Anchorage Citizens Coalition - Title 21 Rewrite

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Title 21 Rewrite

Anchorage's land use laws, referred to as Title 21 after their section of our legal code, are being rewritten. This effort is a mandate of the Comprehensive Plan, Anchorage 2020, adopted in 2001. This is dry stuff that will get you snoozing. It's also extremely important since the rules we prepare now will be with us for decades. If Title 21 is written to implement the vision of Anchorage 2020, Anchorage will continue to be a wonderful place to live.

Since 2002, the city has been enduring the arduous process of rewriting Title 21. The process was one of consistent compromises leading us away from the promise of Anchorage 2020. Over two years ago, the Anchorage Assembly had "provisionally adopted" all but the "Definitions" chapter. ACC wouldn't call the provisionally adopted Title 21 our preferrred result, but it's one that we can live with.

As we move forward, we must avoid the myopic focus on immediate small cost increases and look instead at the lower long term costs and the improved quality of life. The past approach has proved unsustainable and has not been supported by citizens of Anchorage, nor has it proved to be successful across the country.

Dan Coffey calls the provisionally adopted Title 21 "Radical!!! "
Is it radical? Learn more here.

Contents

Recent News

A brief history of the process

What can you do?

Will this effort create the city envisioned in Anchorage 2020?

Public Meetings & Hearings

Title 21 - Documents for Review

RECENT NEWS

The Planning and Zoning Commission has decided that it will look at any and all changes to the proposed code. Every word. That's a surprise since the code has been through extensive review by prior commissions, has been "provisionally adopted" by the Assembly after extensive line-by-line review and then after even more review by Dan Coffey, the mayor and planning staff proposed a long list of amendments. We expected those to be a big enough job. Now the PZC has sent us back to 2002.

At the hearing on Monday the 12th, testimony was dominated by Anchorage's developers who don't want their costs to go up or profits to go down, and then TEA partiers who object to planners limiting their private property rights and 'social engineering' their future.

The public hearing on March 19 was not a big surprise, but disappointing nonetheless. Listen to it here.

Anchorage 2020 advocates made a good showing with plenty of testimony to counter-balance the many TEA partiers who oppose all zoning, most government functions and confuse it all as a U.N. conspiracy. Anchorage's defenders provided articulate, home grown testimony that the chair promptly cut off after three minutes with very little secondary questioning by commissioners.

Interestingly, none were invited to apply to the P&Z Commission, unlike others who favored Dan Coffey's thinking. The chair made a point of encouraging the application of more than one development professional who spoke in favor of Dan Coffey's work.

Tim Potter ended the hearing with about 45 minutes of testimony and discourse.

In the end, commissioners decided to rely on Dan Coffey's 200 pages of comments to guide their consideration of the many amendments that await their recommendation to the assembly. This appears to put all of Dan Coffey's 2011 recommendations back on the table, even though Mayor Sullivan rejected 20 of Coffey's 37 major recommendations last year after weeks of executive review with Mr. Coffey and planning staff. This commission wants all those recommendations back on the table for their consideration. We might ask, why?

Dan's 200 pages are available for your review in hard copy and can be picked up at planning offices on Elmore. We do not yet have an electronic link. Companion pieces are staff's August 23, 2011 rebuttal document with color illustrations why Dan's thinking doesn't work, and Mayor Sullivan's October 19, 2011 'Decisions on the Consultant's Report,' both of which are available on line.

Don't feel guilty if it's too much for you to dig into because

A. the Assembly's Title 21 committee reviewed all these issues over many, many months and recommended final language to the Assembly, who

B. after public review, and some small amendments, voted unanimously (yes, including Assemblyman Coffey) to 'provisionally adopt' that language, awaiting technical-clean up amendments, a few remaining sections and final Title 21 adoption in late 2010.

Now, amazingly, just over a year later, P&Z commissioners say 'the community has changed its mind' and ten years of give and take on our zoning code need to be revisited. Two commissioners stated they support scrapping the rewrite altogether and sticking with the old code.

Another disappointment was the number of 'misstatements' made by developers, from oft repeated, but unsubstantiated cost burdens of the provisionally adopted code to misrepresenting Mr. Coffey's recommendations that effectively eliminate community review of development proposals during the councils' typical summer hiatus. They seemed like honest mistakes, but there are huge factual gaps among Mr. Coffey, P&Z commissioners and planning staff.

Excess misinformation is hanging up this convoluted process, and needs to be addressed pronto, so we can all get back to business and start building a more livable community.

Stay tuned. The next PZC work session is in April. The Assembly has apparently scheduled its first Title 21 hearing for June.

Notes from the March 12, 2012 Planning and Zoning Commission Public Hearing on Title 21

I. Dan Coffey's lengthy comments

II. Claims that development costs will greatly increase under the provisionally adopted code and

III. Claims that reserving industrial lands for industry 'takes' private property.

I. Dan Coffey's comments:

Mr. Coffey started off Monday's testimony before the commission, and commissioners kept him at the microphone for 45 minutes, welcoming his advice. In return, Dan repeated his 2011 speeches criticizing planning and planners, and gave commissioners thick binders containing his recommended policies and Title 21 amendments.

One commissioner remarked: 'I'm concerned we are making [Title 21] decisions we really haven't thought through. People wanted change ten years ago, and perhaps we've changed our minds.'

It's important that you let the Planning and Zoning Commission know you haven't changed your mind....

Some of the problems Dan Coffey found in the Title 21 rewrite:

· The land use code should be limited to health and safety issues. Health and safety were not defined, but do not seem to include bike/pedestrian safety, clean air, or safe outdoor play and leisure activities.

· 'We're not a walking town.' It's unreasonable to make midtown walkable. To walk, people expect safety and comfort. All of Anchorage used to be walkable, and we're gaining it back more every day as we add safe paths, sidewalks and crosswalks. In a world class city, people can easily walk or bike if they want to. And it's past time to make midtown safe for those who bravely walk and bike there.

· The market should make land use decisions not 'central planners.' 'Central' is Mr. Coffey's code for communist or state planning and he says, 'It was tried unsuccessfully by Joseph Stalin and eventually abandoned.' The Title 21 rewrite was adopted after 8 years of public debate and compromise, working from the principles of Anchorage 2020.

· The provisionally adopted code is based on aesthetics, not on costs as it should be. The rewrite is based on Anchorage 2020 values and goals that include aesthetics, economy, environment, costs, community, health and safety. The rewrite holds down development costs while yielding a more functional, higher quality community of lasting value.

· I believe costs will go up dramatically. He provided no numbers. Meanwhile the Title 21 Economic Impact Analysis, prepared in consultation with a nationally respected expert, clearly documents that most development costs will fall or remain the same. No one, including Dan Coffey has provided evidence that refutes those numbers. See Developers say their costs will go up summary below..

· This code's too complicated, with too much detail. From the beginning, developers asked for more specific detail and clearly communicate the 'ground rules' they had to follow. Less detail means more subjective decision making that developers typically criticize. This code is shorter than the current Title 21, converting much information into easy-to-read tables.

· Title 21 'requires' rezones into mixed use, and 'they'll come and find you' if you don't rezone. Not true. Rezoning into mixed use districts are optional, and staff has offered to 'waive rezoning fees and provide administrative assistance to midtown property owners who rezone to mixed use.'

· 'They're picking winners and losers,' ie: some property will be more valuable than another in the future. Sorry, but one property has always been more valuable than another. It's time the public has a voice in where to invest public infrastructure and maintenance dollars rather than simply following developers from site to site, spending our tax dollars subsidizing far flung development. The Economic Impact Analysis shows proposed zones will have neutral effects on most property values.

· Title 21 shouldn't be 'loaded down' with plans that have never been adopted such as the pedestrian plan or the bicycle plan thus allowing staff to impose subjective standards. It should only include plans that have gone through AMATS and the Assembly. Another false argument. Both Anchorage's bicycle and pedestrian plans were approved by AMATS and adopted by the Assembly.

· Mixed use zones are not necessary. Heights should be unlimited in B-3 business zones (Anchorage's pretty-much-anything-goes business zone that is found all over town.) The people of Anchorage have clearly stated they want the city to grow into an urban center where walking is safe, landscaping is plentiful and sunshine gets through to the ground. This attack is primarily to prevent change in Midtown, when Midtown badly needs a new zoning option that produces outdoor public spaces and more walking and biking.

· There is no room for more residential growth in the bowl, look to Chugiak, Eagle River, the Hillside and Powder Ridge. This ignores the need for high quality infill and redevelopment in the bowl that builds a city where pedestrians and bikes have a fighting chance, and transit becomes a convenient choice, while protecting the character of established neighborhoods.

Note that:

As an assemblyman Dan Coffey voted in favor of all the zoning provisions he is now seeking to amend, and
The mayor rejected the majority of the changes Mr. Coffey recommended last year.
Now, with the cooperation of the Planning and Zoning Commission, Mr. Coffey has a new opportunity to again promote all the changes that he originally recommended.

II. Developers say their costs will increase

A number of people spoke from the Building Owners and Managers Association (BOMA) talking points that claimed building costs will increase with

· new building height limitations and setback standards,

· open space standards,

· more landscaping,

· building set backs,

· more open space in developments,

· sunshine protection,

· more upgrades for old buildings,

· keeping industrial lands for industrial uses and

· northern design standards.

On the other hand, Staff worked with a nationally renowned contractor to develop a groundbreaking computer model that analyzes development costs into account, and compares different development standards, zones and existing properties. The tables are easy to read and the reader can judge whether the per unit costs are accurate or not.

The 2008 report contains valuable cost information for a variety of costs such as

· planting a tree or bush or grass

· paving a parking space

· building a space in a parking garage,

· commercial construction

· residential construction.

The bottom line?

Muni planners document how development costs will go down for most kinds of commercial, industrial and multifamily properties.

The municipality's development cost numbers are transparent and available for public scrutiny. Folks who claim those numbers are wrong have not documented their claims.

III. Developers say reserving industrial lands for industry is a 'taking'

A handful of developers testified that Title 21 would take away their property rights and potential profits it restricts industrial lands for industrial uses. They claim a loss of up to 75 percent. The muni claims the greatest loss would be 20 percent. This loss is based on land speculation - turning over land zoned for one purpose into another, higher valued purpose. Typically, selling industrial zoned lands for commercial uses.

Today, industrial zoned lands can be used for a wide range of commercial and other non-industrial uses. While industrial zoned land is taxed at a lower value than commercial land, sometimes the landowner hits the jackpot and sells to a commercial developer. Commercial land is more valuable per square foot than industrial land.

This practice encourages commercial sprawl, and creates a hodge-podge of incompatible customer-oriented retail vs industrial activities. It also increases demand for driving to do business at those sites. On the other hand, Title 21 calls for new commercial development to be focused in 'nodes' that are within walking distance of neighborhoods and more easily served by transit.

Sprawled commercial development can consume industrial lands that should be reserved for future industrial uses. (Anchorage 2020 Policy #26) Anchorage needs to plan for industrial development without creating 'incompatible uses,' such as freight traffic, noise, odors and lighting that can be obtrusive to commercial and other non-industrial uses.

Developers' numbers are questionable: At least one commissioner and several speakers testified that an industrial lot worth $1 million under today's code would be worth only $250-300,000 if it could not be sold for commercial development.

Secondly, ongoing industrial land speculation and commercial sprawl costs all of us in terms of our tax dollars building, operating and maintaining sprawled public roads, utilities, police and fire services. Those costs are real and should be considered as Anchorage zones and develops its lands.

Third, the municipality's Economic Impact Analysis shows the speculator's loss might climb to 20 percent of assessed value, far from the 75 percent claimed last night.

For a more complete discussion of this issue, see page 40, Issue 24 of Staff's August 23, 2011 Review of Mr. Coffey's Proposed Amendments

Also see pages 34-36 of the muni's Economic Impact Analysis.

The precise amendments proposed through the planning department are here:

Proposed Amendments to the Provisionally Adopted Title 21
(PZC Case 2011-104, dated December 12, 2011)
Proposed Amendments to Chapter 21.14, Rules of Construction and Definitions
(Amendment 106 to December 12, 2011 Proposed Amendment Table)
Addendum to the Proposed Amendments to the Provisionally Adopted Title 21
(PZC Case 2011-104, dated February 2012)

The Planning Commission has been having work sessions on Title 21 over the past couple months.
They had a hearing on this new round of review on March 12. You can listen in here.
Read some notes on the March 12 hearing here.

HOW DID WE GET IN THIS MESS?

The Title 21 Rewrite Project was started in 2002 to implement the city’s adopted comprehensive plans.
There have been five drafts, each of which has been reviewed by the public. Thousands of staff hours and volunteer hours have gone into reviewing and amending the various drafts. The extensive public process has been open to anyone who desired to participate.
There have been multiple public hearings at the Planning & Zoning Commission and the Assembly.
With each draft, input from the public, including the development community, has led to changes and improvements.
By the summer of 2010, all but one of the fourteen chapters had been provisionally adopted by the Assembly. (Not counting the separate Chugiak-Eagle River chapter.)
“Provisionally Adopted” means that the Assembly Title 21 Committee had thoroughly reviewed, discussed, and frequently amended at least two different drafts of the code, and the final draft was found to be generally acceptable by the Assembly.
Dan Coffey was a member of the Assembly’s Title 21 committee and he voted FOR every single provisionally adopted chapter.
On July 25, 2010, the Mayor entered into a sole-source contract with Mr. Coffey (who was no longer on the Assembly) to review the provisionally adopted chapters with an assignment to select the top ten most controversial issues in the rewrite and work with interest groups and municipal staff to resolve the identified issues. In a political letter in late 2010 urging support for certain Assembly candidates, Mr. Coffey wrote that the mayor asked him to “re-work” Title 21.
In the Fall of 2010, Mr. Coffey held private meetings (planning staff was not allowed to attend and they were closed to the public) with various interest groups. Instead of identifying and working on the top ten issues, Mr. Coffey submitted to the Planning Department redlined drafts of the rewrite.
At a meeting with Anchorage Citizens Coalition representatives in November of 2010, Mr. Coffey showed redlined drafts of chapters 1 and 2 of the rewrite. He made it clear he is rewriting the code following his own personal opinions and biases. He expressed disdain for planners and discounted studies that did not fit his opinions.
In November 2010, the Assembly Title 21 Committee stopped meeting after Mr. Coffey convinced the chair to discontinue the meetings until he finished his work.
In July of 2011, Mr. Coffey turned in his version of the report. Mr. Coffey began a speaking tour to tell people what a good job he did. In those presentations, he calls the provisionally adopted Title 21 "radical." Only after a threat of legal action was Coffey's report released to the public.
The Coffey/Sullivan version was scheduled for a public hearing at the Planning and Zoning Commission on October 4, 2011. That was delayed until December when two commissioners experienced with Tiel 21 would be replaced by mayor Sullivan appointees.
The planning department released a large number of proposed amendments to the Provisionally Adopted Title 21 in December 2011 and early 2012. These are a combination of amendments to implement mayor Sullvan's proposals, some "technical" amendments to fix small errors or clear up language, and some new things that came from a variety of sources like the Assembly's Title 21 committee and work on the West Anchorage District Plan.
The Planning Commission postponed their hearing until March 12 and 19, 2012.
When will this wrap up? At their March 19 meeting, the PZC stated an intent to finish by mid June 2012.
Educated guesses put it moving out of the Assembly some time late in 2013.

WHY IS TITLE 21 BEING HELD UP?

· The Mayor wants to weigh in. Sure, why not? But the Mayor was in office for over a year before hiring Mr. Coffey to review the draft rewrite. Why couldn’t he have weighed in during that time? Now we have to wait another year? His term is only three years! Let’s get it done.

· The Economic Impact Analysis is flawed. Baloney. A detailed economic evaluation tool was developed by an independent consultant to test the code. Runs of the model show in the majority of cases, costs are the same or less than development under the current code.

· Pre-application design costs and the municipal staff review time/costs wil be too high as the new code is implemented. Okay, sure, there will be a transition period that will exist no matter what changes are enacted. After everyone is used to the new code, the pre-application design time and the staff review time will be about the same as today.

· Some say the new code is a “taking.” The new code does not “take” from land owners but rather “gives” to land owners, either by requiring less land to build the same sized building, or allowing them to build a larger building (and thus collect more rent) on the same sized parcel of land.

· There are “holes” in the rewrite. This is incorrect. There are a few sections set aside to be dealt with later but the planning staff has prepared adequate transition code to use until those are ready.

· It’s the product of planners and they have never built anything! These revisons to our land use laws are hardly recognizable as the ones from the planning staff. The public process has lead to countless changes large and minute. As chair of the Assembly’s committee for years, the provisionally adopted chapters already bear Mr. Coffey’s mark throughout.

· It’s not perfect yet! That’s true. And parts that are great now will probably need to be changed in the future as the city’s needs change. That’s the nature of these things. Even as we’ve been rewriting the code, we’ve frequently amended the “old” code. The revision may not be perfect, but it’s pretty close and we can continue the pattern of amendments as changes are needed.

· The new code will increase bus ridership and that is subsidized! Yep. A reputable group made this complaint. Gosh. Less traffic, less land cleared for parking. We should hope for more problems like that!

Their battle cry is "Free Title 21!"
The Anchorage Press June 30, 2011 By Cindee Karns

How many of you still remember the Anchorage 2020 Comprehensive Plan? I didn't live here in the late ‘90s when they started it, but when I heard about it through Transition Anchorage, I was VERY impressed that thousands of Anchoragites came together over a course of several years and came up with a vision for Anchorage in 2020. There were town meetings, organized conversations, and work groups held from the late ‘90s to the early 2000s. When it was finished it even received national recognition. Yes, Anchorage! ... read more

WHAT CAN YOU DO?

We need to get this rewrite of Title 21 back on track! Chapter 1 of 2020 has a section “Anchorage 2020 – A New Direction” It says, “The demands of rapid growth have faded, and quality of life issues have moved to the forefront.” From this rewrite’s early “modules” through Draft 1 and Draft 2, the changes proposed for Title 21 have drifted steadily away from Anchorage 2020. The Purpose Statement, many details and the dominance of 2020 over the land use rules should be turned back in that “New Direction.”

What can you do to point us in this new direction? Speak at the public hearings on Title 21. You are the expert on what you expect Anchorage to be.

Contact the Anchorage Planning Department E-mail: title21@muni.org or phone: (907) 343-7921
Fax: (907) 343-7927. Tell them you like the vision in Anchorage 2020 and you expect Title 21 to bring us there. The Planning Department's website is here.

Contact Anchorage Citizens Coalition to get on our newsletter and alert list.

WHAT SHOULD BE DONE?

· The Assembly should adopt the Title 21 Rewrite immediately, in the form in which it was provisionally adopted.

· If the mayor and others want changes, they should bring the changes forward as amendments to the after the provisionally adopted code becomes law.

· Amendments should be reviewed by the city’s professional planners who understand the city’s adopted comprehensive plans, which represent the values expressed by thousands of citizens during the creation of Anchorage 2020.

· All Anchorage residents should be able to trust that local government operates using an honest and open public process.

Will this effort create the city envisioned in Anchorage 2020?
We are concerned that as the years of work on Title 21 have passed; as we've moved from the early "modules" to Drafts 1 and 2 and now on to the "Final Public Review Drafts;" we have drifted away from the direction Anchorage 2020 points us. By the summer of 2010 all of the new chapters except the "Definitions" chapter have been provisionally approved by the Assembly. That means they went through an extensive public process and series of public hearings and were found to be acceptable to the Assembly. Once all were provisionally approved, the plan was to then accept them all at one time. As of summer 2011, we are still waiting. And waiting.

Anchorage 2020 says of its Role & Purpose: “Once adopted, the Plan becomes a public declaration of the policies that will guide decisions of the Municipal Assembly, the P&ZC and other municipal planning boards and commissions …” Anchorage 2020 requires that Tile 21 regulations “shall be enforced to the greatest extent possible based in conjunction with policies stated in Anchorage 2020.” Anchorage 2020 is the planning document.

How far has Title 21 drifted from its role of implementing Anchorage 2020?
As the process of rewriting our land use laws has progressed, we have moved away from the goals of Anchorage 2020. That is clear in this draft’s presentation of its purpose in section 21.03.030. Some of this is straight out of Anchorage 2020. It’s interesting to see what got dropped.

2020 says “A balanced, diverse supply of affordable, quality housing, located in safe and livable neighborhoods with amenities and infrastructure that reflects Anchorage’s varied social and cultural physical environment. This draft of Title 21 left out the bold part.
The idea of protecting the character of our diverse neighborhoods is a major part of 2020.

2020 says of a Community Vision: “A northern community built in harmony with our natural resources and majestic setting.” Compare that with this section’s “Minimize adverse impacts of land development on the natural environment.” Every city should play to its strengths and Anchorage’s is this incredible setting in which we live. Let’s set a higher bar!

2020 says on Wildlife: “A wide diversity of fish, wildlife and habitats throughout the Municipality that thrives and flourishes in harmony with the community.” Title 21’s purpose statement? Not a word on wildlife!

2020 says on Natural Open Spaces: “A network of natural open spaces throughout the community that preserves and enhances Anchorage’s scenic vistas, fish and wildlife and plant habitats and their ecological functions and values.” The Comprehensive Plan mentions “a strong commitment to protect natural open spaces ... will maintain the quality of the environment.” Natural Open Space is a big deal in Anchorage and that is reflected throughout Anchorage 2020. This draft of Title 21 tucks it into one sentence with parks and facilities.

Public Meetings & Hearings

COMMUNITY MEETINGS by the MOA Planning Department

PUBLIC HEARINGS AT THE PLANNING AND ZONING COMMISSION

March 12 and 19, 2012.

The Planning Commission has been having work sessions on Title 21 over the past couple months. They had a public hearing on this new round of review on March 12. You can listen in here.

Read a summary and comments on the March 12, 2012 hearing.

Public Hearings at The Assembly

None planned as of May 2011.

ASSEMBLY TITLE 21 COMMITTEE

None planned.

Title 21 - Documents for Review

The provisionally approved chapters and supporting information is available at the Anchorage Planning Department's Title 21 website.

The Planning and Zoning Commission has decided that it will look at any and all changes to the proposed code. That's a surprise since the code has been through extensive review by prior commissions, has been "provisionally adopted" by the Assembly after extensive line-by-line review and then after even more review by Dan Coffey, the mayor and planning staff proposed a long list of amendments. We expected those to be a big enough job. Now the PZC has sent us back to 2002.

The precise amendments proposed so far are:

Proposed Amendments to the Provisionally Adopted Title 21
(PZC Case 2011-104, dated December 12, 2011)
Proposed Amendments to Chapter 21.14, Rules of Construction and Definitions
(Amendment 106 to December 12, 2011 Proposed Amendment Table)
Addendum to the Proposed Amendments to the Provisionally Adopted Title 21
(PZC Case 2011-104, dated February 2012)

ACC's submitted comments on these amendments. Here's the cover letter and the detailed comments.

Where do we draw the line on the endless compromises? We draw the line here.

The mayor's proposals combined with planning department comments are here.
(This is a great source for the larger view on each of Dan Coffey's and mayor Sullivan's proposals.)

The report on Dan Coffey's work is here (It's a very large file, over 400 pages.)

The mayor's memo of October 19, 2011 with a summary of his proposed changes is here (14 pages)

Economic Impact of the proposed changes to Title 21.

Anchorage Housing Market Analysis March 12, 2012. This is a technical report that includes a projection of housing demand, an analysis of residential land supply, and an estimate of financial feasibility of compact housing types.

Media on this release: KTUU , Anchorage Daily News

If you find this information helpful in your effort to understand this issue, please consider contributing to the Anchorage Citizens Coalition.

Following are some older documents. The action has moved beyond these efforts but much of the info is still useful.

Click here for a "side-by-side" comparison of existing code and proposed code prepared by the Planning Department. This is a useful document to get a sense for what is changing. Chapter 7 on Development and Design Standards is an important companion to this information.

Click here for ACC's comments on Chapters 4, 5, 6.

Click here for ACC's comments on Chapter 7.

Title 21 Rewrite Economic Impact Analysis

Click here to go to the EIA documents.

A proper analysis of possible changes to Title 21 must include the direct monetary costs of additional requirements as well as the benefits to the community in general and to adjacent landowners. The direct costs are easy to tally. Those indirect benefits can be huge, but are very hard to calculate. The budget for this study was small so we need to be vigilant that the analysis is fair.

ACC Title 21 Citizen Participation Project

The Anchorage Citizens Coalition organized a series of meetings where citizens reviewed and discussed early drafts of a new Title 21. Each of the three modules were reviewed as they were released to the public. Individual comments and group input was compiled and forwarded to the Municipality of Anchorage Planning Department and Clarion Associates.

Work Groups' Comments received on Module 1:

ACC Title 21 Work Groups Notes, July 30&31, 2003

ACC Title 21 Work Groups Notes, August 6&7, 2003

ACC Title 21 Work Groups Notes, August 13&14, 2003

ACC Title 21 Work Groups Notes, August 21, 2003 (group 2 only)

Work Groups' comments received on Module 2:

Citizens have discussed issues and have arrived at consensus on items.

See ACC Title 21 Work Groups Module 2 Consensus Statements

See ACC Title 21 Work Groups Module 2 Individual Statements

Work Group's Questions on Module 2:

Citizens posed questions while reviewing the draft of Title 21, Module 2, and these questions have been answered by MOA planning staff and/or the consultants. See Questions and Answers 1, Questions and Answers 2 and Questions and Answers 3.

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