awesome all right well thank you everybody for coming this evening uh as I'm sure you all not uh when you enter the room this evening uh we've got an informal format this evening in terms of it's primarily an open house that's intended for you to be able to ask questions uh of myself uh Jennifer has Camp I am the consultant who has been working on the zoning qua update uh for the last year and a half or so uh and we also have staff in the room so if there's questions you have about engineering about natural resources uh about any of the other components that we're going uh to talk about this evening we've got other folks in the room that can help you out as well uh so the intent of the presentation this evening is really uh just to give you an overview of the information that is at the boards this evening and to talk just briefly about some of the key changes that are in the zoning code uh update draft that is online uh so with that we've got stations that are intended really to match up with what some of the most significant topics are in terms of what we've been working on over the last 18 months uh we also have QR codes up here for your use the first QR code is a link to the most current updated draft the draft date on that should be February 2nd 2024 for those of you looking um and the second QR code is actually a link to a survey or questionnaire the idea is we want to hear from you and we also understand that sometimes in an environment like this it's hard for your information and your feedback to get recorded so uh We've prepared a questionnaire that matches up with each of the stations and we have copies of the station boards in the questionnaire to assist as you do this we will have uh the survey and we will have uh also a recording of this presentation online uh for at least a week uh so you have plenty of time to answer the questionnaire if you so choose after the fact if you remember tomorrow uh and want to do it so uh with that the idea is that your your comments and your feedback through that survey will actually be used to help us determine whether or not we've got some additional edits that need to happen to the code uh or whether we're in good shape and we're ready to go forward with the Planning Commission and the public hearing so to give you a sense of where we've been and hopefully where we're headed uh one of the primary reasons why the city undertook this process uh is that it is required that the city's zoning code is consistent with and supports the 2040 comprehensive plan so for those of you that participated during that process I believe the city worked on that for at least a couple years uh it's the 2040 plan so if you're online that's the document you're taking a look at uh and all throughout the Twin City col area all cities are required to update their comprehensive plan every 10 years as part of that process once the comp plan gets adopted the next step is that the city is required to update its zoning to match the comprehensive plan right so that is how we started this process the primary objective being we need to make sure that our zoning matches the comprehensive plan once we had that established uh as our primary objective for the process we identified other things that we should address as we went through this process if we're going to update our zoning uh why not make it an easier to use document why not make it easier to navigate find information also why not hopefully update some sections uh to be more consistent with what we actually see on the ground today in terms of the city's development patterns so with that as our Baseline as we started to go through the process essentially walked through uh with the Planning Commission all of these different topics so the first one being uh we talked about zoning and overlay districts so you'll see over here we've got here's our zoning uh that we are proposing we'll talk about that in just one moment in more detail uh and then over here we've got overlay districts the Planning Commission spent a significant amount of time talking about how do those districts lay out how do they work how dimensional standards work do we have it right and then also making sure that what's in those zoning districts matches the 2040 comprehensive plan which again is required then we talked about allowed and prohibited uses uh the uses turned into an extensive discussion with the Planning Commission in fact I think we might have had four meetings about the allow abuses um so there was a lot of discussion by the Planning Commission about what appropriate within the community what zoning District should those uses be permitted or conditionally permitted should we add to the table of uses are the things that are new that we haven't seen before but we would like to see one of those examples being for example a brewery which when the when the zoning was done you know 40 years ago breweries weren't a thing turns out they're kind of hot now right so the idea is what types of those uses do we would we like to see in the city and maybe we should get those into our table uses maybe it's in Distillery now I know they're kind of on the way out to um so Mota Heights might have missed that Chine might have to jump on the next one but that's okay right um so then we talked about character building and design standards this is the stuff that's about we like our neighborhoods we like our communities uh we like how they feel we like uh the house pattern we like the development pattern how do we protect those things uh and how do we make sure that moving forward we're reinforcing that character right and so the Planning Commission spent some time on that of how to address that again a significant amount of the information in there is actually the same as with in your current code I just revised slightly then we talked about the most important section which would be Administration uh most people don't care a whole lot about Administration until you're the one who has to go through the process then you care a lot about it because you want to make sure that it goes efficiently so that was our last topic uh and with all of those we then put together our first draft the first draft came out uh in April of last year and then the Planning Commission went through every single part of it over again so now here we are 2024 we have another draft uh and that is what is the topic of our meeting this evening sorry about our PowerPoint we're not totally sure what happened here but it got a little messed up uh so a little bit about the zoning districts the only thing I want to highlight is that the majority of what's in the zoning districts is the same as what is in your current coding there are a couple exceptions the first one being in R2 and r R three uh the lot and dimensional standards were revised to match your comprehensive plan remember what I said we're legally required to do that the zoning has been updated to match what your land use designations say your land use designations are in your comprehensive plan so while those things have been modified they're modified based on your adopted policy document already which is the 2040 plan the other thing to note is that we have Consolidated your business districts I think as it stands today in your current code you have B1 B2 B3 and B4 uh and the idea was there wasn't a lot of distinction between those two four districts so it felt like we could probably get it down to two districts and accomplish the same thing and make it easier to understand so that's what we are proposing this evening finally industrial didn't change that one really truly did stay the same other than industrial all of the districts now have an impervious service coverage requirement that have been added in and that is certainly a change from what is in the current code uh so we'll talk about that in just one moment so then after we got our base zoning districts established then we started talking about overlay the overlay District conversation uh was Spirited I would say uh we finally ended up in a place where we've got essentially three overlay districts that exist uh in this draft code the first one being public semiu overlay this is the only one of the three that's actually new the intent of the public sem public overlay district is really to geographically describe that areas in your city where there's already these types of uses occurring in your R1 zoning District that's the intent all right um so for example your schools your schools are actually in R1 today and they were permitted by right all right so what that means is you can put a school in R1 anywhere by right as long as you can meet the zoning standards which are based on a residential zoning District which means no school can meet the zoning District standards right so every time a school wanted to do something it needed a variance this code says if you're in the public semi-public overlay District now instead of a variance you're going to be required to get a conditional use permit which is the more appropriate tool because it says this is permitted with reasonable conditions that for the circumstances or the adjacent properties the only way those uses are permitted is if they are in the public semiu overly District all right now public semi-public uses can happen in your general business districts if they're on the table of uses they are independent from the overlay District because when you look at the map the overly District really is only about those Residential Properties so that's new the second overlay district is a planed unit development overlay District this is somewhat new but not entirely because the city does have planned unit development in its current code it just treats it slightly different the idea here is that planned unit developments allow flexibility from certain dimensional standards within your zoning po all right so what it means is there's a base zoning District that's guiding how the property that developed the planned unit development is an overlay District that allowed certain flexibilities from those based District standards we are just documenting it this way to make it clearer to folks developers Builders Property Owners my property was approved as part of a planned unit development so I have these base zoning District standards that kind of influenced how the development pattern looks the overlay district is what gave me flexibility for certain things dimensional standards Etc on my property right so not different just identifying it on your map in a slightly different way the third overlay district is what I affectionately called Mera overlay District uh which is the Mississippi River Corridor critical area you just can't say that to times fast is the problem becomes Mero the Mero District was adopted in the city about a year and a half ago or so and the Miracle is actually something that the Minnesota DNR required the city to adopt this is also something that was in your comprehensive plan it was the first I believe uh changed your zoning map the zoning map you but the zoning map and your zoning code to try and Implement your comprehensive plan so there are not a lot of Chang that are to this section because it was relatively new uh and had been developed about a year and a half ago the next area that we talked quite a bit about was actually properties in the city that were planted prior to 1982 why 1982 you might ask that's because that's when the code changed the last time for R1 prior to that date there were different lot siiz standards as a result Lots got created that were smaller than your current R1 standards when the city adopted its new code in 82 what ended up happening is it created a bunch of properties that became non-conforming for lot size lot width uh and some other dimensional standards when that occurred what happens is if somebody wants to improve their property and they meet the condition that they are a smaller lot size they are unable to do it without a it's arduous it costs a lot of money uh and then sometimes feels very arbitrary in terms of how you're applying the standard the city council and the Planning Commission said it's important to us to figure out how to bring more properties into conformance number one and number two how do we help our neighbors and our property owners that may be on these smaller lots and give them the opportunity to reinvest in their properties the way that we went about doing that took on several several different iterations uh and where we're at now is that any property that was pled prior to 82 provided it meets certain conditions would be considered a conforming property and those folks could then make improvements to their properties without a variance that is the way the code is drafted today in the draft but it is not how it is in your existing color so this is new it's essentially exception language uh that basically if you meet certain criteria you would be granted the the flexibility if you will from the strict R1 standards and you lastly which is over here to my right one of the most significant changes is the impervious surface calculation so what this says is every zoning District now would be required to implement essentially a maximum impervious surface ceiling and property owners could only go over it up to the next threshold if they Institute bmps now bmps are called best management practices bmps that are recognized are actually from the Minnesota pollution control agency which is the mpca the city is not going to make up what those bmps are the recognized acceptable bmps will mirror what the npca says are acceptable as a result of that we will put on bookends essentially that say look natural res resources are important surface water protection is important and we're going to balance that with the ab ility of folks to develop improve their properties but we're going to set a limit on what that number is whereas today there are no standards except in the industrial district right so as it stands today any Resident could go out and essentially pave over their entire life and that's obviously a little bit of an over statement but to a certain extent it's true this is saying we we that natural resour resources are important we identified that in our comprehensive plan we're going to put in dimensional standards in this case an area calculation that helps support natural resources protection simple enough uh however it will absolutely essentially impact every property owner in the city so it's definitely something that folks need to be aware of understand uh and then also ask a lot of questions about how this might back to you right uh I will say that we have got this map over here the majority of the city when we do the calculation uh would fall underneath what these thresholds are all right so we were very careful to try to determine what the appropriate thresholds might be understanding that the majority of the city is developed today and so what we're talking is Redevelopment some of these teror down house rebuilds um there's a bacon lot establishing those standards uh when new development comes into play but also establishing standards that recognize the existing development pattern so that's an overview of uh the materials that are here this evening it's an overview also of our process and some of the key changes there are I will I might put the other one back up just because there's two QR codes like I said the first one is actually a QR code that shows you electronically the draft code we do have one hard copy up here as reference for folks if they want to page through it otherwise I encourage you to take a look online um and with that not too bad I was about 20 minutes so if there's any big questions that have otherwise we can break back out we will be here until 7:30 um and also anybody who feels like they would like to go home go right ahead uh you don't have to stay if you don't want to put a whole two hours nothing else is going to happen I promise uh and there's also cookies uh in the event you need a snack so these residential or what any wording any of that regarding vbos RBS no so the city is undertaking a separate process uh to address short-term rentals uh you will note that if you go into our questionnaire the last question actually says uh there are a few topics of concern that the city is addressing or talking about over the next several months uh one of those being short-term rentals also this legislation uh there's natural resources ordinances that need to go into play in the environmental title um and so that last question says if these are things that you're interested in please click them uh and then also there's a comment box if there are specific concerns that you have that give you that chance to give us feedback anything you put in that questionnaire we will pass on to the appropriate staff uh but that process itself is going to run separately from this could could you go back to this slide of the Ines the next one one that shows the next one shows the actual percentages the table so you look at R1 35% could be 50% with the BMP so was there debate about going below 35% on the Planning Commission or was that a pretty uniformize that percentage so we actually did calculations uh we had a methodology of establishing a we didn't want to create a bunch of non-conforming lots across the city that was number one from the Planning Commission was directive we wanted to get an understanding of the existing development pattern so we actually uh used this is the Minnesota land cover classification system to understand uh what the coverages were out there today since you're largely developed uh and then we also did some area checking utilizing the area so what we did uh is actually went into areas that we knew had smaller lot sizes in particular that would likely have uh more hard coverage on them uh and started peling them out to come up with if we want to try to keep at least 75 to 80% of our properties in conformance at the low end what does that percentage look like and what we arrived at was about 35% all right then the next goal was all right if we've got 75 to 80% of the properties needing or below 35% how do we get to a bigger percentage how do we get to about 90% of all proper conforming and then what does that threshold look like and that's where the 50% came from all right so at 50% the estimation is at least 85 to 90% of your properties are conforming and that was the goal we didn't want to create a situation where existing properties were nonconforming so it wasn't so much of a debate as establishing what's the methodology to make this calculation and how we ar um if you could go back to the slide yes it says 35% for apprpriate surface up to 50% with who's going to who's going to control the um use of on the property after everything's been approved so ran the Public Works director can a little that so you know in that process um the city already has that does require BMP maintenance agreement so there's an agreement that's recorded against that property so it is on the title of the property um as far as you know can something up through the craft absolutely as far as as you know we might say you know you have to submit an annual report or you know now we're actually you know we're being very stringed now where we're like you need to attach a maintenance plan on back of this BMP maintenance agreement so no matter if that homeowner sells if that agreement goes with the property and that gives the city certain rights to go in and you know make improvements or make a compliance again and then we can assess that back to the problem so that's a record Doc correct okay and um let's see so what um that doesn't really answer all the question you're required to who's going to check yeah so that's where you know eventually we hope to get there you know so you know with this you know right now so we're recording all the agreements um you know keeping a table of them and yeah you know ideally we'll go and then try to inspect them once a year to you know compliancy so um you will have a list of all of the properties that exceed say the 35% and inspect them annually we will have a list of all the properties that have a recorded EMP maintenance agreement so you know we're not if someone's at 40% today you know that wouldn't work you know because they're already grandfathered in right okay but moving forward moving forward if someone comes in and wants to put let's say an addition on their home they will have to prepare a site plan so we actually have added into the new zoning uh code a process for a site plan review uh which may or may not be at the Planning Commission it if it's just prived by right it would be a site plan review to confirm that lies with the standards so that it an impervious will now be one of the standards that will be checked versus right now it's not because it's not a requirement so when a site plan comes in what planners usually do they check the setbacks they check the height uh they check that the driveway Dimension is correct they check uh to make sure that uh they're complying with basically all of the dimensional standards of the zoning District that they're in now impervious surface coverage will be one of those things that they're required to check that will trigger if the addition is going to punch it up over 35% the planner and staff will say all right now I'm exceeding this now we're going to need to look at a BMP and that property owner is going to have to identify what it is that will trigger the BMP maintenance agreement that's how it gets reported so whether or not there is some public process or not will be irrelevant because what's going to trigger it is actually the review at the staff level to say that that's required now in terms of impervious service and impervious service um I understand that there can be issues with perious service in terms of clog and um how is that going to be addressed because the Pria surface is deducted from the um impervia surface based on the dimensions and how um if it's cloged there's going to be a lot more run off and a lot more so I assume you're talking about like a pous pment yeah talking product so uh the way that it's described in the code is that the Public Works director actually has to approve that that prvious P pavement will meet the definition of it and then part of that is likely that there would be a maintenance agreement for it um so I know in other cities that I've worked in that have uh accepted prvious Pavements or papers or those types of things they require maintenance you can't just let them go um because they will PL or plug or those those types of things and so uh the way it's written in the code is the Public Works director has the authority to say that's correct you know we'll accept that as being pervious and that would likely then trigger that same type of agreement to say you know if it needs to be vacuumed every two years or whatever it is in order for it to meet that that standard is that is that likely to require additional staff to accomplish this uh eventually I would say yes and potentially me it depend I mean the other piece I will say though is if you look at um how many properties are going to exceed that 35% threshold uh hopefully it's not allowed because you actually have a fair number of properties that are well below that 35% so so much of it is going to depend on how many people actually uh want to exceed the 35% how many of those maintenance agreements do we actually end up with um 15 years from now could could you have they a lot of them sure might you need staff at that point yes some of it's going to be a monitoring right we don't 100% know um and so but that shouldn't stop us from trying to put the right regulation in and figuring out then how to deal with it um as we evolve and as the city changes uh but initially we're we're not 100% sure because a lot of it is going to depend on a how many properties truly start to push the envelope uh and B uh if you say to somebody you know you can put that in but you're going to be over 35% and so you're going to have to then make that courteous pavement for example there's a lot of folks who decide I can figure something else out because I don't want to vacuum my pavement I don't want to vacuum my house and I don't want to vacuum my right um so there's a lot of folks that will back off from what I've seen and they'll say what can I do to stay under that 35% because I just don't want the responsibility so it's hard to because it's really going to depend on how many folks begin to push that envelope there was a question about how you came up with the 35% and then the 50% and you said you wanted to make sure that at least 90% were in is that in the first three zoning districts or was it was across so 90% of those first three zoning now are 35% or below 50% or yes how how many are between 35 and 50 you know that off the top of my head no but we did actually do that analysis partially at least for the R1 uh we also actually after I visited with the Natural Resources Commission I went back and I looked at re um and honestly I actually think we could change the re uh to be actually 35% flat a 25 35 25 and maybe with 35 with a BM so so I actually think that we might want to look at changing that that re designation those are your larger Lots uh and 100% of the Lots were well below 50% they were also below 35% um so in that case I think setting very high so I I did it top so um why is forance residential estate up to 50% as I just said I think we could change that oh good good that's that's what I was saying so that's we're all for public comment right now so I would recommend submitting that as a comment and after I heard from the Natural Resources Commission we went back we did more analysis and I think uh it makes perfect sense that we would drop that already um the PSO is shown up there for impious surface but it is 60 to 75% right so the pspo you follow you follow the base zoning District so pspo is an overly District so it's not this isn't the P we don't have if you notice there's no public semiu zoning it's an overlay so you would follow the base so like if you look at this map the base zoning district is imp imp the pspo it likely I can't remember what it is it does junp it up though because we're talking about school a residential structure I'm sorry I thought you were saying on the table here it does yeso does allow 60% up to 75% of bmps right because but it's not up here because it's not I just misunderstood now you're saying it's not on the table it's not because it's related but but it doesn't follow the base right because it's giving special criteria for the overlay but if it was redeveloped it would be required to follow the R1 base correct what if it was redeveloped so if like God forbid uh two two rivers gets redeveloped as housing it wouldn't get to keep the 60% it would have to be redeveloped at 35% or 50% well as long as according to the way I read this which is one of the things I have a concern about is when you set the standards for the pspo dimensional standards it applies to all districts that are have the pspo over the yep all of them so if two rivers um were to develop it would revert to R1 it wouldn't have any of those as long as it as long as it was going to a if it stayed in a public purpose say they converted it to a Detention Center yeah they could still expand they could still do this or church or church or anything like that it can still stay that 60 to 75% of so these potentially because remember every single use that's a PSP use is going and it's in that base in that overly district with a base zoning district is going to be required navig conditional use permit correct but which allows development with reason Visions so there might be there might be let's say a project that would come in uh let's say it's next to an a sensitive environmental resource a creek or a or a lake or something uh and as part of that review process if it's a new project the city could actually say look we've got important natural resources that are on this site so we're going to allow you to put up a new school however you can't have that inous surface coverage because got to protect the lake we need a buffer we need these things those would be reasonable conditions if you can demonstrate that that Improvement could have an adverse impact on the natural resource that you've identifi as important so it's not a given but but it's a maximum but it may be an interpretation too that ends up going to the court of law that makes that decision because the developer May argue that this does meet the be you say it doesn't the decid but that's the entire code right well I understand that but I guess what I'm saying here is that um when we create this separate thing we create new standard so it can be up to 40 ft with the CVP for height so if mandona School the school district decides they want to build a say middle school and they want a three story Middle School um to go there as long as you say they're 100t back and they they comply they can build a three story structure there you can't stop them because it's up to 40t with additional use yeah that's that's by Design right so um right now if it's in an our one they'd be limited to a 25 cor so they'd be limited basically to a two story structure because that's the biggest zoning that may fit more into the community at that point um but if it's over that they can they can get it almost by what you just have to reason you can put reasonable conditions but you can't deny exactly and that's by Design I mean I don't I get the impression like you're saying that like it's a negative but the flip side is that literally everything that happens on each one of the school properties is a variance and it's like where you literally have at uh two rivers you know they're subject to the same accessory structure rules as a single family house on a quarter acre lot you know and how many accessory buildings are over on that property you know that that doesn't make any sense either where you're you're basically tossing out the rules of the schools just because now at least now you've got rules now you might say we want to lower the height requirement but like you don't want them coming in for variances for what say normal use of that property right a VAR giving variances for inappropriate reasons will likely end you up in court far more than a conditional use permit with reasonable conditions um regarding the PSD there are a lot of there's a lot of variation between the uses right there how how is it decided to lump these together in this semiu uses are pretty uh sorry Jill I I think she's saying School versus thank and and there two very different uses one is a big wide open Green Space one has big par lot big building tennis cours uh they're different in some respects but not at all in others right uh because a golf course for example ends up having a clubhouse uh several accessory buildings large parking lots uh very heavily manicured Lawns that are environmentally actually not all that great uh and then you have a church that has a large parking lot with impervious service a building may be a shed so in terms of how the uses are categorized they have a public or a semi-public purpose to them and that's how uses end up together um whether one is better worse uh should have different regulations not have different regulations certainly is debatable some cities do look at trying to have some kind of um Park golf course if you will sort of overlay the problem is uh that you cannot Zone you can't Zone park right you can't Zone something for Park you can't Zone something as Golf Course uh the courts have been very clear uh that that is essentially a regulatory taking or can be if you don't have reasonable value left on the property and so most cities have said we're going to Zone our BAS zone of all of those types of things Church golf courses Etc they're all going to have the R1 base zoning and that's that's what's obviously Mota Heights is done um and so there's no distinction between those things all right and a single family residential then you put the overlay District on it and it just says that the way it is right now essentially is it's only documenting existing public semi-public uses it's not any new or potential areas where some of these things could go um and so in terms of how we approached it was those uses are already there today how do we how do we categorize them together uh in a way that gives them certain flexibilities and then certain restrictions also like increase setbacks Etc uh because we would want to set back a clubhouse on a golf course much like we would want to set back a church on a on a property that might be next to so it was looking at how the properties are used but then also paying attention to the fact that we can't Zone something for par or open space agree with that and so I agree with the1 zoning as an under zoning um if there are standards that run the gamut for all of the overs that's so you know I'm just going to suggest to everybody that maybe we do five more minutes of this uh and then we can break out so that if others have questions for specific individuals that are here just in the interest of everybody's time to make sure that they can get out of here and folks can go home to their families Etc so we'll do this for about five more minutes and then we'll break out so um somebody had once said that putting lighting up at the football field at SI um required a variance it did almost didn't get approved um but that's up to council council could approved or not appr um so in the future does that mean there's no discussions I mean the school district can go ahead and put lighting up wherever they want no schools are going to be required to get a conditional use permit moving forward essentially any modification that a school is going to make is going to require a conditional use permit that has a couple benefits to be perfectly honest with you um so from my perspective I was here for about a year as your community development director uh standing until you got Sarah on board what I can tell you is that the lack of documentation of what is permitted on your school campuses is extremely difficult from a planning purpose or planning perspective because when the schools come in and they want to do something uh there's no real record of for example how many parking spells there are uh they want to put on a new addition how do I know if they have the appropriate number of parking spells that can support what they're proposing to do a conditional use permit will document those things and keep a record of it and so then it will say the cup says that these are the improvements that exist here this the parking these were the improvements that were required now if the school comes in and says I want to do some other addition now you have to see a does it work with the conditional use permit that got put into place and what other reasonable conditions might be necessary in order to make sure that we are mitigating and protecting against potential adverse impacts so it will provide a greater sense of documentation of what these public semi public uses have uh and then moving forward if they were to ask for a new permit or an amended permit how does that new information compare to what we have on the record permit so this this this doesn't make it any easier I've heard council members say that it'll make it easier that we can get some of this stuff pass but if it's a cup it will make from a community perspective they're still going to put the same amount of pressure on city council to make decisions Al the city council can say well they by right they have a right to put lights up there we can just put conditions on it so that argument goes away what you're saying well it's I guess it's all in the way you describe easier um right easier to me means that there are there's a path forward the school understands I have the right to do this with reasonable conditions that's different than a variance analysis so to me it's easier because a conditional use permit says I know I have the right to do this with reasonable conditions that is a much different hurdle than I need to ask for a variance for this so the developer it's easier for the developer than it is for the residents it's easier for everybody because you know what's permitted and what's not in this cases the high school the developer or resident they would be the developer I would say they're the resident I mean you know there're stakeholder in the community this isn't some outside person that's coming in purely trying to maximize profit on a piece of property the school's a resident you know has rights in the area they're commercial we would be developer I mean the people executing the work yes yeah I mean you get like the lights is a good example the lights would get the same level of scrutiny as it under C as it did under variant but it it at least sets the a more firm ground to have that discussion as opposed to I mean the school at that point is no different than my neighbor going in and asking to put up you know yeah right but the the argument is different because the school knows are going to get the lights they didn't no no but C they know they're going to get the exactly I don't have to worry about that you're going to get there I'll try and appease the neighbors if I can but if I don't that's fine too because I no but it's not fine if I don't appease the neighbors because you're still going to go through the CP process and the conditions are supposed to be directly tied to and have a Nexus with mitigating for adverse impacts so if you're going to put 10 flights on a property line I I've worked with your councel they're pretty bright and they would say that's not okay my neighbors you have to be a good neighbor to the residential and so you've actually got to offset that by another 40 ft or whatever it may be that is completely doable and reasonable within a CP process but not so much in a variance if I recall correctly the lights in particular is a measurable the bleed over light is a measurable pollution level so you are required you basically have a discuss where a requirement is set for how much the lights when they're on can basically emit onto adjacent propes all right so with that I think we'll we'll stop there and we'll break uh we will be saying we've got we've actually got our Planning Commission representation here now so if you're wondering how we came up with some of this they're here sorry I was at my kids uh what is it parent teacher conferences this is way more pleasant but if you're wondering where some came from they are here to answer your questions as well I will be staying Ryan this here as well so with that please feel free also to go home or have a bir so thank you all for coming to