HomeMy WebLinkAbout2012-09-05; Planning Commission; MinutesPlanning Commission Minutes September 5, 2012 Page 1
Minutes of: PLANNING COMMISSION
Time of Meeting: 6:00 p.m.
Date of Meeting: September 5, 2012
Place of Meeting: COUNCIL CHAMBERS
CALL TO ORDER
Chairperson Schumacher called the meeting to order at 6:00 p.m.
PLEDGE OF ALLEGIANCE
Commissioner L’Heureux led the Pledge of Allegiance.
ROLL CALL
Present: Chairperson Schumacher, Commissioners Arnold, Black, L’Heureux, Nygaard and
Scully
Absent: Commissioner Siekmann
STAFF PRESENT
Don Neu, City Planner
Jane Mobaldi, Assistant City Attorney
Bridget Desmarais, Administrative Secretary
Sabrina Michelson, Senior Office Specialist
Scott Donnell, Senior Planner
APPROVAL OF MINUTES
Chairperson Schumacher asked if there were any corrections or revisions to the minutes of the meeting
from August 1, 2012.
MOTION
ACTION: Motion by Commissioner Black, and duly seconded, that the Planning Commission
approve the minutes from the Regular Meeting of August 1, 2012.
VOTE: 4-0-3
AYES: Chairperson Schumacher, Commissioner Black, Commissioner L’Heureux, and
Commissioner Scully
NOES: None
ABSENT: Commissioner Siekmann
ABSTAIN: Commissioner Arnold and Commissioner Nygaard
Chairperson Schumacher directed everyone's attention to the slide on the screen to review the
procedures the Commission would be following during the evening's Public Hearing.
PUBLIC COMMENTS ON ITEMS NOT LISTED ON THE AGENDA
None.
PLANNING COMMISSION PUBLIC HEARING
Chairperson Schumacher asked Mr. Neu to introduce the first item.
CORRECTED
Planning Commission Minutes September 5, 2012 Page 1
Minutes of: PLANNING COMMISSION
Time of Meeting: 6:00 p.m.
Date of Meeting: September 5, 2012
Place of Meeting: COUNCIL CHAMBERS
CALL TO ORDER
Chairperson Schumacher called the meeting to order at 6:00 p.m.
PLEDGE OF ALLEGIANCE
Commissioner L’Heureux led the Pledge of Allegiance.
ROLL CALL
Present: Chairperson Schumacher, Commissioners Arnold, Black, L’Heureux, Nygaard and
Scully
Absent: Commissioner Siekmann
STAFF PRESENT
Don Neu, City Planner Jane Mobaldi, Assistant City Attorney
Bridget Desmarais, Administrative Secretary Sabrina Michelson, Senior Office Specialist
Scott Donnell, Senior Planner
APPROVAL OF MINUTES
Chairperson Schumacher asked if there were any corrections or revisions to the minutes of the meeting from August 1, 2012.
MOTION
ACTION: Motion by Commissioner Black, and duly seconded, that the Planning Commission approve the minutes from the Regular Meeting of August 1, 2012.
VOTE: 4-0-3
AYES: Chairperson Schumacher, Commissioner Black, Commissioner L’Heureux, and
Commissioner Scully
NOES: None
ABSENT: Commissioner Siekmann
ABSTAIN: Commissioner Arnold and Commissioner Nygaard
Chairperson Schumacher directed everyone's attention to the slide on the screen to review the procedures the Commission would be following during the evening's Public Hearing.
PUBLIC COMMENTS ON ITEMS NOT LISTED ON THE AGENDA
None.
PLANNING COMMISSION PUBLIC HEARING
Chairperson Schumacher asked Mr. Neu to introduce the first item.
CORRECTED
Planning Commission Minutes September 5, 2012 Page 2
1. MP 12-01/LCPA 95-10(C) – VILLAGE MINIMUM DENSITIES – A request to recommend
(1) approval of an amendment to the Village Master Plan and Design Manual to
implement part of Program 2.1 of the 2005-2010 Housing Element, and (2) that the
amendment is within the scope of the Mitigated Negative Declaration previously adopted
for the 2005-2010 Housing Element.
Mr. Neu introduced Agenda Item 1 and stated Senior Planner Scott Donnell would make the staff
presentation.
Chairperson Schumacher opened the public hearing on Agenda Item 1.
Mr. Donnell gave a brief presentation and stated he would be available to answer any questions.
Chairperson Schumacher acknowledged receipt of an errata sheet for Agenda Item 1.
Chairperson Schumacher asked if there were any questions of Staff.
Chairperson Schumacher asked what would happen if a developer were to propose a project which has
20 dwelling units per acre, which would be higher than the existing minimum but not as high as the
proposed minimum number of dwelling units, and if additional work or studies would be required of the
developer. He asked if situations such as that would actually dissuade people from proposing
development in the Village. Commissioner Schumacher further asked if there is a way to work with
developers or applicants that is not able to meet the new higher minimum. Mr. Donnell stated yes and
that is already acknowledged in the Village Master Plan. There is a standard that permits modification of
development standards, particularly in the cases where a developer is struggling to meet the minimum
densities including these new proposed densities. In such situations, Staff can work with developers to
try to achieve that new minimum; however it is acknowledged that in some situations particularly with very
small lots, that even with a standards modifications it may not be possible to achieve the minimum
density. In those cases, some of the proposed text amendments would allow densities below the
minimum subject to the making of additional findings.
Commissioner L’Heureux asked about the densities of two projects in downtown Encinitas. Mr. Donnell
stated he did not have a number for density for those projects; however he gave density numbers for
projects in Carlsbad. He stated that the Village by the Sea project, which is a mixed use project, has a
density of just under 23 units per acre. Commissioner L’Heureux asked about density for the project on
Laguna Drive across from Maxton Brown Park. Mr. Donnell stated he was not sure for that project but
would suspect it is under 20 units per acre.
Ms. Mobaldi stated that in regards to the question about density, the government code provides that if a
project is approved and it is below the minimum density then there has to be a finding that the density that
was not accommodated, because the project went below the minimum, can be accommodated
somewhere else at other sites. In other words, the state’s Housing and Community Development
Department does not want a net loss of density.
Commissioner Nygaard inquired if the additional density could be placed in the Excess Dwelling Unit
Bank (EDU). Ms. Mobaldi stated the EDU is not applicable in the Village area; however those units would
need to be accounted for and there would need to be other sites that could accommodate those units that
were not used to accomplish the minimum density. Chairperson Schumacher asked if that would trigger
additional work on the part of the property owner or if the property owner would then be responsible for
finding a site or sites able to accommodate the units. Mr. Donnell stated that he believed state law has a
provision that places the burden on the land owner. Typically though that is something the applicant and
staff can work together to identify other sites.
Commissioner Scully asked where the number of 28 came from. Mr. Donnell stated that in working with
the Housing Element consultant and Staff with the Housing and Neighborhood Services Department,
Staff needed to identify sites that the state would accept as being acceptable for lower income housing.
Staff knew the Village area was an area of the city where density was acceptable rather than other parts
of the city. The figure of 28 units per acre was used because it was a percentage of the existing
maximum density. Mr. Donnell stated that that percentage was a formula or a means for the state to find
Planning Commission Minutes September 5, 2012 Page 3
a new minimum density acceptable. He further commented that the figure of 25 units per acre may have
been acceptable however there was a requirement to go higher than 25. Commissioner Scully asked
what the reality is of the sites reaching the minimum density of 28 or larger. Mr. Donnell stated that it is
tough to say because there has not been a lot of development of late in the Village. He stated that he
does suspect that for a property owner to reach the minimum density there will need to be standards
modifications made. Commissioner Scully asked if there have been any consolidation of properties now
that there is something in the pipeline. Mr. Donnell stated that there have been preliminary reviews in the
past, which are informal proposals, which were at very high densities. Mr. Donnell stated that merging of
parcels in the Village is actually very rare because so many of the properties are owned by different
owners and some of the properties have been held in a family for generations.
Mr. Neu commented that the density increase would allow smaller sites to have two or three units where
previously the density would only allow one unit.
Commissioner Nygaard asked what the impact is if the Commission does not move forward with this. Mr.
Neu stated that if the program was not implemented, the City would have to make up the units that were
projected to come out of the program in another means, either through designating specific sites or
developing another program that may affect other properties. Mr. Neu stated that Staff is starting work on
the new housing element that will run from 2013-2020. This current element was extending beyond the
2010 horizon. Staff would prefer not to have to go back and redo an old element while starting on the
new one.
Commissioner L’Heureux asked if the new housing element would have further requests to increase
densities in the Village area beyond what is currently proposed. Mr. Neu responded he did not believe
so. He stated many of the sites, as seen in the Draft Preferred Land Use Plan for Envision Carlsbad, are
being planned to meet the new housing requirement. Mr. Neu stated that he did not believe the City’s
current housing element compliance track involves going back to the Village and increasing the density.
If anything, because the city anticipates a certain ability to create units out of the Village, the City can
count those units for the new element. Commissioner L’Heureux said that the actions tonight would set
the density level in the Village area through 2020. Mr. Neu stated yes.
Chairperson Schumacher asked how density is calculated on sites such as Paon which is a mixed used
project with a restaurant, office and residential units. Mr. Donnell stated that the density is calculated by
simply taking the acreage of the site and dividing the number of units by that acreage. It would be treated
as a fully residential site. Chairperson Schumacher asked if this action tonight would dissuade
developers from proposing mixed use projects in the Village. Mr. Donnell stated he did not believe so
because the emphasis in the Village is mixed use. In fact, when the Housing Element considered what
the density yield would be from these higher densities, it was based on a mixed use arrangement. Mr.
Donnell stated that in addition to that, when Council adopted changes to the Village standards in 2007,
the Council entertained having a density going up to 45 units per acre. What was ultimately approved
was 35 units per acre but as part of that change the Council also modified standards such as building
height, setbacks, and lot coverage, to recognize that that higher density was coming and to help
accommodate it.
Commissioner Black asked about lot merging of many lots in the Village. Mr. Donnell stated he does not
feel the vision or standards of the Village would allow for a “superblock” type of development. If such a
project were to occur than the project would have to be designed to look more like individual projects in
order to maintain that pedestrian scale and that smaller feel that is in the Village.
Chairperson Schumacher asked if there were any further questions of Staff. Seeing none, he asked if
there were any members of the audience who wished to speak on Agenda Item 1.
Chairperson Schumacher opened public testimony.
Lucinda Vigne, 3880 Hibiscus Circle and owner of a site on State Street, asked for clarification regarding
the proposal. She stated the new minimum density proposed is too high.
Chairperson Schumacher asked if there were any other members of the audience who wished to speak
on Agenda Item 1. Seeing none, he closed public testimony.
Planning Commission Minutes September 5, 2012 Page 4
Ms. Mobaldi clarified that the densities have already been approved by the City Council with the approval
of the Housing Element 2005-2010. This was a part of Program 2.1. This is merely the implementation,
changing the documents to reflect what has been approved in the General Plan.
Chairperson Schumacher stated he is concerned that the City is creating a hurdle for property owners
and/or developers for reaching the minimum densities and additional studies or reports, and costs being
put on the land owner. He asked if there is a way that when an applicant proposes a project that will not
be able to meet the minimum density that there will be a path on how to the applicant can work with the
City on how to achieve that and how to rebalance those numbers.
Mr. Neu stated that the Commission recently approved minimum densities throughout the city for the RH
and RMH land use designations. Findings have successfully been made for several projects to be below
the minimum required density. He further stated that he believes the City will still have the ability and the
flexibility on sites, particularly the smaller parcels, to have a way where the land owner does not have to
meet the minimum density should it be shown to be infeasible. Staff has not had to ask applicants for
additional studies as most of the time Staff can review the site, the project design and the product, and
review the other development standards in order to make a determination.
Commissioner L’Heureux asked if the property owner will have to find another site in the Village to make
up the difference in units if the minimum is not reached. Mr. Neu stated that the requirement has not
been implemented in that strict of a manner. State law requires that you show that by reducing the
density on a particular property that there are adequate sites elsewhere in the city to make up the
difference. The City has relied heavily on the Excess Dwelling Unit Bank, in that any particular residential
or non-residential site can request dwelling units and through the density increase process or
redesignation to residential could conceivably be allocated units. One of the issues that the city is
running up against with the update to the General Plan is that there are more people asking for units than
the City has dwelling units with the Growth Management caps. Practically speaking there does not seem
to be an insurmountable problem right now. It is more of an issue being able to accommodate housing
when the demand is higher for attached product. Mr. Neu further stated that to date the City has not
asked a developer to go out and identify a specific site. If the City gets closer to running out of available
sites, then Staff might take a harder line at some point in the future. Commissioner L’Heureux asked if it
is possible that as there are fewer units in the Excess Dwelling Unit Bank that projects are denied
because enough units are not being proposed. Mr. Neu stated he supposed that could be possible
however that the city is a ways from that in terms of available land left in the city. He stated that some
level of review is necessary so that the City is not abandoning the idea that the minimum is the target and
that there is flexibility to go below the minimum but Staff would want to make sure that there is rationale to
make the finding to go below the minimum. Commissioner L’Heureux asked if that by adopting the
language it does not require a certain product type, any price cap or any requirement that low income
housing be constructed. Mr. Neu stated that the requirement for income restricted housing is as it is
today in the Inclusionary Housing Ordinance. As the housing program has been administered, there are
options for onsite or offsite housing, and there are quite a few options for specific sites.
DISCUSSION
Commissioner Nygaard stated that no one wants to see increased density anywhere but that is not the
vision of the State. She stated that it is very important for the City to have a certified Housing Element. If
the City does not have a certified housing element, the City would have a huge amount of problems. She
feels that density does belong around transportation centers such as in the Village. The densities have
already been approved by City Council, however it is important for the Council to hear the Commission’s
concerns regarding how difficult these densities will be to achieve.
Commissioner Arnold stated that he knows the Commission is mainly being asked to give a
stamp of approval onto something the City Council has already authorized, a zoning increase or a
density increase, but in light of that, the Commission’s vote is basically very symbolic. His
symbolic vote is going to be no because he believes that there are too many problems that the
City has to look at. The City wants to encourage mixed use and here the City is holding people
who want to build a restaurant and maybe a boutique to the same standards as a purely
residential building. Also, down the road it could cause the City to question a development
because the City is not hitting these very high minimum units that are being set with this action.
CORRECTED
Planning Commission Minutes September 5, 2012 Page 5
What the Commission is doing, in essence, by approving this is making it more difficult for private
developers to do something that makes sense to them with their property. He understands that
the state is breathing down the city’s back and the City does have a lot of requirements that have
to be met there but he believes this is the wrong thing to do so he is not going to support this
proposal.
Commissioner L’Heureux stated that this is a situation where reality is bumping up against concepts. It
bothers him that the City has arbitrarily taken the areas in the Village and applied the density numbers,
particularly in Area 9. He stated he is concerned about the unintended consequences, and he
understands the dilemma the City is in regarding the housing element. Commissioner L’Heureux will vote
to approve the changes but encouraged staff to look at Area 9 where it surrounds the transit station.
Commissioner Scully stated she has voiced her opinion on the Housing Element many times on many
different occasions. She concurs with her fellow Commissioners in that the project will create issues
further down the road. Commissioner Scully stated she will not approve this item particularly for Areas 1-
4. It is not what is right for Carlsbad.
Commissioner Black stated that the density increase has been thrown at the City. If the units do not go in
the Village, then the units would need to go elsewhere in the City. He feels that the increased density in
the Village is appropriate and he can support the project.
Chairperson Schumacher stated that the numbers have already been established, however through the
implementation of the policy it could backfire and discourage development. He would like to have
language added that is more assertive in acknowledging that densities may need to be transferred.
Applicants need to be aware that the City will work with them to help achieve the densities.
Commissioner Nygaard agreed that language should be added to the resolution. Ms. Mobaldi suggested
proposed language stating that projects proposed at less than minimum density may be considered if
findings can be made in accordance with the Government Code. That acknowledges that a project can
be proposed that is below the minimum density, and it also acknowledges the state law which mandates
that certain findings be made to approve a lower density. Commissioner Scully stated she would support
the additional language as long as it was very clear that applicants had options.
Commissioner L’Heureux asked if the city attorney had the particular Government Code section. Ms.
Mobaldi stated she could provide the correct code section later. The code section she is referring to
provides that if a project is approved below the minimum density, then the Council or the decision making
body, has to make a finding that those units which were not built can be built somewhere else in the City
so there no net loss of density. Commissioner L’Heureux stated he wanted to make sure that was
citywide and not specifically in the Village. Ms. Mobaldi stated it would not be limited to the Village.
Mr. Neu added that the issue which makes it difficult in terms of getting the city’s Housing Element
certified is that if there is too much flexibility, then the state looks at it as if it is not really a standard the
city is trying to meet. There is a minimum density that the state considers as providing housing that is at
more affordable levels. Mr. Neu stated that the City has built in a fair amount of flexibility but it still has to
be meaningful enough that the State will look at it and believe that there will be enough units produced
around that density level to achieve the target. Ms. Mobaldi stated that an excerpt from the City of
Carlsbad Village Master Plan and Design Manual already includes those findings found in Government
Code 65863, which provides that the City has to find that the reduction in density is consistent with the
adopted General Plan including the Housing Element and secondly that the remaining sites identified in
the Housing Element are adequate to accommodate the City’s share of the Regional Housing Need
pursuant to Government Code Section 65584. Ms. Mobaldi stated the City would have to show sites in
the city where the required density can be accommodated.
Chairperson Schumacher asked if there are properties available to accommodate units if a project was
proposed and it is, for example, ten units below the minimum density. Ms. Mobaldi stated that at this
stage in time, there is enough land left in the city that is vacant or is underutilized to accommodate
additional units; however it is a constantly evolving state of affairs and at some point in time, it may
change. Chairperson Schumacher asked if the additional language could be crafted to encourage mixed
use as opposed to specifically trying to meet the Regional Housing Needs Assessment numbers. Ms.
Planning Commission Minutes September 5, 2012 Page 6
Mobaldi stated that in terms of mixed use, the Village Master Plan and Design Manual already has
language encouraging mixed use development along with other development guidelines.. The
Commission has not seen many of those projects because the Design Review Board used to review
projects in the Village until fairly recently. In terms of the density numbers the City has to have language
that satisfies the city’s commitments with regard to Housing Element Program 2.1.
Commissioner Scully asked if the additional language is not being proposed now. Chairperson
Schumacher stated the language is already included in the Village Master Plan and Design Manual. Mr.
Donnell pointed out that the language is also included in the staff report as Exhibit A.
Chairperson Schumacher asked Mr. Donnell if there would be an ability to accommodate the units in the
Village from projects that could meet the minimum density. Mr. Donnell stated because projects in the
Village tend to be smaller, he believes the potential is greater to accommodate units in the Village for
projects that might not meet the minimum density because of redevelopment opportunities. In the
Housing Element there are a number of parcels which show underutilization and the potential to
redevelop.
Commissioner Black commented that everything gets shifted and asked what happens to all of the
reserve units at the end. Mr. Neu stated that in the end there should not be just one project responsible
for a large number of units. Every housing element the city goes through the Regional Housing Needs
Allocation (RHNA), each jurisdiction in the county is given a number of units based on what SANDAG
deems an available amount of land amongst other things. SANDAG has other objectives with the RHNA
in that each jurisdiction is providing its fair share of lower income housing. There are jurisdictions in the
county that have more than the county average of lower income housing which is 40%. Carlsbad is one
of four jurisdictions that has less than the average amount. Mr. Neu further stated that either as a region
the county can accept a lower number or the region will keep getting numbers that are larger and the
jurisdictions will be asked to increase the densities in the built areas of the community. As a region,
generally speaking, there is an effort to put more development in the coastal areas or the more developed
parts of the county as opposed to the eastern parts of the county. Mr. Neu stated that what staff foresees
in a future housing element cycle is that the city may reach a point where it is right up against the growth
management dwelling unit cap.
Chairperson Schumacher hopes staff continues to help applicants with their projects in the Village area.
He stated he can support the project.
MOTION
ACTION: Motion by Commissioner Black, and duly seconded, that the Planning Commission
adopt Planning Commission Resolution No. 6905 recommending that MP 12-
01/LCPA 95-10(C) is within the scope of the Mitigated Negative Declaration
previously adopted for the 2005-2010 Housing Element (GPA 03-02) and
recommending approval of MP 12-01/LCPA 95-10(C) based on the findings
contained therein.
VOTE: 5-1-1
AYES: Chairperson Schumacher, Commissioner Black, Commissioner L’Heureux,
Commissioner Nygaard and Commissioner Scully
NOES: Commissioner Arnold
ABSENT: Commissioner Siekmann
ABSTAIN: None
Chairperson Schumacher closed the public hearing on Agenda Item 1 and thanked Staff for their
presentations.
COMMISSION COMMENTS
None.
Planning Commission Minutes September 5, 2012 Page 7
CITY PLANNER COMMENTS
Mr. Neu commented that the Planning Commission received a packet for the workshop on September 12,
2012. The focus of the workshop is to improve the way in which the Commission is able to conduct its
business and deliberations.
CITY ATTORNEY COMMENTS
None.
ADJOURNMENT
By proper motion, the Regular Meeting of the Planning Commission of September 5, 2012, was
adjourned at 7:11 p.m.
~/t
DON NEU
City Planner
Bridget Desmarais
Minutes Clerk
Planning Commission Minutes September 5, 2012 Page 4
Ms. Mobaldi clarified that the densities have already been approved by the City Council with the approval of the Housing Element 2005-2010. This was a part of Program 2.1. This is merely the implementation,
changing the documents to reflect what has been approved in the General Plan.
Chairperson Schumacher stated he is concerned that the City is creating a hurdle for property owners and/or developers for reaching the minimum densities and additional studies or reports, and costs being
put on the land owner. He asked if there is a way that when an applicant proposes a project that will not be able to meet the minimum density that there will be a path on how to the applicant can work with the
City on how to achieve that and how to rebalance those numbers.
Mr. Neu stated that the Commission recently approved minimum densities throughout the city for the RH and RMH land use designations. Findings have successfully been made for several projects to be below
the minimum required density. He further stated that he believes the City will still have the ability and the flexibility on sites, particularly the smaller parcels, to have a way where the land owner does not have to
meet the minimum density should it be shown to be infeasible. Staff has not had to ask applicants for additional studies as most of the time Staff can review the site, the project design and the product, and
review the other development standards in order to make a determination.
Commissioner L’Heureux asked if the property owner will have to find another site in the Village to make up the difference in units if the minimum is not reached. Mr. Neu stated that the requirement has not
been implemented in that strict of a manner. State law requires that you show that by reducing the density on a particular property that there are adequate sites elsewhere in the city to make up the
difference. The City has relied heavily on the Excess Dwelling Unit Bank, in that any particular residential or non-residential site can request dwelling units and through the density increase process or
redesignation to residential could conceivably be allocated units. One of the issues that the city is running up against with the update to the General Plan is that there are more people asking for units than
the City has dwelling units with the Growth Management caps. Practically speaking there does not seem to be an insurmountable problem right now. It is more of an issue being able to accommodate housing
when the demand is higher for attached product. Mr. Neu further stated that to date the City has not asked a developer to go out and identify a specific site. If the City gets closer to running out of available
sites, then Staff might take a harder line at some point in the future. Commissioner L’Heureux asked if it is possible that as there are fewer units in the Excess Dwelling Unit Bank that projects are denied
because enough units are not being proposed. Mr. Neu stated he supposed that could be possible however that the city is a ways from that in terms of available land left in the city. He stated that some
level of review is necessary so that the City is not abandoning the idea that the minimum is the target and that there is flexibility to go below the minimum but Staff would want to make sure that there is rationale to
make the finding to go below the minimum. Commissioner L’Heureux asked if that by adopting the language it does not require a certain product type, any price cap or any requirement that low income
housing be constructed. Mr. Neu stated that the requirement for income restricted housing is as it is today in the Inclusionary Housing Ordinance. As the housing program has been administered, there are
options for onsite or offsite housing, and there are quite a few options for specific sites.
DISCUSSION
Commissioner Nygaard stated that no one wants to see increased density anywhere but that is not the vision of the State. She stated that it is very important for the City to have a certified Housing Element. If
the City does not have a certified housing element, the City would have a huge amount of problems. She feels that density does belong around transportation centers such as in the Village. The densities have
already been approved by City Council, however it is important for the Council to hear the Commission’s concerns regarding how difficult these densities will be to achieve.
Commissioner Arnold stated that he knows the Commission is mainly being asked to give a
stamp of approval onto something the City Council has already authorized, a zoning increase or a density increase, but in light of that, the Commission’s vote is basically very symbolic. His
symbolic vote is going to be no because he believes that there are too many problems that the City has to look at. The City wants to encourage mixed use and here the City is holding people
who want to build a restaurant and maybe a boutique to the same standards as a purely residential building. Also, down the road it could cause the City to question a development
because the City is not hitting these very high minimum units that are being set with this action.
CORRECTED