to the land records as well.

But if it goes just to your office, if I stamp and sign it and just go to the land use office,

It will be put on laser fish.

And is that kept forever?

It's kept forever, yeah. Okay. But, again, I guess the point is that if for the ZBAs, the variants will reference a map.

Yes.

If you think that the variance doesn't make sense without the map, you can require the map to be recorded on the land records. I'm not saying you should always, but you may reserve that right as something you have as a right.

Okay, so my other question is, if we ask them to submit and send a final plan to stamp and sign, they never submit them.

And the variance is not...

Right. So that's still a condition of approval, so it still wouldn't be approved. Okay. So we'll leave it there. We don't really use it right now, but we can leave it there.

I would leave it in place in case you decide to use it. I wouldn't waive that right.

This is Sylvia's wording. No variance shall become effective until not shall become on void.

That's fine.

Okay.

I think that's right.

So then I think that's the end of Chapter 22.

Yeah, that's appeals to court. And then next is 23 moratoria. So, okay.

Yeah, okay. So then the next thing we wanted to talk about was definitions. And the last time we spoke about definitions, we said that we thought that the way that they had the definitions have broken up into multiple chapters, that it was very confusing.

Well, but one is for definitions and one is for uses. So they were broken up deliberately.

Right, but I'm saying... what we thought is one chapter should be all buildings and structures and one should be uses because right now it's confusing because it's some things it's called accessory structures but they so the thing what we what is suggested is that if they're not on one chapter then to make them include all buildings and structures whether whether accessory or not in one section. So if you're looking for it, a deck, because right now deck is under accessory use, but it's an accessory structure. So then the thought would be put all the definitions, this is just, and they can take it away if they want.

So a lot of these things in, so some of these things were accessory, accessory building or structures.

But, so the point is this, I think it's better if I can show you the table.

Just as in principle on this, you're saying you want to fully segregate and have no overlap, or is a little bit of redundancy actually helpful in this?

I think redundancy would be confusing.

I know, but like if you're looking at something that you think of as a usage, But we've decided you're putting it in the other category, in structure category.

But I think the point is, it's either a building or structure.

And I'm not thinking ahead. I'm just saying, is that 100% clear? Do you want me to forward it to you now? There could be a little wobble around that. And would you allow a little redundancy for the wobbly items, the ones that could end up in both? Oh, yes.

So, like, let's see, like. So like right now, under like 6.1, they have, it says accessory use, a table of 6.1 on page 20. Do they have their regulations with them? No.

They have four attachments.

They have extra copies here.

21 members, first one.

I don't know which.

Did Richard ever get his?

Did you ever get?

Okay, did they have it before? He has four attachments to it. This is yours, Richard. He needs to have this here. Again, I downloaded it.

I found it confusing. The thing is, if you're not going to have, because right now all the definitions are in one chapter. This section provides basic zoning terms for these regulations, including both building and structure definitions. For definitions related to the overlay zones, see section 13. And for section 26, definitions including primary. That's the one.

I think it's

So I'm trying to take everything that was a building or structural building to chapter 25 and put it in chapter 26. And the thing is, what helps with that is because we were talking about this table, 6.1, it says accessory uses. What page? It's page 20. The whole first part of it is basically, it says accessory use, but it's really... buildings and structures. There's only as much smaller section of accessory use. Actually, it goes on to the next page. Yeah, I know, but I'm saying, if you look at this, I'll see if I hold it up. Yeah, we got it.

We all have it.

I'm saying, this entire section is basically structures and buildings.

So, Why does it need to be in this big, complicated table? Why can't we just have, if there's accessory uses, just talk about the uses, and then it would just be... Well, but it has boarding of horses.

It has home occupation and keeping of pets, letting of rooms, memorial gardens. All of those are uses.

Where?

Yes, but that's under uses.

Yeah, use. Right, but this is buildings and structures. Why does buildings and structures need to be in the table of uses?

Because we've broken the uses into primary uses and accessory uses.

Right. So I'm saying, why not have it... No, these are principal uses. Principal uses. These are all uses.

These are all... Right. This is the way the zoning regulations are broken up. Principal and accessory. Right. So...

But I'm saying, these are uses... but these are buildings and structures. These are from here down as the uses.

Okay, what are you asking for then?

So the suggestion was, if you took this and put all these definitions on structures, buildings and structures, then you could simplify this table, you'd have a more clear list of definitions. And then all the zoning in both definitions would be tied with the structures in those.

People don't have to do it if they don't want to do it. We will take your suggestion to the fact that the zoning commission is consulting to see where it would go. I don't suspect that they're going to take that out of this table. That's just my education.

Yeah, that's fine.

I actually thought the table was really useful.

The table's useful, but the second half of the table.

I'm saying I think it's really useful to be able to see both, like right here without trying to find it somewhere else, both the accessory use and the structure of buildings, all of that.

But if you look at this, this is all the same. The only thing that's different is those two things, and you can put that in the definition. Accessory farm buildings is only not allowed in

Yeah, I just think, I mean, just for me, it was really useful to be able to, like, look at a chart.

Okay.

It was just very clear. And that's probably a couple of pages if we're done and see if we're really talking about it.

Well, and, again, the theory was under the prior regs that we didn't have one unified table. You had to go section by section and figure it out. The thought was to have it all in.

No, no, and I love the idea, and I love the idea of the table for the usage.

Okay. But you don't want the buildings and structures.

But, again. No one else has to agree with that.

And it's not so bulky. And what's the overlap between what you're saying there and the definition segment? Because that's where we started this conversation.

Every place you see when you scroll down Hang on, hang on.

I'll scroll down.

Anything that's in green is something that I've moved on to chapter 26. Anything that's I still need to move to chapter 26. Accessory use. So why doesn't that be under use? And then scroll down.

We can talk about specific things.

We can talk about specific definitions later, but I just want to scroll and see the, it's like this is one, Central air compressor and heat, why wouldn't that be in with the building and structures? I didn't zoom ahead. Anytime you see a green one, anything, so that electrical charges, that one may be because it's special purpose, right? Scroll down. There's a lot of farm stand, fence, garage, handicapped access. It was all under uses instead of under zoning. So there's instructions.

Don't go down.

Okay.

Off-tree parking. Keep scrolling here.

Yeah.

It's not under both. It's just that, like, garage is under use instead of structure.

You can see this.

To me, it was like, if somebody wants to learn about the definition of a building or structure, they go to one chapter. If they want to learn about use, they go to one chapter. And so, but we don't have to change the table .

The first table, section 25 says zoning terminology definitions. It doesn't segregate it as structure definitions. And this 26 is use definitions.

Right, so sometimes they'll find under use, they'll find debt. Why isn't that under zoning?

Because debt isn't a zoning terminology. Right? So we tried to limit 25 to zoning terminology, which wouldn't be, I mean, again, things that wouldn't necessarily be understood by a common person. Building height, building official, building permit, bulk. These are things that the common person wouldn't understand the definition for, so we gave a terminology piece of it. And anything that wasn't a terminology, whether it was a use or a structure or anything else, went to the second part.

Okay. I found it confusing, but anyway, I could just be dumb.

You're not dumb. Clearly you're not dumb. I've been trying to explain why things got segregated the way they got segregated.

Right. Okay, so I thought it was easier to have all building structures in one chapter and one using another, but we don't have to do that. But then let's look at some of the definitions.

Nancy, if you could echo what the... The theme is how you think it was separated into 25 and 26. What's the...

Right now. So I think you go to the top of 25.

It says zoning terminology definitions.

The zoning terminology. To me, that meant, you know, like deck, garage, terrace. The things that come before us all the time that are in the bulk regulations. Things that they... So the bulk relations apply to these things.

And DEC made it in there. Yeah. DEC is in there. DEC's here. It's also repeated in usage.

I'm not sure why. That's right. Some things were in duplicate spots.

Yeah. Which is that weird, I mean.

I think that's okay, though. Okay. That's my reason. I think it's more clear for people that if you're looking for it in one place, as long as the definition is the same. Correct. At a glance, the deck one does look like it's just repeated. Yeah, it is just repeated. So, I mean, I just think it might just be easier for the user to have it in both places. Because then you have it in both places. As long as there's no contradiction, I think it's fine.

I guess this is my record.

Because it can be both. No, but it can be both. You know, it can be.

Let me have something in two places. It's more probably of inconsistency or errors.

Well, that's what we have to make sure that if there are duplications that they do not.

I think we should avoid duplications. Nancy, I mean, I hear what Michaela's saying because as a user, this is a big document. I don't, you know, I'm like, oh. So I'm going to look at it in a lay person's way. You're a zoning girl. You know what I mean? You look at it from a different place. So when they see it, oh, that's where DEC is. But maybe you were going to look at it over here for DEC.

I think it depends what you call it. If you call the chapter zoning terminology, buildings, and structures, then you know where to look. If you call it uses, you know where to look. But again, if no one wants to change it, no problem. I just leave that coming up. I would suggest it.

I mean, I don't see where you're reading. It does say... buildings and structures, just said zoning terminology. So that's like an overview type thing.

The other one is separated out.

Specifically uses.

The dumping ground.

I mean, I'm not sure I'm legally sophisticated enough to know how to segregate things into uses rather than just raw terminology. People that know what they're doing made that choice.

And it's a field where issues like use versus you know, bulk versus whatever else, the layperson is not going to keep up with that. It's something where even lawyers struggle with how the term gets used in practice. So I think the reality is we're probably going to just leave it the way it is at the moment. But if you want to make that suggestion, Nancy, I'm happy to bring it back.

Okay. I mean, the only, perhaps, Section 25 and Section 26... could be merged into a single zoning terminology and use definitions.

A single section. And it all regulates it with one chapter.

Yeah, because then everything would be in one place, and I think that would be easier for the end user.

Unless it's all, because what we said is a zoning for until last time was that we thought it would be easier just to be one, but if it was broken up into two, maybe this would be easier.

Be less cumbersome when you have, you know what I mean? It's like the whole thing now it's cumbersome where you have, okay, this, this. Okay. Well, again, you know what I mean? Simple.

I like the one unit and say, here's, here's all the definitions of both terminology definitions. And what was it? Used. I have to look in two places. I just want to look up what's a deck.

Right. I'm not sure I understand that myself.

But again, Why don't you tell the zoning commission you think it belongs in one chapter and not two chapters?

If you go to the top of this section. Oh, here it is.

What do you call it up top?

The comment. Hang on, hang on. There you go.

Unless all definitions are combined into one section rather than divided between sections 25 and 26, suggest listing all building and structure definitions here, limit definition 26 to primary access for use. That was a comment. So I think our comment was put it all together. To me, it was more logical to have all these definitions that the bulk regulations apply to. Because bulk regulations don't apply to uses. They're measurements.

Could you embed them all in one document and just put a symbol for the ones that you would consider use Does that make any sense?

What was the utility of separating the definitions from uses? Was it just so that the uses are clearly distinct uses that should be?

Yeah, the theory was that the uses appeared on the use table and that other things that didn't appear on the use table were separated out as terminology. Right. The thought was use table gets use definitions and everything else is separated.

Which is why I suggested the use table has accessory definitions buildings, accessory structures, and accessory uses. Put all the buildings and structures, take it out of that table and just put it under the bulk regulation table. But anyway, but again, I understood that discussion, but we don't want to spend too much time on it.

I think leaving the suggestion there is fine.

They can do whatever they want.

Exactly.

All right. Awesome. So let's look at some of the definitions themselves. Scroll down.

Hang on. Scrolling down. How far down do you want to scroll?

An extension or increase in floor area height or volume. Because we've talked about that before. That gets confused sometimes.

And then where are you? Addition. Addition.

Because sometimes people just put in a dormer or something like that. So scroll down. Please. Okay, stop. Now here's something that I didn't understand. So adding the space between the top surface and ceiling beam, the top surface and the bottom surface of the roof rafters. Now we've seen many, many, many times that people, I think the zoning commission intend the roof rafters to be the rafters directly under the roof. But what's happened is people like five foot 11 inches high put a roof rafter horizontal and say that now that it's not floor area, because it's less than six feet. So could you click over here where it says comments?

Hang on. And then the siblings vaulted over top of it. Yeah.

And the point is, and I didn't know what, so this portion of the definition is relevant. It does not. Oh, so either delete roof rafters or use a roof rafter. but make it more specific. So the space between the top surface and the bottom surface of the roof rafters, which needs to be defined more specifically. And I didn't know what is the purpose of saying the space of distinction on other spaces. What's the purpose of that? I didn't understand that.

Okay, well, we'll go back and leave the comments. I mean, I'm not going to try and interpret line by line with all the interpretations. If you thought it was unclear, we'll go back to them and say this was not clear.

But I think we wanted to point out that we've seen this misused many, many times. And especially the example that we have where a 30-foot tall garage is considered one store because they have roof rafters that are less than six feet tall. They have the ceiling on one floor that's five feet, 11 inches tall. but it was very disconcerting.

Yeah, loopholing it.

Loopholing it. And then basements. This is a question I had, but it doesn't, it's a, I can't read it. The level is partly or wholly, if it's wholly below grade, then it's a seller, I think. It's poor grade, but, and at any point, the potential for floor level access. I guess my question is, if you have a building, That is three sides underground and one side is a grade, but they didn't put in an access yet. Is it a basement or is it has the potential to have an access? So is it a basement or a cellar?

It's a basement because it has potential for floor level access.

Right, but this is added. That's not what it's in there now. So I'm saying we've seen that before too. People kind of scurry around whether it's a basement. In the basement, it's important because the basement counts as floor area, but a cellar does not.

Right.

So that was a suggestion.

So you have to have the potential for, because that makes it. Right. If it's got potential for a basement, it's a basement. Yeah. Okay.

Does this overlap with, I mean, if you have a cellar, you can't really utilize that as certain kinds of habitable spaces.

Let's go down fire hazard, egress issues and all that, or yes or no? You can't have a bedroom in a basement or a cellar. Right.

We actually...

Without an extra egress.

Yes, exactly. We've had a discussion with the building official before because there was one case where someone came and said they needed a variance because they wanted to put a bedroom in the basement. But people get confused. Basement and cellar are different. So if you have an external egress access from that basement, then you can put a bed down there. But if you don't, in a cellar, you can't. Right. So then just contrasting with cellars, that portion of the building has its floor fully below grade.

Why do we need all this other stuff?

Because then it gets confusing.

And the other thing that we've seen before too is people have a basement and then they put an artificial wall halfway across the basement and say, oh, now this part of the basement is sell it because it's not access but it's still potential to access it so i think we've seen we're just raising these things to the zoning commission and say is this what they intended or not if they're not leave it then what you know whatever i make it clear that it's not yeah that is that is confusing whatever so like here equip is common hang on that's there The other thing I want to point out too is that cellar corresponds with the FEMA definition of basement, which is very confusing. So the point is, do we want to align our definitions with FEMA so it's less confusing?

Probably. I just assumed I didn't have the vocab understanding that I should have as a normal human being. So I'm like, okay, yeah, that's a basement. That's a cell phone. But if FEMA disagrees, then we've got to figure that out.

So FEMA defines a basement as all... You can't have them defined differently. All below grade. Do they use the term cellar? No.

It's not a term they use.

Anyway, so I just point this out because there's another part of the regulations we get to when we get to FEMA regulations where they're talking about basements. And it's very confusing because they don't say... It's just very confusing.

Would it be helpful to say FEMA regulations do not discriminate between basement and cellar?

They do discriminate between basement and cellar, but their definition of basement, so they would say they just use the term basement, which would correspond with our cellar. Otherwise, it's just an open space. access area. They don't call it a store because the low base flood elevation, but it's not a basement. You're not allowed to have a basement. But our definition of basement, you would be allowed to have.

Well, maybe we should match up with FEMA.

Maybe they should not be allowed. That's only in instances of FEMA, though. There's more and more all the time.

I'm raising these things to let them know. This is your definition of Sometimes people twist the definitions to get away with county floor area, but also it's potentially confusing because it doesn't line with city law. So let them decide how they want to handle it. But we're just pointing out the issue.

You have the comment in there?

Yeah.

And we'll bring it back to the zoning commission.

Okay. Did we miss? Hang on.

We'll zoom back up here.

Okay. Basement...

Am I scrolling down again?

Yeah, just click next change. I think it goes fast if you just hit next, but anyway, whatever. And then this is the other thing, deck and terrace. This comes up all the time. So I think Stephanie mixed up for the awning is a flexible surface, but in here the definition says you can't have an awning over the deck, but you can if it's not a fixed surface. and compare the definition of terrace. So if we go to terrace.

Hang on, I'll scroll down to terrace.

Make that fix to just fix the definition. Yeah, yeah.

That was good text, Stephanie. Getting there, hang on.

So this was not in this section, but moved it over. And I think the point is, It used to say, at any point, such great dimension at the existing natural grade prior to site chaining compared to definition of deck. So I think I just tried to make this, it's either a deck or it's a terrace. Like you could have a meandering definition that's not quite clear. So this, it says in the old regulations, it said compared to deck, but now it's back in there. And so basically, if you build up more than 12 inches off the ground, It's a deck, not a terrace, even if it's made of... A terrace has to be on the ground level. At no point can it be more than 12 feet above, 12 inches above the ground.

Okay, but what if they change grade?

No, it has to be... Original grade. Natural grade.

So if we're looking at something and they're swaling it up and they've got something built on top of what they put, that's a deck. It's still a deck, yeah.

That was why I had the question about, do we need to define courtyard? Right. Because they've built up three feet of walls all the way around this pool, but it's not a deck. It's not a terrace. It's Courtyard.

And one of the key elements here is the terrace doesn't count for coverage, but deck does.

Yes. But that courtyard, if they built it up three feet, then it's a deck. Well, it depends how you make the definition.

It was just soil at that point in time. It was a garden. It was a garden. They called it a garden. So it didn't have coverage on it. It had soils. So they're saying we are adding this. And, again, I made sure that Jeff Jacobson on the FEMA side was allowing that to occur because I was very concerned that adding this much spill in the flood zone.

Did he ever comment back?

He said it was okay.

Okay.

And are we opening the door then to have considerations about, like, where they've done the architectural adding some fill to make runoff move in a certain direction? Yeah, yeah. Does that become deck two because it's – I mean, if you're too...

It's not the earth part that's the problem. It's the structure. So that's why it's good to have it under structure. If they've got a lawn that's two foot higher.

That is our structure. Right.

But again, if you lift it up, you add structure underneath it. You put some stones on that, that's a deck.

All right, so then we need to make sure that it says it's structured.

There's got to be some way to do it, because there's a lot of gray stuff here, and you've got to draw a line somewhere.

So this is a surfaced area. But the deck, we should make sure it's in the structure?

Well, let's go back up the deck, then.

I'll take another look.

Keep going. That was in use. It wasn't in the terminology. It was in use originally.

That's what I'm saying. I think it's easier to have a little structure.

It is what it is. I don't know why it got put there, but there's a reason.

See, this is in a structure, so that's good. So it says structure.

It says restructure, right there in the definition, okay?

Right, so that's good. All right, so then just hit next or whatever.

That's absolutely right.

But to me, that's why it's getting confused going back and forth between uses and structures. This just moved. I put this, a drive-in is a use. I just thought it was a very use. Okay.

Why isn't it green then? No, because it wasn't. Green is going from 26 to 25.

Yellow is going from 25 to 26. Yeah. Okay. Okay. Okay, floor area. Now, this is really, this comes up all the time. A covered space of a building, except cellars, because they say it elsewhere, except cellars, whether enclosed by walls or not, which has, and here, this is the tricky part, ceiling. They're very tricky about how they use the word ceiling. So I thought, as a measured height of six feet or greater, see section 9.2 on how measured. Because in 9.2, that's when I talk about how slurry is measured. Can we jump to 9.2 here?

Can I jump to 9.2? Give me a second.

It takes a while for the computer. You can just go to my book.

Hang on. We're getting there.

8. Photogram coverage. Okay. So 8.3.

Give me a second. Scroll down now. 9.8. Okay. Okay. Okay. 9.2.1.

9.2. Just go to the. Yeah. Okay. So now here's measurements of floor area and coverage. So area measurements should be taken from the outside surface of exterior walls and floor area. Floor area of less than six feet in height, and this is my suggestion, as measured from the top surface of the floor, the top surface of the floor immediately above. So, because what we've seen before is like people say they have a whole floor and then they make the ceilings in the closets five feet, 11 feet tall. So it doesn't count as floor area. Or they have an attic and they put a cross beam at five feet, 11 feet tall. I think the point is you can change it to six or seven feet, but the point is I think it should be measuring from one floor level to the floor level above it. or the roof above it. There's no gray area. There's no messing around with it. But anyways, that was one suggestion. And cellars fully below gray and use solar storage as the same. The proportion of an attic as measured from the top surface of the ceiling beams of the floor immediately below or at the E, for some reason they talk about E level, to the exterior of the room above. So the point is, There's no question. It's not where you put structural cross beams, not where you put the ceiling of a closet. It's not. So everything's measured to the outside surfaces anyway. Why not measure it from one floor to the next floor to the roof? Yeah. That was a suggestion.

Is that awkward for you or is that doable? Well, I guess.

I think that what you probably are needing to say is that you're only looking for the structural beams supporting the roof, not to the exterior of the roof. Yeah. Because I think the six feet should, you're going to end up with a situation where you're going to have two by fours, two by sixes, whatever it is that's supporting the roof. And that's going to interfere with the headroom or whatever else you have up there. if you're measuring to the exterior of the roof. So I understand the issue you're describing, but I think that you're really referring to the structural support of the roof itself and not any lateral beams that are underneath.

Right, so I think somewhere I had a comment, either you clearly say what is a roof rafter, because people are misinterpreting roof rafters, you make it clear, or you make it some measure that you can There's no arguing about it.

And I think by tying it to a structural support of the actual exterior roof, you're probably- Immediately under the roof.

Immediately under the roof.

What's the term for the cross? Is that collar ties? What's the one that goes across from one wall to the other and the rafters go up above?

Cross beam, right?

Cross beam? You can have-

But the thing is, this came up in the past, and we brought it to the building officials. The building officials would not make the call. You've got the vocab.

The bottom of that cross tie is at 511, and you've got a beautiful big vaulted ceiling. That's not an attic where you put your Christmas stuff. You know, it's the kind of space that people could make a bath. Collar ties. Collar ties.

Okay, but again, the definition here, a joist is a horizontal structural beam used in building construction. So that's what we're talking about, horizontal.

Yeah, but I think his thing is more specific. A vault and ceiling, you call it a collar tie.

I think what's happening here is that somebody argued that, I won't say who, that... that it should count as the cross-type because they said that was structurally needed. And they went to the building official and the building official said, oh, I'm not going to say whether it's structurally needed or not. And so, you know, you can put it in there and then you can move it later. It should be something that's mutable. But I guess the point is, you can either... You can make it something very measurable like the roof, or you can either clearly define what the roof fractures are for definition.

Okay. We'll go back to them and talk to them about that.

Okay. I have a question. Yeah. On the cellar and in services that support the uses of other floors. Yeah. So a use that would support the other floors, could that be a fully finished, you know, pool table and help people make it living space? It could be a cellar and still be finished.

To me, this whole thing, the whole thing about, use soil for storage of account equipment is mushy. I would just say if it's fully below grade, it's a seller. And you don't need all this other stuff because the more other stuff you put in, the more machinations.

Yeah, the more you can split it.

Yeah. Which is why I went from little ceiling beams with floor being below to somewhere else they talk about being at A level. But not every half story is at eave level, because sometimes you have half stories that are flat roofs. So anyway, so covered porches, whether closed or not, well, that's not correct, because if it's enclosed, it's not a porch. And then here, and then heavy pipe as measured above. So you just need to be consistent in how you're measuring it. So I can take this and say, just make a comment saying, This definition did not fully align with other sections, e.g. exclude sellers. So I think I had some comments there, but I can just say, or just more clearly define the definition of roof rafters. So you don't have to have this. I think that's it. Okay, yeah.

All right. There has to be. Yeah, I agree. I mean, the more structural word. Right.

All right, so let's zoom down. Sorry, Eric. Hang on.

I was trying to write some notes down.

Keep going.

Oh, this is just a typo. What are detention retention?

No, those are two different things.

Okay.

One is to keep the water. One is just hold the water.

Stop. Go back up a little bit. So then this is where we come to the whole building and structure pipes. There's You can have the height of other things, but this is how building structures are measured. And then it still has the old 8.3.3 there. Oh, yeah.

But in the book, it doesn't have that. Yes, it does. No, it does. 9.4. Oh, I have 8.2.2.

Yeah, 8.2, that's what it has, the old number.

But it just says, it doesn't have buildings.

She added those words.

Oh, you're adding those.

And then deleted the existing section number that was previously left in.

Got it. Maybe adding could be one color and deleting, you have the line through, I'm sure, but maybe it should be a different color.

The way Word works is the color goes by the editor.

So different editors have different colors.

So I could exchange all of them to a different color, but I can't.

Yeah, no, that would work.

Could you just quickly, but is there anything else here? I'll go back to the definitions. Oh, this is where I thought height exceptions could come in. Fine types are required. Do we want to say that existing dwellings located in a flood zone that did not currently compose FEMA flood zone requirements beg to see building height to the maximum height necessary to become FEMA compliant, but no cases? This is just, you know, 10 feet above maximum district. It's just a thought of... If no other... Because usually it's less than 10 feet.

Okay, and you're saying that was automatic, and if it's more than 10 feet, they can come to us for a...

And that's if no other variances are needed? They won't need a height variance if they do this. We're going to get to the FEMA stuff.

If you're violating the normal height regulation because of FEMA component, then you opt out. You don't need a variance. Does that make sense to us?

Oh, yes.

So the point is, if you're in the R10, you've got 34 feet.

We'd lose a quarter of our cases.

People who elevate tend to max out their size, because if you're going to spend the money on the elevation, you're not going to just elevate the same.

But you can say to them, listen, you don't even have to come in for a variance if that's all you do. Yes.

But I think later we're going to get to commenting on the FEMA requirements and the coastal site plan review requirements, because I think we should we've brought up before is that Marcy Ballant used to always say, you should minimize the increase in living space in a flood zone. So just because you raise your house, you spend a lot of money, doesn't mean you can make it in some enormous structure. I think we should put that in the regulations since now that we have a new Connecticut EEP reviewer, he doesn't say that anymore. So if it's important to us as a town, we should put it in the regulations, but we'll come to that when we go to the FEMA regulations. um and uh except for those accepted to find a section eight but i moved this to section eight and i think also let me slow down a little bit do they have this in the middle of nowhere paris is made projected to require you to remove the 50 percent it should be someplace where you can find it because the only way you find this because you look here it's in not in the logical spot so i put it in a more useful spot in section 8.2.

Okay.

So we're done with this. So I think we, oh, we'll go back to definitions in chapter 25.

So we detoured into measurement.

Measurement.

And we got it done.

Yeah. Okay. So now we're going to slide back to definitions. Some definitions.

Some more ones that seem problematic on your review.

Yes. Thank you for summarizing that.

I'm the one that's genuinely lost, so I'm just trying to make a comment about where I think we are.

Okay, so then we did, we were at floor area.

Keep going here, floor area. Okay, thank you. What section is this? 25 or 26? Oh, yeah, 25.

So these are things that were in use, but I thought were helpful in building structure, but we can...

Here we go then.

Yes, yes. High building, C building. I just thought this was hard to define sometimes.

Scroll down a little bit, please.

Hang on. Keep going?

I think if you just click next, it'll just take you to it. Stop. Okay. This is a little confusing to me. We have lot line front, lot line rear, lot line side, and we have

Street lines.

And I think we've had some confusion about this, Gordon. I don't feel very strongly about what we recommend, but we've had people that have street lines on two sides or three sides or two opposite sides. And the question's always been, do they need a rear line or are they all, if they have two street lines or is it a sideline? And I don't care which way the zoning commission says it, but they need to make up their mind. This is really confusing. And the thing is, what's the difference between front line and street line? The difference is the lot line being along the street, but later there's the definition of street line. But the point of what makes it front is on what's the principal building has a street address or otherwise by the front. We've had that point before too. And then rear line is, I don't know why it's the shortest. It's a single... straight line, which is roughly opposite the farthest from the front line. And then we need to say clear one way or the other. If more than one straight line, there is no rear line, or there's sidelines.

Sidelines, what are they?

Well, again, anything that is not a front or a rear is a side.

Yeah, but if you are on a corner, what's rear or side?

Well, I think like if you're on two streets, like if your house is between two streets.

Remember we've talked about this. Sometimes you say, sometimes they say we've implemented it. If you have two street lines, then you have two side lines. Otherwise you have two rear lines and then your buildable area is tiny. Or sometimes you've had streets with lots of streets on three sides.

Yeah.

And so the point is, I don't care what you decide. Either they're, become side lines or they're rear lines, but it's not being applied consistently now that I can see. We need to make sure.

If there's no railing authority to make a decision about that, do you usually go with the least restrictive or most restrictive?

I tend to give them two fronts and two sides. Let's put that in the regulations.

That's what this is saying.

Because having two fronts and then a rear or right side and a rear, you only have one rear. The rear is always opposite the front door, essentially. So there's only ever going to be one rear, but you can still have more than one front.

So if you have two fronts and a rear, then you can have two straight lines and only one front line. Because I want to get to it later because there's a definition for street lines. which I think we should probably, there's front line, rear line, side line, and street line.

You can have two street lines, but only one street. Do you want me to read that quick? Because I'm sitting on it.

Or you can just roll down. Okay.

Because it's a really short, weird definition.

Yeah.

The right-of-way or taking line of any street has to be defined above.

So street line, so I thought it should say the lot line of butting the right-of-way or taking line of any street. But the point is it's... You can have more than one street line, but you only have one front line. And it's in the bulk regulations, they talk about front, rear, and other. They don't even mention side. So we should probably be consistent and say, if you have a front, you have a rear. But if you have more than two streets, then you have Are we on a side or two sides or other? That makes sense, a rear and a side.

Is it defined in the deed about which is the street address and that would be your street line?

So that's why I put in which has a street address that otherwise, so the point is, so that was in some other definition somewhere else. I moved it here because it made sense. But the point is, I don't care what they decide, but Eric, can probably make some suggestions.

I will talk to the commission about that and we'll sort out how we want to handle it because, again, the use from my standpoint that makes most sense is to give them sides opposite whatever the front is and not have a rear yard.

Yes. But we're not saying what they decide. It's just a suggestion. They can make whatever they want, but it's not clear.

Just make it clear. What are the different line definitions used for? Like, is it important?

Yeah, because we'll get to the bulk regulations.

That's the bulk regulations.

So the bulk regulations say you can be X number of feet from the front line or a street line. Let's go back. That's what table.

It's going to be in Section 5 or 6, I think.

Oh, I can't see without my glasses.

Okay, that's the answer.

But I think it is. I noticed that in the book table, they don't mention sideline. They mention other.

I think it's in. That's the one thing. I used to know all the numbers.

I don't know.

Okay.

Did it change? Has this?

The numbers themselves haven't changed.

Section 9. Section 9. Section 9. Move from here. Section 9.

Hang on, we'll get there in a second.

Okay. It's working better than Sprint Out, isn't it? Yeah.

Together. Getting there. Area, yard, height, standards.

Almost there.

Yeah, I can't.

You know, you can just...

Hang on, yeah, I know.

Give me a second.

Just go, like...

I know. Wherever you scroll by. Yeah, that one, but it makes sense.

Table on section 10. Okay, here we go. Minimum setbacks and such.

This is the fastest way to do this. I'm just saying it's not.

See, Richard, so it's like Yeah, yeah, thanks.

So street line, doesn't say front line, it says street line. So if you have two streets, it's that close. Then it has rear property line, but it doesn't say it's, so rear property line is defined as Eric's saying, away from the front. So maybe that this, then it says other. So really it's side property line. Because there's no definition of other property line, unless you say, if you're not a front or street or rear, you're a side.

But those are both 35s. I mean, they're both uniform. No, they're not uniform.

But are you?

Are you 15 and stuff? That's where it gets smaller. Yeah, that gets tighter.

All right. So the point is, we just need to be consistent. How many rears and how many sides? And then straights line versus front line versus side puddles.

And how come they don't have the SVB district? It's covered separately.

It's a separate table.

There it is.

And I noticed that I thought we should add G. We'll scroll down to other again.

What does G mean?

I'm going to tell you. So C section 11.4 for SVBD. And it should be VBD, sorry. Purpose, Accolade, Process, and Design Standards. That's not, it's only listed in 11.

And there's a lot there.

And then section 9.2.2b for total coverage potentials, site development plan increases in C30 and C3 districts. So it's just a few little more notations, but other than that, that's why it's important to say which one we're talking about because it does matter as the measures, the bulk requirements. Okay. What time is it?

It is 7.43.

Okay. Sorry, that's over now. But we're done almost with definitions. Can we go back to definitions?

I'm sorry. It's okay.

That was supposed to be C30S, not D5. Did you say 5? S. S. Okay. I wouldn't mind.

Okay. So we're at street line. I'm in 26.

5.5. Let's keep it going up here.

Here's 25. Hang on. Just about there.

Last stop on 25. Lot line.

Lot line side. There you go.

So the A line is not a front lot line, or I should say street lot line. or a rear lat line, this should say street.

It should say street, yeah.

It should say street. And then a side line.

And then, so I'll, whenever you like that, I'll mark right down.

Street.

Fine. Okay. Next. I think if you just hit next under.

There's so many... So many on the same page here.

These are scenes that were just moved. We can only move things.

They don't have to move them. That's what it is. Okay.

Story is the next one, presumably, you want to talk about. Yeah.

Story. That enclosed part of a building other than the basement or cellar, including between the surface of any floor and floor above you. You can find floor to floor as well. And if there's no floor above it, there's space between the floor and the neck. See, this is the ceiling. This is where they play the game. The ceiling above it. Or if there's no floor above it, then the roof above it, or the roof rafters above it.

Yeah, the roof rafter. You called it the roof rafters, or we can say, again, the roof structural support rafters. Let me talk to the building official about how you would describe that.

Yeah. But I think the thing is, we should be going after the volume.

It's a different thing when you go up, there's a collar tie that goes across, and you've used, or you have joists that go across, and that's a ceiling, a flat ceiling, a vaulted ceiling with just a couple of connectors in between. It's a very different space. I don't know whether we want to get too edgy about it.

And then here, it's a fan story. Having a floor joist level with the roof eaves. Well, you can have a flat roof and you don't have, and you'd have a half story. So that doesn't make any sense to me, at least measured by kind of six feet grade. So I think take that out. The more you can simplify, and here's the street line, the lot line abutting the right of way. So I don't know why it's street line here and not lot line, street lot line, I don't know, whatever. And then zoom up here. I suggested that they separate windmills from solar panels.

And the blues and the yellows are just chunks you move from one place to another.

Right, exactly. And I'm saying, like, they have wind turbines, and then they have solar panels. So you should separate those out a little bit, but that's a suggestion. Here, the argument here required. This is where I get back to accepting the case without more than one street line, but you can make whatever you want. Not that there is no rear yard, there's only one rear yard. This was tied back to whatever we decided to do with the lot lines, definitely.

The normal side yard required. This is lined instead of slimed.

In the case of a lot with more than one straight line, because it couldn't be, it doesn't have to be a corner lot. All right. I think that's the end of definitions.

Stephanie has some.

Oh, okay.

Go ahead, Stephanie. That's okay. Go ahead. 188, 188, 188, 168.

Oh, I don't know. I don't know if that's a real thing. I should have looked it up. Landscaping. Under landscaping, what's that? The last word in that.

That just means things that are attached to whatever you're talking about.

Oh, I guess that's real work.

We could zoom ahead. I guess. Yeah.

You use definitions. You've got things in there as well.

You want to go up a little bit more. So this is where I said any purpose which a building or structure or premise may be designed, arranged or intended, maintained or occupied or any activity occupies. Oh, that's just moving to the use definition under uses definitions. This section provides all principal and accessory uses and use table provided in sections five and six respectively. And I think that's why I suggested taking some of these buildings and structures as sections five and six. And then, well, for that, this is not identifying uses here. It should be section 25, not 20. Okay. And then, most of these are just moving things. Oh. So there's accessory farm buildings and accessory farm building new systems. And I just moved it from some other place. I've just seen another place.

Alternative energy systems. I think they said... You're taking that out?

No, no, I added... She added language in. I just put the definition here instead of saying consists of the following. But I suggest they separate solar energy and wind turbine structures and put them somewhere else. But we don't have to do that.

Bud down, please.

Yeah.

Commercial greenhouse is listed somewhere where there's no definition of it anywhere. So I just move it in here.

Just move those things around.

I think most of these are just moving things around. I didn't write. get into the uses, definitions.

Okay.

Okay.

I think we're at the end here. Where to next?

So that was definitions. So I guess if we wanted to talk about blood zone regulations, so I think let's go to chapter 12 or 13.

Special regulations, it's

Here we go.

So what I did in 12 and 13 is I, some things that were in ZBA sections or other sections I put, if it was related to FEMA, I put it in FEMA. That's in 13.

13 overlay zones is FEMA? Yeah.

It's FEMA. Okay. Oh, and I thought of something else I forgot to add. Okay, but let's...