Planning Commission

Okay, Mr. Villalobos will you please make the TV coverage announcement?

be joining us in just a couple of minutes.

Okay, could we please have the projection report Mr. Wilson?

Good morning chair and commissioners I'll begin with the agenda status report if that's okay Mr. Chair and then we'll move into the projection report on our standard agenda today we have two items the first item is The land use permit and conditions permit for the Chick-fil-A in the Eastern Goleta Valley community area. And then we have the Rose comprehensive plan amendment zoning map update or zoning map amendment.

Public comment. This brings us to general public comment, this is for public comment to allow testimony or a comment on any items not on today's agenda so at this time do we have any persons wishing to make public comment either in person or online?

I see no one rise. I see no hands raised from our zoom attendees

Okay, so that will conclude general public comment for this hearing next planning commissioners informational reports any reports from individual commissioners on interest items of interest such as planning issues seminars meetings or literature Commissioner Park, I knew we could count on you.

Well good, I like to be reliable. We report on courses and things we've taken. And nowadays that's not just going to a seminar somewhere, a boondoggle type thing. It's what we might watch on our television sets as part of our video education. So I've been taking mandatory continual continuing legal education courses on planning to keep my bar license active It took two last week that I thought, I'll never need these but I've just got to kill two hours to finish it off. And one was on section 15183 and one was on VMTs and I guess they are more relevant than I thought.

But the VMT ones in a general sense had a fascinating idea. A speaker from the Western Riverside Council of Governments They have noticed, like all of us, that VMTs are confusing to figure out. Many projects get them just because they have traffic and it's hard to figure out how to mitigate VMTs. This is under CEQA within a project so this new program they have down there WRCOG is that if you are generating VMTs, you come to them. They act like a broker or a banker and they have projects that reduce VMTs so you help fund those projects and that's how you mitigate your VMTs That's kind of interesting. You might think, well okay if I've got VMTs to deal with and I help fund a bicycle path that's one way of reducing VMTs but one of their programs for reducing VMTs is affordable housing because they find that some affordable housing projects, because they concentrate housing and because they put them in urban areas and because it allows people that would otherwise commute hours and hours to get to work.

That it does reduce VMTs. And it struck me that here in Santa Barbara County, and I always complain about this is that we don't have any funding for moderate income housing. We do for low-income housing, but not for moderate. And it's a danger to all of us because at some point policemen, firemen, teachers, nurses etc., will not be able to live in Santa Barbara County and what will it be like to live here without them?

And we generate a lot of EMTs as they come from all directions And this is a potential source of funding for modern income housing coming out of EMT mitigation. And one of my long non-Brown Act horseback rides with Commissioner, I mean Supervisor Hartman yesterday we talked about this. She's quite excited and I'm looking at you Director Plowman because she wants you and I to put together a little talk on this and so let's chat a little bit after this.

So I think that's exciting. I hope it made sense to at least one or two people in the room

Okay, thank you. Now we go to the minutes. We're going to consider approval for the minutes of March 11th with staff submitted changes to item 1. Have you all reviewed these corrections to item one? Yes Mr. Chair. Commissioner Cooney? I will move approval of the minutes as corrected We have a second?

Yes, second.

Commissioner Ford seconded. All in favor of approving the minutes over the March 11th hearing? Aye. Aye. Which brings us to the Director's Report. So Ms. Plowman proceed please.

Good morning Mr. Chair members of the Commission.

Good to see you back

Nice to see all of you. I will work with Commissioner Park on this idea, I think it's a very interesting idea. It's true that we have virtually no source of funds for supporting moderate income housing and we're always looking for ways to try and stimulate it in fact we have programs And our housing element that direct the department to investigate opportunities to promote and support moderate housing. So yeah, I'm happy to meet to discuss that. And I've already talked to my staff about researching it, the Riverside program.

I don't have much to report on board items because there haven't been any board actions since we last met. But what I can talk to you about is what's coming up at the board We have our three-year work program for the Long Range Planning Division at the board on the 7th of April. As part of the budget constraints that the county is facing, all departments were asked to make some adjustments to their budgets and tighten the belt a bit and one of the things that we have proposed to reduce our general fund reliance is to keep two vacant positions in the long range planning division Thank you.

The two lost positions and one last position. So they get to see the difference if they restore one of our positions. Currently, we have 15 full time employees in that division or hoping to have 14 and we may end up with 13. And what that does is simply slows the work that we have. Thank you. But we will initiate that discussion with them on the 13th of April when we have budget workshops. So the board's budget workshops run the week of the 13 and the Planning and Development Department is up on Monday, the 13. And so if you're interested in monitoring that, it would be probably late morning that the department would be presenting in the workshop.

I also wanted to let you know that as part of the budget workshops, the CEO has asked Chris Chirguin who is the head of our IT department to present along with myself and Chris Sneddon on the progress with Acela which is our online permitting system. Both of our departments have fully incorporated Acela into our systems in terms of online services. We also have the fire department that has Acela and environmental health has Acela, and of course the CEO's office has it for cannabis. So if you're interested in that, that's going to be on the 15th of April we'll be participating in that presentation.

A local preference program going to the board on the 21st of April. And we're going along with Community Services Department, their housing division because we're taking to the board a concept of creating local preference guidelines for Capital A affordable housing that would be included in the rules and regulations that our county HCD implements with these affordable projects.

That would basically set it up so that people who were living or working in Santa Barbara, like the South Coast but living in the North Coast would sort of have the highest priority. So we could try and get people to live and work in the same vicinity. And that is a long-term objective for a lot of reasons, but one of them is VMT as Mr. Park suggested earlier today.

And then for market rate it's trickier. We all would very much like to make sure that all the new housing gets built as part of our housing element on the South Coast goes to people that are working here right? So that we can house our community There are laws in place that prevent any kind of potential discrimination and so we have to be very careful how we navigate this. But the concept that we have developed is, and it doesn't have a lot of teeth but I think it's the best we can do requirement for a marketing plan that shows how these developers are going to be targeting the locals early in the process and all of the publications that they're going to be listing their developments in, the businesses they contact, the work they do with the chamber.

And so that is how we are trying to get at it and that's what's going to be going to the board on the 21st. And we hope that it does make a difference. Most of the developers will tell you that they prefer having locals because they're more stable, people who are working in the community and so we're suggesting to them also in our program that when all else is created equal, you know, in terms of two candidates Please should prioritize the local person so that we can

yeah, I might know what you're kind of emphasizing South Coast in terms of the market rate. Yeah a tremendous need in the North County Santa Maria Oregon Hills areas because we're looking at one big new development now We've had others in the past and if there could be some I would like to So anything that could be done for the North County would be deeply appreciated.

I appreciate those comments and I think that'll be an issue that the board will discuss whether they want to expand it beyond the South Coast, yeah. I know I'm not agendized for this so council's looking over at me. Commissioner Park do you have a question?

One of the things that I remember from the housing element, I thought was really a nice piece were the various programs. Is it 25 programs or something like that in the housing element? And one of them was employee housing for all employers on site, not just ag dwellings. And I think that is an important workaround on this local preference because if we require a larger employer as a condition of something they want to do to provide employee housing And they basically buy a piece of it that some developer is building. As for their employees, I think that gets around the local preference constitutional issues and is also a good way to fund. COMMISSIONER

MARY ANN BORGESON Yeah. Commissioner Park, that's an excellent point. We do have one project on the South Coast where a local company is going to be buying I think it's around 150 units, and then selling them at a subsidized price to their employees. And it's the way they can attract and retain critical staff.

And I do agree with Commissioner Reed that it's very much a North County issue because I deal with folks when I'm volunteering on seniors Discuss those housing issues, and it's exactly as he's described it. And also when we talk to employers up there about expansion in providing more jobs in the North County other than some ag jobs, they all say the same thing. I can't really get the workforce I need because there isn't a

housing. Yeah. Yeah, the problem is spreading. The other

thing I will, Commissioner. This is of deep importance to me but I'm wondering in your definition of locals does it just include human beings over 18 years old who have a job here? Or do young people who go to schools here and have programs that they can only get, for example, in a certain area—Santa Barbara, for example—do they qualify as a local?

Well it's an interesting question. I would have to look at it. It's tiered right so there are higher priority people like actually have a job and a profession and they're working in the community. And then you go down from there, you might be the next category I think is somebody who has a job offer here. They're going to be moving to the area that kind of thing so we haven't really focused on students.

Students have been an issue. kind of a problem actually from UCSB taking up a lot of the housing in the Goleta area. So our primary focus is really more on our local employees. Okay, yeah thanks and then so the on the 7th of May we are going to be going to the board with a briefing and this is gonna be An item that will come to the PC eventually, but it is making sure that we are identifying the right areas where we want to create new ministerial permits. And this has been a long-term goal of the Board of Supervisors to simplify our permitting process. Right now, we are an anomaly.

Most jurisdictions allow a lot of different types of development with truly ministerial permits like for a single family home So that you don't do noticing and appeals and all of those things. So we are going to be moving in that direction per the board direction, and that is a package that will come before the Planning Commission. But Mr. Tuttle and his team are going to bring forward the concepts that we're looking at on May 7th so we make sure that we're going in the right direction before we develop the complete package. So if you're interested in that I would pay attention to that.

What date is

that? The 7th of May. And

that's all I have.

That'll be very interesting to watch hopefully that will happen and not create a feeding frenzy for appellant lawyers. One last thing since we're here, we have a workshop tonight in Santa Maria regarding a new development. We want to make an announcement on that?

Sure! There is a scoping hearing for the Solomon Hills project. It's a scoping hearing for the environmental impact report and it's going to be in the hearing room at the Beto O'Reilly government center?

That is correct.

What

time?

530.

An item there's been a great deal of interest on so I know it's been published but if anybody's watching this who hadn't known thus far might be a good way to spend a bit of time this evening.

Thank you for reminding me that Appreciate it.

You're welcome. So

do we have Brown Act issues if we attend? If two of you attend, you won't have Brown Act issues but yeah

I'm attending.

Yeah.

We don't ask questions at this either though, do we?

Vincent are you going? Excuse me? Is it

tonight? Just one question that this scoping hearing are we allowed to ask questions or are we only there to observe?

Chair and commissioners, my recommendation would be to observe only. This item at some point is projected to come before this body so I'd recommend not engaging or asking any questions. Observe only if you decide to attend.

Thank

you. Is this something that is available by YouTube, Zoom? Yes. On the county planning site?

Yes. But let me double check, I don't think there is the TV but

it's

recorded and people can attend.

It won't be live in other words so don't try to see it tonight. It will come afterwards.

It won't be on CSB TV but people can participate by Zoom if they want to provide comment

or just observe. And that information is on our site? Okay, thank you because I mean that's why I'm figuring I'll be working and I'll be looking from Zoom. Thanks.

Okay so are you finished? I'm done. Wrapped up okay so Mr. Villalobos could you please read the first item into the record

Yes, thank you Mr. Chair the following item is on the following is a hearing on the request of Turnpike Lodge's property owner to consider following case numbers 22 CUP 7 as well as 26 LUP 53 and to determine that no additional environmental review is required for the project pursuant to section 15183 of the state guidelines the implementation of the California Environmental Quality Act.

So staff are we ready to proceed? Please do.

Excuse

me. Sure. Ex parte, sorry.

Yeah

exactly. Commissioner Cooney?

Shall I proceed with ex parte? Yes. I had four meetings I'd like to report one was on March 16th a zoom meeting and there were two people From the Brownstein firm, Sarah Bronstad and Beth Collins. I had a separate zoom meeting on the 23rd with Mario Gorman. And finally on the 6th of March. I had a conversation with Neighbor of the project, who is Kathy O'Leary.

Well I'll go right now. I had last Thursday a site visit with Brian Robinson, Beth Collins and Sarah Bronstadt. Commissioner Ford?

Thank you. I also have met with Beth Collins, Brian Robinson, Sarah Bronstadt and two community members, Mario Gorman and Lisa Kenyon.

Commissioner Park?

I met with Commissioner Ford in Sarah Bronstadt and Beth Collins and Brian Robinson at the site a couple of weeks ago, I think it was Met at Starbucks with Mary O'Gorman this week. Had a conversation at sort of a social gathering with John Price and his son Jason Price. John basically owns the project next door, and Jason's office is above Starbucks. And if I've left anybody out, I apologize.

Okay, so now please proceed.

Good morning commissioners my name is Willow Brown I will be presenting the Chick-fil-A at Cayo Real project The property outlined in blue on this map is located at 4765 Calle Real in the Eastern Goleta Valley Community Plan Area, 2nd Supervisorial District. The property is a 1.42 acre lot zoned retail commercial. Access is provided off of Calle Real. Surrounding uses consist of Highway 101 to the south, Calle Real and commercial development including the Ramada Hotel to the north, residential development and vacant land to the east, and commercial development including the existing Starbucks drive-thru to the west.

The project is a request for a land use permit to allow for the demolition of the existing restaurant on-site and construction of a new 2,647 square foot quick service restaurant. The project also includes a conditional use permit to allow for a dual lane drive through with two covered canopy areas. The project is a commercial use on a commercially zoned lot which has been developed with the restaurant use for over 50 years.

Restaurants are permitted use in the retail commercial zone and the conditional use permit is solely required for the drive-thru use. This is a photo simulation of the project as viewed from Calle Real. This is the proposed site plan. The project site will be accessed from one driveway off Calle Real in the northeast corner of the project site. The project also includes access improvements including re-striping the eastbound approach along Calle Real to provide an exclusive eastbound right turn lane both for the project site and for the existing Starbucks drive through to the west.

Site access was reviewed and approved by the Fire Department and County Public Works Transportation. This slide shows elevations of the proposed restaurant. The proposed restaurant will have a maximum height of 22 feet, four and three quarters inches which is significantly under the 35 foot zone district height limit and is similar in height to the existing restaurant on site to be demolished As previously stated, the project is for a restaurant which is a permitted use in the retail commercial zone on a site that has been developed with the restaurant use for over 50 years.

The drive-through is an allowed use in the zone with approval of a conditional use permit. As outlined in the staff report, staff analyzed consistency with impacts to areas such as visual resources, traffic and circulation, air quality hazardous materials and noise and found that the project is consistent with all applicable comprehensive plan policies. The project also complies with all LUDC standards as it is consistent with the purpose of the Retail Commercial District, meets setbacks, exceeds parking requirements and complies with all standards related to drive-through facilities.

The project is exempt from CEQA pursuant to CEQA Guidelines Section 15183. CEQA Guidelines Section 15183 is applicable to the project because the project is for commercial use on a commercially zoned site, which was anticipated by the Eastern Goleta Valley Community Plan EIR. All impacts anticipated from the project can be mitigated by Eastern Goleta Valley Community Plan policies and standard conditions.

Although the project is exempt from further environmental review, the 15183 exemption still allows for analysis of issue areas to determine if there is a possibility for more significant impact than anticipated by the EIR. The 15183 analysis discussed several issue areas including impacts to traffic and air quality. The current metric the county uses to evaluate a project's transportation impacts under CEQA is Vehicle Miles Traveled, or VMT. The county presumes that projects meeting the VMT screening criteria in the County's Environmental Thresholds and Guidelines Manual would have less than significant impacts to transportation and would not require further VMT analysis.

The project is considered a locally serving retail project and is below the threshold of 50,000 square feet as shown in this table and is therefore screened out of VMT analysis. However, the traffic study submitted for the project also analyzed traffic and circulation impacts based on level of service and queuing which I will now summarize. The traffic study was peer-reviewed and reviewed by Public Works Transportation and found to meet county requirements The Eastern Goleta Valley Community Plan contains policies regarding maintaining a minimum level of service for roadways and intersections in the community plan area, and considers a level-of-service standard C acceptable.

Impacts from the project to level of service were analyzed for the intersections and roadways in the vicinity of the project site. The analysis confirmed that the intersections and roadways will still operate at a minimum level of service standard C with implementation of the project, and the project will not have a significant impact to level-of-service. The project will not result in queuing onto the roadway and will not interfere with circulation on site. The project anticipates a maximum queue in the drive-thru of 31 vehicles. The queue can be accommodated entirely within the drive-through lanes, which have a maximum capacity of 32 vehicles as shown on this site plan.

With regards to air quality, short-term and long-term impacts from the project were reviewed. The main proponent of long-term air quality impacts is mobile emissions. An Air Quality Technical Memorandum was submitted for the project analyzing air quality impacts and impacts from mobile emissions were estimated based on the anticipated vehicle trips as outlined in the traffic study.

Under the most conservative approach, which did not take into account that some trips are pass-by trips and did not reduce trips from the previous restaurant use on site. The emissions were determined not to exceed county thresholds or result in a significant air quality impact. The Air Quality Memorandum was reviewed and approved by the Air Pollution Control District.

In addition to the air quality impacts reviewed under CEQA, the LUDC requires that projects proposing drive-thru facilities show that the project will not have a greater air quality impact than the same use without the drive-through. The air quality memo shows that the cars idling in the drive-through would give off less emissions than cars parking and restarting for walk-in service.

This table shows the anticipated emissions for the drive-thru compared to the same number of walk-in customers at the maximum anticipated queue of 31 vehicles. The project is consistent with the LUDC requirement as the drive-through facility will have a lesser air quality impact than if the restaurant only provided walk-in service In summary, the project is consistent with all applicable policies of the Comprehensive Plan including the Eastern Goleta Valley Community Plan. The project is consistent with all standards in the LUDC including standards related to drive-through facilities and the project will not result in a significant environmental impact Staff recommends that your commission make required findings for approval of the project, determine the project is exempt pursuant to CEQA guidelines section 15183 and approve the project subject to the conditions of approval.

This concludes staff's presentation. Staff and the applicant are available for any questions. We also have Will Robertson from Public Works Transportation online to answer any questions related to transportation review.

All right, questions from commissioners? Commissioner Ford.

COMMISSIONER MARY ANN BORGESON Thanks. I greatly appreciate all the reports from both sides, super comprehensive. Just wondering about the traffic report. Who actually enforces the jams that we have all seen or experienced, talked about or heard about? The ones right in the middle of

I'm sorry, Commissioner Ford. The traffic jams like cars lined up in the street? Yes. Will Robertson are you able to answer that question for us?

Mr. Chair, Commissioner Ford, Will Robertson, County Transportation staff. So just for clarity when you're asking who enforces the, did you say backups or congestion? Are you meeting from the existing land uses or

Just in general, I mean, I don't know about other existing land uses that have documented traffic jams like this particular one. So who enforces it?

So the reason I ask is because there's going to be a lot of discussion about the Starbucks to the west and the queuing that occurs with that Starbucks. Technically, the enforcement arm would be And I'm going to start with the highway patrol. Okay, and then it would be dependent on whether or not the vehicles are actually violating the vehicle code. So it is just because vehicles back out onto a roadway is not necessarily a violation of the vehicle codes so as a lot of people are aware enforcement of something like that in the city of Santa Barbara with the Chick-fil-A there was quite nerve wracking So I'm going to go back to my statement. The official enforcement arm would be the highway patrol, but depending on conditions of approval of the project it could be planning and development or transportation staff.

Thanks.

Is

that all? OK, Commissioner Martinez.

Yes, good morning. My question is in regards to your slide number 8. In regards to these calculations, does the traffic study or whoever does these things, do they just use an accepted general standard? We got a small project, so therefore we plug in the number for 110 trips or fewer trips a day. Is that the way it's worked? Or is there a look at the reality? And the reason I'm asking this question is because, I mean, we know, I mean, we just can't ignore the reality when you drive by Chick-fil-A. It's going to have way more cars than I hate to say it, Lynn Carl's Jr. or even McDonald's sometimes but I think their best comparison is in and out so that's why I'm asking this question is this just an accepted standard that says okay you're 50 you're so many square feet the lots this much this is a number that gets plugged in is that what happens or do we consider other factors?

Mr. Chair, Commissioner Martinez the VMT screening criteria is from our thresholds and guidelines manual this is considered locally serving retail so the threshold for VMT specifically is 50,000 square feet but the project was also analyzed based on level of service impacts for the surrounding roadways and intersections as well as a queuing analysis done to ensure that cars would not be backing into the roadway

Okay, that went right over my head. So when you when you so this hundred and ten is this what we're saying is 110 trips or fewer per day for the site?

Mr. Chair, Commissioner Martinez the sorry the small projects row is not applicable to this project that was just also in the table but this is only related to the locally serving retail category and yes for specifically for CEQA like vehicle miles traveled that type of transportation review we do screen it out based on the square footage

So in this instance, can you tell me how many during the traffic analysis? How many trips were anticipated or is forecasted for the site which obviously is going to be Monday through Saturday since they're not open Sundays. Do we arrive at a forecasted number for that?

Mr. Chair, Commissioner Martinez I believe the vehicle trips estimated was 971 trips per day and that reduced some trips based on pass-by trips so just people passing by and stopping out of convenience but did not reduce based on the existing IHOP.

Okay thank you. Commissioner Martinez if I could add something to staff's comments It's important to understand that this is a CEQA threshold that triggers a certain level of mitigation required but it doesn't mean that we, if the project is under that threshold and we don't study it like this had additional traffic analysis even though it came in under this threshold.

Okay. And because that's where I was looking in regards to, let me get to the slide here. An odor abatement plan on number 11 proposed in compliance with what is an odor abatement plan for a car?

Mr. Chair, Commissioner Martinez there's an Eastern Goleta Valley Community Plan policy requiring odor abatement plans for any project that could produce odor including fast food restaurants and so the applicant submitted I believe it was attachment F to the staff report but I would have to double check that an odor abatement plan so they have a contact for odor complaints and processes to look at the existing equipment that they're proposing. For like, it's like hoods when they're cooking the chicken and yeah it's just to comply with the policy and that was reviewed by their pollution control district and found to be adequate.

Okay, so and the reason I ask this because I imagine some people just from the general public may say well an odor abatement plan has to do with the cars. It doesn't have to do with the car it has to do with the product being processed or cooked there on site. That's correct. Okay thank you.

Commissioner Park.

Thank you. I want to echo Commissioner Ford's comments that it is a good staff report. It is very complicated matter to put in writing and discuss, and I want to also refer to your section 15183 analysis, and I hope everybody read that. bottom of the page when you're looking online. And that's, what is it? 20 pages or something like that and it's even more complicated and sophisticated to get to so kudos to you for that. And also I want to thank you for the time you spent with me over the telephone going through these issues because that's very helpful for me and I think it's good for everybody. I point out to everyone we We noticed, Ms. Brown and I as we're discussing this that of course we have to be referring to the traffic study that the applicant submitted and to their air pollution study but they weren't even part of the public record.

I had no access to them neither anybody in the public and so after we got off the phone Ms. Brown put them in the public record and they're all there so everybody's had them you know from last week to look at I have a few questions that relate to traffic and things like that. The first thing is, let me ask you to explain to everyone the changes to the right-hand turn lane that will serve both Starbucks and Chick-fil-A because it seems important to me.

Is it possible to put slide 10 up on the screen? Will Robertson may have additional information on this as well, but currently there is not. If you notice the right-hand turn lane that turns into the Starbucks site and then further down onto the entrance for Chick-fil-A That doesn't currently exist. They're proposing to implement that so that cars turning right and not wanting to go to Starbucks or Chick-fil-A can just keep going straight and turn directly into the other lane, and there's now that bike lane in between the right hand turn lane and the through lane so that cars turning into Starbucks or Chick fil A would not have to turn Mr. Chair, Commissioner Park so the Chick-fil-A team actually was

really nice and listen to public works in the county as far as the operational issues that occasionally occur with the Starbucks project to the west. And what we came up with was since there is only one travel lane that goes through the intersection from the in and outside, we decided that we would just drop the number two lane, the lane closest to Starbucks And make that just a right into the project, the Starbucks project. What that does is it allows us to push the bike lane out away from the curb which gives better visibility for the cyclists It also allows us to eliminate the merge that currently happens right after the Starbucks driveway heading east.

And the merge was problematic because it's just another decision point for drivers to make as well as navigating the queue that may occur at the Starbucks, as well as conflicting with the original proposed second driveway that Chick-fil-A was going to have on their western edge of their property. So this allows us now to have one seamless lane. It allows us to create a right turn pocket dedicated exclusively for the Starbucks project. It allows a dedicated right turn pocket, dedicated solely to the Chick-fil-A building and it should help again with the visibility of the cyclists in the area providing a safer path of travel.

So all in all, transportation staff is really happy with the proposed changes. And this is the striping changes are fully supported.

Thank you Mr. Robertson I think that helps a lot. I'd now like to turn to our zoning standards and one that's particularly important. And I'd like to ask you to go to page 21 of your staff report Ms. Brown Preliminarily, Commissioner Ford and I had a really good site visit. We walked the site, looked at plans and Ms. Collins was very candid with us in pointing out that we would essentially need to make a finding that's embodied there in section 3542-130 of the LUDC that's in your staff report to the effect that the drive-thru has to, well no I got that wrong. The drive-through facility shall have no greater adverse impact upon air quality than the same use without the drive-through facility and that's why we thought that the Air Pollution Report was so important because it deals with it and it needed to be in the record.

But when I look at the findings, I don't see any finding that refers to this. The most I see that might refer to it is that the project meets the standards of review required for zoning but there's nothing more specific. I would think we should have a specific finding in there. Should we not? And even if you think we shouldn't, can we at least address whether it would hurt anything and there'd be anything wrong with it?

Yeah. That is fine. I think it's Commissioner Park. We're happy to add language specific that is written out. This is a development standard which doesn't necessarily equate to a direct fining but a CUP is so broad that we can easily work in this language, um, in terms of compatibility or one of those findings. I think it is appropriate to roll that in there.

Yeah. as a standard all throughout the life of the project, right?