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Dear Director Loya:
On behalf of our client, EdgeConneX, Inc., we respectfully submit the following comments in advance of the City of Arcata’s Planning Commission Special Meeting on June 13, 2023. These comments address Agenda Item III(C), which concerns the Draft Gateway Area Plan. EdgeConneX supports the Gateway Area Plan’s rezoning efforts. But EdgeConneX offers these comments to clarify allowed uses in the proposed Gateway Hub (G-H) zone and otherwise to conform allowed uses under the Gateway Area Plan. The requested revisions include revisions to the Draft Land Use Element, the Draft Gateway Area Plan, and the Gateway Area Table.
For context, EdgeConneX owns property at 1296 11th Street (APN 020-123-002). The City’s recent rezoning efforts include this property, and will rezone the property to G-H. There is, however, a potential inconsistency in how the rezoning will apply to this property. For instance, the property is presently zoned Industrial-Limited (I-L). Allowed uses under I-L include “light industrial activities (when conducted within a building),” such as the property’s current use as a data center and uninterrupted power supply battery storage. EdgeConneX understands that the Gateway Area Plan will not narrow or impact these allowed uses. But to clarify this understanding, two suggested changes can benefit the Gateway Area Plan and assist those that will rely on the Plan.
First, EdgeConneX requests that the Gateway Area Plan expressly confirm that the G-H district will permit the same uses allowed under the current I-L zone. The City’s Draft Land Use Element explains that the proposed G-H district will allow for “light industrial, and other similar uses.” This explanation implies that allowed uses under I-L fit within the “light industrial” activities allowed under the G-H district. As a result, EdgeConneX understands that its present and future use (e.g., data center, battery storage) will remain legal conforming uses. We would appreciate the City confirming and making this understanding more explicit in the Gateway Area Plan.
Second, there are slight inconsistencies in allowed uses within the G-H district among rezoning documents. The City’s Gateway Area Plan, for instance, provides that the G-H district would allow for “light manufacturing and other similar uses.” The Gateway Area Table, however, provides that the G-HCity of Arcata Proposed Rezoning
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district would permit “light industrial, and other similar uses.” Since the difference between “light manufacturing” and “light industrial” activities is arguably material, EdgeConneX asks that the City clarify and make consistent the terms used within the Gateway Area Plan and Gateway Area Table by using the term “light industrial” exclusively.
EdgeConneX appreciates that the City’s rezoning involves a substantial effort, and that this effort is a work in progress. EdgeConneX supports these efforts. And to that end, EdgeConneX offers these suggestions to ensure that the final Plan avoids inconsistencies on issues like allowable uses.
Regards,
Sean G. Herman Senior Counsel
cc: Via Email Only
Bridget Dory, City Clerk ([email protected])
Commission Member Peter Lehman ([email protected]) Commission Member Scott Davies ([email protected]) Commission Member Judith Mayer ([email protected]) Commission Member Daniel Tangney ([email protected]) Commission Member Joel Yodowitz ([email protected]) Commission Member Matthew Simmons ([email protected])