HomeMy WebLinkAboutORC minutes 010417Approved 2.1.17
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SUMMARY NOTES 1 ORANGE COUNTY PLANNING BOARD 2 JANUARY 4, 2017 3
ORDINANCE REVIEW COMMITTEE 4
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NOTE: A quorum is not required for Ordinance Review Committee meetings. 6
7 MEMBERS PRESENT: Lydia Wegman (Chair), At-Large Chapel Hill Township Representative; Tony Blake (Vice-Chair), 8
Bingham Township Representative; Maxecine Mitchell, At-Large Bingham Township; Lisa Stuckey, Chapel Hill Township 9
Representative; Andrea Rohrbacher, At-Large Chapel Hill Township; Patricia Roberts, Cheeks Township Representative; Paul 10
Guthrie, At-Large Chapel Hill Township; Buddy Hartley, Little River Township Representative; Kim Piracci, At-Large; Laura 11
Nicholson, Eno Township Representative; 12
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14 STAFF PRESENT: Craig Benedict, Planning Director; Michael Harvey, Current Planning Supervisor; Meredith Kern, 15
Administrative Assistant II. 16
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18 AGENDA ITEM 1: CALL TO ORDER AND ROLL CALL 19 20
Lydia Wegman called meeting to order. 21
22 23 AGENDA ITEM 2: UNIFIED DEVELOPMENT ORDINANCE (UDO) TEXT AMENDMENTS – REORGANIZATION OF TABLES OF 24 PERMITTED USES 25
To review and discuss proposed amendments to the UDO that would reorganize the Tables of 26
Permitted Uses in response to the Byrd v. Franklin County judicial decision. As work progresses on this 27
item, which is expected for the September 2017 quarterly public hearing, the ORC will have additional 28
opportunities for review and comment. 29 Presenter: Michael Harvey, Current Planning Supervisor 30 31
Michael Harvey reviewed the abstract. 32
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Paul Guthrie: Can I ask one question? More give me a better idea of the framework within. You mentioned nuclear power 34
plant, which I realize was to make an example. Nuclear power plant can only be built if it’s permitted by the federal 35
government. Federal government rules total charge of that particular industry. Would this thing you’re working on have any 36
ability to stymie the federal government? 37
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Michael Harvey: No. Just like the County cannot deny or allow it’s Boards to deny a telecommunication tower based on 39
concerns over RF radiation or RF radiation poisoning. When the federal government has essentially said, “You local 40
governments don’t have jurisdiction over this. We have found there to be no problem”. 41
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Paul Guthrie: The second thing was just a general broad comment that I think I’m fair in saying the two largest military bases 43
in the state were created by the federal government without regard to either state law or local jurisdiction and Camp Lejeune 44
and Fort Bragg. So I think somehow we need to make very clear that this is what is available under state and County 45
regulation and law, but anything occurring at the federal level will certainly supersede it. 46
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Michael Harvey: Well it goes without saying Federal law preempts state and local regulatory authority. Just like state law 48
preempts us. State can essentially do what it would like to do with its property without any local involvement whatsoever. Now, 49
we have been fortunate at times for the State to actually want to encourage and promote cooperative relationships on the 50
local government level and want to work with local government officials in addressing state development. That doesn’t always 51
have to be the case and I can point to a couple of examples in Chapel Hill and even Raleigh, involved with the Universities 52
where that level of cooperation probably was not as heartfelt. 53
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Paul Guthrie: So I guess my only comment is that I think that this is an even more difficult task than just going through this 55
stupendous process to get through the tables that make the existing Planning function. 56
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Michael Harvey: Well I’ll do you one better Paul. I think that one a certain level you don’t have to worry about the Federal or 58
even the State preemption because it exists. You can sit there and say, “We’re not going to allow nuclear power plants”, which 59
means that you as a member of a utility company looking to break into an area as a profit based initiative have no opportunity 60
to develop that particular land use. Whereas Federal and State governments through their utility commission authority can 61
say, “No. Duke or Piedmont or whoever, we’re giving you a license to develop this type of facility and Orange County or 62
whoever, you’re preempted from stopping us from moving forward”. Now, it still has to go through their various processes and 63
there are various processes they have to go through where you can still have a denial of a permit. Our authority comes from 64
153(a)340. And the state giveth and the state can taketh away. And the asphalt plant, I know, is a bad example but it’s 65
designed to kind of spell out that the State has defined that we can do X, Y, and Z. But they have the right under the 66
provisions of the State Law to tweak how we get to do X, Y, and Z. Our goal here is to ensure that we are not creating a 67
loophole where by somebody gets to do something because we either weren’t as detailed oriented as needed be to ensure 68
compliance with Byrd V. Franklin. Or that we didn’t think of a particular land use category and said, “Oh, well we think it’s this”. 69
And then it becomes and interpretive nightmare and a potential court proceeding where we’re told, “No, you didn’t list it so by 70
definition it’s allowed”. 71
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Tony Blake: What does this decision actually say? 73
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Michael Harvey: Well the decision actually says… 75
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Tony Blake: Because I had two questions regarding that inside this… 77
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Michael Harvey: The Court stated as I’ve pulled out of the abstract, the law factors uninhibited free use of private property over 79
government restrictions. So you have to spell out what is and is not allowed so that you know. 80
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Tony Blake: So if it’s not stated it’s permitted? 82
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Craig Benedict: Right. 84
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Michael Harvey: If it’s not stated it’s permitted or if you don’t define it to a point where you say, for example sexual oriented 86
businesses because this is a conversation we’re currently having with the Attorney’s Office. We’ve defined sexually oriented 87
businesses as including a plethora of activity. So the question that James and I are wrestling with is do we need to list out 88
these 50 uses we have in definitions or is it reasonable to have them in definitions? Right now he’s edging his bets and saying 89
I think the definitions will work because we’ve defined this is what they are, oh and by the way here are the 50 individual 90
definitions for each use. 91
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Tony Blake: So then let me just follow my train of thought here because when I read that and how I interpreted it and that was 93
what I thought… I came up with two things reading this. For one thing, banks and financial institutions are listed in two 94
different categories. One in commercial and one in financial, I think. Why? Is one an ATM and the other a full-blown walk in 95
bank bridge or? That’s the kind of use that I’m… The way somebody using something has a big bearing on this. Above ground 96
water tanks is another example where if you’re using them for the purposes of fire suppression to prime a sprinkler system or 97
something like that it’s different than something there to wash out a garbage truck. What I’m saying is the intent of the use is 98
more open in this sort of a… 99
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Michael Harvey: Well I would actually do you one better. A water tank in this context, when you’re looking at it from this point 101
of view is typically looked at as a primary or principal use. Which doesn’t mean that your business, already listed and 102
developed, can’t have a water tank as an accessory. Either to prime a required sprinkler or do other things you need to do. So 103
part of the thing you have to keep in mind is we’re looking at defining what allowed uses are per district. There may be 104
ancillary uses that every use is allowed to develop as a customary accessory use that may not necessarily have to be listed 105
this table either. The other example I’ll give you is: Single family residence you want to build a playground, a swing set for your 106
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children. A swing set’s not going to be listed in here as an example. We don’t have to get to that granular level. But it is 107
covered under the vernacular of accessory land uses, which and again I’m taking your one example to a little bit of an extreme 108
but it’s designed to try to give you an answer that you’re comfortable with. The other thing I want to remind everybody here is 109
that we basically have only two categories of land uses in this County. And those are the general land uses that get further 110
broken down and permitted by right, meaning staff review and approval or Special Use. Meaning they go to Board of 111
Adjustment or County Commissioners for Class A SUP. Then you have the conditional. Conditional districts know, as you 112
might recall from when we did Hearts Mill, list out their own individual uses as part of that development proposal, that 113
development application. There are activities shown in table 5.2.3., which we have in attachment 2 but primarily you also as 114
an applicant can negotiate with the County Commissioners about what those activities could be in certain circumstances. 115
Now, Rita… Everybody remember Rita of the rural economic development activity area, on the 57? That has a list of specific 116
uses. You rezone to Rita, you have to pick one of those uses. Master plan is a global conditioning-zoning district where you’re 117
picking and choosing and proposing to this Board to make a recommendation and the elected officials ultimately approved. 118
That was Hearts Mill, just to give you an example. So part of this is to ensure that when we’re talking about the general use 119
districts you all know and love, such as rural buffer, neighborhood commercial, general commercial, I’m not going to list them 120
all but you get the gist. And then the economic development districts, Buckhorn, Eno, and Hillsborough. You’re going to have 121
consistency in how each land use category is referenced, defined. Within the County you may have a difference in where 122
they’re allowed. For example, you may only allow an asphalt processing batch plant, and again this is just example, in the 123
heavy industrial, which is I-3 and the Hillsborough Economic Development district 5, and nowhere else. But those are the two 124
places where that land use category is going to be permitted. Is everybody with me so far? 125
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Lisa Stuckey: Does this have to be so precise that you include indoor ski resorts and tesla reproduction manufacturing plants? 127
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Michael Harvey: The direction I’m getting from the County Attorney’s Office is I have to be as explicit as humanly possible. 129
Now do I have to spell out a Nissan manufacturing plant or Tesla? It’s a good question. Do I have to spell that out implicitly? 130
No. I have to say automotive manufacturing and that can cover the gambit. 131
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Tony Blake: But there may be a distinction between a gasoline powered manufacturing plan and an electric powered 133
manufacturing plant. 134
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Michael Harvey: Well it’s still a car. 136
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Tony Blake: Right but they have different materials and processes and hazards. 138
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Michael Harvey: Well you may want to have a distinction from the standpoint of what district you allow them in but you don’t 140
necessarily point out and spell out unless you want to. If you want to get to that granular level you could conceivably do that 141
with this. We didn’t take it that way for this example, I think we have actually in there automotive manufacturer. And that’s the 142
category. So the other part of this and this goes back to Lisa’s question earlier, the NAICS code. We are using NAICS 143
because it is an exhaustive list. 144
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Lisa Stuckey: Well, why reinvent the wheel? 146
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Michael Harvey: Well that’s part of it. The other part of it is the Staff is still trying to determine if we want to keep references to 148
sector numbers and our initial response here is we’re probably not going to because it’s just going to confuse the issue. 149
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Tony Blake: Well how do you enforce that granular area? 151
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Michael Harvey: Well you define uses in your own UDO. And because you also can’t, and James Bryan would disagree with 153
me, I have a hard time saying that we’re going to reference an external document or an external table in terms of defining 154
what this is. It needs to be in our code. So this is the level of complexity we’re about to begin. 155
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Craig Benedict: It helps with Economic Development. When I would say light manufacturing is allowed in economic 157
development Buckhorn they would say, “Are you sure? You just have it all under light manufacturing. I’d like to see that food 158
processing is allowed”. And under the NAICS code there is something, you know candy production is listed as a sub-category. 159
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Also a device that we’re going to use to move through these things as fast as possible, as Michael said the general 160
categories, the RV’s, and the commercials, and the residential, and the economic development and conditional zoning, we’ll 161
put up a use somewhere and we’ll try to populate it as much as we can based on what’s in there. And then we’re going to say, 162
“do you have trouble with rubber hose manufacturing?” and we’re going to have some little voting clickers and if everybody 163
kind of gets a straw vote that it’s ok then we move to the next one, because there’s going to be a lot of questions. The 164
Commissioners have, just when we went through the Hillsborough Economic Development Zone we asked them to weigh in in 165
those districts and there were five separate districts in Hillsborough and they had questions. Not the majority, but some did 166
have questions. And then the question was what does that exactly mean and the NAICS code does have definitions of those 167
specific areas, so we threw that their way. So it is a long task but it is going to add to some specificity for really everybody 168
concerned, instead of Craig or Michael saying, “Oh that seems like light manufacturing to us”. We’ll have a little more 169
coverage if it’s listed or not. 170
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Tony Blake: This reminds me of the old IBM thing in the park right when IBM moved into the park and everybody was 172
complaining and they said, “this is a research park, we don’t allow manufacturing” and IBM attorney’s came back and said, 173
“Well we don’t manufacture, we assemble”. So back to my water tower example, doesn’t the way they’re going to use that 174
matter? 175
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Michael Harvey: On one level, no. On another level, stand-alone water towers… are you concerned we’re not going to allow a 177
utility to have a water tower? 178
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Tony Blake: No, I’m just… When I look at it it’s not a use. It’s a thing that can be used in a myriad of different ways. 180
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Michael Harvey: I can actually point to two water towers in Orange County that are stand alone uses that serve a utility 182
function for the utility provider that has it there. I can also tell you water towers in certain volunteer fire departments to serve as 183
prime pumps to drain and put into an engine as emergency water preserve. But in that instance I would call it a customary 184
accessory use to the volunteer fire department versus a stand-alone use. It’s connected to the principal activity… And it’s a 185
broad example. 186
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Tony Blake: Again, I get back to what happens when this thing is listed in two different categories, like banks and financial 188
institutions. 189
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Craig Benedict: We’re going to get them all into one. 191
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Tony Blake: Ok. So the intent is to remove them from the commercial use and put them in the financial? 193
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Michael Harvey: Well I think as we have the footnote we have it listed as it currently is and we said we’re going to have to 195
broaden and move it. Just like retail. 196
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Tony Blake: I guess I’m over it. I was left with this… when I look down this column called “Use type” there are things in there 198
that don’t strike me as uses so much as they are… 199
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Michael Harvey: Well there are examples all throughout. One big example I’ll throw out as Tony’s looking for his example is 201
somewhere in here, and we included it because it’s listed in the NAICS table, we’ve actually foot noted it and said this is just to 202
kind of give you an illustration for discussion purposes, land subdivision. I’m on page 43. And the footnote we have, this is 203
listed in NAICS, and our goal is to try to pull in as much of NAICS as possible to kind of show you what we’re dealing with. 204
Land subdivision is not a land use. We included for reference and discussion purposes. This actually goes to Tony’s point. 205
There’s stuff in here that we’re not going to be keeping but we have to have it in here because we’re trying to give you what 206
the NAICS table says because at some point, I know if I were you, I’d be wondering, “Well I went and looked at the NAICS 207
code and you skipped two uses; was that on purpose?”. 208
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Tony Blake: So special events were another one that that’s something that is an activity somewhere else. There isn’t really a 210
special event? 211
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Michael Harvey: Well that’s a current land use. 213
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Craig Benedict: The NAICS code almost went beyond just a use type. It listed an activity, like construction. I think it does give 215
a very exhaustive list and we can weed through some of those things. 216
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Tony Blake: And they apparently do make the distinction in here between manufacturing and assembling. 218
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Lydia Wegman: So you’ve given us an example of the NAICS code here. 220
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Michael Harvey: And we’re going to get into some of the specifics in a few minutes. 222
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Lydia Wegman: Ok, that’s fine. Paul has a question I think. 224
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Paul Guthrie: I just happened to read something on this particular page that you were talking about and that is streets, 226
highways, and bridge construction, and then your explanation is obviously there. Many of the secondary roads in this State 227
and in this County have never had formal right of way acquisition. In the 1930’s when the State took over the right of way 228
system they just did it by Fiat and I know for a fact, at least 15 years ago when my parents were selling their property, there 229
was no record of the State right of way across the property; how are you going to handle that in this rigid schedule of 230
definitions. 231
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Michael Harvey: I’m not. That’s a State problem. And I’m going to let it be a State problem. 233
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Paul Guthrie: But it’s also a land owner’s problem. 235
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Michael Harvey: Unfortunately, the County since we have no jurisdiction over the Department of Transportation there’s no 237
reason, from my stand point at least, for us to get into the fight. We will regulate private road development through the 238
subdivision process still and I would suggest… The subdivision road construction is going to be consistent with the ordinance, 239
which means you need to show us your right of way. If you, as a developer on a private road, want to take it to the center line 240
and deal with some of the ramifications of that then that’s your prerogative, we don’t recommend it. We have private roads out 241
of there where the right of way is just that, it’s a right of way. And it’s been plated independently to A: Avoid impervious surface 242
issues for the adjoining property owners and B: to get a clear title for the Home Owners Association about what they are 243
maintaining. That is, unfortunately, the exception to the rule. In most modern subdivisions where a public road is proposed we 244
look for dedication of the right of way. DOT, as you’ve pointed out, just has to establish a right of way, say it’s for X purpose 245
and go through the condemnation process prescribed by State law, but doesn’t have to take end fee title to that land but it is a 246
right of way that is defined for state purpose and state use. While clumsy, if that’s the way the State chooses to do business, 247
God bless you. I don’t want the liability of having to get in that because we’ll lose every time and for the exact reasons that 248
you’ve already brought up. That your parents went through some frustrations with their house. 249
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Tony Blake: So an elevated water storage tank, in order to use that to charge or keep pressure in your sprinkler system in 251
your building you would have to classify that as a utility? 252
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Craig Benedict: Not if it’s an accessory use. 254
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Tony Blake: Ok so that’s what Michael was trying to say? And I probably wasn’t hearing exactly that. 256
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Lydia Wegman: So I’m wondering at this point, unless there are any other questions, it’d be helpful for Michael to go through 258
some examples with us. 259
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Michael Harvey continued reviewing abstract. 261
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Craig Benedict: Let me just make one comment about the Economic Development District. There are two in Buckhorn, two in 263
Eno, and five in Hillsborough. If by chance when we come up with the uses that are allowed in those nine districts in what we 264
have in there now, if it happens that Economic Development Buckhorn one is the same as Economic Development Eno one is 265
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the same then we may suggest as a second step, “Let’s come up with ED-1 and get rid of the B and the E and all that stuff. 266
But we’re going to have to go through this iteration because those zoning categories are on the ground and we’ll have to 267
actually go through a zoning process to rename them the different areas. So just like you might remember some of those 268
general or conventional districts we came up with. That new office-manufacturing district, that was a really good mix of uses. 269
We can’t use that in our Economic Development zones right now. We’d love to use that in the other categories so we might 270
come up with some as we’re looking at this and say, “Oh that would be good somewhere else”, and have to go though some 271
extra steps to collapse it even further to use more of a general Economic Development zone. We know there’s uniqueness 272
between those three zones. They’re kind of a part of three separate agreements with the local municipalities that they annex 273
them. So they’re probably going to retain some of their uniqueness, but if there’s a chance we can collapse, we may. 274
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Tony Blake: That’s why I asked that question this afternoon about Chapel Hill’s new light industrial and the thing that we just 276
approved outside of Hillsborough sounds like they should be similar, if not the same. 277
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Lydia Wegman: Ok, so that’s not what you’re doing? 279
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Michael Harvey: Right. We may be making recommendations but this is not going to collapse anything. I think it’s fair to say 281
we would get lost in the minutia of the collapse versus getting the table permitted uses fixed. This is, again, already going to 282
an endeavor. This is already going to be involved. There’s not reason to overcomplicate this ay more than it’s going to have to 283
be. But I think it would be valuable to hear your comments along those lines as we move forward. Why do we have it broken 284
up this way? Why can’t we look at collapsing it? County Commissioners, maybe a future project is X, that is something that 285
you need to keep in mind and that is something that could be beneficial as we go through the process. 286
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Tony Blake: So just for the sake to make it easier to parse the information is it possible to get this in an XL spreadsheet? 288
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Michael Harvey: Anything’s possible. 290
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Tony Blake: Yeah I’m just… being able to write a formula to say, “give me all the ones that have this use, or all of the 292
categories of zoning districts that have this use” because I expect that the paper is going to be longer even than it is wider. It’s 293
going to be huge. And just being able to sort in a spreadsheet would be, I think, easier. And then later, as a Word product if it’s 294
in a common separated format it’s easier to computerize or put in a place where it can be accessed electronically as opposed 295
to by paper. That’s all. I’m making that suggestion, not necessarily… 296
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Michael Harvey: It’s not a bad idea. The question is how many iterations are we going to be producing? 298
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Tony Blake: Right, you want one controlled copy. 300
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Michael Harvey: Yeah, and I think that’s probably where most of my concern is. I think that it’s important that we’re providing 302
you this information in a format and a mechanism that you all can make best use of it and if that’s the best way to do this then 303
we’re going to have to investigate it. Obviously, it’s going to have to be in a table when we get to the final iteration of this so 304
that it’s going to be able to be put into the UDO formatting. 305
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Paul Guthrie: Can I ask one quick question just to help me get a reference on how we deal with this? What was the decision 307
and on what subject of the Byrd case? 308
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Michael Harvey: Well the Byrd case involves somebody being denied. There were elements of references to a shooting range 310
but if there was another land use and somebody wanted to develop and somebody made the distinction that, “Well the land 311
use in and of itself is not permitted” We think it falls into this category however which is not permitted in your zoning district. 312
And the suit was, “No, you have to give me a comprehensive list telling me what I can and cannot do with my property. 313
Because if you’re not then you’re denying me fair and impartial use of it because you’re not telling me you can do this and this 314
and this. If it’s all based on your supposition of what this term means and this term means then I don’t have a clear, easily 315
understandable, definable path to determine whether I can do something with my property”. And the Court basically said, 316
“That’s accurate. The responsibility is on the government to provide that data so that you as a property owner can make that 317
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choice without necessarily either A: Having to have a degree in Planning or B: At the whim of a Craig or a Michael to decide 318
how to define the term”. 319
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Paul Guthrie: And then once you do that then it can be litigated. 321
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Tony Blake: Or it can change over time. 323
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Paul Guthrie: So the question is do you make a list that is as encompassing as possible in definition of functions or do you 325
make a list that is as complicated as it will be to things you can’t do? 326
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Michael Harvey: Well Paul, I guess beauty’s in the eye of the beholder. Because I think it’s going to be both ways. I think there 328
are some people that are going to see this as, “Wow, you just listed 50 things I can’t do” but, “Yeah, we’ve listed also 20 things 329
you can do”. “But I want to do this”, “Sorry, you can’t. It’s not permitted. You’re choices are amend the ordinance or do 330
something else”. We are however giving you that level of detail and that definitive detail so that you don’t necessarily have to 331
rely on an interpretive call that could change either because Craig leaves and you get somebody else in that seat that has a 332
totally different view of how to interpret a certain land use category. That’s what this is an attempt to start memorializing. Now, 333
as I indicated at the onset of this meeting, this is not going to be the all-encompassing list. It’s going to be as close as we can 334
get it. Land use is a fluid, ever-changing monster. And Craig and I have said this is many meetings, we know you’ve heard it, 335
the UDO is a living, breathing document that is designed to change over time, albeit sometimes slowly, to address the current 336
needs of the community, and to address the changing aspects of the community. There are land uses that some Board 337
members may now say, “We want to allow this here but we don’t want to allow this here anymore because it makes more 338
sense”. That’s perfectly reasonable and that’s what some of this is going to, I think, pull out. 339
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Craig Benedict: This version of the NAICS code is 2012 and there might be a 2018 and we might have to see what the 341
differences are and find if it’s a ruling to say that we now need to list those new uses and decide whether they’re ok or not. 342
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Tony Blake: So it strikes me there’s two activities here. One is the list of use types, however we pair it up or down and then 344
two, filling in all the little boxes along the appropriate NAICS codes. 345
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Michael Harvey: Well remember, that’s also a point of contention we need to talk about. We have provided the NAICS code as 347
the example because that’s what we started out with for the Hillsborough district. We’re not married in the fact that the County 348
Attorney’s Office vacillates depending on when you talk to them on whether or not we should get whole heartedly embrace the 349
NAICS code or just list uses and not rely on the sectors. One example is, both Perdita had brought to James’ attention our 350
concerns of, “If there are changes to the NAICS code what does that do to us?” and his initial reaction and it still is to some 351
extent now is that it doesn’t matter. You’re referencing a certain NAICS code, a 2012 NAICS code; so what if there’s an 352
update? If you don’t choose to update your code, you’ve at least made reference to the appropriate code you’re using, or don’t 353
use the NAICS code at all for the stand point of referencing sectors, list the uses and make sure you’re properly defining them 354
if you need to; article 10 in this case. And the NAICS is just a guide in terms of a comprehensive list of uses. So again, there’s 355
a lot of ways this is going to have to be discussed to potentially pan out. 356
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Tony Blake: What are other jurisdictions doing? 358
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Michael Harvey: I don’t think it’s fair to say that there is any one jurisdiction that has the same opinion about this as the other. 360
In talking to some of my brethren from other Counties some are hiding under rocks and quite bluntly some are saying our 361
Attorneys say this isn’t as big of a deal as it seems to be, and we’re just going to wait until we’re sued. And I don’t mean that 362
meanly, but they’re attitude is, “We believe we have defined our land use tables sufficiently that we don’t need to worry about 363
Byrd v. Franklin”. We need to worry about Byrd v. Franklin for a couple different reasons. One because we have terms like 364
“light industrial” that provide a grotesque synopsis that relies on a determination to be made by a staff person. We have an 365
overall definition of office and personal service class 1, 2, 3 where your difference in class 1, class 2, class 3 is either a traffic 366
impact assessment or something else. We have health services, that all-encompassing title that says 10,000 square feet and 367
under. What’s a health service? Does that include this, does that include that? And then that goes back to some of the 368
discussion I think you were having, not to kind of mince the issues here but it will hit the point home I hope; what’s the 369
difference in the Hillsborough Economic Development district with a 1.9 acre parcel doing something but a 2.1 acre parcel 370
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having to go through an SUP if it’s the same use? Because just with the size of property. And it’s the same problem here. Just 371
because of the size of the structure or anticipated traffic impacts with a nebulous term of what it means that relies on a staff 372
determination you’re either going to be allowed to doing something or not do something. I think where James’ concerned gets 373
legitimized is the notion that our current process as others surrounding us relies too much on a staff interpretation of the 374
terminology, if we’re having a good day. And they want to avoid conflicts with whomever. Michael gives one answer, Craig 375
gives a second answer, and Patrick gives a fourth answer, because Rachael gave a third answer already. So that’s what the 376
Attorneys Office is hoping to avoid with a more detailed, encompassing list. 377
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Tony Blake: So then does it make sense to approach this by, I don’t want call it low fruit but the areas of concern first? 379
380
Michael Harvey: I think… Why don’t we go through the tables and start looking at what we’ve done and start trying to answer 381
some of those questions and I think some of them will become self answerable. We’re obviously going to get through as much 382
of this as we can tonight because I think some of your direction is going to give me answers to questions on how I’m doing 383
some other things. 384
385
Michael Harvey continued reviewing abstract. 386
387
Lisa Stuckey: Is there going to be a difference to our land owner whether they’re going to be permitted to do tobacco farming 388
or cotton farming in a particular area? 389
390
Michael Harvey: Well again, you’ve kind of hit the nail on the head. 391
392
Lisa Stuckey: Well I think in reality if there’s going to be a difference then it should be broken down as small as it is here so 393
people know what they can do. If there’s no difference then get rid of some of the sub category. Is that what you’re asking? 394
395
Michael Harvey: No. Well, we’re going to be asking that on several categories. In this one specific example as articulated on 396
page 34 on footnote 3 we’re providing this list but we believe we’re going to be preempted by the State law saying you don’t 397
define farming, that this is going to be coming out. I’ve put this in here to ask your opinions, if you’re comfortable if we take this 398
tact with the Attorneys Office on Thursday that listing these uses out is moot. 399
400
Lydia Wegman: So you would leave the current uses? 401
402
Michael Harvey: Yeah, I’m going to leave the current uses alone. Current uses we’re not changing except it’s going to be on a 403
bigger table. 404
405
Paul Guthrie: And Byrd had nothing to do with agriculture. 406
407
Tony Blake: But if you’re in an AR zone and you want to keep bees or chickens, there is nothing that’s going to stop you from 408
doing it, right? 409
410
Michael Harvey: Correct. We do not regulate you keeping bees or you keeping chickens. In fact, remember when we were 411
doing the UDO there were several questions about kennels and the definition of kennels because we do regulate how many 412
dogs you can keep. Language of the definitions of kennels Class 1, Class2 stipulates that includes all animals with the 413
exception of domesticated livestock. So Tony has 21 chickens on his property, doesn’t mean he has to get a Class 2 kennel 414
because he’s got 21 animals because that’s one of the thresholds. A chicken is a domesticated farm animal so it’s exempt 415
from having to do that provision. 416
417
Michael Harvey: And what I’ll point out to you is that the NAICS code takes several of these activities and puts them into totally 418
separate land use categories and use types. What we’re trying to do here is just kind of provide you our thought on what some 419
of the existing categories would become morphing into. So for example, school; it’s not just dance and art, it’s karate, martial 420
arts, gym, sports training. 421
422
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Tony Blake: So your example earlier of this thing where you go in and fight your way through levels and do all of this, that 423
could be entertainment or it could be training. 424
425
Michael Harvey: Yeah. I would classify it based on what I’ve read about it as an arcade, because it’s not training from the 426
standpoint of physical exertion. It’s like indoor paintball for lack of better way to put it. It is a fun activity. But that’s exactly the 427
point we’re making. So schools: elementary, secondary, public, or private. You don’t differentiate between public and private. 428
It’s a school. And we’ve had that discussion a couple different times as we looked at Carolina Friends School, Emerson 429
Waldorf, and of course and County school. My favorite one, commercial uses, which begins at the bottom of page 39. Look at 430
the footnote. We’ve made some small modifications. This is where the NAICS code provides expanded lists of a ton of 431
different activities. And Tony has hit on a couple, banks and financial institutions. This land use category will be expanded into 432
a new category titled “Finance of Insurance consistent with NAICS code” in a future draft. That’s where you get into insurance 433
brokers, you get the laundry list of activity that all makes up a financial institution besides just bank. Its stockbrokers, it’s 434
insurance. 435
436
Lydia Wegman: So you’re expecting to have that whole list in here? 437
438
Michael Harvey: Yeah. It’s going to be broken out in its own separate category. 439
440
Paul Guthrie: You can get some, probably not in Orange County, but you can get banking as some guy sitting in a room with 441
three computers. 442
443
Michael Harvey: So beauty and barbershop. Again, we’ve kind of broken down what we’ve found in the NAICS code to sort of 444
broaden that out. It’s not just a beauty and barber shop, it can also be manicure/pedicure care, massage non-therapeutic, day 445
spa, bath house, steam rooms, etcetera. This is again, the granular level of detail we’re going to have to be going for. 446
447
Paul Guthrie: I was just looking at the mining. To my knowledge there’s been no indication of coal, for instance, in Orange 448
County. Wouldn’t you eliminate that from your list? 449
450
Michael Harvey: No, because then somebody could claim it’s permitted because we didn’t list it and then not say it’s allowed. 451
452
Paul Guthrie: So you think they’d go dig in a hole for something else? 453
454
Michael Harvey: Yes. Well here’s what I don’t want Paul, this actually goes more to your point. What I don’t want is for 455
somebody to claim that you didn’t list it, therefore it’s permitted, and it’s unregulated, and we can do whatever we want, and 456
we’re going to give it a try, and then you hit something else. 457
458
Lisa Stuckey: So I have a question going back to this beauty and barbershops. Is that a heading or an individual category? I 459
see that manicure and pedicure is indented, what’s the significance of that indentation? 460
461
Michael Harvey: We were providing you a synopsis of how beauty and barbershop would have to become its own independent 462
category and then be broken down further. 463
464
Lisa Stuckey: Ok, because you guys have left out hair cutting. 465
466
Michael Harvey: Yeah, we didn’t capture everything… It gets even worse when you get to page 41 and you get to office and 467
personal services, where the NAICS code actually provides you some personal services that include grooming services. So, 468
these are issues that we’re going to have to be resolving and working with you all. 469
470
Lisa Stuckey: Right. So is it an individual category or a sub category is very important? 471
472
Tony Blake: But that’s again back to what I was trying to get to earlier… Are some of these categories meant to be accessory 473
uses? I mean why would they list them in two different places? 474
475
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Michael Harvey: The best answer I’m going to give you is you don’t need to look at this from the standpoint… I think if you 476
continue to look at this in the standpoint of whether it’s a principal or accessory you’re going to get lost in the weeds. You 477
need to look at this as these are principal uses. And the weeds are going to get thick anyway. My job here tonight is I’m 478
providing you some specific examples, you’re giving me some direction, which I appreciate, and I think you’re getting the idea 479
of the complexity that this is going to be. You’re going to have these types of conundrums. And it gets worse as I point out on 480
page 41 with retail where you have 60 independent land uses that constitute retail. With restaurants you get to the same 481
problem. You’ve got 30 different uses for restaurants so a lot of these are going to become their own, new land use category 482
with a list of uses. And we’re going to be recommending where they go. Right now we just have a general colloquial term 483
building contractors. The NAICS code breaks it down even further. Residential building contractors, heavy and civil 484
engineering construction offices, this is the level of detail that we’re going to be looking to provide. 485
486
Paul Guthrie: Are the attorneys then going to make you translate that into relevant State law? Citations for instance, licensing 487
for certain types of construction and building? 488
489
Michael Harvey: I think the fairest way I’m going to answer that Paul is to say that we’re going to list a specific land use that is 490
going to be allowed or not allowed. Whatever license you have to get to legally have that land use will drive whether or not 491
you’re really going to do it. So it’s kind of a dual end sword. 492
493
Tony Blake: So I kind of see the problem with the NAICS code here because I look at this construction and I see new single 494
family housing construction except for for sale builders and then 236117 new housing for sale builders. There’s not a 495
difference as far as I can tell but if you would omit one of them then somebody’s going to claim to be that and be unrestricted. 496
I see that so the minute you say you’re using the NAICS code you immediately become subject to every little… so I’m just 497
echoing that concern. 498
499
Michael Harvey: Yeah, because what I’ve heard from all of you so far is it’s a neat list but I’m not hearing a lot of oohing and 500
ahhing about getting into bed with the NAICS code. And I’m certainly not going to dissuade you of that. 501
502
Lisa Stuckey: I don’t even know what the NAICS code is. 503
504
Michael Harvey: Well the NAICS code is was originally looked at as a way of trying to categorize and catalogue what activities, 505
what land uses, what business you had to make counting for the census perspective easier. We’ve got this many of this, this 506
many of this, this many of this. And there were some attempts early on to say this should just be the definitive land use code 507
for this land use category. The problem with NAICS is, as Perdita pointed out to you a lot, it only covers a certain spectrum of 508
allowable land uses. It doesn’t touch residential, for example. Like single family or some of the other activities. So what I’m 509
hearing you all say and looking at the glazed look in your eyes, because trust me I get it too going through NAICS code, is that 510
NAICS is a good guide but you’d prefer to have something in a vernacular that you have a little more connection with without 511
referencing section numbers and without getting into this level of detail of, “Do we really care for for sale builders, not for sale 512
builders?”. And if you’re asking me, “Do I want to get to that level of minutia to say that Paul, who is a Spec builder, and Tony, 513
who is a custom house builder, can’t have an office in the same zoning district?” it’s a house. And if everybody’s ok with that 514
that’s why we have the footnote there to say… 515
516
Tony Blake: And the overwhelming majority of them are probably doing both anyway. 517
518
Michael Harvey: Correct. 519
520
Paul Guthrie: Let me just point out one little subversive tool for you when you’re talking with the attorney… You get into some 521
of this kind of stuff, is the Byrd agreement taking without due process under the law? And it’s a good question to ask him 522
because some of the things we’re saying here would, in fact, be a taking. 523
524
Lydia Wegman: I don’t think it’s a due process thing. 525
526
Michael Harvey: Well I think where Paul’s headed with this, quite bluntly, is the argument that local government is not 527
providing you sufficient detail in what you can do with your property and as a result that’s an adverse impact that results in the 528
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11
taking of rights, without compensation. And I think that the honest answer is, I don’t think that Byrd got to that level Paul. But 529
what I think Byrd came from is, you as a government entity have a legal obligation to define for you what’s permitted and if you 530
choose not to say or take a definitive stance on oil and gas pipeline and related structure construction then the person should 531
assume they could do it. 532
533
Paul Guthrie: Ok, I can understand that but I’m going back actually a little further, and that is as you redefine our processes to 534
try to comply with the attorneys view of the Byrd decision you may in fact be retroactively making a taking of someone’s 535
property. 536
537
Michael Harvey: I don’t share that concern but I understand why you’re asking the question. 538
539
Paul Guthrie: Oh I understand that, I’m just saying… 540
541
Craig Benedict: We’re putting them into a slot that might not have been as specific as it was before. So we’re trying to match 542
what they can do there now, but there’s going to be some things where we’ve never really answered that question before. 543
544
Lisa Stuckey: So then Paul’s question is relevant. 545
546
Craig Benedict: Michael, I have a question that you can pose for the attorneys. On page 43, if you had specially trained 547
contractors and this NAICS code heading 2, 3, 8 if we thought all those sub uses below were ok that we didn’t mind if they 548
were in any district or whatever, could we just use the main heading? 549
550
Michael Harvey: Yeah. But if I don’t show you and everybody else, because that’s what got us in trouble at the Cou nty 551
Commissioner level with the Hillsborough district, when certain assumptions were made that everything in this particular land 552
use category could be allowed or should be allowed… Well that’s not fair, Perdita had a couple land use categories where no 553
boxes were checked and the concern was, “Well in this land use category this land use is allowed. We don’t know what land 554
uses are allowed” and of course Perdita’s honest and straight forward answer was, “It doesn’t matter, we’re not allowing them 555
in the district” and that’s when we got into some of the problems and trouble we did. But Craig is right. If you have a land use 556
category, or a sector category for example, that lists uses that nobody cares, they’re all fine then you can just have the 557
reference, as long as you’re properly defining all that reference entails somewhere. 558
559
Lydia Wegman: So you would say specialty trade contractors NAICS 238 and all… 560
561
Michael Harvey: If we stick with NAICS code references, yeah. Or the better example, if you have beauty and barbershop as 562
the overall category and then break it down to what beauty and barbershop could entail as long as it’s the encompassing list. 563
Page 45 begins extracted uses, mining, quarry, and oil and gas extraction. This became a huge issue at the County 564
Commissioner level dealing with the Hillsborough Economic Development district because the concerns that you could have 565
manufacturing activity that may not be deemed reasonable for the area in question. So we listed everything out, obviously 566
capturing everything we currently allow on page 47. What I have listed is what I believe we currently already allow through that 567
proves but yeah, we specifically didn’t include geranium mining. 568
569
Tony Blake: Well how about sand, gravel, and ceramic. I mean if you look at the merits over at Chapel Hill Gravel, it’s by 570
definition… 571
572
Michael Harvey: Well I would actually say it was stone mining and quarrying, but I understand your point… Again, what I’m 573
hearing a lot of you say and the nods of consensus are that we need the level of detail but if we can eliminate the sector 574
references and just group them it would be a lot easier to understand. 575
576
Lydia Wegman: What do you mean by eliminate the sector references? 577
578
Michael Harvey: Well for example, I have put in here all the sector references as they live in the NAICS code. What I’m 579
hearing you all say is if you can give the land use category and then provide the uses it would be a lot easier for you to track 580
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12
and follow without worrying about what sector X does, sector Y does. And that’s a pretty constant theme I’m hearing from you 581
all right now. 582
583
Lydia Wegman: I need an example to understand what you’re talking about. 584
585
Michael Harvey: Instead of saying metal or mining section, just have metal or mining see list below and then list them all out, 586
instead of relying on sectors. 587
588
Lydia Wegman: I see. 589
590
Lisa Stuckey: If they’re not all allowed? 591
592
Michael Harvey: Right. If we want to allow stone mining and quarrying just allow stone mining and quarrying without having to 593
break it down into its added finite. The next comment I’ll make goes to an earlier comment Paul made, go to page 49. The 594
bottom of 48 and all of 49, this is government uses and public administration. That’s a category under the NAICS code. We’re 595
getting into executive, legislative, and other general governmental support, executive offices, legislative bodies, and public 596
finance. 597 598
Lisa Stuckey: Michael, if you and the other Michael Harvey’s in the state are all doing this is this not a ridiculous and huge 599
reproduction of effort? 600
601
Michael Harvey: Well that’s the problem because the other Michael Harvey’s in the state aren’t necessarily doing it this way 602
because the other Michael Harvey’s of the state don’t answer to the County Attorneys for Orange County. Orange County’s 603
legal advice is to say you need to fix our table permitted uses to make sure we don’t find ourselves in a predicament where 604
we’re going to get sued and lose because of Byrd v. Franklin. 605
606
Lydia Wegman: But it was a State Supreme Court decision, so it applies statewide but each County is responding in its own 607
fashion. 608
609
Craig Benedict: Everybody has a different opinion of what uses they would want in their area and what would be prohibited. 610
When I worked in Florida I used a rendition of the previous NAICS called the standard industrial code classification. I used 611
major categories in there, I didn’t list it but it was just better, it was organized to talk about manufacturing and assembling and 612
distribution and warehousing. It seemed to have some organization and we listed as many prohibited uses as we could think 613
of, but things changed over time. 614
615
Tony Blake: I think the minute you include the NAICS numbers you’re opening yourself to anything you leave out. 616
617
Michael Harvey: Yeah, and I think some of the direction I’ve received is to take the NAICS numbers out. They’re here to give 618
you a reference point right now. 619
620
Craig Benedict: We may use our own numbering. 621
622
Tony Blake: Well your own numbering would be useful if it was in a separate column and it could be from a data perspective. If 623
it’s an individual index it could make data indexing faster, it could make organization faster when it’s electronic. 624
625
Lydia Wegman: Just going back to the governmental uses, there doesn’t seem to be much benefit to the NAICS code in that 626
instance. 627
628
Paul Guthrie: What is your deadline to get this done? 629
630
Michael Harvey: Well you all are going to be reviewing it in June or July for recommendation with a public hearing in 631
September. 632
633
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Lydia Wegman: But you did say we might have other ORC discussions? 634
635
Michael Harvey: Well there are going to be a lot of ORC discussions. You’re cited to do a minimum of at least one more. I’m 636
probably thinking there will be one more after that so you guys are going to see this in a couple different f ormats. I’ve kept 637
manufacturing, assembly, and processing consistent with the work you’ve already done that begins on page 51. There was no 638
reason to change that. I thought the work you all did with Perdita and the work she did needed to be preserved. So that is 639
incorporated verbatim from what you’ve already seen, and done, and played with. Let me ask you a question as we get to 640
page 57. Medical uses. We currently break down medical uses really to health services over 10,000, health services under 641
10,000. I don’t see a reason to have an arbitrary square footage limit because I can actually think of several health services at 642
9,000, 8,000, 7,000 square feet that would probably be something you don’t want in several districts, and some let’s say at 643
2,000, 3,000 you may want to allow in more prevalent locations. So if you’re comfortable I’m going to abandon the square 644
footage issue and just list out what I consider health services using some of the makes, physicians’ officers and the likes. Are 645
you all ok with that for the next draft? 646
647
Unanimous approval. 648
649
Tony Blake: What about page 62? I keep hearing people float the idea of some sort of a, for lack of a better comparison, wolf 650
trap type thing around here. Smaller but it’s an outdoor performing arts summer theatre type of thing. Is that intended to be 651
covered under this? 652
653
Michael Harvey: I’m sure it will be. 654
655
Lisa Stuckey: So the fact that we allow no performing arts… 656
657
Michael Harvey: Well this is just the list, one of the reasons is I haven’t figured out what I want to do with some of this yet. But 658
to answer Tony’s question about recreation uses from that standpoint, I think part of my answer to you Tony is going to be if 659
you’re proposing and we currently haven’t defined a recreational facility that is a wolf trap-esque it would be a Class B SUP. 660
661
Michael Harvey: So utilities… One of the concerns that I am working with on utilities is trying to figure out what State law does 662
and does not let me do. Current code says that for you to have a utility distribution line over a certain wattage or pressure in 663
terms of gas, you have to get a SUP. There is some thought that State utilities commission actually trumps what we can or 664
can’t do because they’re saying PSNC, UPiedmont have an obligation to provide a service, you have to get it in. Well the SUP 665
was denied. Well who is Orange County, or Chapel Hill, or Durham to tell you that you can’t install a mandated state utility? 666
667
Tony Blake: They won’t let you… There are grid requirements that would trump you. 668
669
Paul Guthrie: That case is going to get fully aired as they build a new pipeline through Eastern North Carolina. 670
671
Michael Harvey: The regional pipeline issue going through Virginia, North Carolina I think actually bears some scrutiny 672
whereas the PSNC Pipeline that went through Orange County that provides service to County residents and handles outside 673
County, it’s part of their distribution line. I think it’s a better argument for that one to say why are you requiring this to have a 674
SUP when you have to approve it? Because what PSNC argued during their SUP hearing was, “We’re a public necessity” and 675
there was some truth. Now they still went through the process, they didn’t sue me; they went through the process… 676
677
Paul Guthrie: And then sold themselves out to Duke Power. 678
679
Michael Harvey: Yes, and then we had a really ugly public hearing. It was not pretty, but the SUP was approved. So you’re 680
going to be hearing more about utilities as we move forward from that standpoint. I wanted to at least call your attention to why 681
there may be a change. Wholesale trade, again, we’ve just provided you the breakdown to show you the level of detail. And I 682
think I have sufficient direction to get you to phase 2. 683
684
Michael Harvey: You’ll see this in March. Now what I’ll do for you to get you something in either a table or an Excel format that 685
will make it a little easier for you to search electronically, which we can do. It’ll take me some time to figure out. 686
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687
688
Lydia Wegman closed the meeting. 689
690
691
692
___________________________________ 693
Lydia Wegman, Chair 694