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HomeMy WebLinkAboutAgenda Item - 2025-08-11 - Number 07.1 - Staff Memo 08-01-25 PCWS-2 08-11-25 w-Attach PP 25-0002 503-635-0290 380 A AVENUE PO BOX 369 LAKE OSWEGO, OR 97034 WWW.LAKEOSWEGO.CITY TO: Lake Oswego Planning Commission FROM: Evan Fransted, AICP, Senior Planner SUBJECT: Code Audit and Amendments - Work Session #2 (PP 25-0002) DATE: August 1, 2025 WORK SESSION DATE: August 11, 2025 EXECUTIVE SUMMARY This work session will update the Planning Commission (Commission) on the City’s recently initiated project to conduct a comprehensive review of the Development Code (CDC) to identify barriers to housing production and economic development, then implement code amendments to address those barriers. Since the first work session, the Planning Department applied for a $306,000 Metro 2040 grant to hire a consultant for the project. The Metro Council will decide on the grant in a public meeting in late September. If successful, a Request for Proposals (RFP) will be released in October, with consultant selection to follow, and commencement of the project estimated to begin in early 2026. The Commission will be involved throughout the process, providing input on code concepts, draft amendments, and the final recommendation to the City Council. The project is anticipated to be finished by August 2027. BACKGROUND While the City is committed to upholding high community standards, its development code has become increasingly complex over time. The Planning Department annually prepares amendments to the CDC to comply with state law, improve the code's clarity and predictability, and to address issues identified by staff and the public in applying the code. However, the need for a more in-depth, comprehensive analysis of the CDC was identified in the Economic Development Strategy and Resource Plan (2022) and Housing Production Strategy (2024) and is supported in the 2025 City Council Initiative to “Begin a comprehensive review of the Development Code to identify barriers to housing production and economic development and implement code amendments to address these barriers.” DISCUSSION Project Objectives and Scope The project will be conducted in two phases: Page 2 of 3 The first phase is the code audit. The purpose of the audit is to conduct a comprehensive review of the CDC (Chapter 50) to: 1) Identify obstacles to housing development and business activity; 2) Identify code standards in the CDC that can be streamlined, right-sized, or updated to reduce complexity and inefficiencies; 3) Identify needed updates to comply with existing State land use laws, as well as those that were passed during the 2025 legislative session; 4) Identify procedural requirements that delay and add cost to housing and business development applications; 5) Evaluate ways that developers access the CDC, including specific areas that can be improved to support a smoother development process; and 6) Identify any duplicities and/or inconsistences across zoning districts with potential opportunities for simplification and consolidation of zoning districts or overlays. The second phase is the implementation of the recommendations in CDC Audit Report by adopting code amendments and executing process improvements to: 1) Address development standards that are barriers to housing and business development while maintaining high-quality design and livability; 2) Ensure consistent and clear guidance for applying development standards; 3) Remove unnecessary obstacles to housing and business that contribute to increased costs or review timelines; and 4) Improve accessibility and ease of use of the CDC to support an efficient development process for applicants. Public Involvement The consultant (with staff support) will draft a Public Involvement Strategy that will help guide the project to ensure the community’s vision and values are reflected. The community engagement process will likely include open houses, stakeholder interviews, community surveys and online communications (e.g. social media posts, web updates, press releases, etc.). A Technical Advisory Committee (TAC) comprised of key City staff and representatives from the development community will be formed to help direct the technical work of the project. Planning Commission Involvement The Commission will be involved throughout the process, providing input on code concepts, draft amendments, and the final recommendation to the City Council. There are expected to be as many as eight Commission Work Sessions for staff to provide project updates, summarize public engagement, and receive advisory input at key points throughout the project. In addition, there will be at least two Commission public hearings to review the proposed code amendments, and issue final recommendation to the City Council. See schedule, below. Timeline and Next Steps The Planning Department applied for a $306,000 Metro 2040 grant on July 10th to hire a consultant for the project (Attachment 1). Letters of support for the project from the City Page 3 of 3 Council, the Lake Oswego Chamber of Commerce, and the Home Building Association of Greater Portland were included. The Metro Grants Screening Committee will meet in early August to evaluate the grant application and prepare a recommendation for the Metro Chief Operating Officer (COO). The Metro Council will decide on the grant in a public meeting likely in late September. If successful, the consultant RFP will be released in October, with consultant selection to follow, and the project anticipated to begin in early 2026. All tasks—including adoption of code amendments—are tentatively scheduled to completed by August 2027). The tentative project process and timeline are as follows: PROJECT MILESTONE DATE DUE 1 Project Kick-Off Background Report and CDC Review Draft Public Involvement Strategy and form TAC January 2026 February 2026 March 2026 2 Perform Audit: CDC Review and Public Outreach July 2026 3 Draft and Final Audit Report First Draft of Code Audit Draft Recommendations Memo Second Draft of Code Audit Final Draft August 2026 September 2026 October 2026 November 2026 4 Draft Code Amendments March 2027 5 Adopt Code Amendments August 2027 ATTACHMENT 1. Metro 2040 Grant Combined Application, 07/10/2025 Community Development Code Audit: Housing and Business Analysis Combined Application – Table of Contents 1 Table of Contents 2-7 Short Project Narrative 8-11 Letters of Commitment o Lake Oswego City Council o Lake Oswego Chamber of Commerce o Home Building Association of Greater Portland 12 Location Map 13-25 Appendix A – Detailed Scope of Work 26 Appendix B – Detailed Project Budget 27 Appendix C – Detailed Project Timeline PP 25-0002 ATTACH 1/PAGE 1 OF 27 2040 Planning and Development Grant Application | Planning Inside the UGB Project Name: City of Lake Oswego - Community Development Code Audit: Housing and Business Analysis Funds requested: $306,000 1. Project description Describe the proposed planning project, its intended purpose, and key desired outcomes. The purpose of the project is to conduct a comprehensive review of the Development Code to identify barriers to housing production and economic development, then implement code amendments to address those barriers. We propose a two-phase project: The first phase is the code audit. The purpose of the CDC Audit Report is to conduct a comprehensive review of the CDC (Chapter 50) to: 1) Identify obstacles to housing development and business activity; 2) Identify code standards in the CDC that can be streamlined, right-sized, or updated to reduce complexity and inefficiencies; 3) Identify needed updates to comply with existing State land use laws, as well as those that will be passed during the 2025 legislative session; 4) Identify procedural requirements that delay and add cost to housing and business development applications; 5) Evaluate ways that developers access the CDC, including specific areas that can be improved to support a smoother development process; and 6) Identify any duplicities and/or inconsistences across zoning districts with potential opportunities for simplification and consolidation of zoning districts or overlays. The second phase is the implementation of the recommendations in CDC Audit Report by adopting code amendments and executing process improvements to: 1) Address development standards that are barriers to housing and business development while maintaining high-quality design and livability; 2) Ensure consistent and clear guidance for applying development standards; 3) Remove unnecessary obstacles to housing and business that contribute to increased costs or review timelines; and 4) Improve accessibility and ease of use of the CDC to support an efficient development process for applicants. 2. Link to development or redevelopment Describe how the proposed planning project will facilitate development or redevelopment within the urban growth boundary. In this context, development means new construction of buildings and structures and associated improvements (landscaping, parking, streets, etc.). Redevelopment means significant expansion or alteration to existing buildings to improve their capacity for occupancy. Redevelopment does not mean interior changes to an existing building (for example, tenant improvements are not considered redevelopment). PP 25-0002 ATTACH 1/PAGE 2 OF 27 2040 Planning and Development Grant Application | Planning Inside the UGB The Community Development Code regulates all development within the City of Lake Oswego including new construction and redevelopment. By conducting a comprehensive review of the development standards, the project has the potential to facilitate housing production and commercial development by: • Amending or removing development standards that are barriers to housing and business; thereby making it easier for new construction and redevelopment opportunities; • Removing unnecessary obstacles that contribute to increased costs or review timelines; thereby, allowing more opportunities for lower budge construction projects; and • Streamlining the way that developers access the CDC, including specific areas that can be improved to support a smoother development process; thereby making construction projects easier for the applicants/builders. 3. Project readiness A. Capacity and expertise ­ Describe the staff members and any community partners that will lead and/or help facilitate the project. Explain how their capacity and level of expertise will enable them to oversee the work and implement the plan. ­ Describe what type of technical or consultant support, if any, will be needed and the tasks that will be completed by consultants. Specific private firms should not be named in the application unless they have already been selected through a public procurement process. The project is led by the Planning Department: • Evan Fransted, AICP – Senior Planner (project manager; 11 years with LO; annual code updates) • Jessica Numanoglu, AICP – Community Development Director (over 24 years with LO; led 2009 code audit) • Erik Olson – Planning Manager (over 6 years with LO; HB 2001 implementation, HNA, HPS) Internal support from Building and Engineering Departments is fully committed. We will select a primary consultant by December 2025. The Scope of Work (Appendix A) details the responsibilities of the consultant. A multidisciplinary Technical Advisory Committee (TAC)—City staff, Metro and DLCD representatives, design and development professionals, and the Chamber of Commerce—will guide the consultant team. B. Project scope and schedule. Provide a detailed scope of work that includes defined tasks, associated outcomes, and deliverables. For each task, include an estimated timeline. The scope should clearly identify all project milestones and each step necessary to achieve the desired outcomes for the work. All tasks—including adoption of code amendments—will be completed within 23 months (by August 2027). Ultimately, the project team will be responsible for the materials that are generated under the Scope of Work (Appendix A). Task #0: Consultant Selection - Timeline: October – December 2025 PP 25-0002 ATTACH 1/PAGE 3 OF 27 2040 Planning and Development Grant Application | Planning Inside the UGB Over the course of the project, the City will manage the consultant selection process as well as develop and manage the consultant work scopes in order to successfully deliver the products as described in detail in The Scope of Work (Appendix A). Products/Deliverables: • Executed Consultant Contracts • Monthly Consultant Performance Reports Task #1: Project Kick-Off - Timeline: January – March 2026 Estimated Cost: $35,000 The purpose of the project kickoff is for the Consultant to become familiar with local conditions, the CDC, and other relevant Planning documents; and for the parties to confirm the objectives of the project and refine the project schedule. The Consultant will meet with staff to establish the project expectations and familiarize themselves with City-specific concerns. The information gathered during this phase of work will provide a solid basis for the scope of the audit and subsequent refinements of the report. Products/Deliverables: • Background Report • Initial CDC Review Memo Task #2: Perform Audit - Timeline: April – July 2026 Estimated Cost: $65,000 Building on information provided in the background and research phase, the Consultant will prepare an initial draft CDC Code Audit Report presented to staff for review and comments, then prepare a second draft report that will be presented to the City Council, PC, TAC, and general public. The draft Report will include: • Lists of specific places in the CDC that will require updates in order to be compliant with existing State land use laws, as well as those that will be passed during the 2025 legislative session. • An outline of CDC standards or procedures that have the effect of discouraging housing through unreasonable cost or delay. • Identification of specific areas in the CDC that could be streamlined, clarified, or amended for greater effectiveness, including potential zoning district and overlay consolidation and simplification of development standards or processes. Products/Deliverables: • Drafts of the Code Audit Report findings • Presentation materials for findings Task #3: Draft Audit Report - Timeline: August – November 2026 Estimated Cost: $96,000 The draft CDC Code Audit Report will include recommended improvements to the CDC. The Consultant will draft memo an Initial Recommendation Memo that will include: PP 25-0002 ATTACH 1/PAGE 4 OF 27 2040 Planning and Development Grant Application | Planning Inside the UGB • Strategies that specifically address the obstacles to development within the CDC, including specific recommendations on how the CDC should be amended to address the obstacles. • An action plan that will allow staff to move forward quickly into the code drafting and adoption process. The draft recommendation will be presented to staff, the TAC, and public open house or focus groups for comments. The Consultant will then prepare the Final Code Audit Report with revisions based on the comments received. The Final Code Audit Report will include recommendations on the types of changes to implement the solutions identified. The Final Audit Report will be presented to City Council, the PC, the TAC, and at open houses or focus groups as determined by the Public Involvement Strategy. The project team will assemble comments received and forward recommendations on how to respond to those comments to the TAC. The project team will identify the Code Audit Report recommendations that should move forward in light of the feedback received, then present the Final Code Audit Report to the TAC and public forum for a second round of comments. Products/Deliverables: • Initial Recommendations Memo • Final Code Audit findings and recommendations • Presentation materials for findings and recommendations Task #4: Draft Code Amendments - Timeline: December 2026 – March 2027 Estimated Cost: $90,000 After review of the findings and recommendations of the Final Code Audit Report with comments received from the TAC and public, the Consultant and staff will prepare draft amendments for modifying the CDC as recommended by the Action Plan in the Code Audit Report. The amendments will be presented to City Council, the TAC, the PC (at two work sessions), and to the public for review and comment, as determined by the Public Involvement Strategy. Following revisions of the draft code amendments based on the comments and feedback received, the project team will refine and finalize the document as described in Task #5 below. Products/Deliverables: • Draft CDC ordinance, code graphics, exhibits, and submittal package. • Presentation materials to explain draft to TAC and the public Task #5: Adopt Code Amendment - Timeline: April – August 2027 Estimated Cost: $20,000 Staff will prepare final draft code amendment documents supplemented with necessary exhibits, and assembled into a format that will allow it to be submitted for public hearings with the Planning Commission and, ultimately, City Council, for those bodies’ review and consideration. The Consultant will coordinate with staff on hearing arrangements and creating presentations for the PC and City Council hearings. Products/Deliverables: • Final Code amendment, ordinance, and exhibits submittal package • Revised presentation materials for PC and City Council Hearings C. Project budget. Use the budget template provided to show the estimated project costs. The budget table should align with the scope of work and include the tasks and deliverables identified in question 3B. Indicate PP 25-0002 ATTACH 1/PAGE 5 OF 27 2040 Planning and Development Grant Application | Planning Inside the UGB estimated costs for technical/consultant work as well as other direct project expenses. In the space below, describe the methodology used for estimating project costs, and identify additional funds (if any) that have been pledged by project partners or other sources. We have included the draft budget as Appendix B. We are requesting $306,000 for costs associated with consultant fees for each task outlined above. Staff looked at prior City projects and similar code audit projects from surrounding municipalities to get an idea of anticipated consultant fees. Staff time is not included in the request. D. Project support. Describe the support for the proposed project including how it aligns with other agency-led plans and projects, commitment by local government to implement the resulting plan, and leadership support. The Scope of Work (Appendix A) details the full background of the project. The City of Lake Oswego is known as having friendly and customer-service oriented staff but an overly-complicated development code. Consistent with the 2025 City Council Goal to, “Strengthen public trust in the City through continuous improvement, outstanding customer service, infrastructure investments, and fiscal stewardship,” the Planning Department annually prepares amendments to the CDC to comply with state law, improve the code's clarity and predictability, and to address issues identified by staff and the public in applying the code. However, the need for a more in-depth, comprehensive analysis of the CDC was identified both as part of the City’s Economic Development Strategy and Resource Plan (2022) and Housing Production Strategy (2024). A 2025 City Council Initiative calls for staff to “Begin a comprehensive review of the Development Code to identify barriers to housing production and economic development and implement code amendments to address these barriers” as part of the Council Goal to, “Plan for change and growth, with a focus on enhancing the community's quality of life and sense of place.” As shown in the attached letters of support, the project is championed by the City Council, Lake Oswego Chamber of Commerce and the Oregon Home Builder’s Association. 4. Community engagement Identify the communities that will be impacted by the proposed work and summarize available data or information about them (race, income, educational level, languages spoken, etc.). Describe the plan for conducting meaningful engagement with those communities, particularly with communities that have been historically under-represented in planning processes. Explain how and when engagement will occur throughout the project and how that input will impact project milestones. Be specific about how community input will be accurately reflected and how it will be used to impact final outcomes. If impacts are minimal or difficult to quantify, discuss how information about this work will be shared with the public to provide transparency. Metro encourages mutually beneficial partnerships with community-based and non-profit organizations. Describe any plans for coordination with organizations or individuals who can serve as liaisons and trusted resources in the communities impacted by the proposed work. Include information about how those organizations will be selected and how their participation will be supported. The Scope of Work (Appendix A) provides the details on the public involvement process. Public involvement is essential to delivering a successful code audit and meaningful code amendments. Effective policies are built with community input and shared ownership. This public participation effort is not a separate task—it is a core part of the entire work plan. The Consultant, with City support, will lead this effort, ensuring that all work reflects community priorities and incorporates public feedback. The process includes identifying stakeholders across multiple audiences whose input is critical in shaping the audit report and code amendments. A specific Public Involvement Strategy will be drafted PP 25-0002 ATTACH 1/PAGE 6 OF 27 2040 Planning and Development Grant Application | Planning Inside the UGB which incorporates community issues and concerns as part of the planning process. The Draft Public Involvement Strategy will then be presented to the TAC and the Planning Commission (PC) for further refinement. Upon acceptance of the final Public Involvement Strategy, the Consultant will execute the strategy and manage public communications and outreach efforts, with an eye towards gaining broad- based support for the proposed amendments. 5. Alignment with 2040 Growth Concept If the proposed project is within an identified land use designation per the 2040 Growth Concept map, list the designation here (for example, project is within a designated center, station community, or is employment land). Describe how the proposed project will support one or more of Metro’s six desired outcomes for the region. Those desired outcomes include: ­ Climate change adaptation or mitigation ­ Advancement of racial equity ­ Economic growth and prosperity ­ Complete and vibrant communities ­ Provision of housing options ­ Safe and reliable transportation While this project is consistent with all six of Metro’s desired regional outcomes, reducing barriers to housing and business will most-directly support: • Advancement of racial equity: Addressing barriers to housing in the CDC will hopefully allow for a wider variety of housing development that can better serve the needs of individuals from different racial backgrounds. This includes housing that better accommodates intergenerational living and housing that is appropriate for a range of different family sizes. It also includes promoting more affordable housing options within affluent areas, which can address historical disparities, promote access to opportunity for communities of color, combat the negative impacts of residential segregation, improve economic stability, and foster more inclusive communities. • Economic growth and prosperity: Removing unnecessary obstacles to housing and business development that contribute to increased costs or review timelines will help encourage economic growth in the City. If builders and developers know that the development review process is streamlined, they will be more likely to develop within the City. • Complete and vibrant communities: The CDC includes standards that focus on maintaining high- quality design and livability. One of the project goals is to address development standards that are barriers while maintaining high-quality design and livability, which will help ensure complete and vibrate neighborhoods within the City. • Provision of housing options: Identifying and addressing barriers to housing in the CDC is explicitly intended to allow for more housing options to be constructed within the city. For more, see ‘Advancement of racial equity’, above. PP 25-0002 ATTACH 1/PAGE 7 OF 27 CITY COUNCIL 503-635-0215 380 A AVENUE PO BOX 369 LAKE OSWEGO, OR 97034 WWW.LAKEOSWEGO.CITY July 10, 2025 Ms. Serah Breakstone Metro Regional Government 600 NE Grand Ave Portland, OR 97232 Dear Ms. Breakstone, On behalf of the Lake Oswego City Council, we are pleased to submit our application for the Community Development Code (CDC) Audit project to the Metro 2040 Planning and Development Grant program. As our community and region continue to grow, we must ensure the CDC standards incorporate the needs of new and prospective residents. My colleagues on the City Council and I have prioritized this equity-focus in our 2025 City Council Goals and we see the CDC Code Audit project as a tremendous opportunity to address barriers to housing and economic development. We unanimously voted in February to make this project a 2025 City Council Initiative, recognizing that the timing is right to plan for change and growth with a focus on enhancing the community's quality of life and sense of place. Central to our community’s growth is the creation of new housing, and expanding the range of housing options is a top-priority of this Council. We anticipate needing nearly 2,000 additional housing units in Lake Oswego to meet the demand of the next twenty years, with 36% of new housing units needing to be affordable to residents making less than 80% of the regional median family income. We see construction of new housing and redevelopment of the existing housing that this project will help create as the one of the best methods we have to address these forecasted needs, to advance Metro’s 2040 Growth Concept, and to contribute to the state’s housing production goals. My colleagues and I support and champion this project and look forward to bringing this project to fruition. Thank you for your consideration, Joe Buck Mayor City of Lake Oswego PP 25-0002 ATTACH 1/PAGE 8 OF 27 PP 25-0002 ATTACH 1/PAGE 9 OF 27 7/9/2025 Metro 2040 Grant Review Committee Attn: Ms. Serah Breakstone Metro Regional Government 600 NE Grand Ave. Portland, OR 97232 Dear Members of the Grant Review Committee, On behalf of the Home Building Association of Greater Portland I am writing to express our strong support for the City of Lake Oswego’s grant application to conduct a comprehensive audit of its development code. This project presents a meaningful opportunity to support housing production and economic growth in Lake Oswego— We applaud the commitment from the city in reviewing its practices reaffirming our shared commitment to expanding housing options and sustaining a strong, affordable, local building industry. The City’s proposal reflects a thoughtful, strategic approach to improving its Community Development Code (CDC). This audit—identified as a key implementation measure in the City’s adopted Housing Production Strategy—has the potential to unlock new housing opportunities and support commercial investment by: • Amending or removing development standards that act as barriers to housing and business development; • Eliminating unnecessary obstacles that contribute to increased project costs, prolonged timelines, or administrative inefficiencies; • Streamlining how developers and applicants access and navigate the CDC, including identifying specific code areas where clearer language, organization, or flexibility can promote a smoother development experience. The project also seeks to: • Identify barriers to housing production and economic development embedded within existing regulations; • Highlight standards and procedures that can be right-sized or simplified, including overlays and zoning districts; • Flag procedural requirements that add time or cost to development applications; and PP 25-0002 ATTACH 1/PAGE 10 OF 27 • Ensure the City’s code is fully aligned with state land-use law, helping to avoid legal risks and ensure policy consistency. Lake Oswego’s decision to pursue this effort sets a strong example for other jurisdictions, and we encourage cities across the region to undertake similar, solutions-oriented code reviews. As a major voice of the residential building industry in the region, we welcome the opportunity to engage in the audit process and contribute to efforts that will create a more predictable, efficient, and cost-effective environment for housing development. Sincerely, Isaac Ambruso Deputy Director of Policy & Government Affairs isaaca@hbapdx.org PP 25-0002 ATTACH 1/PAGE 11 OF 27 Feet This product is for informational purposes only and may not have been prepared for or be suitable for legal, engineering, or surveying purposes. Users of this information should review, or consult, the primary data and information sources to ascertain the usability of the information. This map represents the best data available at the time of publication. While reasonable effort has been made to insure the accuracy of the information shown on this page, the City of Lake Oswego assumes no responsibility, or liability, for any errors, omissions or use of this information. 0 Location Map - City of Lake Oswego 7,000.0 7,000.03,500.00 7/7/2025PP 25-0002 ATTACH 1/PAGE 12 OF 27 Community Development Code Audit DRAFT Scope of Work Page 1 Appendix A: Scope of Work Introduction The purpose of this audit is to review the City of Lake Oswego’s Community Development Code (CDC) to identify regulatory or process barriers that may hinder housing development and economic growth. The findings will support recommendations for code amendments to promote more efficient, equitable, and sustainable development that meets the needs of the community. The City of Lake Oswego is known as having friendly and customer-service oriented staff but an overly- complicated development code. Consistent with the 2025 City Council Goal to, “Strengthen public trust in the City through continuous improvement, outstanding customer service, infrastructure investments, and fiscal stewardship,” the Planning Department annually prepares amendments to the CDC to comply with state law, improve the code's clarity and predictability, and to address issues identified by staff and the public in applying the code. However, the need for a more in-depth, comprehensive analysis of the CDC was identified both as part of the City’s Economic Development Strategy and Resource Plan (2022) and Housing Production Strategy (2024). A 2025 City Council Initiative calls for staff to “Begin a comprehensive review of the Development Code to identify barriers to housing production and economic development and implement code amendments to address these barriers” as part of the Council Goal to, “Plan for change and growth, with a focus on enhancing the community's quality of life and sense of place.” In November 2022, the City adopted the Economic Development Strategy and Resource Plan (the “Plan”), which found that the permit process can be cumbersome, time-consuming, and in some cases cost-prohibitive, particularly for small tenant improvements and other commercial projects that require land use review. The Plan recommended conducting a comprehensive review/audit of the CDC as it applies to businesses, and to remove impediments to business investment and job creation while maintaining high-quality design and livability. This is also consistent with the 2025 City Council Goal to, “Support business investment and job creation in Lake Oswego.” In October 2023, the Lake Oswego Housing Needs Analysis (HNA) was adopted to identify and analyze what housing is needed for the city’s current and future residents. The HNA indicated that nearly 2,000 new housing units are needed by 2043 to serve individuals at a wide range of income levels through a variety of different housing types. In November 2024, the Lake Oswego Housing Production Strategy (HPS) was adopted, which commits the City to pursuing a code audit and amendments as one of thirteen different strategies to increase housing production in Lake Oswego and meet the needs identified in the HNA. The HPS recommends undertaking a comprehensive audit of the CDC to address: • Barriers to accessory dwelling units (ADUs) and middle housing; • Ways to facilitate smaller units; • Procedural requirements that add cost and delay to land use approvals; • Open space requirements in high-density zones; • Barriers to residential development with mixed-use districts; • The impact of neighborhood and design district overlays, restrictive siting standards, or other regulatory provisions; and • Other identified Code barriers. PP 25-0002 ATTACH 1/PAGE 13 OF 27 Community Development Code Audit DRAFT Scope of Work Page 2 The HPS also identifies a range barriers to housing development in the CDC that resulted from interviews with stakeholders involved in housing production. During these interviews, stakeholders expressed that the CDC is especially challenging to work with compared to some other jurisdictions. The following specific code barriers were identified: • Overlay and Design District standards are highly prescriptive, which can add to the cost of development and limit flexibility. Stakeholders pointed to detailed architectural standards as being a particular challenge – e.g., requirements for specific siding materials adding to construction costs. • Tree protection and tree planting and landscaping standards are also very prescriptive and can be difficult to meet on constrained sites. • Open space standards for multi-family housing are considered by stakeholders to be excessive, limit the available space on a site for housing units, and don’t necessarily lead to great outcomes. They note that open spaces can be smaller and more concentrated while still providing appealing amenities for residents. • Setbacks and other standards limit middle housing infill opportunities. Stakeholders shared that siting standards can make it difficult for middle housing such as duplexes and townhomes to fit on existing lots. Stakeholders also noted that Lake Oswego’s development review and permitting processes can be lengthy and contribute to housing costs. A few stakeholders noted that this limits the number of developers that are interested in building in the city. In particular: • The design review process in Design Districts adds time and cost. • Building permit review can also be slow. • Due to prescriptive standards, applicants often need to apply for multiple variances, which lengthens the process and adds uncertainty. • Public improvements (e.g., road improvements and utilities) can be very costly. Community Development Code Audit – Product and Process The project will be conducted in two phases. The first phase is the code audit. The purpose of the CDC Audit Report is to conduct a comprehensive review of the CDC (Chapter 50) to: 1) Identify obstacles to housing development and business activity; 2) Identify code standards in the CDC that can be streamlined, right-sized, or updated to reduce complexity and inefficiencies; 3) Identify needed updates to comply with existing State land use laws, as well as those that will be passed during the 2025 legislative session; 4) Identify procedural requirements that delay and add cost to housing and business development applications; 5) Evaluate ways that developers access the CDC, including specific areas that can be improved to support a smoother development process; and 6) Identify any duplicities and/or inconsistences across zoning districts with potential opportunities for simplification and consolidation of zoning districts or overlays. PP 25-0002 ATTACH 1/PAGE 14 OF 27 Community Development Code Audit DRAFT Scope of Work Page 3 The second phase covers the implementation of the recommendations in CDC Audit Report by adopting code amendments and executing process improvements to: 1) Address development standards that are barriers to housing and business development while maintaining high-quality design and livability; 2) Ensure consistent and clear guidance for applying development standards; 3) Remove unnecessary obstacles to housing and business that contribute to increased costs or review timelines; and 4) Improve accessibility and ease of use of the CDC to support an efficient development process for applicants. Completion of the CDC Audit Report is expected to take approximately 10-12 months, and it will take at least another nine months to develop the specific CDC amendment language and hold the public hearings for adoption of the amendments after the CDC Audit Report is complete. As part of the code amendments, the consultant will be responsible for: • Developing targeted amendments to the CDC addressing the items identified in the CDC Audit Report and presenting at public hearings; • Ensuring compliance with state laws and Lake Oswego’ Comprehensive Plan policies; and • Conducting community outreach and incorporating community input into the amendment process. Work Plan The Scope of Work (SOW), work schedule, and budget, together with the descriptions of work within the work plan, describes the work to be performed by the City itself, or to be performed by the City through or with consultants to be engaged by the City. In the event of any conflict between the provisions of the SOW and the work plan, the terms of the work plan shall control. Unless specified otherwise, references in the SOW to the "project team" shall mean, the City together with the consultants it has engaged through the process outlined in the work plan and the SOW. 1.0 Team Organization + Project Management 1.1 Project Management The City, as the Project Manager, will provide overall project management for the process. Ultimately, the project team will be responsible for the materials that are generated under this work plan and for ensuring that the outcome of this process meets the community’s needs. Specific issues related to the management of this process are outlined below. 1.1.1 Consultants Over the course of the project, the City will manage the consultant selection process as well as develop and manage the consultant work scopes in order to successfully deliver the products described herein. The process will be open and transparent, and will PP 25-0002 ATTACH 1/PAGE 15 OF 27 Community Development Code Audit DRAFT Scope of Work Page 4 include significant City oversight throughout. A. Consultant Selection The City Project Manager will identify the specific deliverables and scope of work for the consultant as required by this work plan. In order to ensure the selection of the most qualified consultants and maximize the City’s value, the City will advertise for an open solicitation for Request for Proposals (RFP). At a minimum, it is anticipated that the following services will be needed for the project and that appropriate consultant will be selected to provide these services: • Planning/Land Use • Community Engagement • Public Policy • Architecture and Urban Design Consultant selection will be done by the City’s Project Manager and include development of an RFP Invitation for selecting qualified consultants. Evaluation criteria will include, but not be limited to, relevant firm experience in: land use planning; public participation; working with and applying development standards; code organization; applying state statues; local experience and knowledge; billing rates; and references. All firms must demonstrate their standing as an Equal Employment Opportunity (EEO) employer and meet City COBID requirements. Prior to issuing the RFP, the City’s Project Manager will establish specific scoring criteria for consultants. This information will be communicated in the RFP package. The selection team will have the right to select a consultant based on their response to the RFP or may, at its option, conduct interviews with potential consultants. B. Consultant Scope of Work/Contracts As part of the RFP package, the City will prepare an initial outline of the scope of work that is being requested, based on this work plan. This initial SOW will be used as part of the basis for consultant selection as well as to assist potential consultants in assembling a qualified team and their responses. Following consultant selection, the City’s Project Manager will work with the selected consultant (“Consultant”) to more clearly define their scope of work, including a delivery schedule and not-to-exceed budget for the work. Where Consultant budget or schedule exceeds the established project budget and schedule, the City’s Project Manager will work with the Consultant to meet the budget or schedule through reduced/reassigned work, increasing the budget allocation for certain tasks, or proceeding to negotiate with the second (or next) ranked Consultant. The City’s Project Manager shall approve of any reductions in/reassignments of work, budget increases, or decisions to move to the next Consultant. PP 25-0002 ATTACH 1/PAGE 16 OF 27 Community Development Code Audit DRAFT Scope of Work Page 5 Products/Deliverables: Executed Consultant Contracts C. Manage Consultant Scope of Work/Contracts The City’s Project Manager will manage the Consultant Scope of Work/Contracts to ensure delivery of the desired Consultant products within the established budget and timeline for the project. This work will include regular meetings with Consultants to review project progress, direction to Consultants to ensure consistency and coordination with other work tasks, and management of costs to ensure budget certainty. Monthly reports will be prepared by the Consultant for review with the City’s Project Manager in order to track Consultant performance to date, including budget, schedule, work completed, and acceptability of Consultant products. Products/Deliverables: Monthly Consultant Performance Reports 1.1.2 Project Schedule The City’s Project Manager will manage the project so as to deliver final products in accordance with the final project schedule based on the conceptual/anticipated Project Schedule. The Project Schedule will be updated monthly by the Consultant (or more as needed) to reflect approved Consultant SOW and reflect progress to date. The Project Schedule will be reviewed at least monthly with the City’s Project Manager, and adjustments will be made as needed based on the outcome of these monthly reviews. Products/Deliverables: Project Schedule and Schedule Tracking Reports 1.1.3 Accounting and Cost Control The Consultant will track the Project Budget reflected in the SOW and provide all accounting and cost controls for the project. Invoices will be submitted monthly to the City for review and approval. The City’s Project Manager will track submitted invoices against the Consultant contracts and the Project Budget and Schedule. Invoices will be approved only if the work performed was included in an approved Consultant contract or approved in writing in advance of the work being performed. Consultants must submit supporting material to the City’s Project Manager for review and approval. Any project expenses exceeding $1,000.00 must be countersigned by the City. Additionally, the Consultant shall submit a summary invoice for that month’s approved costs, including project expenses and fees. A budget tracking report must also be provided to measure Consultant performance against the Project Budget and Consultant fees earned. Upon the City’s review and approval of the summary invoice and tracking report, the City shall electronically transfer payment to the Consultant account. Products/Deliverables: Monthly Invoices/Checks; Budget Tracking Reports 1.1.4 Project Team Meetings The project team will be expected to meet on a regular basis to review project progress, PP 25-0002 ATTACH 1/PAGE 17 OF 27 Community Development Code Audit DRAFT Scope of Work Page 6 ensure consistency and coordination between work tasks, discuss potential schedule changes, and manage costs to ensure budget certainty. Products/Deliverables: City and Consultant – PT meetings on an ongoing basis; Consultant – Agendas and Minutes for all PT Meetings. 1.2 Project Oversight This work plan is an important step in the establishment of a public involvement process focused on broad outreach that provides a range of opportunities for community members and stakeholders to be involved and engaged in the process. The establishment of a Technical Advisory Committee (TAC) will provide technical expertise on subject matters. The Consultant will be tasked with drafting a public involvement strategy that will then help guide the code amendments to ensure the community’s vision and values are reflected. The community engagement process will likely include a kickoff public event, focus groups, community surveys and online communications (e.g. social media posts, web updates, press releases, etc.). Ultimately, the City Council will make the final decision to approve the amendments, so it will be well served by the guidance of the community and technical expertise of the TAC. 1.2.1 Technical Advisory Committee A Technical Advisory Committee (TAC) comprised of key City staff and representatives from the development community will be formed and managed by the City’s Project Manager and Consultant to help direct the technical work of the project. The TAC is anticipated to be tasked with providing input on this project as well as other strategies identified in the HPS, including the Rezone Land strategy. While the scope of work for the TAC will likely extend beyond the tasks related to this project, the Consultant will only be expected to manage the TAC in relation to the scope of work and tasks outlined for this project. This group will provide an opportunity for the City and the Consultants to test and refine planning concepts and to ensure that work products will meet the City’s needs for delivery of a final CDC audit and resulting code amendments. The proposed core membership of this group will include the following: • Planning Department staff • Building Department staff • Engineering Department staff • Oregon Home Builders Association Representative • Design and Development Professionals, including: • Multifamily and Middle Housing Developers • Architects / Landscape Architects • Real Estate Professionals • Housing Finance Professionals • Chamber of Commerce Representative • Local Business Owners • Economic Development Professionals PP 25-0002 ATTACH 1/PAGE 18 OF 27 Community Development Code Audit DRAFT Scope of Work Page 7 • DLCD Representative • City’s Sustainability Coordinator The Consultant, with input from the City, will develop a charge statement for the TAC that outlines the role and responsibility of the committee with respect to this scope of work. It is anticipated that this group may meet monthly after the kickoff event during the development of the code audit and resulting code amendments. The Consultant will prepare meeting agendas and distribute information to the TAC in advance of each meeting outlined in the scope for this project. Products/Deliverables: Project Advisory Group Meetings 1.2.2 City Council Meetings The Consultant will be expected to attend and assist with presenting at as many as five (5) City Council study sessions at key points throughout the Plan update process to provide project updates, summarize public engagement, and receive direction related to future phases of the project. The Consultant is also expected to attend and participate in up to two (2) City Council public hearings related to the adoption of code amendments. In addition, the Consultant will coordinate with the City Project Manager to prepare the necessary documents, including staff reports and presentation materials for all City Council study sessions and hearings. Products/Deliverables: In-person attendance and participation at up to five (5) City Council study sessions and up to two (2) City Council hearings; Coordination and preparation of materials in advance of study sessions and hearings. 1.2.3 Planning Commission Meetings The Consultant will be expected to attend and assist with presenting at as many as eight (8) Planning Commission (PC) Work Sessions to provide project updates, summarize public engagement, and receive advisory input at key points throughout the Plan update process. The Consultant is also expected to attend and participate in up to two (2) PC public hearings related to the adoption of code amendments. In addition, the Consultant will coordinate with the City Project Manager to prepare the necessary documents, including staff reports and presentation materials for all PC work sessions and hearings. Products/Deliverables: In-person attendance and participation at up to eight (8) Planning Commission (PC) Work Sessions and up to two (2) PC hearings; Coordination and preparation of materials in advance of study sessions and hearings. 2.0 Public Participation + Community Involvement Public involvement is essential to delivering a successful code audit and meaningful code amendments. Effective policies are built with community input and shared ownership. This public participation effort is not a separate task—it is a core part of the entire work plan. The Consultant, with City support, will lead this effort, ensuring that all work reflects community priorities and incorporates public feedback. PP 25-0002 ATTACH 1/PAGE 19 OF 27 Community Development Code Audit DRAFT Scope of Work Page 8 The process includes identifying stakeholders across multiple audiences whose input is critical in shaping the audit report and code amendments. A specific Public Involvement Strategy will be drafted which incorporates community issues and concerns as part of the planning process. The Draft Public Involvement Strategy will then be presented to the TAC and the Planning Commission (PC) for further refinement. Upon acceptance of the final Public Involvement Strategy, the Consultant will execute the strategy and manage public communications and outreach efforts, with an eye towards gaining broad- based support for the Plan. 2.1 Manage Public Involvement Process The Consultant will manage the public involvement process in collaboration with the City, based on the public involvement strategy produced in Task 2.2 below. Throughout the process, the Consultant and the City will continue to review and refine the public involvement strategy to maximize opportunities for citizen participation and meaningful involvement. 2.2 Public Involvement Strategy The Consultant will prepare a Draft Public Involvement Strategy and submit to staff, the TAC and PC – who acts as the Commission for Citizen Involvement (CCI)- for review and comment. The Public Involvement Strategy will be the “roadmap” that guides public planning efforts for the project, with the goal of preparing final recommendations with broad community support. The Strategy will include: • Recommended public events (workshops, open houses, presentations, etc.) for broad dissemination of information; and • A communications strategy for keeping the public informed of the process. Based on comments received from staff, the TAC, and the PC/CCI, the Consultant will refine the Public Involvement Strategy and move forward with its implementation. It is anticipated that Consultant and the City will revisit the document throughout the planning process, and continue refining the strategy to ensure that opportunities for public involvement are maximized. Product/Deliverable: Draft and Final Public Involvement Strategy 2.2.1 Public Events Consistent with the final Public Involvement Strategy, the Consultant will plan, organize, and manage a series of public events (open houses, workshops, or similar formats) with the goal of providing a wider audience with an opportunity to review work products and provide feedback to the Consultant team as well as to the TAC. In advance of the public events, staff will create a mailing list comprised of interested parties/stakeholders, including property owners, residents, and businesses. The City will prepare and mail meeting invitations, with at least two weeks’ notice provided to potential attendees. Following the events, the Consultant will provide a summary of results, comments, and other feedback received at the events. PP 25-0002 ATTACH 1/PAGE 20 OF 27 Community Development Code Audit DRAFT Scope of Work Page 9 Products/Deliverables: Three Public Events (TBD); Event Summaries 2.2.2 Communications/Webpage Good communication with interested citizens and other stakeholders is critical to the success of this effort. Throughout the planning process, the Consultant will maintain open lines of communication with the stakeholder groups as well as with each of the committees working on the project. An interested party list shall be developed at all public events to allow people to sign up for updates and other relevant information. The City shall be responsible for maintaining and sending information to people on the interested party list. At key points in the process, press releases, website updates or similar products shall be produced to broadly communicate the work efforts to date and to highlight upcoming events. The City will set up a project web site as an additional means for interested parties to keep abreast of the planning process and communicate with the team. Products/Deliverables: Periodical Newsletters; Web site design/upkeep 2.2.3 Stakeholder Focus Group As part of the Public Involvement Strategy, the Consultant will be expected to prepare and facilitate a Stakeholder Focus Group that includes people who regularly use the CDC, such as developers and land use planning professionals with experience in Lake Oswego. The Focus Group will be used to gather qualitative input regarding the barriers to housing and economic development in the CDC. Products/Deliverables: Stakeholder Focus Group materials and event facilitation 2.2.4 Online Engagement Tool As part of the Public Involvement Strategy, the Consultant will prepare an Online Engagement Tool that can be posted on the City’s website in order to receive input from a larger number of people in the City on the project. The format of the engagement tool has not been specifically defined, and the Consultant will be expected to propose an effective tool (i.e. – online survey, interactive map, or similar) that will allow the project team to gather public feedback based on the information identified in earlier project tasks. Products/Deliverables: Online Engagement Tool 2.2.5 Engagement Summary Report The Consultant will prepare an Engagement Summary Report that summarizes the key findings from the Stakeholder Focus Group, Online Engagement Tool, and any public events that have been held up to that point (as defined in the Public Involvement Strategy). The Engagement Summary Report will then be presented to the City Council, the PC, and the TAC, as determined by the Public Involvement Strategy. PP 25-0002 ATTACH 1/PAGE 21 OF 27 Community Development Code Audit DRAFT Scope of Work Page 10 Consultant will have biweekly check-ins with the City to discuss major project milestones and work products, address questions, and identify follow-up actions. Products/Deliverables: Engagement Summary Report 3.0 Project Kickoff - Background and Analysis The purpose of the project kickoff is for the Consultant to become familiar with local conditions, the CDC, and other relevant Planning documents; and for the parties to confirm the objectives of the project and refine the project schedule. The Consultant will meet with staff to establish the project expectations and familiarize themselves with City-specific concerns. The information gathered during this phase of work will provide a solid basis for the scope of the audit and subsequent refinements of the report. The Consultant will develop an action item list as identified through these initial meetings and will develop and share a proposed schedule for the completion of all tasks (See Task 1.1.1). The level of detail required for the proposed project schedule will be determined by mutual agreement by the City and the Consultant. 3.1 Background Report Staff will provide the Consultant with an initial list of issues identified as potential barriers to housing and/or business development. This list will help the Consultant get a basic understanding of the types of issues staff is experiencing and the overall complexity of the CDC. Products/Deliverables: Background Report 3.2 Initial CDC Review The Consultant will review the CDC to identify specific code sections that are related to the obstacles and opportunities identified during the Background Report memo. The Initial CDC Review Memo, along with the Background Report, will be presented to the PC, the TAC, and elsewhere as determined by the Public Involvement Strategy. Products/Deliverables: Initial CDC Review Memo 4.0 Draft Code Audit Building on information provided in the background and research phase, the Consultant will prepare an initial draft CDC Code Audit Report presented to staff for review and comments, then prepare a second draft report that will be presented to the City Council, PC, TAC, and general public. The draft Report will include: • Lists of specific places in the CDC that will require updates in order to be compliant with existing State land use laws, as well as those that will be passed during the 2025 legislative session. • An outline of CDC standards or procedures that have the effect of discouraging housing through unreasonable cost or delay. • Identification of specific areas in the CDC that could be streamlined, clarified, or amended for PP 25-0002 ATTACH 1/PAGE 22 OF 27 Community Development Code Audit DRAFT Scope of Work Page 11 greater effectiveness, including potential zoning district and overlay consolidation and simplification of development standards or processes. Products/Deliverables: • Drafts of the Code Audit Report findings • Presentation materials for findings 4.1 Draft Recommendations The draft CDC Code Audit Report will include recommended improvements to the CDC. The Consultant will draft memo an Initial Recommendation Memo that will include: • Strategies that specifically address the obstacles to development within the CDC, including specific recommendations on how the CDC should be amended to address the obstacles. • An action plan that will allow staff to move forward quickly into the code drafting and adoption process. Products/Deliverables: • Initial Recommendations Memo • Presentation materials for recommendations 5.0 Final Code Audit Report The Consultant will prepare the Final Code Audit Report, which includes revisions that reflect input learned from staff, the TAC and public outreach as part of the draft Code Audit phase. The Final Code Audit Report will include recommendations on the types of changes to implement the solutions identified. The Final Audit Report will be presented to City Council, the PC, the TAC, and at open houses or focus groups as determined by the Public Involvement Strategy. The project team will assemble comments received and forward recommendations on how to respond to those comments to the TAC. The project team will identify the Code Audit Report recommendations that should move forward in light of the feedback received, then present the Final Code Audit Report to the TAC and public forum for a second round of comments. Products/Deliverables: • Final Code Audit findings and recommendations • Presentation materials for findings and recommendations 6.0 Draft Code Amendments After review of the findings and recommendations of the Final Code Audit Report with comments received from the TAC and public, the Consultant and staff will prepare draft amendments for modifying the CDC as recommended by the Action Plan in the Code Audit Report. The amendments will be presented to City Council, the TAC, the PC (at two work sessions), and to the public for review and comment, as determined by the Public Involvement Strategy. Following revisions of the draft code amendments based on the comments and feedback received, the project team will refine and finalize the document as described in #7 below. PP 25-0002 ATTACH 1/PAGE 23 OF 27 Community Development Code Audit DRAFT Scope of Work Page 12 Products/Deliverables: • Draft CDC ordinance, code graphics, exhibits, and submittal package. • Presentation materials to explain draft to TAC and the public 7.0 Adoption of Code Amendments Staff will prepare final draft code amendment documents supplemented with necessary exhibits, and assembled into a format that will allow it to be submitted for public hearings with the Planning Commission and, ultimately, City Council, for those bodies’ review and consideration. The final documents will be delivered in double underline/strikeout (showing new and deleted text) to indicate changes to the existing code language. Staff will schedule and provide notice and agenda for hearings to adopt the code amendments. The Consultant will coordinate with staff on hearing arrangements and creating presentations for the PC and City Council hearings. Products/Deliverables: • Final Code amendment, ordinance, and exhibits submittal package • Revised presentation materials for PC and City Council Hearings Work Schedule and Budget: PROJECT MILESTONE DATE DUE 1 Project Kick-Off Background Report and CDC Review Draft Public Involvement Strategy and form TAC January 2026 February 2026 March 2026 2 Perform Audit: CDC Review and Public Outreach July 2026 3 Draft and Final Audit Report First Draft of Code Audit Draft Recommendations Memo Second Draft of Code Audit Final Draft August 2026 September 2026 October 2026 November 2026 4 Draft Code Amendments March 2027 5 Adopt Code Amendments August 2027 Task #0: Consultant Selection Timeline: October – December 2025 Estimated Consultant Cost: $0 (Planning Staff) PP 25-0002 ATTACH 1/PAGE 24 OF 27 Community Development Code Audit DRAFT Scope of Work Page 13 Task #1: Project Kick-Off Timeline: January – March 2026 Estimated Consultant Cost: $35,000 Task #2: Perform Audit Timeline: April – July 2026 Estimated Consultant Cost: $65,000 Task #3: Draft Audit Report and Recommendations Timeline: August – November 2026 Estimated Consultant Cost: $96,000 Task #4: Draft Code Amendments Timeline: December 2026 – March 2027 Estimated Consultant Cost: $90,000 Task #5: Adopt Code Amendment Timeline: April – August 2027 Estimated Consultant Cost: $20,000 Budget Total: $306,000 PP 25-0002 ATTACH 1/PAGE 25 OF 27 Appendix B - Proposed Project Budget Community Development Code Audit: Housing and Business Analysis Grant Funds Requested: $306,000 Other funds Pledged: $0 PROJECT COMPONENT CONSULTANT FEES STAFF TIME, IF APPLICABLE (MAY NOT EXCEED 20% OF TOTAL GRANT REQUEST ) CBO PARTICIPATION AND/OR COMMUNITY LIAISON (IF APPLICABLE) OTHER DIRECT PROJECT COSTS TOTAL (Phase, element, deliverable, etc.) Task #1: Project Kick-off: Background and Draft Public Involvement Strategy $ 35,000 $ - $ - $ - $ 35,000 Task #2: Perform Audit $ 65,000 $ - $ - $ - $ 65,000 Task #3: Draft/Final Audit Report and Recommendations $ 96,000 $ - $ - $ - $ 96,000 Task #4: Draft Code Amendments $ 90,000 $ - $ - $ - $ 90,000 Task #5: Adopt Code Amendments $ 20,000 $ - $ - $ - $ 20,000 $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - TOTAL PROJECT BUDGET $ 306,000 PP 25-0002 ATTACH 1/PAGE 26 OF 27 Appendix C: Project Timelline Community Development Code Audit Project 7/10/2025 Tasks Months Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug 0.0 - Request for Proposals 3 1.0 - Project Initiation 3 2.0 - Perform Audit 4 3.0 - Draft Audit Report and Recommendations 4 4.0 - Draft Code Amendments 4 5.0 - Adopt Code Amendments 5 Total 23 2025 2026 2027 PP 25-0002 ATTACH 1/PAGE 27 OF 27