The Anchorage Assembly has begun public hearings on and will hear more public testimony on January 22 beginning at 5:00 PM
Click for information on 2013 updates
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
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.
21 is written to implement the vision of Anchorage 2020,
Anchorage will continue to be a wonderful place to live.
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.
Coffey calls the provisionally adopted Title 21 "Radical!!!
Is it radical? Learn more here.
A brief history of
What can you do?
Will this effort create
the city envisioned in Anchorage 2020?
Public Meetings & Hearings
Title 21 - Documents for Review
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.
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.
public hearing on March 19 was not a big surprise, but disappointing
nonetheless. Listen to it here.
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.
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.
Potter ended the hearing with about 45 minutes of testimony
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?
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
feel guilty if it's too much for you to dig into because
the Assembly's Title 21 committee reviewed all these issues
over many, many months and recommended final language to the
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.
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.
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
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.
tuned. The next PZC work session is in April. The Assembly
has apparently scheduled its first Title 21 hearing for June.
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
that reserving industrial lands for industry 'takes'
Dan Coffey's comments:
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.
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.'
important that you let the Planning and Zoning Commission
know you haven't changed your mind....
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
· I believe costs will go up
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
· 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.
- 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
Developers say their costs will increase
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.
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.
2008 report contains valuable cost information for a
variety of costs such as
· planting a tree or bush or
· paving a parking space
· building a space in a parking
· commercial construction
· residential construction.
Muni planners document how development costs will go down
for most kinds
of commercial, industrial and multifamily properties.
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'
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
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
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.
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.
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
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.
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.
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
see pages 34-36 of the muni's
precise amendments proposed through the planning department
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
- Dan Coffey was a member of the Assembly’s Title
21 committee and he voted FOR every single provisionally adopted
- 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
- 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,
- 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
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
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
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
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!
battle cry is "Free Title 21!"
The Anchorage Press June 30, 2011
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
WHAT CAN YOU DO?
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
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.”
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.
the Anchorage Planning Department E-mail: firstname.lastname@example.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.
Anchorage Citizens Coalition to get on our newsletter and alert
WHAT SHOULD BE DONE?
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
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.
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.
far has Title 21 drifted from its role of implementing Anchorage
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
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
PUBLIC HEARINGS AT THE PLANNING AND
12 and 19, 2012.
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,
Public Hearings at The Assembly
planned as of May 2011.
ASSEMBLY TITLE 21 COMMITTEE
Title 21 - Documents for Review
provisionally approved chapters and supporting information is
available at the Anchorage
Planning Department's Title 21 website.
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:
Amendments to the Provisionally Adopted Title 21
(PZC Case 2011-104, dated December 12, 2011)
Amendments to Chapter 21.14, Rules of Construction and Definitions
(Amendment 106 to December 12, 2011 Proposed Amendment Table)
to the Proposed Amendments to the Provisionally Adopted Title
(PZC Case 2011-104, dated February 2012)
comments on these amendments. Here's the cover
letter and the detailed
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
Impact of the proposed changes to Title 21.
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:
If you find this
information helpful in your effort to understand this issue,
contributing to the Anchorage Citizens Coalition.
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
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
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
Work Groups' comments received on Module
have discussed issues and have arrived at consensus on items.
21 Work Groups Module 2 Consensus Statements
21 Work Groups Module 2 Individual Statements
Work Group's Questions on Module 2:
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