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# Special Planning Commission Meeting and Planning Commission Work Session - September 19, 2024

> Auto-transcribed civic record · Commission · September 19, 2024

- **Permalink**: https://meetings.lexingtonky.news/meeting/6221
- **Source video**: https://lfucg.granicus.com/player/clip/6221?view_id=14&redirect=true
- **Date**: 2024-09-19
- **Body**: Commission
- **Last revised**: March 29, 2026
- **Length**: 17,413 words

> ⚠️ **Auto-generated content.** Audio from the official Granicus video was auto-transcribed by OpenAI Whisper-1, with speaker labels folded in from Granicus closed-captioning. Structured facts were extracted with GPT-4o; the narrative summary was written by Anthropic Claude Sonnet. Speaker labels and verbatim wording may contain errors. See [methodology](https://meetings.lexingtonky.news/about/methodology) or [report a correction](mailto:editor@lexingtonky.news).

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## Meeting Overview

The Urban County Planning Commission convened on September 19, 2024, at 1:30 PM in the 3rd Floor Conference Room of the Phoenix Building at 101 E. Vine Street in Lexington, Kentucky. The commission addressed four agenda items during the session, including one action item and three informational presentations. The commission took two votes during the meeting and heard no public comments.

The primary business item involved addressing a Planning Commission vacancy, which received approval from the commission members. The remaining agenda focused on informational updates covering municipal stormwater management and comprehensive planning initiatives. Staff provided the MS4 Annual Update, detailing the city's compliance with federal stormwater regulations. Additionally, commissioners received presentations on the UGMP Regulatory Framework and the UGM ZOTA and UGMP Comprehensive Plan Update, both related to ongoing urban growth management and zoning ordinance revisions.

The meeting served primarily as an informational session to keep commissioners updated on various planning and regulatory matters affecting Lexington-Fayette County's development and environmental compliance requirements.

## Votes and Decisions

The Commission took two votes during the September 19, 2024 meeting, both related to filling a vacancy on the Planning Commission.

**Motion to Enter Closed Session** [timestamp: 00:30]
Mr. Wilson made a motion to go into closed session for the purpose of a discussion that might lead to the appointment of a planning commission member. The motion passed unanimously by voice vote, with no second recorded.

**Appointment to Planning Commission** [timestamp: 02:00]
Following the closed session discussion, Mr. Owens made a motion to approve Frank Penn to fill the vacancy on the Planning Commission. The motion was seconded by Mr. Jones and passed by voice vote with no opposition recorded.

Both votes were conducted by voice vote rather than formal roll call, so individual member votes were not recorded in the meeting record.

## Appointments

The Commission made one appointment during the September 19, 2024 meeting.

• **Frank Penn** was appointed to the Planning Commission.

The appointment was processed as part of the Commission's regular business to fill vacant positions on city boards and commissions.

## Planning Commission Vacancy

[timestamp: 02:00] The Planning Commission addressed a vacancy that needed to be filled for a term ending July 1, 2028. The discussion involved consideration of appointing a new member to serve on the commission.

During the proceedings, several commissioners participated in the discussion, including Mr. Wilson, Mr. Owens, and Mr. Jones. The commissioners reviewed the application and qualifications of the candidate under consideration.

Frank Penn was presented as the candidate to fill the vacant position on the Planning Commission. The commissioners discussed his background and suitability for the role during their deliberations.

Following their review and discussion of the appointment, the Planning Commission voted to approve Frank Penn's appointment to fill the vacancy. Penn will serve a term that runs through July 1, 2028, completing the remainder of the vacant position's term.

The appointment was successfully approved, allowing the Planning Commission to return to full membership with Penn's addition to the board.

## MS4 Annual Update

[timestamp: 03:00]

Bailee Young from the Division of Water Quality presented the annual update on the Municipal Separate Storm Sewer System (MS4) program to the Commission. The presentation focused on the program's inspection activities and compliance efforts related to stormwater quality management.

Young provided an overview of the MS4 program's regulatory framework and its role in protecting water quality by managing stormwater runoff from municipal storm sewer systems. The update covered inspection protocols and compliance monitoring activities conducted throughout the reporting period.

The presentation addressed how the Division of Water Quality works with municipalities and other entities to ensure adherence to MS4 permit requirements. Young discussed the program's approach to evaluating stormwater management practices and identifying areas where improvements may be needed to protect water resources.

The update served as an informational briefing for Commissioners, providing insight into the ongoing efforts to maintain stormwater quality standards across the state's municipal storm sewer systems. The MS4 program represents a key component of North Carolina's broader water quality protection strategy, requiring covered entities to implement measures that reduce pollutants in stormwater discharge.

No formal action was required on this agenda item, as it was presented for informational purposes to keep the Commission informed about the program's activities and compliance status.

## UGMP Regulatory Framework

[timestamp: 04:00]

Caleb Racinot from TSW Design presented information on potential regulatory standards for implementing the Urban Growth Boundary Master Plan (UGMP). The presentation focused on establishing appropriate regulatory frameworks to guide development within the urban growth boundary.

Racinot discussed the balance between flexibility and specificity in zoning and planning regulations for the UGMP implementation. The presentation addressed how regulatory standards could be structured to support the master plan's objectives while providing clear guidance for future development projects.

The discussion centered on creating regulatory frameworks that would effectively implement the Urban Growth Boundary Master Plan's vision and goals. TSW Design's analysis examined various approaches to zoning and planning regulations that could accommodate the master plan's requirements.

This was an informational presentation with no formal action taken by the Commission. The discussion provided background information on regulatory considerations for the UGMP implementation process.

## UGM ZOTA and UGMP Comprehensive Plan Update

[timestamp: 05:00] Hal Baillie from Long Range Planning presented updates on the UGM ZOTA (Urban Growth Management Zone of Transition Amendment) and UGMP (Urban Growth Management Plan) Comprehensive Plan to the Commission.

Baillie's presentation focused on proposed changes to zoning and planning policies designed to better align with the master plan. The updates represent ongoing efforts to coordinate zoning regulations with comprehensive planning objectives in the urban growth management areas.

The presentation was informational in nature, providing commissioners with an overview of the current status of these planning initiatives and the proposed modifications being considered. The discussion centered on how the zoning amendments and comprehensive plan updates would work together to implement the community's long-term vision for development and growth management.

This agenda item served as a briefing for the Commission, allowing members to stay informed about the progress of these significant planning documents that will guide future development decisions in the jurisdiction's urban growth areas.

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## Decisions

- **Motion** — passed (0-0): Motion to go into closed session for the purpose of a discussion that might lead to the appointment of a planning commission member.
- **Motion** — passed (0-0): Motion to approve Frank Penn to fill the vacancy on the Planning Commission.

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## Full transcript

We have a motion on the floor the school is meeting order is one thirty September nineteenth welcome to the urban county planning commission meeting. First on the agenda we have the planning commission vacancy seat was worth yeah Mr chair I'd like to move pursuant to care is sixty one dot eight one oh one F. that we go into closed session for the purpose of a discussion that might lead to the appointment of a planning commission member okay we have a motion on the floor the school is meeting order is one September nineteenth by Mr Wilson- any further discussion to that motion. Okay we're going upstairs. I don't think we need to but we need a full vote. All right all in favor please raise your right hand. Are unanimous thank you. Mr chair Mr chair- members if you all would just head up to the seventh floor to the second floor. Mr chair one vote. One vote. Okay all in favor please raise your right hand. Are you unanimous. Okay with that motion. I'll move forward to the next item. 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Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. Diolch am wylio'r fideo. So I need a motion to bring us back into. Live session come out of the executive. Okay all right. Welcome back everyone. Floor is open for a motion for the planning commission vacancy. We need a vote to come back. All right. Why did you bring? I'm 12. I know. We talked about that. And how did you identify the person who was calling you? What's the opportunity? Yeah, we both did. No, I haven't. We did. We did. Yeah, wait for me. Oh, okay. All right. Oh, boy. Where have you been, man?  All right. Mr. Wilson, you need a moment? Mr. Owens? Yes, sir. The floor is open for a motion if you... After much discussion in our closed session with a variety of applicants for vacancy on the Planning Commission, I'll move to approve Frank Penn to fill the vacancy. Okay, decomposition and we have a second. My Mr. Jones has any further discussion to that motion? All right, all in favor, please? Aye. Aye. Aye. Any opposed? None opposed. All right. Thank you. So that put us now on the real agenda. This is the real agenda. MS for annual update. Mr. Chair, I'm sorry. Can you actually adjourn this meeting? Okay. Yes. This meeting is adjourned. And now that I put us on the Planning Commission work session. Okay, agenda item number one, Bailey Young, MS for annual update, Division of Water Quality. And Mr. Chair, just to punctuate while Bailey's coming up, you all do get credit for this training for this session for training. So that's why we were passing around a clipboard for your signature. We'll make sure and log that in your training log today. Thank you. Okay, I'm going to talk about MS for stormwater quality, and the focus of our talk is going to be on inspections that are covered within the MS for umbrella. And so the MS for program has 10 program elements, and the five in the box include inspections. And so those are illicit discharge detection and elimination, construction site stormwater runoff control, post construction stormwater management, pollution prevention for municipal ops, and industrial facility stormwater pollution prevention. And the departments responsible for those inspections include compliance and monitoring, MS for and sewer line maintenance, and environmental services. And so within compliance and monitoring, there's 13 staff responsible for inspections with MS for, we have three staff. With sewer line maintenance, there's seven people that do inspections. And with environmental services, there's one. So that's 24 people making up all of our inspections for each year. And the inspections are part of our permit requirements. And so with illicit discharge detection and elimination, we're looking for eliminating illicit connections and improper disposal of waste into the storm sewer system. And determining the types and sources of the illicit discharges entering the system. So in order to do that, the guys go out, and we had 187 investigations performed in 2023. And so they go and try to find the source of the pollutant and what parameters exceeded. And so this is what the form looks like that they fill out to record what they found. And they receive notifications through Lex call, dry weather screening, and other departments. And they go out and they research the storm sewer in the area. And they sample the discharge. They identify which parameters are being exceeded and find the source and responsible party. They stop the discharge and do cleanup, close the investigation, and then record their results. So common exceedances are chlorine, fluoride, E. coli. And so common sources for chlorine and fluoride is obviously potable water, which is accompanied by the chlorine odor, increased flow, muddiness, and then E. coli is an indicator of sewage. So high ammonia values, odor, bacterial growth, white gray color, sanitary debris. And this chart shows all All the inspections performed in 2023 under each category. So for the first one we just discussed, there were 187. And IDD also covers major outfalls, so they go out and they screen if there's flow or just physical appearance of outfalls that are 36 inches in diameter or greater, or if it's zoned industrial, that would be 12 inches or greater. And the permit requires that 20 percent of them are screened each year. This is what the assessment looks like for the inspection, and it's looking at physical indicators such as outfall damage, deposits and stains, abnormal vegetation, benthic growth, odor, color, turbidity. And then they if there's flow in the outfall, they test it for chlorine, fluoride, ammonia, detergents, pH, temperature, total dissolved solids. And there were 244 outfalls screened last year. We also have inspectors go out and do erosion and sediment control inspections on construction sites, and those include commercial properties, residential subdivisions, home lots, capital projects, demolition projects, and anytime there's complaints. And those sites are inspected monthly unless they're targeted sites where they're disturbing five acres or more or they require 404 or 401 permits. And the inspectors use the same LDP form that is issued for self-inspection. So it's this form, and so it is looking at whether stormwater pipe inlets and curb drop boxes are protected from debris entering them. So you can see in the photo on the left, there's like rock bags that are allowing the water to filter, and then the photos on the right have nothing to protect the inlets. So the debris is allowed to enter the system. They also check to see if there's a 50-foot buffer strip between the stream and the construction activity. So you can see in the photo on the right, there's not. The stream's right there, and construction activity is occurring. But on the left, vegetation has been established. They review silt fences. So the photo on the right, you can see that the debris is allowed to overtop. And you can see the effects of that in the stream in the picture below. But on the left, the silt fences are installed properly and trenched in. They check for construction access. So the photo on the right, you can see dirt and debris is pulled out into the street. But the photo on the left, they have aggregate base so that they're not tracking their dirt. And they're eliminating it from entering the system. And so enforcement for construction sites look first like informal notice, and then a notice of violation, and then a citation, an administrative order, a stop work order, or a permit block, followed by a criminal prosecution. And there were 5,412 active construction sites inspected last year, and 423 targeted. We, yes. Can you tell us what the trend has been? Are we getting better in terms of compliance? I'm not sure. I've been here six months, so I don't know a trend. But maybe next year. I think it's overall getting better, but like with anything, you know, there's good days and bad days. But generally, I think the trend is better. And most of us from developers, builders, and contractors are on board with things. And if you notice an issue, they correct it right away. Most of the developers, builders, and contractors are pretty much on board. And if our inspectors see something and bring it up to them, they'll correct it in short order. So I think if you looked at an overall trend, we're probably getting better that we're issuing fewer violations and citations over the years. We also are MS4 group inspects post-construction. So that includes detention basins, retention ponds, private water quality control devices, underground detention basins, and critical culverts. And those are all inspected at different frequencies. So detention ponds are semi-annually. Retention ponds are quarterly. Water quality control devices are annually, and undergrounds are annually. And this is what we use to chart them. So the one on the left is January of 2023, and the one on the right is December. And so the orange shows lack and like what hasn't been done yet, and the blue shows it being filled up and that all inspections were completed by the required frequency. And the images below is rainfall totals for the month. So this is what a condition assessment looks like for a basin. And so they're looking for if there's structural damage to the embankment, how the outfall looks, if there's erosion. And so if there are issues, first a warning letter goes out to the property owner, followed by a notice of violation, and there's always follow-up inspection. And then if the issue isn't resolved, another notice of violation would go out, followed by more follow-up inspection. And then if still things were unresolved, enforcement would go out. Some of our basins are on LFUCG property. And so if there's an issue or something needs to be fixed, we fill out a unit price contract form, and our contractors go out and fix the issue. And then we record the date that compliance is achieved. So you can see the detention basin on the left. There's bare soil, and it's able to enter into the storm system. And then the one on the right looks good. Here's some inlet filters. And so the one on the left is really filled up, and they went out and cleaned it. Here's a rain garden that's filled with invasives that needs to be cleaned out. And so you can see on the right, it's been cleared. And so there's a lot of inspections done in post-construction. And then critical drainage culverts are inspected. And they're inspected at least monthly, and they're also inspected after a one-inch rain event that happens within a calendar day. And so this is what they look like. They are prone to get filled with debris, and so that's why they're critical and why we inspect them each month. And 731 inspections were performed on those within 2023. And then municipal operations is another permit element. And so within that, we inspect 96 LFUCG water quality control devices quarterly. And then we also inspect municipal waste facilities once per year, and then we go above and beyond the permit and inspect municipal facilities with a SWIP. And there's 50 of those. And those include fleet services, streets and roads, DES operations area, pools, golf courses, parks. And the table on the right shows a snip of some of our city-owned BMPs. So those include rain gardens, water quality features, wetlands, stuff like that. And so this shows what we're looking at. We define the type of the BMP, if it's functioning as designed or not, if there's any compliance issues, what the condition is. And then DES and Sarah Donaldson goes out and she inspects all the waste facilities. And so she makes inspection forms that are tailored to each waste facility, so they're varied. And then she sends out a letter that accompanies that with any issues that need to be resolved. And so this is the municipal recycling facility, and so she just commented that some of the plastic was getting out of the bales, which was near a storm drain. And so she asked them to keep an eye on that and fix that issue. And so with water quality control devices, we inspected 384 in 23, and we did the 54 annual municipal facility inspections. And then the last one is industrial facilities. So compliance and monitoring inspects them, and the permit requires at least 90% of the high-risk commercial facilities to be inspected each permit cycle. And so a high-risk facility has the potential to discharge stormwater-containing pollutants into the storm system, and so that could be horse and livestock facilities. It could be operation centers, outdoor storage and fabrication services. And so you can see the map on the right. The red dots are industrial, and the yellow triangles are high-risk. And for the industrial facilities, we inspect at least 70% of those once every two years. So this is the list of facilities in Lexington. And for the industrial inspections, we're reviewing stormwater BMPs, waste management, materials management, equipment and vehicle O&M plans, secondary containment for fuel, parking lot and other drainage areas and drainage systems. And we're checking them for litter and debris, if the waste is contained and covered, if leachable materials are covered, and if spill kits are available. We also look and make sure that there's secondary containment for fuel tanks. And so this is what the form looks like. It lists off pollutants of concern, whether the structural and non-structural BMPs are appropriate and look good. And there were 33 of those inspected last year. And so that brings our total to 12,151 over the course of 2023 with the 24 staff. And that's all. Any questions? Do we have any questions? Ms. Young. Thank you. Thanks. All right. Next up, agenda item number two, UGMP regulatory framework. Ms. Caleb and Caleb, do you mind pronouncing your last name for me? Yeah. It's incorrect on your agenda, it's Rosico. Oh. So a bit easier to say, but not much easier. Thank you. Yes, French. Perfect. Well, thank you very much for giving me the opportunity to be here this afternoon. Again, I'm Caleb Rosico with TSW. Let me figure out how to run this. Okay, great. And we are here today to talk about the potential regulatory standards that would implement the Urban Growth Boundary Master Plan work that Sam Castro of TSW's Lexington office has been running for the city and county. And before I do that, I wanted to give a little bit of background on the process for those members of the planning commission who are not fully aware of what we're going to be talking about today. The first thing that we wanted to do was to help the city of Lexington come up with a series of potential regulations that would accommodate and support the vision that was coming out of the Unified Growth Master Plan areas. Additionally, as part of that, we wanted to make sure that we recognize that these areas are going to be an extremely long-term build-out. And so everything that's been done in the master plan, all the drawings that you've seen, they may work today or they may work conceptually today, but this is going to be a very, very long-term endeavor for the city. And so we wanted to build in flexibility where appropriate and more specificity where appropriate. And then finally, we wanted to make sure that whatever we put together was in such a way that it would be easy for the city staff to administer. So we focused very heavily on making sure that the language was clear, user-friendly, and something that, you know, everyone can understand. Give me a second here. I'm going to pull this up so I don't have to look in both directions. Okay, here we go. Additionally, I wanted to tell you a little bit about our methodology, how a guy based in Atlanta, for better or worse, can help give the city of Lexington some standards that we think will be appropriate as this very important, very critical process moves forward. The first thing that we tried to do was we tried to look at these master plans and look at the public input received, and where something was quantifiable, meaning where it was drawn a certain way or where there had been public conversations a certain way, we wanted to give a standard that would support that very specifically defined quantifiable standard. Additionally, however, there was a lot that is in the master plan document and that is in the community feedback that we've received that isn't quite as black and white, isn't quite as quantifiable, and so these were areas where we really had to say, okay, based on what we're hearing from people, based on what is in the plan, these are sort of best practices, if you will, within the framework of Lexington's existing zoning code and the place builder that we believe would begin to codify that vision, begin to give the city of Lexington something that they can move forward with. Additionally, we've determined very early on that the recommendations that we would give you would really fall into two categories. There's one set of things that are really policies, meaning they're very specific sort of policy aspirations for the urban growth master plan areas that are appropriate for the place builder that the city has, and I believe you have an example of the proposed amendments to that in advance. In front of you. But there were also several provisions that should really eventually be codified in the city's zoning ordinance, so we broke both of those out into two categories. In the handout you have the category on the left is a policy recommendation, and the category on the right in the table is the actual potential language to the code that would implement it. And then finally, we knew that there were things that were absolutely fundamental to achieving the vision of the UGMPs, and we called those primary recommendations. So these are the things that in our professional best practice and our professional recommendation have to happen or really should happen in order to ensure that vision that's come out of the process is achieved. The secondary or the supporting recommendations are things that really would be nice. They may not be as critical, but they'll help the regulations and help the policy support that vision even stronger. So again, you've got policies, you've got code changes, and then your recommendations are broken into primary recommendations, which are the priority, supporting recommendations, which are the second priority. So with that said, we've also divided the recommendations into a couple of different categories, really for our internal use and for the city's internal use. The first thing I'm going to talk about today as I walk through all of these are regulating plans. Those are basically the types of maps that will be adopted for the areas. We're then going to talk about density and land use. We're going to talk about circulation. We're going to talk about open space, which we know is very important. Building design, and then a couple of very specific use provisions. After that, we also have a couple of other recommendations related to additional use standards that may have application, potential application in other parts of the city, if that is where the city chooses to go. Subdivision amendments that would need to support the vision, and then finally, a couple of ideas for changing zoning districts. So primary recommendations. The heart of everything that I'm about to talk to this afternoon is based on a desire to codify the plans that were developed as part of the UGMP process. So when you have a chance to review that document, when it's released, you'll see that there are beautiful renderings showing what these various five urban expansion areas might look like. Those plans are very, very detailed, but they're very conceptual, and I cannot emphasize this enough. These drawings were things that our planning team put on paper based on the public feedback we've received, but we all know that whenever a public policy document occurs, nothing ever looks exactly like the plans. You'll have individual developers coming in. You'll have different market conditions coming in. So we used these as a framework, as sort of a vision, but in some ways, they're too detailed for actually codification purposes. So the second thing you'll see is what we're calling a regulating plan. We've basically taken those very general ideas, and we've distilled them down into the things that are most central to achieving the vision of the UGMP. They're detailed, meaning they show things like different land uses, which I'll talk about in a moment. They show things like streets and parks and open spaces, but they're intentionally conceptual. You know, we all know that when, in any area, when a developer comes in and proposes a project, they may have a certain way that they want to lay it out that may be different from this. And so what we've tried to do is distill down the main components, provide specificity where we need it, and flexibility where we do not. So in terms of how the city could use these regulating plan maps, they show things like land use, which is flexible for the most part. They show things like densities, which are a range that would have to be achieved. They show things like street locations, again, which are flexible for the most part, paths and open spaces. So when you look at the document before you, you'll see that every one of these five areas has a regulating plan. And as I just alluded to, there would be varying degrees of compliance recommended for all of these. So after working very closely with staff, after reviewing the public comments, we recommend that there are three areas that are really critical that should not be disregarded ever as these urban growth boundary master plan areas are built out. And those are the locations of the critical mixed use and town center land uses. These are shown in purple on the map. These are areas that are intended to be the focal point of what are basically new walkable neighborhoods, walkable villages, walkable towns. They're intended to provide both housing and commercial uses in a, you know, in some way similar to the historic urbanism found in older parts of Lexington. And we feel very strongly that providing those kind of land uses is critical to the effective build out of the UGM piece. It is something that is so critical in our minds, and so we've recommended that those must be provided in the approximate location shown. The other thing that's really critical is there are regional, if you will, street connections that really have to occur. So that as these properties build out, we assure that they're not funneling all the traffic onto the same corridors. And so the plans designate two street types, one called boulevard, and one called path, and one called avenues. These are the major roadway connections between developments that will ensure that as these areas build out, that we don't create more traffic problems, that we ensure multiple ways to get around in the developments. And then there's also paths that are shown on here. So we're recommending that those three kind of transportation facilities are in the approximate location shown. And then the final thing that's really critical, if you look at the last round of urban growth master plan expansions, is they didn't always build in provisions for future connectivity into the adjacent areas. And so there are a series of recommendations showing where future connections might occur. Such that in 20, 30, 40, 50 years, if Lexington ever decides that they want to move the boundaries again, these developments will be able to connect to future developments and achieve the walkability benefits, the traffic benefits, the bicycle benefits, the transit benefits of interconnectivity. So those three things, town center land use, major circulation, and major connections are recommended to be per the plan. A lot of the rest is purely conceptual. So all of the other land uses, we're recommending that those could be provided as development occurs. Obviously, there would be documentation in the place builder to make sure that they are a minimum acceptable density. Again, part of the idea here is to make sure that these urban growth master plan areas are well planned, walkable, and quite frankly, relatively dense so that they can absorb growth for much longer than we've seen in the last round. And so that minimum density, which is defined in all of the land uses and defined in the place builder, is really critical to doing that. And so you'll see that every one of the land uses in this document are defined. We have everything going from low density residential, which is really about 8 to 12 units an acre. This is primarily detached houses, but not exclusively. There could be things like townhouses, cottage housing, even some potential multi-family within those areas. We've got a slightly more intense category, which would be more of a mixed housing type with single family, townhomes, small apartment buildings. There is a higher density category at 25 to 30 units an acre. Again, primarily multi-family, but you could even begin to have commercial uses in some of these. And then finally, you have the village center defined, the town center. And then very interestingly, there's a category we're recommending called flex space, which is a category for areas that may have perhaps light industrial uses, or mix of light industrial uses and recreation uses, or a sporting facility. Really everything else that is in the master plan, but is not a low to medium to high residential use, or a mixed use category. So those are sort of the land use categories that are proposed. The other thing that I wanted to mention now, now that we've gone through that, is I stated before that development would have to provide the walkable mixed use village centers or town centers. But they don't have to provide them exactly where is shown in the master plan. Again, we know that there needs to be some flexibility. So the proposed language before you in place builder would grant the city the ability to, and the developer the ability to move them a little bit. So as a project comes in, staff can work with developers as part of the rezoning process and make sure that they provide a town center, but it might shift 200 feet in one direction. But what's really critical here is the town centers and the village centers would also have to always line up with that major transportation facility that I mentioned before. So they would have to be on an existing arterial street abutting the property, or they would have to be on a boulevard or an avenue. The second part of the regulating plan language is that there is a provision in there for a temporary 100 foot buffer adjacent to the rural service area. This would, again, apply along the edge. It is shown in all of the graphics, but we envision this as being temporary so that if, again, 20, 30, 40 years, if the boundary ever moves out further, there could be some seamless connectivity between these areas and any future areas. So that was the regulating plan. Again, it's a map. It is regulating with regard to town center and village center locations, street types and paths, and connectivity, but everything else, there's quite a bit of flexibility. The second part of the document before you is about density and land use. And so here, our goal was to make sure that as projects come before the city for rezoning, we want to make sure that developers actually build them out in a way that they're more than just the same old product that they're used to building. So there are a couple of what are called concurrency requirements in the draft. The first one is to limit the amount of single family homes that can be built without providing commercial uses. So as drafted, a development could build up to 20% of the proposed single family uses. But beyond that, they have to have some commercial uses. Again, we want to make sure that as these areas build out, they're walkable, they're more neighborhoods than just being subdivisions. And part of neighborhoods is having services within them. There is also an acknowledgement that some of these areas may be much more commercial intense in the coming years. And so there is also a commercial concurrency requirement recommended. We're recommending that no more than 80,000 square feet of commercial, and that's basically a grocery store with some out parcels, should be allowed to occur. And over 80,000, you would have to have a portion of residential uses in the plan actually built. And we put both of these provisions in there, because I am a former public sector employee, and I know that developers love to come in and get plans approved. And say they're going to build these cool centers, and they're going to be walkable and mixed use. And then they only build the housing, and they only build the retail. So this is a way for the city to ensure that before the city can issue building permits above those thresholds for other uses, you've got to have that mix in place. And we wanted to write those provisions in such a way that we acknowledge that the meaning of commercial doesn't quite have to be as strict as most of us intuitively think in our minds. So we have allowed, or we have recommended allowing things like live work units, which are basically a town home where you have a ground floor commercial space and you live above, but it's a single town home. We recommend allowing that to count towards the commercial requirements. And we actually recommend allowing developers to count what I'm calling retail ready space to the commercial requirement. Such that, imagine an apartment developer coming in. And their sort of way of building is to build 300 apartments in a go. This would allow them, again with rezoning approval, to build the apartments. But they would have to provide space on the ground floor that can convert to retail. It doesn't have to be retail today, because there may not be market for retail today in all of those locations. But it's designed with ceiling height and glass and flexibility so that at some point it can convert use as the market changes. There are also a couple of other recommendations related to the mix of residential uses within the development. When you looked at the plans that were done, you'll see that there was a very fine grained mix of residential uses distributed throughout, even in the low density residential areas. You didn't just have a cluster of townhomes and a cluster of single family and a cluster of apartments. They were all connected, they were all integrated, and they were all basically part of the same community. So we're recommending that in those single family areas, that you have up to five lots of single family, and then you have to throw something different in there. It could be a two family unit, it could be a small walk up, it could be a couple of townhomes. But the idea is to make sure that housing types for different people and different ages and different incomes are distributed throughout the development, not isolated in one area. Also recommending a limit on the amount of what I'll call large lots, single family lots, those over 5,000 square feet, to 20% of the development. That would not, of course, replace any density requirements. And we talked before about how every one of these zones has a density requirement. And there would be a concurrency requirement, such that developers can only build about a quarter of the single family units. Before they have to build other uses. So you can imagine a developer plotting a site, they really, really, really don't want to build any townhomes, or any walk ups, or any two family. So they lay out five single family lots here, and five there, and five there, and five there. As a way to get around the above provisions. But this says that once they reach more than 25% of the total number shown in the plan, they have to provide alternative housing types, even if it doesn't meet one of the above. Okay, now for the easier parts. Circulation is the third part of your document. Circulation has provisions that would allow the major streets, meaning the arterials and the avenue, I'm sorry, the boulevards and the avenues to move up to 200 feet from the location shown in the plan. Again, you've got to build in a little bit of flexibility. The street designs would have to be per the forthcoming complete street manual. And I can't emphasize this enough. We are attempting to codify, again, a walkable mixed use development pattern. That is very different from a lot of the recent growth that has occurred in Lexington. And in order to do that, you also have to think about the design of roadways. And so, very, very strong policy recommendation for some flexibility in that complete street process. Additionally, paths would have to conform to the Lexington Path Bike Pet Plan. We have put in place some standards to limit the number of driveways across paths to one per maximum 300 feet or minimum 300 feet. And we've also recommended limitations on the number of curb cuts. Again, one per block face in those more dense walkable areas. We don't want a situation where this wonderful trail system goes through development and the developer designs it in such a way that you have a driveway every 25 or 30 or 40 feet. That's very unsafe for pedestrians. It's very unsafe, especially for children who may be using these facilities. And we want to make sure that those multi-use trails that tie into your regional trail network are truly safe for all users. And then finally, under circulation, and this is a big one. I've alluded to the idea that all of this new development should be laid out as a town, as a neighborhood, as a place, rather than a collection of subdivisions. And the way we're getting that, in addition to the regulating plan, is we've actually recommended some standards for maximum block sizes. So when you look at the document, you'll see that the first policy provision is to make sure the development connects internally. And it connects to, or it has connections to adjacent developments in the UGMP areas. And then it prescribes a series of maximum block sizes. And these vary from the way the city currently calculates block size. This is an example of one of the sub areas. The numbers range from 2,000 square feet maximum in the more walkable urban areas. 2,000 feet, 2,400 in sort of the less intense areas. And then up to 3,000 in other areas. But the idea there, let me step back for a moment. I cannot go back. Other one. Measurement unit, is that correct? Yeah, great question. So this is done differently. I'm going to get into the weeds now, I apologize. Today, when the city of Lexington measures your block for the purpose of subdivision, they do it only based on the block face. We are recommending that in these areas, so that we don't have a grid iron of every block being 500 by 500 foot square. We're a little bit more flexible, and we measure based on the perimeter. So if you look at this one here, that is probably a 300 foot perimeter on the side adjacent to the white, and then on the side adjacent to the pink. But the other perimeter is longer. And based on our experience, having coded in multiple jurisdictions, done a lot of land plans, we find that regulating based on perimeter gives a little bit more creativity. And it allows properties to better respond to topography without the need to do a lot of grading. So that would be measured based on the center line of the perimeter, okay. The other thing that I wanted to add is in order to meet these block size requirements, there are a couple of caveats. The first thing is that we're recommending that these could be public or private streets. So imagine someone coming in and doing a commercial development, primarily commercial or office or something like that. They may not wish to plat and dedicate the streets to the city, so they could certainly do that as drafted to give a little bit more flexibility. And this is really important if you ever did get any interest in major retail in this area. A lot of times the retail developers just, they want to be able to control the street right in front of the building so they can do other things. So they could be public or private, but they could not be gated. So nothing in here would say that there can't be gated private streets, but they would have to be in addition to these minimum sizes. Additionally, we are recommending limits on the length of cul-de-sacs. Again, cul-de-sacs are highly discouraged, but we know that there are going to be situations where there may be a stream, or there may be a slope, or there may be a historic cemetery, or there may be some unknown extenuating circumstance where everyone in this room would agree that the city should be able to grant relief to that. So we've provided options for those in the code, under exceptions. We've also put in place recommended standards for those future connectivity along the urban service area. Maximum one, minimum one per 2,000 feet of property length. And that could go up to 3,000 feet in more industrial areas, if there ever are industrial areas in these expansions. And then everywhere else, connecting to adjacent properties would be one per 750 feet. And then again, there would be exceptions, like we talked about for environmental situations, creeks, floodplains, etc. There would also be recommended connectivity standards for paths. We're recommending that if a path adjoins a property, the development has to provide at least one non-vehicular connection to that. Again, making sure that the residents of these developments can actually get to the trails safely and easily. And that that connection would have to be at least 12 feet wide. And again, there would be exceptions based on topography. And then the final elements of the transportation and circulation section are less glamorous, but equally as important. We are heavily recommending the use of shared driveways where possible, especially in the commercial areas. We are codifying potential standards for inter-parcel access between the more intense uses. So like the commercial, the multifamily, so the developments, even if they don't have to have a block, they do connect. And again, exceptions for that based on topography and other situations. We are highly recommending the use of alleys. And when we say alleys as in this document, they could be private, they could be public. We really don't get into that level of detail. But the idea is that rather than having a driveway every 25 feet along a street, we could try to put as much in the rear as possible. Now there would be requirements for that along boulevards and arterials for housing types. So those would be in here. There would also be requirements for alleys in the purple and the commercial mixed use village and town centers. There would be requirements for timing of the alleys. Again, I've probably worked for too many developers who like to find loopholes, but we want to make sure that if there's an alley, that they use it. And that they build it, and they don't just build it and then never use it, and use that as justification for bad design. And the idea is that alleys would have to be where the garages are located, and the garages would be placed relatively close to them. And then we do have a couple of recommended changes for bicycle facilities. Bicycling is part of the vision of the UGMP. We have recommended bicycle parking along the shared use paths. So if you've ever cycled, and especially as folks get up in years, they like to have an opportunity to pull over to sit on a bench and rest or watch people. And so there's a recommendation for benches and bicycle parking along the shared use paths, which is new. And then within the developments, we are recommending that there be a minimum bike parking standards. And that is both codified as external and internal. So that you imagine someone doing a 200 unit apartment building. They would have to have bicycle parking inside the building for the occupants. So they couldn't just be out in the parking lot where your bike's going to get rained on and snowed on and rusty in a couple months. We also have recommended a couple of modifications to your loading standards. We do believe on-street loading is really important, especially in the town and village centers. We think that that should be allowed to count to the city standards. We believe that any other, we're recommending that any other loading should be screened, ideally to the side or the rear of the building. And that the amount of loading required should be reduced. Your current loading space requirements are the highest I have ever seen. I've worked on zoning codes in probably over 100 jurisdictions. Would really recommend, at least in the UGMP, you lower them and then allow them to be shared. I think it's really critical. Okay, the other thing that's really important. So if we're going to have a walkable neighborhood and a walkable community, we need to have street trees. This is not an option, especially in Kentucky in the summertime. And so we are highly encouraging the complete streets manual to come up with standards for the placement of street trees. We like to see those between the sidewalk and the curb, but we know that that's not always possible, and especially on higher speed roadways. But as you build out these areas, and if you actually want people to walk, people who have a choice of not walking in the summertime, you need to have street trees. And so there are standards in this document, heavily, heavily, heavily encouraging the city to come up with protocol for that. Okay, the next part of the document is open space. This is a really short one. We're not recommending any changes to the city's current open space requirements, which are typically about 15 to 20% depending on the property. What we are recommending is that if a developer is building housing, and again, we've basically required them to build housing, that they can't put all of the open space on the other end of the property where no one can get to it. So there is a standard that says every door of a dwelling unit must be within 1,500 feet of either a public park or a private open space. Again, this is really important in the vision is to make sure the open space is scattered throughout the community and not, you know, put on the floodplain on the other end of the property where no one can get to it. The next part of the standards, yes, sir? Did you have a comment? No, I'm watching it. Okay, great. The next standard gets into a little bit more like conventional zoning. But again, I've worked with developers. I know they try to find loopholes. This is what we're calling building design. And in here, there are a couple of policies that we believe could build on very strongly the strong basis of regulating buildings that you already have in your zoning code today. And the first one of those, again, I may be paranoid. I have seen too many developments come in and they have the streets, they have the open spaces, they have the mixed use, but then they have blank walls all along the round floor. Imagine a Kroger comes in, a Kroger comes into one of these expansion areas. And rather than putting out parcels along the street, Kroger just puts a three, 400 foot long blank wall across the street. So in order to prevent stuff like that, we are recommending something called active depth. And basically, all this is is a requirement that all buildings have to have 20 feet of space at the ground level that is used for people places. Housing, offices, retail, restaurants, but not parking, but not loading, but not dumpster storage. I mean, we'll have to have that in some places because we want to make sure that, again, these buildings have active uses at the ground floor. Just walk around where we are now and look at the difference between some of the historic urbanism you have, where you do have active uses on the ground floor, and a lot of what sort of the urban renewal stuff from the 70s, 80s, and 90s. It's very different. And if we're trying to create a walkable community, people need to feel safe walking. And one of the great ways they feel safe walking besides having sidewalk and trees is having something to walk next to where they can make a connection with the people inside. So again, this is more of a zoning thing, but it's really important. Now, mind you, we do recommend relief for industrial users. If you land a tenant that everyone wants, industrial users typically do have alternative standards. So this would be for everything other than industrial and single family where they're likely to do it anyway. Okay, and then the other one, drive-throughs. So a lot of conversation in our team, among our team, about how do we handle drive-throughs. And the recommendation before you is actually to allow them, but with a couple of caveats. So the first thing is we are recommending that if drive-throughs come into the UGMP area, they can't be the same old drive-through that everywhere else in the country has received for the last 50 years, which is basically the building, the drive-through that goes around the property, and you may have a window on the side. The standards before you this afternoon would allow drive-throughs, but they'd have to have one of two forms. First, they would have to be completely inside a multi-level parking structure. So if this area ever gets dense enough that we have office buildings or large apartment buildings, they can go inside it. No one can see it. Now we know that that's a very, very long-term prospect. I'm a realist here, right? We know that that's long-term. So we've also said, okay, well, if they're not in that, they can be conventional, if you will, but they have to be completely behind the building, and they have to be completely screened by active depths. So imagine a city block, and again, we're about creating towns and villages and not necessarily subdivisions in the commercial strip development in this plan. As long as they had buildings along the edge, they could have a conventional drive-through in the middle. Yes, sir? You piqued my interest. The indoor drive-through, is there any example now anywhere in the country where anybody's doing that currently? We have required this in the city of Atlanta for about five years in most parts of the city. Yeah, and this is actually a brand new Starbucks that went in, just opened a couple weeks ago. But we have an urban format Starbucks. We have a really cool Chick-fil-A under construction right now, and you know how Chick-fil-A is. They like want the biggest drive-through in the world. We have Dunkin' Donuts that have them inside buildings. So, it's relatively new, but again, it can be provided. I think the second option is more feasible. Just put them in the middle of the block where you can't see them. Okay, so let's see. Almost done, guys, I promise you. Okay, the final part of the UGMP standards are regulating uses. Now again, we mentioned that these areas are going to build out over many, many, many years. But there are certain types of uses that can make or break the kind of development that the stakeholders in Lexington have envisioned for these areas. And those are things like data centers and self-storage. I know data centers are very likely to come here because of the high land values. But we are recommending that if, again, if the city, meaning the elected officials and the stakeholders, agree that they want to allow these uses in there, and they are currently allowed today in your current zoning code, they should be limited to no more than 50% of the development. Meaning, if I'm going to do self-storage, I have to put it at the back of the lot, and I have to have apartments or retail or something like that around it, in order to prevent the sort of self-storage that we just get everywhere. These will be a killer of the kind of community that's been envisioned for these areas. So those are the main recommendations related to the UGMP. There are a couple of really, really brief ones. I've got three more slides that I wanted to run through you. And these are things that we would like to change in the UGMP, but they're really bigger city-wide discussions. The first thing is I would recommend you actually define data center in your zoning code. You do not currently define it today. And that you define commercial self-storage. You do allow them, but you basically lump them in with warehousing. So we definitely recommend that you define those differently. We would also recommend that you think about, again, I'm just thinking of what's happening in other communities, you're seeing a lot of what are called micro-distribution hubs in walkable neighborhoods, these are basically like Amazon stores, where Amazon may come in, they may do some last mile distribution out of it, but they're right on the ground floor of buildings. So that is a kind of use that is becoming more and more popular. If Lexington has not seen them yet, you will be seeing more pressure for them. And they do like to go into walkable areas. So they're almost like an industrial distribution center, but they're really, really low impact. So definitely would recommend looking at that. Related to that is this idea of low-impact manufacturing. This is one of those things that, again, has come out of COVID. A lot of companies are changing from being purely office or purely retail to doing more and more low-impact manufacturing on-site. So we would recommend that you think about allowing some of those uses, very small footprint, very low impact, in some of these mixed-use areas. It's an example of what you're talking about. Yes. So we were, Sam and I were talking earlier. I live in a neighborhood where we actually were a historic district, so we allow this because it's one of the patterns. We have a shop right down there at the corner. It has, it's sort of a hill. The back side that is away from the street is an 8,000-square-foot coffee roaster and packaging plant, so they roast coffee, they package it, and they distribute it from the property. The street level is a coffee shop, so they're two separate uses from zoning. And before, the city of Atlanta, at least, would not allow you to actually roast and make and package and distribute the coffee from anywhere other than an industrial district. And so this would be an example. Another example we see a lot of is 3D printing. A lot of places where 3D printing is actually determined as manufacturing. Furniture makers, dressmakers, you know, a lot of very low-impact uses that you wouldn't think of as industrial that actually are. The big one, though, tends to be food. I mean, and with your rich agricultural history, I could see a lot of food facilities having this. You might have a, again, a restaurant that they have the most amazing salad dressing, and they want to open a place on their property, 2,000 or 3,000 square feet, where they actually bottle the dressing and sell it. It's that kind of thing. Okay. The next recommendation is related to your subdivision. When I was reviewing your draft code, when I was reviewing your current zoning ordinance, I found a potential problem with your requirement that every lot in the city has frontage on a street. That doesn't work for this new cottage housing that you've recently allowed, so you probably want to change that. Additionally, there are a series of provisions in the code where it may be a good idea to provide relief from some of the waivers based, again, on conditions other than the size, shape, and topography in the underlying zoning, and so those are also noted in there. Again, they're not critical for the UGMP. They're just stuff that, you know, when I was looking at your zoning code, wanted to let you know about. And then the final one, which is related to the UGMP, is a big one. So we've talked about sort of being able to legalize the patterns of a lot of the older neighborhoods in Lexington in these newer areas, and your city has a rich tradition of corner stores, and these are currently not allowed in any of your R2, R3, or R4 zoning districts. So we just thought that if you really want to be able to reproduce that, you could think about allowing that either through a site-specific rezoning on some of these properties or for greater flexibility, you could say we're going to allow them by right in certain conditions in this UGMP area. So again, I know that's a big policy decision. It would have city-wide ramifications, but it is one of those things that might be important to look at. And then the other district that we looked at was CN, Commercial Corridor Zone. Notice a couple of weird things in there that I don't think were intentional. The first thing is that you don't allow outdoor sales and storage, which is understandable, but what if someone wants to do a small walkable nursery or garden center? Or, you know, the beautiful place we had lunch today. What is it? Forestry? Kentucky Forestry? Yeah. Kentucky Native Cafe. So that facility, right, that from a zoning perspective, that area where you have the uncovered sale of the plants, I mean, that's technically outdoor storage and sales from a zoning perspective. So the idea is to allow those very low-impact type of uses that are compatible with the patterns. Legal nonconforming, right? Additionally, we would recommend some greater flexibility on things like garden centers and greenhouses. And I promise you all, I had this in here before I went to the cafe. I had the, I sent this to the city a couple weeks ago, the draft. It is very big. So, again, those kind of uses are very compatible. No one's ever complained about having a guy selling flowers next door, or, you know, or a woman. A couple of other things we noticed, the required minimum density in CN is very high. It's 2.0 floor area ratio. You might want to look at lowering that if it's not working over the next couple of years. You might want to also think about lowering the minimum density of 30 units an acre over the next couple of years. And we found a couple of typos in the sustainability bonus standards that we have recommended that staff clean up. So, that concludes my presentation. I know I've talked about a lot, and I've probably talked really fast. But I would love to answer any questions that you may have. Okay, any questions for Caleb? Go ahead, man. Thank you. Caleb, I really appreciate your thoughts on pathways and avoiding driveways, because anytime you're walking with kids, you just pay such close attention every time they cross a driveway, and it's anxiety-ridden. Would you say that the proposed block size that you're considering, would that be consistent with typical block sizes in the early 19th, or I'm sorry, early 18th, early 19th century developments? I'm sorry, early 19th, early 20th? Generally, yeah. They do vary by different parts of the country. You have relatively medium-sized blocks here, so they would be compatible with the block sizes in some of your older neighborhoods. Okay, thank you. Yes, ma'am? This is really a question for staff, but it involves something you just said. In terms of the complete streets model for street trees, how close are we now in the changes we're making to our ordinance to what's in that plan? That manual update is underway with consultants, and I think their timeline is to be finished with that in the next year. Yes, yes. We've been coordinating. I mean, Sam is a sub on that project as well, so the consultants are linked up, and we've had conversations as recently as last week about terminology, making sure those things are compatible, making sure terms carry over. We're a little ahead of them, but there has been a great attempt to make sure that the language we're using here should be very close to what's in that manual, yes. Good presentation, thank you. Thank you, sir. You have listed an enormous number of proposed implementing regulations that include codifying one thing and another. What is the process that you see to get that done? Is that done entirely in-house? Is that something that you will be involved with? So that means we have to triple the planning staff tomorrow? Well, actually, sir, first of all, the way this is set up, the place builder policies that you have before you, those will give the city staff and elected officials the ability to vet projects as they come in immediately upon plan adoption. Now, they may not come in that quickly, but it would give the city to vet them because it becomes an official city policy, and you can tie zoning considerations to that. I wrote those in such a way, I tried to avoid legalese, so hopefully they're more understandable, but I do have a more legalese version that I will be sharing with staff. So basically the amendments are already written. It would just be a situation of saying where they go in the ordinance. And does that become a reactive process? It sounds like you're saying that as things move, then you have to get X, Y, and Z codified to deal with what is being proposed, or is it more proactive where we methodically pick items that we need to get codified? Yeah, Graham, I think in our discussions with Caleb, it's been real important for us to make sure that we take the shalls and put them on sort of what you see on the right, and the shoulds for the policy, and as Hal's gonna go through with the place builder, linking these policy recommendations that you'll see for zone changes into the early preliminary development plans, and that there's still some time between when we likely will see development. There's time for us to take the regulations that are recommended here and begin a ZOTA process as well. There's gonna be a lag before development occurs where we're gonna take these recommendations, sort of triage them, prioritize them, and come back with another round of, like a UGM ZOTA round two. I mean, the first one was a big one, took us a full year to do it, but I think we can do the same with these as well. So I think we'll be back before you with some of that. Thank you. Caleb, very nice, a lot of good information. Thanks, sir. And I didn't mean to interrupt on one second, one moment, but good information that you presented from, I mean, I love the thoughts of alleyways, street trees, open spaces within a certain area. The one thing that I really didn't hear, I saw a picture that looked like there was a parking structure, but then you said something about, you know, not being a parking structure. How do we handle the parking needs without always just doing surface parking? This one, yeah, that is a parking structure in that case. The ability to finance parking structures is something I'm not qualified to speak on, but I will say that they're expensive. I mean, in the Atlanta market, and I would assume here, they can be $50,000 to $70,000 a space. So, you know, we have not changed. There is no parking requirement under the current code. That would continue to apply. I think, and I'll obviously defer to staff on this as well, but I think that it's gonna have to pencil out for the developer in order for them to make it happen. Have you seen anything, anywhere, where to be able to get a parking structure, you give allowances or on something else? Yeah, you can incentivize them in a lot of different ways. We have done work in many different communities, and one of the communities, they gave a density bonus for parking. I mean, that's probably not as much of an issue here. You know, you could, and I hate to recommend this, because this is sort of what are we, what kind of community are we creating, but you could count open space. You know, if your open space requirement was too high, you could count parking towards open space, which I don't like, but again, you could do it. In order for it to work, it has to be economically viable, and even in Atlanta now, with interest rates what they are, people are trying to do surface parking. I mean, other than the prime 100% locations right in town, because it's so expensive. So are they doing, pushing more for alternative modes of transportation, you know, as opposed to car transportation? Yeah, a lot of them are. The other thing, again, this is, I am not speaking for the city in the following remark. You could legally, you can always restrict the amount of land dedicated to physical surface parking if you wanted to, but again, that would be a really, that policy decision would require a lot of conversation, because there are unintended consequences to any regulation, and I know that, for example, Lexington has the same housing crisis that everywhere else does, and if forcing structured parking means that the rent has to be $300 more per month than it would otherwise be, that's something that your elected officials need to determine before it is implemented, because, again, parking is so expensive. Well, I've got you. I understand that we're in kind of catch-22. We've got to provide housing and needs for everybody, but with that, parking comes along with it, so thank you. Thank you. Could you flip just to one of your colorful overlays of one of these proposed areas that you kind of just show your, yeah, any of them is fine like that. Yeah. You know, right now, we're sort of discussing parking, and this was one of the sort of things that jumped out at me, and I think one of the answers is sort of in your code when you talk about the corner store a little bit, but in our older neighborhoods in the sort of, a lot of the commercial parking is street parking, and those corner stores or those mixed uses, those residential side streets have a lot of parking capacity that isn't used entirely by the residences, where we see a lot of the new subdivision sort of neighborhoods are built with the capacity for street parking, but it's essentially unused or very low use, whereas then there's the retail shopping center where all that parking capacity is, so essentially the parking is double built in sort of surface form, and so looking at this, I think this is moving in the right direction, but I do think that this town center concept is still concentrating this parking in these large surface lots and then creating underused spaces in those residential areas, and I think the more that the plan embraces and moves, for example, by allowing by right these corner stores, the more it'll distribute that balance of commercial and residential parking and utilize those street spaces enabling smaller lots basically here. That would be sort of one observation, because I think for me personally, this still has larger lots than I would think of as ideal, and then the other sort of comment that I had has to do with sort of a little bit this sort of reconciling these concepts of where you wanna go with the implementation of applying sort of a mosaic of current zones over the area, and while that, while I expect there are a few members of our development community that are capable of navigating that complexity, I would expect many of them to seek sort of simpler concepts, and so I wanted you to maybe speak to that a little bit, just because that concept of this mosaic of zones on a project seems challenging to actually get some people to implement. Can I ask staff to talk about that? I have some closing remarks regarding the zoning, because we've actually had this discussion internally, because my question is, is it gonna be zoned one thing, and I thought the idea was it would be zoned multiple things, but to your point, how do you allow natural evolution? And mind you, we have basically five colors plus one. You could think of those as five potential zoning districts. I would say that based on what we are recommending, those are all variations of mixed use, a little bit less mixed use in the low-density residential, because it's primarily houses, but it might have other stuff, but by the time you get to the town center, it's fully mixed use, and so can you talk about which districts may achieve that, and how it would apply to a project? So what we have tried to do over the last seven or eight years of text amendments is broaden the commercial zones to accommodate residential in varying formats, and we haven't seen a lot of developers take advantage of that, because you're largely talking about already developed sites with a lot of complex lease issues, and so the redevelopment potential hasn't really happened there, but we have, with the changes to B1 and the changes to B6P, in large part could handle an entire town center, not to mention what we've done with the existing, how some developers have managed to make the MU zones work, notwithstanding its difficulties, but we've tried to take the things that work out of the MU zones and allow them in the B6P, as well as the B1, and so in a lot of these cases, they may not even be residentially zoned at all. It's possible that a big chunk of them could come in under our old B6P or B1. That's been our intention, is to get it to where a town center, village center could be built under one of our commonly used zones. I hope it's not five zones, please. I don't think Tracy wants to deal with application for five zones, and nor do we under Place Builder. We're trying to simplify that is how we'll go into it in the next piece. And I'll just add, with the text amendment that we just went through, we also allowed for that natural or organic development of commercial to occur in residential with the shift with the R4 and the R5 zones to allow for neighborhood businesses to develop over time. So that gives the inverse. We're not just trying to allow for that inclusion of residential and commercial zones. We're allowing for a lesser onerous process to allow for a commercial to be located within residential zones. Other things, Kayla, that are mentioned in here, though, that are things that we had not considered, like the retail-ready ground floors, that's painfully obvious in hindsight, right? Like, you know, it's one of those things where, like, how did we not think of this? Right, some of the drive-through standards, you know, we just got drive-throughs out of B1. Well, if there ends up being enough of an outcry that we have to address that in some way, we have now something to address that. And, Chris, can I mention one thing? The challenge with making anything legal nonconforming, right, is it never goes away. So we've worked in too many communities where they don't want drive-throughs anymore and they don't want gas stations. So what does that mean? Well, the property owner that owns a drive-through, his land doubles or triples in value because he can't get any competition, and if you want that use, you gotta go in that building. So we advocate a more flexible approach that allows them to redevelop, but puts very strong standards on the design because otherwise they will be frozen in amber and they won't go anywhere. Thank you. Okay, look, I think that's all the questions. Thank you for all the work you put in. Thank you so much, everyone. Mr. Bailey, UGM Zoda, UGM P, Comprehensive Plan Update. Yes, thank you very much. So I think this ties very well with what Caleb just presented and going back to Graham's question of, is this a proactive approach? Is this a reactive approach? And since we are going through the process of potentially adopting a new element or component of the comprehensive plan with the UGMP, and since we just went through a major zoning ordinance text amendment, we thought that it was a perfect time to also amend an element of the comprehensive plan, the place builder. So just to go over some of the aspects that we have gone through over the past year and a half or so, we have adopted the UGM zoning ordinance text amendment. This made substantial changes to the ordinance and reflect many of the comments and policies that Caleb presented on and built upon today. In addition to that, we have these recommendations that are being called out within the policy document and some of the regulations that we're seeing in your document in front of you with the place builder that would try to make sure that we are adhering to the policies and standards that are being called for in the master plan. So you can see in front of you, you have the first few pages that I'll discuss, but there are also the maps that we have been talking about that would be included specifically in the place builder, like we utilize the expansion area master plan and the rural land management plan currently in the place builder. So just a refresher, the place builder is our element or a distillation of our goals, objectives and policies from across the entirety of the comprehensive plan and put into a more simple place so that people can review development criteria during the zone change process. In terms of what we are recommending for changes to the place builder, here is what we currently have. What we are recommending is a few different changes on this first page within the downtown, removing the MU2 and the MU3 zones, both of those zones are not heavily used within our community and the incorporation of the CN zone gets at a better utilization of our land and is a better recommendation for those areas. In the second tier urban area or place type, staff is recommending again, adding in that CN zone. These are areas in which we are trying to produce a little bit more density and transportation access, removing the specific form based request with the B1 zone or the neighborhood business zone. We made modifications to that B1 zone with the UGM ZOTA that would allow for the B1 to be more contextually sensitive in those areas and allows for a little bit more development on those sites. And then again, removing those MU zones. For the regional center, staff is recommending adding back in the B3 zone, the corridor business zone. This has not been recommended within the comprehensive plan since 2018 and with the changes that we made to the corridor business zone or the B3 zone, staff believes that it is now time that it should be into our corridor zone. It allows for a little bit more intensity, density and that inclusion of residential activity in that zone. Because that B3 is being added back in, staff is recommending the removal of the B1 zone and then again, the removal of the MU zones or the mixed use zones. In terms of this section of the place builder, staff is recommending several modifications. The corridor zone, again, bringing in that B3 zone. So getting that corridor business on our corridors. That was one of the major pushes for our UGM ZOTA. Adding in the CN zone, that corridor node zone for increased density, housing density, really focusing on densifying our corridors with residential opportunities. And then again, removing our mixed use zones. Our first major change to the place types and then the development types is the new complete neighborhood. With the urban growth master plan, there are areas that are being recommended for low density residential land uses. As such, we think that it would be appropriate that we add back in a low density residential zone or the R2 zone. This was also modified with the urban growth management ZOTA that was approved just recently. So with that, we did have to add in and let's see if I can do this. Yeah, there we go. That low density development type into this section, adding in the R2 zone to allow for that to occur. And then removing some of the other mixed use zones and removing the form-based requirement for this zone. This allows for any of the B1 uses to occur or recommends that any of those B1 uses be allowed within that zone. In terms of the enhanced neighborhood, staff is recommending the removal of the R3 zone and the mixed use zones and then incorporating that R2 zone or the mixed low density residential zone in that area. So replacing the R3, the planned neighborhood residential zone with a mixed low density residential zone. That allows for a little bit more compatible development as well as it allows for the R4 zone to be that next step up and the preference zone for anything that would be a higher density multifamily area. And then we have no changes to what we are looking at for the industrial and production center. Touch on the blue sky real quick. Yes. So we will be looking at blue sky coming up in the future. That would be associated with a small area plan that is planned for this next year. That would allow us to maybe take a little bit of a deeper dive into the industrial and production center place type and some of the uses zones that might be appropriate. For the urban growth master plan, as you heard from Caleb's presentation, that really focuses in on a little bit more of the flex space, looking at light industrial land uses. But for right now, for the land uses that we're seeing with the urban growth master plan, we are focusing more on the residential and then the integration of residential and some mixed use commercial to create walkable neighborhoods. Yes, Ms. Worth. So we're mixing the uses, but are we also, at the same time, moving in the direction of, like we do with the ED zone, where you've got this amount that's job development, this amount's residential. Are we moving in the direction of saying you've gotta have certain percentages? You're jumping ahead of me a little bit. No, that's all right. So one of the aspects of this change to the place builder would be incorporating the policies and the different recommendations of the urban growth master plan that TSW and Caleb have been adding into this document. So you can see many of the headings that are up on the screen, the section one regulating plans, development density and use, all of those are the presentation materials that you heard from Caleb earlier today. So we will be incorporating those into the recommendations. So when you hear a zone change for an area in our potential expansion areas associated with the UGMP, you will also be hearing how an applicant is meeting these different policies. So tying in these areas with specific recommendations that are coming out of that master plan. So, yes. I have a question real quick. Could you just give me an example? Downtown is pretty self-explanatory. Could you describe the second tier urban? Just give me a few examples in our community of what that might be. Yes, so this is not changing from what we're currently using it as. You have actually approved several zone changes utilizing the second tier urban. It's typically the area just outside of the downtown within a walkable distance of the downtown. We typically have a little bit more density and intensity in theirs as we go out of the downtown core. So it has been utilized for several places as we've been going out Midland, along Maxwell, and then up one or two places on the northern side of town. Yes, you're welcome. So I do want to, I copied that already. So just associated with this so that we're not keeping you here too long, I just wanted to give you a heads up on the timing of this. Since this is a blend of a adoption of an urban growth master plan and an amendment to the comprehensive plan, there are actually two overlapping kind of things going on over the next couple of weeks. We are hoping that we would have that first hearing on October 17th. That would be the presentation of the urban growth master plan and a presentation on the amendment of the comprehensive plan, specifically the place builder. So going to Mr. Pohl's question, this is us being proactive to ensure that we are getting the urban growth master plan recommendations into the comprehensive plan so that we make sure that any zone change that comes in in the near term is still meeting those recommendations and is still complying with the other elements of the comprehensive plan. It's in its totality. When it comes to any zoning ordinance text amendments, that would be an implementation item like we do with the comprehensive plan coming out of the urban growth master plan. So these are a little bit more of the timeframes, but I'd be happy to answer any questions you might have. Thank you, Mr. Bailey. How many opportunities will the public have to give us public comment? So the public has been providing comment as they have been seeing this throughout the process. We have been doing a fair amount of outreach to different organizations and different neighborhoods, but we have also been posting these after all of our work sessions. We have a very active public in this, not just from the neighborhood level, but the current owners of those properties. They've been providing a fair amount of feedback throughout this entire process. We will be getting much of this information up today on our website, and we anticipate hearing a fair amount back. But I'm sorry, I mean, will the public have the opportunity to speak in front of us? Oh, yes. So that October 17th period is specifically for public comment. So much like we did for the comprehensive plan, we take public comment one day. You are able to deliberate about that public comment, provide us suggestions, and then we come back for the 31st in which we would have a fuller discussion of adoption. As a follow-up, do you think that will be enough time? I don't know. Do you think that'll be enough time for public comment given the fact that we're talking about one date? So we've been having public comment throughout the process. So that would be, I mean, we're gonna try to get this out to you as a full document for the public to review, and we can take public comment from a email, posting on the website, posting on the actual document. But we also have, with all of our major plans, comprehensive plans, this is the typical process. And Mr. Owens, let me punctuate that. That October 17th hearing date is just to put information on the table. So the consultants and staff will be making a presentation to get it on the record. Then we're recommending that you all open up the floor for public comment and take the rest of that for the rest of the day. We don't have anything that keeps us from stopping that evening. And then we won't do anything else with that, unless, except that you all would have direction to us that you wanted more information or you wanted something for or by the 31st, and then come back. Well, that definitely helps, having been through some of this in the past. It's like, well, you know, Joe Smith can't be there on the 31st. He's not given an opportunity. You know, and I'm just using that as an example, you know, and throwing it out there because I've been there before and I'm sure we'll hear it. But the 17th, I didn't know that. That's two different dates. Right, so the 17th is when anybody can come to the mic. And, of course, people can submit comment in advance and then writing. Yeah, thank you. And Mr. Duncan, before we move on, again, we talked about October 31st. Right, and I think, Mr. Davis, that that's important because by then it's gonna be back to you all. We don't expect that you would take additional public comment on October 31st. It'll still be a public hearing and open to the public, and we expect people will be in the audience and paying attention. But at that point, you're deliberating on what you heard on October 17th and making any final changes or directions to the plan and then considering whether to adopt the plan at that time. So is it basically a one-item agenda that day? Yes. OK. Yes. No, it can't. We got, it's a very important day on the calendar for kids. Yes, my children. Yes, Bill. Gotta collect the candy corn. Just to put this in, oh, I'm sorry. Quick. How, what, could you explain a little bit about why the mixed-use zones were extracted? So the mixed-use zones have not been popular use, and they've been relatively hard to use. So that came out of a fair amount of conversation with the Newtown Pike extension. And we established certain location criteria in which they should go, certain mandatory amounts of mixed use across the site to be integrated vertically. And we have found that that has not worked in Lexington. And we have not seen a lot of users come to that. But with what we have changed with the UGM ZOTA and the major modifications with the CN zone, the B1 zone, and the B3 zone, they're more attractive zones to go to that allow for the mixture of land uses, but don't require them. So by taking those out, we're pushing for more flexibility in these zone changes, and also realizing that individuals or property owners have not been interested in utilizing those zones. Thank you. You're welcome. This is just to put this in context. About how many people have participated in all the hearings you all have held through this process, all the different locations? You have a ballpark? We can get you that information later on. We have had some very well-attended meetings. And I will say the interaction online has been very high. It's been dominated by a few issues, and you will be provided much of that comment. But the vast majority of what we have been hearing has been supportive of some of the ideas that are going through. And Judy, also, in addition to inviting people to come to us, such as the senior center and at the Whitaker Y, we've also then gone to not focus groups, but neighborhood meetings. And I can't, the word's escaping me. But anyway, specific interests and met with them as well individually. Special constituencies and interest groups, is that good enough? That sounds a little hot. Something like that. No, we have really tried to make sure that the neighborhoods that are affected had, we were going out to them. We have done several meetings with different districts that weren't specifically publicized as come to this for this event. But we've had a lot of participation in this. Same as in the case, there's been around 7,000 unique visitors to the website. So that tells you about what we're seeing. Mr. Bailey, this may already be your staff's plan, but prior to the 17th, any feedback that you have collected that you intended to share with us, could it be sent to us a few days before the meeting? So we've been collecting those at the end of every month that we receive and sending them to Sam. Sam has been taking them with what they've been receiving that may come to them outside of to us. We can get you that at least two days, I think. We could probably do that before. There's going to be a period of once we get the plan on the website and open up a big promotional round of public engagement and feedback that we may be getting right up until the meeting. So whatever we give you early, we'll probably have more to give you the day of the hearing. So it just makes it a lot easier to listen to the public comment without having to try to read simultaneously. I think we can do that. But just as long as you all understand, there's going to be stuff coming in all the way to the end. Does that mean we're going to get 7,000 emails sent to us? Possibly. Yeah. Be careful what you have to say. Yeah. Yeah. I've got a couple of questions specific to the categories. The first one is with this update, you all are sort of addressing that issue of the B3 uses not being recommended anywhere. The one that stands out to me that still falls in that category, I guess, would be the B4. And if I recall correctly, and I could be wrong since this didn't end up applying, but like with the project I'm currently doing with the bakery, if I had not agreed to put the retail counter in, it would have needed to be a B4, everything else being exactly the same. Because it would be producing for the other business as opposed to direct consumer. So it seems like we have a lot of uses that, like Caleb mentioned, with the coffee roaster example or with the sort of food production example, which I just brought that are important in the community. And this doesn't say how they fit in. So within the UGM ZOTA, there was also the inclusion of artisanal manufacturing. And we can look at that in a way of what was trying to be produced with the PUD to that North Limestone area. And that allows for a little bit more flexibility in that level of distribution. But it is really meant to be low scale. Well, I don't think PUD is really the flexible application I'm talking about. We've included that in the B1 zone. So we've taken that language from the PUD and included that in the B1. Oh, no, you're good. I don't think that's super flexible for someone. Not the PUD 2. But we've included that language now in the B1 to give greater flexibility like that. I think Caleb would like to see a little bit more flexibility based off the language that we've been provided. And I mean, I guess that does still leave the question of where, I mean, if we don't define where and how we want to see those uses, then they're just going to get a plot. The applications are just going to come in for anywhere. And we saw that where we had that application for the Beaumont Center. And so I guess I'm just wondering, because we don't know where we want these uses, we're just not going to put them in because we don't want them? So with self-storage warehousing or something along those lines, or are you talking about the smaller scale production manufacturing? Well, I guess I'm talking about both. OK, so I think that the UGM ZOTA helped a lot to answer some of those questions for a smaller scale enterprise. In terms of the self-storage, that would fall closer to a flex space location from a land use perspective. So they have those lined out in their maps. And that fits a little bit more with that. I don't think that in the conversations that we've had with other groups, we wouldn't really want to see those large scale self-storage units, especially multi-story or single story, in the other zones as much. But that's something that we can look at with a review of the B4 zone, which I do believe that they are recommending within future text amendments. OK. Hey, Robin, real quick too, I think that the B4, we didn't make changes to the B4 in the UGM ZOTA. But again, the Blue Sky Small Area Plan is going to address a lot of small business incubation type of situations. Maybe there's not a lot of B4, I don't believe, about Blue Sky. But these B4 and I-1 and how they overlap is a bit of an issue. And so the fact that it's still not a recommended zone illustrates that we still have a problem with figuring out what we want the future of B4 to be. That's the same problem we have with P1. And so P1 and B4 are the two zones we're still trying to figure out what to do with because there's not a lot of demand for them. So is there any, I mean, this is just a question that, I mean, I guess I should have thought of P1. It just didn't jump out. But is there any reason that we have P1? That's kind of what we're asking ourselves. And what do we do with it to make it an attractive and useful zone? And B4? As opposed to just rezoning P1 to B1? That comes with a whole other complicated process. The real difference between the P1 and the B1 at this point in time is the hospital, which we just added into the B3 zone. So there are some different elements that we've taken away from the P1 a little bit and made other zones more attractive to some of those uses just because they're more properly located in a lot of different ways. But we do need to take a look at those P1 land uses and say, how do we want these to develop? And we've been asked to look at that from the public as well. Yeah, the P1 was a very effective transition use when the B1 allowed gas stations and drive-thrus. But now that it doesn't, B1 doesn't really need a transition zone. So again, that's the issue we're trying to figure out is, how do we make that zone attractive and useful? And then I've got. Yeah, that's the part about rezoning. It's just a mountain of non-conformities and possibly upset property owners if we propose to do so. That makes sense. And then just to, I guess, just a couple of just comments that what, or I guess this is a question. What does this, I mean, downtown uses, downtown zones are some of the most flexible zones that we have. What does a CN zone bring to the downtown? And why would we want to see that added when we already have pretty flexible use zones downtown? So compared to the, let's call the B2A, the CN zone is actually more flexible in form than function. In terms of height, planning commission review, things like that, the CN does allow for a fair amount of extra flexibility. The B2, probably the easiest zone to work with out of all of these. But the B2, it has been centrally located in certain areas. So this would just allow for another option for someone to look at. And it also gives you all an ability to look at these in a way of talking about limiting surface parking, talking about how to develop some of these very large residential structures to focus on more residential downtown or in the downtown area. And then the way that I read this, so the places where B1 is listed, that is B1 or form based B1. And then now you're saying no regular B1, or B1 is not recommended with the caveat is if we get to comment on the design in the corridor. Correct. So that B1 form based on the corridor, we want to ensure that we're getting bigger buildings on our corridor. We're getting something that's a little bit more form based rather than just talking about a smaller scale B1 on those quarters. We're pushing bigger. I guess, I mean, I can see it either way. I do think that it, I see why you dropped it in the others with the form based, but I would say if you delineate that way, it might make sense to keep that separate things. But that's the end of my comments. Thanks. Thank you. And I'm sorry about my alarm. Thank you, Mr. Bailey. Thanks, sir. Thank you. Mr. Duncan. Thank you. So we expect to have a draft of the plan from the consultants into this week that we'll be reviewing and then getting them comments back. And then our plan is to have it up on the website by the end of next week so that we can open a public comment period and start publicizing that through all of our different avenues. So when that plan is publicized, we will send an email to the planning commission so you all know that it's available, where to direct people, if people reach out to you. So that is our goal, is by the end of next week, fixed Thursday, Friday, to have that plan online. And back to the ordinary business, you all have a zoning hearing next Thursday, September 26 at 1 30. We'll be back in the council chambers for that. And the word I was looking for earlier was stakeholder. That's the word. Thank you. Meetings adjourned. She says she loves you. Your brothers, the anger you went. How far to the point of no return? To the point of no return. How long? How long? Today I found the message floating in the sea from you to me. Lord, that when you could see it, you cried with fear. The point was near. Was it you that said, how long? How long? How long to the point of no return? How long? How long to the point of no return? No return. How long? How long? How long? How long? How long? How long? How long? How long? How long? He comes around every time. He sways and he gets out of swing. Everywhere he pá, pás. Where ever he pas lay. Does he pás, pás, pás, pás, fá, fá. notions, visions, visions. Is he pás. towards the reality. Is he pás, pás, pás, pá, pás. He consumes the memory. Where it is love goes. I don't know if even heaven knows. I know you had some dreams that didn't quite come true. Now I'm not the one little girl who's keeping you. I was either standing in your shadow or blocking your light. Though I kept on trying, I could not make it right. For you, girl, there's just not enough love in the world. I know people hurt you so bad. They don't know the damage they can do. And it makes me so sad. How we knock each other down just like children on a playground. Even if that old sun went down. I was either standing in your shadow or blocking your light. Though I kept on trying, I could not make it right. For you, girl, there's just not enough love in the world. Oh, darling, there's still a shady little town. And sometimes it's so hard to smile. For the world, for the camera, still has something left. You don't have to prove nothing to nobody. Just take good care of yourself. I'm not easy to live with. I know that it's true. You're no picnic hero, babe. That's one of the things I loved about you. Time will come around when we need to settle down. Got to get off this merry-go-round. I was either standing in your shadow or blocking your light. Though I kept on trying, I could not make it right. For you, girl, there's just not enough love in the world. For you, girl, there's just not enough love in the world. Not enough love in the world. Not enough love in the world. In the world. In the world. Cherish is the word I use to describe all the feeling that I have hiding here for you inside. You don't know how many times I wish that I had told you. You don't know how many times I wish that I could hold you. You don't know how many times I wish that I could mold you into someone who could cherish me as much as I cherish you. Perish is a word that more than applies to the hope in my heart each time I realize that I am not going to be the one to share your dreams, that I am not going to be the one to share your schemes, that I am not going to be the one to share what seems to be a life that you could cherish as much as I do yours. Oh, I'm beginning to think that man has never found the words that could make you want me, that have the right amount of letters, just the right sound that could make you hear, make you see that you are driving me out of my mind. Oh, I could say I need you, but then you'd realize that I want you just like a thousand other guys would say they loved you with all the rest of their lives when all they wanted was to touch your face, your hands, and gaze into your eyes. Cherish is the word I use to describe all the feeling that I have hiding here for you inside. You don't know how many times I wish that I had told you, you don't know how many times I wish that I could hold you, you don't know how many times I wish that I could hold you into someone who could cherish me as much as I cherish you. And I do cherish you. And I do cherish you. Cherish is the word. So you're leaving in the morning on the early train. Well, I could say everything's all right, and I could pretend and say goodbye. Got your ticket, got your suitcase, got your leaving smile. Oh, I could say that's the way it goes, and I could pretend that you won't know that I was lying. Because I can't stop loving you. No, I can't stop loving you. No, I won't stop loving you. Why should I? We talked. We talked. We talked. Maybe the last time I don't feel in harmony with the rumble on the railroad track. Oh, when I hear the whistle blow, oh, when I hear the whistle blow.
