HomeMy WebLinkAboutPATEROS CREEK - PDP - PDP130011 - DECISION - MINUTES/NOTESPlanning & Zoning Board
June 20, 2013
Page 9
Member Heinz said initially she was a little concerned about the play area being close to the wetlands
but she'd be a little more comfortable with it with a little more signage especially if there were an
educational component. She said she's a little curious to see how the interface between the high traffic
area and a private development will go but she'll just trust it will work out. She thinks it's a great project
and the applicant did a great job.
Chair Smith said with regard to the comments made by Ms. Levingston, data would suggest 'the broken
windows theory'. He said people who've been on the trail in the past might think no one cares, no one's
watching. He thinks when it's kept up and there are a lot more folks about, folks may be a little more
reluctant to do anything criminal in nature. Smith said he's not concerned about the small wetland. He
used to play in wetlands growing up. He said it has a way of self-regulating (you stay away when it's a
little too muddy). As he understands it, they are very resilient. He would hate to discourage kids from
going there when the project appeal is that of the interaction between an urbanist style and natural
spaces. He's looking forward to seeing a great community amenity where it had previously been
blighted. He's supportive of the project.
Member Hart made a motion that the Planning & Zoning Board approve the Pateros Creek Project
Development Plan, #PDP130011 based on the findings of fact and conclusions on page 16 of the
staff report. Member Schneider seconded the motion. The motion passed 6:0.
Member Kirkpatrick returned to the room
Project: 2013 Annual Revisions, Clarifications and Additions to the Land Use Code
Project Description: This is a request for a Recommendation to City Council regarding the annual
update to the Land Use Code. There are proposed revisions, clarifications and
additions to the Code that address a variety of subject areas that have arisen since
the last annual update in 2012.
Recommendation: Approval
Hearing Testimony, Written Comments and Other Evidence
Chief City Planner Ted Shepard noted in this round of proposed revisions, clarifications and additions to
the Land Use Code there are 26 proposed items that change, clarify or add to the Land Use Code. The
revisions, by Article, are summarized as follows:
• Article One — Organization — one change;
• Article Two — Administration —four changes;
• Article Three - General Development Standards — nine changes;
Article Four — Districts — seven changes;
• Article Five — Definitions — five changes.
Shepard said there was supporting material in the board's agenda packet (and posted on the City's
website) and staff was available for any questions.
Member Hart said it might be helpful for the public to know the board has spent a great deal of reviewing
the proposed changes in work sessions so they are quite familiar with the individual changes.
Planning & Zoning Board
June 20, 2013
Page 8
Member Hart said he saw something a while ago about improving access to the trail at Shields. Is a
parking lot going to be built there? Someone in the audience said yes on the northwest corner of Shields
and the Poudre River Trail.
Member Heinz asked staff to speak to the alternative compliance issue. Ex said the Alternative
Compliance Request refers to Section 3.6.3(H) of the LUC. The intent of that standard is built on direct
connectivity for vehicles and pedestrians wherever possible. In this case, the alternative compliance is
for the parcel to the south (Nauta Pond). One of the reasons for justifying alternative compliance is the
protection of a natural area. Instead of providing the full vehicular connection, they're proposing a
pedestrian connection instead of a full vehicular connection.
Member Smith said he really wants to make sure we do our best to address Ms. Levingston's concerns
about the behavior of some of the folks who are using the trail. He asked staff to describe the board's
purview when it comes to behavioral issues. Shepard said behavior is not Land Use Code related but it t
does come up a lot in the context of multi -family housing. Shepard said there are provisions in Chapter
20 in the Municipal Code that addresses nuisance issues, remedies, and penalties. He would encourage
Ms. Levingston to work with Police or Neighborhood Services to become familiar with the nuisance
provisions in the code and its enforcement.
Member Schneider asked if the Poudre River Trail is on public or private land. Shepard said the main
trail is not on the project property. Deputy City Attorney Daggett said the Poudre River Trail is in some
places on property that is actually owned in fee by the City of Fort Collins. There are also places where
the city has acquired easements for the trail. The City has obtained the property right to have the trail in
the location where's it's situated and are managing the trail Chair Smith asked for confirmation that this
project would not affect the operations of the trail now or in the future. Ex said correct.
Board Discussion
Member Hart said the modification of standards will improve the quality of the neighborhood and make
the area much more livable. He thinks it's equal to or better than the standard.
Member Carpenter said the alternative compliance request for the pedestrian connectivity to the pond
works for her.
Chair Smith said he would agree the applicant's request for reducing the non -arterial setback from 15
feet to 9 feet is not detrimental to the public good and it is equal to a comparable plan simply because of
what they've demonstrated as far as it being a heavily landscaped street. It harkens back to the intent
we talked about 20 years ago with City Plan (houses pulled forward with porches close to the sidewalk
and garages pulled back). He thinks in his opinion it merits approval.
Member Hart made a motion the Planning and Zoning Board approve the Modification of
Standard to Section 3.5.2(D)(2) regarding setbacks from a non -arterial street because the
Modification of Standard would not be detrimental to the public good and it meets the standard
equally as well or better a plan that complies because it provides a more livable environment.
Member Heinz seconded the motion. The motion was approved 6:0.
Member Hart said when he looks at this development in comparison to what had been on the ground for
the past few decades, he thinks it's a substantial upgrade to the quality of the area. He thinks it'll provide
a catalyst to keeping that area upgraded. He was concerned about the letters, particularly from Ms.
Levingston but he think they mostly relate to people's behavior. He's pretty well convinced there's not
going to be that much congestion because there's going to be improved access at Shields, there's still
access at Martinez Park, and parking is going to be patrolled. He said with these new homes, he thinks
there will be eyes on the trail.
Planning & Zoning Board
June 20, 2013
Page 7
for the question related to pedestrian access, they look at how the trails systems are designed in relation
to a flood way. The trails need to be designed so they are not filling with water, pushing water off on
other properties, or causing a rise in the water surface elevation. The project's paths are designed to be
at existing grade with crusher finds on top of that. She said there are no restrictions for walking across
floodways or flood plains.
Member Heinz said with regard to question to a question raised at the worksession related to lots 1 and 2
— what would the alternative proposal be? What would it look like if that boundary was extended to
encroach more on those lot lines. Hilmes-Robinson said there are two different issues. First is the
floodway issue for Lots 1 and 2. They are in the West Vine Floodway. The city and the county are
currently working on a project on the west side of Shields to create a more defined outfall for the West
Vine Floodplain. They are in the final design stages of construction. The intent is the floodway that
currently crosses Shields and continues through the Pateros Creek Development would no longer be in
place after that project is constructed. She said we cannot absolutely (100%) say that's what's going to
happen because we're not far enough along on that project. Until it's completely built and remapped,
that floodway and floodplain will be the effective floodplain. They've put notes on the plan that no
development can take place on those two lots until such time as the map is revised.
Hilmes-Robinson said question two relates to floodplain mapping of the Poudre River. FEMA (Federal
Emergency Management Agency), in cooperation with the city, is remapping the entire Poudre River
through the city of Fort Collins. It's a program called Risk Map. They're looking at the hydrology (how
much water is coming down the river) and the hydraulics (where the water .goes). As a part of that
process, we will have a new floodplain map. At this point, we do not know what that floodplain map will
look like. It may be a year or two before we see a draft map and another year or two before it becomes
effective. Hilmes-Robinson said they have notified the applicants that the process is taking place. At
such time if any additional lots are mapped in the floodplain, they would have to comply with whatever
regulations are in place before any building permits are issued.
Member Heinz asked the applicant if they had a backup plan should lots 1 and 2 be unbuildable. Russell
said currently those lots would not be built if the floodplain does not change
Chair Smith asked staff to discuss the traffic study and its findings. Andrew Gingerich, Staff Engineer for
the City of Fort Collins, said the Traffic Engineer was not available and he'll provide traffic study
highlights. He referred the board to page 10 of the Delich Associates report. The table summarizes the
daily vehicle trips — it compares the 45 dwelling units of Bender Mobile Home Park to the 41 units
proposed for Pateros Creek. Bender Mobile Home Park had 436 daily trips and Pateros Creek is
estimated to have 458 daily trips. On page 11 of the staff report, he referenced staff comments relative
to LUC Section 3.6.4 Transportation Level of Service Requirements. Traffic and Engineering staff have
reviewed the study and it's concluded that all vehicular, pedestrian and bicycle facilities proposed are
consistent with the standards in Part II of the City of Fort Collins Multi -modal transportation level of
service manual.
Member Hart asked staff to speak to parking on Wood Street. Gingerich said they did consider on -street
parking on Wood Street. Currently Wood Street is about 24 feet in total width; it includes a 4 foot
concrete apron along the Fort Collins Service Center side or 21 feet of asphalt. With this project, that
portion of Wood Street would be widened to 30 feet of travel width. They're anticipating not providing
parking along that area. The Fort Collins Service Center is there and they have some large vehicles
coming in and out of that service area so they'd like to keep that road as clear for large vehicle turning
movements. They'd also like to keep the trail connection from becoming a trailhead to cut down on
congestion. When asked about plans for signage, he aid he'd need to talk to the Traffic Department to
confirm their plans for signage and stripping.
Planning & Zoning Board
June 20, 2013
Page 6
standing water). It periodically has ground water that feeds some plants that are wetland species. It's
more like a wet meadow and not quite as sensitive as the classic Army Corp of Engineers definition.
The play area is currently located in a great stand of cottonwood trees; they could certainly exploring
moving it if required.
Member Hart asked if the location of the playground affects its operation as a wetland. Russell said it
would not affect the hydrology.
Chair Smith asked that we consider the issues raised by Ms. Levingston in her letter. He asked if Mr.
Russell had any comments - ways the project could help to not push problems into adjacent properties.
Russell said they've proposed an access easement which is 14 feet wide from the edge of the trail. (They
are trying to preserve trees by their design.) They've also proposed a crusher finds path rather than a
concrete trail. He thinks it'll be more of a casual appearing path and would not typically be recognized as
a public point of access. He said they do have quite a bit of surveillance on this path - they have
residential lots that look out onto it. He thinks if there is a perception that things are well maintained it
reduces the amount of vandalism and undesirable activity.
Board Questions
Member Carpenter asked if there would be any signage that states its Pateros Creek Neighborhood.
Russell said they've not planned for that to date. Russell said they could consider signage indicating its
private property. Member Schneider asked if there would be sign "Access to the Poudre River Tail
System" from Wood Street. Russell said he'd expect Parks & Recreation would want a sign there.
Member Hart wondered what the distance from Wood Street to the Poudre River Trail is along that bike
path. Russell said about 200 feet. - --
Member Heinz asked if that's intended to be a protective wetland, will there be fencing? How would the
HOA manage that so it would get restored if needed? Russell said what they can do is relocate the play
area on the site plan to be a little further away from the smaller wetlands. There's potential the plants
could be disturbed. He could see moving the play area further south.
Member Heinz asked Senior Environmental Planner Ex to define a wetland. Ex said the city has the
same standards at the Corp (of Engineers) as far as what a wetland is. It has to have hydrology, soils,
and vegetation to support a wetland for two weeks out of the year. Ex said it's important to point out how
small the wetlands are north of the play area. They are about 250 square feet. She said every wetland
can play a different role. If they're larger they can play a habitat role but at that scale, you could almost
look at them as being an amenity to that play area. She said you can look it the wetland and see
different wildlife than you would with the rest of the riparian forest. She thinks the Board's ideas about a
lower fencing and even interpretive signage would contribute to that wetlands area.
Member Schneider asked if there's anything in the code that state you cannot disrupt those wetlands,
floodway or flood fringe. Ex said with regard to the wetlands, the intent is to preserve their value. Value
is something we look at on a continuum. She said certainly larger wetlands such as the McMurray
Ponds you want people around the edges. Other wetlands are more about ground water recharge. The
big concern would be compaction. The fencing is a great way to address that. If one child comes in
would not be a problem because wetlands are fairly resilient systems that spring back. If we start seeing
that it becomes a mud fest, it would be a little different situation. .
Member Schneider asked if it requires special care. Ex said it does require special care. Schneider
asked if there was any concern about pedestrian traffic or use of the floodway/flood fringe area. Does it
need to be protected from access? Fort Collins Floodplain Administrator Marsha Hilmes-Robinson said
Planning & Zoning Board
June 20, 2013
Page 5
Public Input
Perry Todd, 639 S. Loomis, said he uses the Poudre River Trail and noticed the development. He
wanted to see if it was going to be something that was compatible. From what he's seen tonight, he said
it looks like a well thought out. They've done a pretty good job.
Tom Janca, 918 Sycamore, said he had questions about egress and ingress out of Wood Street. He'd
like to know what traffic studies have been done and what impacts the development would have to Wood
Street traffic. He'd also like to know about plans for emergency egress for that area due to the municipal
utilities operations and storage yard as well as a major refueling station.
Karin Levingston, 930 N. Shields, said her main purpose is to read the letter she sent to the board (and is
a part of the public record). In summary, the primary concern expressed in her two page letter is
increased risk as victims of crime or property damage. She believes the increase to the 600 people per
day will exacerbate problems of dog attacks on farm animals, bombs left on pedestrian bridge (as
reported by the Loveland —Reporter Herald), theft, vandalism, fires, drowning, human excrement near the
McMurray Ponds beach. She believes there are numerous access points without adding the Pateros
Creek bike trail. She thinks it should be removed from the plan. She also thinks parking might be a
problem.
Brigitte Schmidt, 932 Inverness, said she's familiar with the area because she feeds feral cats on Wood
Street every morning. She agrees with Ms. Levingston was saying. She's seen people open gates and
trespass on that property. Schmidt wonders if the proposed playground will negatively affect the nearby
wetlands. She would like to know who will have responsibility for the wetlands so they don't become an
additionaliplayground area for kids and dogs.
Leroy Cynkar, 2614 W. Prospect, said they're interested in moving to this property. From what they've
heard so far it looks to be an excellent project. He likes how the proposed 9 foot setback will increase
the size of the green area. He thinks it will enhance the neighborhood and create a little more open
space. He's in favor of the project.
Kurin Decker, 1320 Green Street, said she's also interested in this property as a potential place to live.
She was attracted by the concept of the small house, the infill and its proximity to old town. She's in
support of the project.
End of Public Input
Applicant Response
Craig Russell said in response to the question about emergency access and traffic studies. There have
been traffic studies done -- it's a requirement of the planning submittal. It has helped determine this
configuration will not cause any adverse impacts on Wood Street or the adjacent neighborhoods.
Russell said the emergency access consists of a 16 foot wide corridor that's at the corner (and that has
a duel function of a pedestrian path that connects Wood Street to the project) and the typical entry point.
It's been reviewed and signed off by PFA (Poudre Fire Authority) Fire Marshal. They typically require
two points of entry in case there's an obstruction in the roadway. He said the Poudre River Trail provides
connectivity to open spaces. It's defined as an access easement (a neighborhood point of entry) to the
Poudre River Trail.
Chair Smith asked him to speak about the preservation of the wetlands. They're near the playground on
the east end of the site. What are the plans for the preservation of it? Russell said it will be managed by
the HOA (Homeowners Association) as a wetland. It's not what you'd characterize as a marsh (with
Planning & Zoning Board
June 20, 2013
Page 4
With this P.D.P., the project is requesting a Modification of Standard to Section 3.5.2(D) (2) to allow for
the front yard setback to be reduced from 15' to 9', allowing front porches within this additional six feet.
The project is also requesting alternative compliance to Section 3.6.3(F); instead of providing a public
street connection to the south (where a large pond currently exists), the project is proposing to provide
pedestrian connections to this potentially developable parcel. Staff is recommending approval.
Applicant Presentation
Craig Russell, Russell + Mills Studio, said he's the planner representing Bellisimo, the project developer.
He said in June 2012 they came before the board to request a modification that allowed the project to
increase the overall average density in to 2.36 dwelling units per acre or 41 dwelling units. He
introduced Ralph Shields and said he would provide a brief overview. .
Mr. Shields provided an aerial view of the project. It indicated the property's relationship to the Poudre
River and the Poudre River Trail. He provided a history of the land, its previous owners and how the
name Pateros Creek had been derived. He said as a riparian corridor it was a perfect place for
agricultural development -- a 'gardener's paradise'. He showed photographs of how the land had fallen
into disrepair as the Bender Mobile Home Park and described how a cleanup process had begun.
Shields said their emphasis was on quality not quantity resulting in homes where people would want to
plant their roots and call it home for years to come. Their intent is to rehabilitate the gardens and
surrounding forest area and to create a place where homeowners would enjoy community gardens, fruit
orchards, and common open green space.
Russell said redevelopment of the 17.34-acre parcel includes residential single-family lots within the
southwest portion of the site surrounding the proposed loop drive. He said it would be a courtyard
community with small lots surrounding a community green and gardens comprising the interior of the
loop road. He said they've made special efforts to provide a high quality habitat for wildlife. He
described Pateros Creek community amenities and indicated access points to the Poudre River Trail He
described how they hope to preserve as many trees as possible and described the housing product
types —bungalows with several different architectural old town styles.
Russell said project preserves the wetlands within the Natural Habitat Buffer Zone. The wetlands are
mitigated through a forebay wetland just east of the existing pond. This mitigation provides for one larger
wetland rather than the existing, separated, low value wetlands that exist along the south property line.
This larger wetland is preferred because larger habitat patches provide higher quality habitat value than
separated, smaller patches and meets the requirements of Section 3.4.1(E)(1)(d) and Section
3.4.1(E)(2)(b) of the Land Use Code. Russell described how the project was designed to address the 300
foot top of bank buffer with the average distance of 350 feet. .
Russell said the modification to LUC Section 3.5.2(D) (2) Setbacks from a Non -arterial Street was
requested to allow the community green/courtyard to function better. Russell ended his presentation by
sharing how the project advances the Land Use Code and supports Plan Fort Collins principles such as
Compact Development Pattern, Interconnected System of Open Lands, Redevelopment and Infill
(redevelopment of the existing Bender Mobile Home Park, which is currently in a degraded state,
diminishes the quality of the Poudre River Trail experience), Community Gardens, and (agricultural)
Heritage Preservation.
Planning & Zoning Board
June 20, 2013
Page 3
Classical Schools reserves the right to extend the length of the fence at any such time as is
deemed necessary. In addition, Ridgeview Classical Schools reserves the right to make
adjustments to the location of the fence in relationship to it's' distance from the property line but
not in such a manner as to either diminish its existing length or height."
Public Input
None
Member Carpenter made a motion to Ridgeview Classical School Expansion Site Plan Advisory
Review, SPA130002. Member Kirkpatrick seconded the motion. The motion passed 7:0.
Member Kirkpatrick recused herself due a conflict and let the room.
Project: Pateros Creek Project Development Plan, # PDP130011
Project Description: This is a request for a Project Development Plan for Pateros Creek. The parcel is
17.34 acres in size and located on the east side of Wood Street, approximately''/<
mile east of North Shields Street. The project proposes clustered residential
development with 40 dwelling units on 8.02 acres of the parcel, approximately 46%
of the site. The remaining 54% of the site (9.32 acres) is dedicated as permanent
open space, either in the central green or in the Poudre River Buffer Zone.
Recommendation: Approval of Pateros Creek Project Development Plan, PDP #130011, Modification
of Standard to Section Modification of Standard to Section 3.5.2(D)(2) Setback
from Non -arterial Streets.
Hearing Testimony, Written Comments and Other Evidence
Senior Environmental Planner Lindsay Ex said this is a request for consideration of a Project
Development Plan (P.D.P.) for Pateros Creek. The parcel is 17.34 acres in size and located on the east
side of Wood Street, approximately'% mile east of North Shields Street. The site is developed and
formerly known as the Bender Mobile Home Park, which was a development that occurred while the
parcel was in Larimer County. In 2012, the parcel was annexed as the Wood Street Annexation and
was zoned Urban Estate.
The project is located within the Northwest Subarea Plan, which suggests if this area is developed any
residential development should be clustered. Accordingly, the project proposes clustered residential
development with 40 dwelling units on 8.02 acres of the parcel, approximately 46% of the site. The
remaining 54% of the site (9.32 acres) is dedicated as permanent.open space, either in the central green
or in the Poudre River Buffer Zone. The average width of the Poudre River Buffer Zone is 350'.
A stand-alone Modification of Standard to Section 4.2(E) (2) (c) was approved in June, 2012. This
Modification allowed the project to increase the overall average density in clustered residential projects
from 2.00 dwelling units per acre to 2.36 dwelling units per acre, or 41 dwelling units. The project
proposes 40 dwelling units over the 17.34 acre parcel, for a gross density of 2.31, in compliance with the
approved Modification.
Planning & Zoning Board
June 20, 2013
Page 2
session to get a better idea before there is a project to be reviewed. She's working on the Committee for
PDOD (Planned Development Overlay District) and while there are not currently any applications maybe
the consideration is more the use of modification of standards. There needs to be some predictability=if
you are here, "x, y, z" happens. She thinks the time is right for the board to look at all kinds of things you
can do with that.
Consent Agenda:
1. Minutes from the May 16, 2013 Hearing
Member Hart made a motion to approve the consent agenda which consists of the Minutes of the
May 16, 2013 Hearing. Member Hatfield seconded the motion. The motion passed 7:0.
Discussion Agenda:
2. Ridgeview Classical School Expansion Site Plan Advisory Review, # SPA130002
3. Pateros Creek Project Development Plan, #PDP 130011
4. 2013 Annual Revisions, Clarifications and Additions to the Land Use Code
5. Addition of Permitted Use Policy Discussion
Project: Ridgeview Classical School Expansion Site Plan Advisory Review,
SPA130002
Project Description: This is a request to convert the former Little Bears Child Care facility, 1900 South
Lemay Avenue, into an expansion for Ridgeview Classical School by remodeling
the interior into classrooms that would serve grades 7th through 12th. The building
contains 7,500 square feet and 19 parking spaces. There would be no changes to
the total square footage and no changes to the existing parking lot. The existing
playground would'be converted to open space serving the entire campus. The site
is one acre in size and zone R-L, Low Density Residential.
Recommendation: Approval
Hearing Testimony, Written Comments and Other Evidence
Chief City Planner Ted Shepard said Ridgeview Classical School presently serves 754 students in
grades kindergarten through 12th. As with all public and public charter schools in Fort Collins, this
expansion would be processed as a Site Plan Advisory Review per Colorado State Statutes.
Public schools are a permitted use in the R-L, Low Density Residential zone. The Site Plan Advisory
Review complies with State Statutes as to the location, character and extent of the project. Further, the
project complies with the applicable General Development Standards, Zone District Standards and is in
conformance with City Plan.
Shepard read into the record a letter dated June 20, 2013 from Kristina Menon, President of the Board of
Directors of Ridgeview Classical Schools. It reads:
'Ridgeview Classical Schools, in conjunction with the Site Plan Advisory Review for 1900 South
Leman Avenue, shall maintain a solid wood fence for its existing length parallel to the property
line that separates the Ridgeview property from adjacent Stonehenge residual properties. The
purpose of the fence is to provide buffering for the Stonehenge Neighborhood. Ridgeview
Chair Andy Smith called the meeting to order at 6:03 p.m.
Roll Call: Carpenter, Hatfield, Hart, Heinz, Kirkpatrick, Smith and Schneider
Staff Present: Shepard, Eckman, Ex, Hilmes-Robinson, Gingerich, Barnes, Beals, Lorson,
and Sanchez -Sprague
Chair Smith provided background on the board's role and what the audience could expect as to the order
of business. He described the following processes:
• Consent agenda items are considered items which have no known opposition. Any member of
the board, staff or audience may request for an item to be pulled from the consent agenda and
discussed in detail as a part of the discussion agenda.
• Discussion agenda items will include a staff presentation, an applicant presentation, and
questions by board members, staff comments and public comment.
• At the time of public comment, he asked that you come to the podium, state your name and
address for the record, and sign -in. He asked that the speaker clearly state their position and he
encouraged them to share comments relevant to the topic under discussion.
• Responses by applicant and staff will follow public comment.
• The board will deliberate and reach a decision once a motion has been made and a vote taken.
He will begin each new item with a description of the development type being considered. The
board will do their best not to use acronyms or jargon.
Agenda Review
Chief City Planner Ted Shepard reviewed the agenda. Shepard noted the applicant asked that a letter
they sent be read into the record for the Ridgeview Classical School Expansion Site Plan Advisory
Review.
Citizen participation:
Brigitte Schmidt, 932 Inverness, said as a former member of the P&ZS Board, she'd like to speak to the
topic of modification of standards. She said a modification can be approved if it is not detrimental to the
public good and meets one of four criteria. At the orientation of new member Schneider, Deputy City
Attorney Eckman said if that criterion is met than the doors are wide open. Thinking about it further, she
does not believe that to be the case. She said we need to ask ourselves what is a modification. Is it a
small or large adjustment —is there a significant difference (a statistics concept). There is no definition in
the Land Use Code (LUC) of modification. Does that mean that once you meet those standards you
throw out the LUC and anything goes? She would encourage the board to have a discussion at a work