HomeMy WebLinkAboutAppeal Narrative
Geoffrey M. Wardle
(208) 388-3321
gwardle@clarkwardle.com
Via Citizen Access Portal Submission
April 15, 2026
City of Meridian
Meridian City Council
33 E Broadway Ave
Suite 102
Meridian, ID 83642
RE: City Council Review – Appeal of Denial on ACZCU-2026-0002
CW File #: 24446.1
This appeal of Meridian Staff’s denial of CZCU-2025-0002 is submitted pursuant to Section 11-5A-7 of
the Meridian City Code.
In support of this request, we provide the application materials that were previously submitted and the
following analysis.
A. Introduction
We represent Long Dog, LLC the owner of 100 S. Adkins Way, in Meridian, Idaho. The building currently
has two tenants that occupy approximately 50% of the gross space. A construction company occupies
3,150 square feet and a classic car broker occupies 750 square feet. The remainder of the building was
previously occupied by the Idaho Division of Vocational Rehabilitation until it vacated the premises.
Long Dog acquired this property because it was “flex space”, enabling Long Dog to have investment
income from the existing tenants while allowing Long Dog’s members to utilize the space vacated by
Vocational Rehabilitation for their other business interests. The members of Long Dog are also the
principals in Ketlinski Law Office, PLLC. The members of Long Dog also have a collection of classic
vehicles that they desire to store in a single location. One of the members of Long Dog is a Certified
Functional Strength Coach who is starting a strength training and coaching business and the other is in
Date: April 15, 2026
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Meridian Appeal Narrative - 2
the preliminary stages of creating a new animal-related business that is a principal permitted use within
the zone, both of which could be operated jointly out of these premises.
To that end, Long Dog desires to initiate a remodel of the space to modify it from the office
configuration used by Vocational Rehabilitation to house all of Long Dog’s members’ business interests,
by converting three existing offices into warehouse and storage space accessible through the roll up
door, by creating a larger meeting space from two existing offices, and by including an additional
restroom replacing an office. Long Dog’s proposed remodel of this portion of the building increases its
functionality as “flex space” and in fact makes it more compatible with the IL Zone, by facilitating uses
contemplated in the zone and reducing the amount of existing office space.
Due to that desire to remodel, Long Dog requested a building permit but was denied the ability to
remodel this property by Meridian Staff. This application was initiated to ensure that there was an
application appealable under the Local Land Use Planning Act, specifically, Idaho Code 67 -6519; Idaho
Code 67-6521, and Idaho Code 67-6535, and a complete, supportive record of the City’s actions.
Meridian Staff’s denial of CZCU-2025-0002 is appealed for the following reasons:
• Requiring a certificate of zoning compliance to convert space that provided personal and
professional services to one that will provide personal and professional services violates the
takings clauses and the due process clauses of both the Idaho and United States Constitutions.
• Requiring a certificate of zoning compliance for a mere change in the user of property where the
use remains the same violates the takings clauses and the due process clauses of both the Idaho
and United States Constitutions.
• Denial of this application by Meridian Staff is an act that is arbitrary, capricious, and an abuse of
discretion.
• Denial of this application contravenes the intention of the Idaho legislature in its recent
enactment of S1326, the “Property Rights Protection Act”, signed into law by Governor Little on
March 31, 2026, and effective upon its passage and approval.
In support of this appeal, we provide the following additional analysis.
B. Argument on Appeal
Long Dog seeks to modify space that has long been used for professional and personal services for the
personal commercial use of its members, through the conversion of the space to facilitate its members’
law office, vehicle storage, and potential training facility. There are no exterior modifications to the
property other than the construction of the proposed roll up door. The property was originally
approved for development and platted more than thirty years ago.
1. “Flex space” is the Use.
We note, that there has long been confusion on the part of Meridian Staff how “flex space” is intended
to function. That confusion appears rooted in the fact that there is an unwillingness in any zone to
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Meridian Appeal Narrative - 3
acknowledge “flex space” as an actual use. The analysis that Meridian Staff has applied here (“When a
building includes multiple tenant spaces, however, the City analyzes each tenant space separately”) is
wholly inconsistent with the plain language of the UDC and how “flex space” is intended to function.
“Flex space” is defined in Meridian City Code Section 11-12-1 as “the use of a building or a portion
thereof for small scale warehousing and/or light industry with associated office and/or retail showroom
space. Flexibility in the use of the interior spaces and low scale, attractive exterior appearance
characterize flex buildings.” Thus, “flex space” is clearly defined as a distinct use that combines these
other elements. And the members of Long Dog’s legal practice is associated with Long Dog’s ownership
of the property, and use of other permitted or conditional uses as part of a multi tenant investment
property.
2. The Use, “Flex Space”, is Subject to Specific Use Standards
Why do we note that “flex space” is the designated use? It is because Meridian City Code Section 11 -4-1
reiterates that the purpose of the “Specific Use Standards” are as follows:
This chapter provides specific standards for all uses as set forth within
the applicable district in accord with chapter 2, "district regulations",
of this title.
Moreover, the Specific Use Standards have specified applicability to the entirety of “any property where
the specific use is listed” under Meridian City Code Section 11-4-2:
These regulations apply to any property where the specific use is listed
as a permitted, accessory, or conditional use in the tables of allowed
uses by district in accord with chapter 2, "district regulations", of this
title. It shall be unlawful and a violation of this title for any person to
use, construct, locate, initiate, alter, or maintain any structure, land or
real property, or cause any structure, land, or real property to be used,
constructed, located, initiated or maintained, in any manner which
violates, omits, or fails to conform to any procedure, standard or
requirement set forth in this chapter.
Meridian’s Staff’s premise by premise analysis is inconsistent with Meridian City Code and deprives
owners of “flex space” the value of their properties, by functionally prohibiting “flex space” as a use for
multi-tenant buildings.
3. Meridian is not Consistent in its Interpretation of its Code
Moreover, Meridian’s recognition of the importance of “flex space” as such, was reiterated most
recently in the City of Meridian’s adoption of Ordinance No. 25-2099. As implicitly acknowledged in
Ordinance No. 25-2099, once “flex space” is designated as the use, the user must also satisfy the specific
use standards found in Meridian City Code Section 11-4-3-18, which we restate here for convenience:
Date: April 15, 2026
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Meridian Appeal Narrative - 4
A. Office and/or retail showroom areas shall comprise a minimum of
thirty (30) percent of the structure and/or tenant space in the C -C
District, fifteen (15) percent in the C-G District, ten (10) percent in the
M-E District, and twenty (20) percent in the I-L and I-H Districts.
B. Light industry and warehousing shall not comprise more than seventy
(70) percent of the tenant space in the C-C District, seventy-five (75)
percent in the C-G and M-E Districts, and eighty (80) percent in the I-L
and I-H Districts.
C. In the C-C, C-G and M-E Districts, roll-up doors and loading docks shall
not be visible from a public street.
D. Retail use shall not exceed twenty-five (25) percent of leasable area
in any tenant space.
E. At a minimum, one (1) parking space shall be provided for every one
thousand (1,000) square feet of gross floor area.
If a “flex space” property complies with the specific requirements of Meridian City Code Section 11 -4-3-
18, and the ratios of the uses set forth above, then the evaluation of what uses take place within the
“flex space”, except for compliance with building codes and life safety requirements, ends. Meridian has
adopted ratios of use within the “flex space” use that are independent of the land uses that are
otherwise permitted. The individual tenant premises analysis Meridian Staff utilizes has no basis in
these specific use standards.
This interpretation is evidenced by Meridian City Code Table 11-2B-2, the table of allowed uses within
commercial districts as well as Meridian City Code Table 11-2C-2, the table of allowed uses within
industrial districts.
First, the use “office” is not expressly identified in either Meridian City Code Table 11-2B-2 or Meridian
City Code Table 11-2C-2. There are various uses which certainly necessitate offices therein, but in and
of itself, office is not a use that is specified as prohibited, permitted, accessory or conditional. Yet,
pursuant to Meridian City Code Section 11-4-3-18(A) there are specified minimums within “flex space”
for “office and/or retail showroom areas”. In establishing the minimum of twenty (20) percent in the I -L
District, it is clear that office use and retail use are contemplated to be much more than merely an
accessory use within the I-L District as otherwise designated in Meridian City Code Table 11-2C-2.
Next, Meridian City Code Table 11-2B-2 establishes that “Warehouse” is prohibited within the C-C
District and is authorized only as an accessory use within the C -G District. Moreover, pursuant to
Meridian City Code Table 11-2B-2 the use “Industry, light” is also prohibited within the C -C District
while permitted with a conditional use permit in the C -G District. Notwithstanding those prohibitions,
we note that pursuant to Meridian City Code Section 11-4-3-18(B) that those two uses are actually
permitted within either of the C-C District or the C-G districts up to 70% and 75% of the “tenant space”
respectively when “flex space”. In this instance, “associated” as cited by Meridian Staff in the definition
Date: April 15, 2026
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Meridian Appeal Narrative - 5
of “flex space” is doing significant work since the “associated” uses are neither permitted, nor
conditional, nor accessory. The uses that Long Dog proposes for its property are in fact either
permitted, or conditional, or accessory.
Thus, we see that because “flex use” is the use, other than satisfaction of the amendments to Meridian
City Code Section 11-4-3-18, further evaluation of additional uses within in the structure are irrelevant.
Nothing in these recent amendments support the notion articulated in Meridian Staff’s denial of this
request that for a multi tenant building the City is to analyze each space distinctly and divorced from the
facts underlying the proposed “flex space” use.
4. Meridian is not Consistent in its Enforcement of its Code
We have repeatedly heard Meridian Staff claim that they merely seek to preserve the IL Light Industrial
Zone for light industrial uses as the rationale for why certain other commercial uses have been excluded,
Meridian’s economic base requires buildings in the IL Zone, and that is why Meridian Staff is so
protective in its interpretation of the UDC.
However, that belief is far from reality.
Meridian has repeatedly and willingly granted conditional use permits for recreational and personal
services within the IL Zone, without any of the concerns articulated about the impact that it has upon
the stock of “flex space” within the IL Zone. Among these most recent grants of conditional use permits
for recreation and personal service uses by the City of Meridian are the following:
• K1 Speed CUP H-2021-0077
• Black Box VR CUP H-2023-0022
• Daily Fit Bod CUP H 2023-0060
• The Base Jiu Jitsu CUP H 2023-0032
• Treasure Valley Athletic Center MCU-2024-0003
• Elite Fitness CUP H-2025-0021
• Uplifted Gym CUP-H2025-0023
• The Tee Box CUP H-2025-0056
We acknowledge that Meridian Staff will respond “but indoor recreation is a conditional use”, which it
is. But in reviewing the staff reports and the decisions adopted in the approval of those conditional use
permits, neither the planning and zoning commission nor the city council have ever adopted the analysis
and process that Meridian Staff has articulated with respect to office uses that desire the flexibility
afforded by “flex space”.
Date: April 15, 2026
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Meridian Appeal Narrative - 6
The concern articulated by Meridian Staff, however, is further belied by the lack of enforcement of
professional and personal service office prohibitions within the IL Zone. Various other service office
uses have been allowed to exist throughout the IL Zone in Meridian, including:
• Land Use Solutions – 231 E. 5th Street
• Farmer’s Insurance – 226 E 5th Street
• Assurity Drug and Alcohol Testing – 480 E. Frankling Road, Suite 102
• Idaho Horse Rescue – 890 E Franklin Road, Suite 202
The foregoing is not an exhaustive list of conditional uses allowed within the IL Zone, nor an attempt to
compel existing commercial uses to be curtailed. The foregoing are offered as evidence of the arbitrary
and inconsistent manner in which Meridian Staff has applied the relevant code.
The rise of “flex space” as a use and the City’s expansion of its permissibility to additional zones, has
corresponded to the fundamental recognition that truly mixed use commercial spaces are necessary in
today’s economy. The rigid notions of Euclidian Zoning have been abandoned by many jurisdictions,
including Meridian, in the embrace of mixed use development.
Certainly, at the time of those evaluations, Meridian Staff lacked the benefit of the 2025 amendments
to Meridian City Code Section 11-4-3-18. By acknowledging that a minimum amount of office or retail
activity is required in “flex space” even in zones that otherwise limit them to being accessory uses, and
that warehousing activities are permitted “flex space” activities within zones that clearly prohibit it, it is
clear that the City Council has determined that the analysis of “flex space” begins and ends with the
building as a whole and that Meridian Staff’s ongoing retreat into the depths of the Meridian City Code
to do a secondary evaluation of the use is erroneous.
It does not seem plausible, especially in light of the City Council’s 2025 amendments to Meridian City
Code Section 11-4-3-18, that the City of Meridian seeks to punish so many small businesses and small
property owners with unreasonable and uneven enforcement of its code regarding “flex space”,
especially in older properties like this one that have had several cycles of diverse tenants. The uneven
nature of enforcement of limitations on office uses within “flex space” is evident from our review of
similarly zoned and developed properties throughout Meridian.
C. Conclusion
Long Dog purchased this property because it would permit its members to consolidate all of their
desired professional and personal uses in a single location. They know the neighboring uses, they know
the tenants that they have and desire to maintain. They selected this property exactly because it was
permitted “flex space” and do not desire to materially modify the use, rather they seek to make the
space more compliant with “flex space” through its renovation.
Consistent with the foregoing and this application, on behalf of our clients we respectfully request the
following:
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Meridian Appeal Narrative - 7
• Approval of a Certificate of Zoning Compliance requested above for Long Dog,
LLC.
• Approval of the site plan that it has proposed to facilitate its intended leases for
the space.
• Authorization to proceed to obtain a building permit for those improvements.
• Additionally, the City should amend its ordinances so that office uses that seek
the ability to have “flex space” elements, i.e. storage, warehousing, roll up
doors and the like, are permitted as a conditional use, just like gyms, training
facilities, dance studios, and martial arts studios.
We look forward to this matter being heard by the City Council.
Sincerely,
Geoffrey M. Wardle
Application Narrative
Geoffrey M. Wardle
(208) 388-3321
gwardle@clarkwardle.com
Via Citizen Access Portal Submission
March 25, 2026
City of Meridian
Community Development
Planning Division
33 E Broadway Ave
Suite 102
Meridian, ID 83642
RE: Long Dog, LLC – 100 S Adkins
CW File #: 24446.1
City of Meridian:
We represent Long Dog, LLC, the owner of 100 S. Adkins Way, in Meridian, Idaho. 100 S. Adkins is a
multitenant flex building that has a gross area of approximately 8,400 square feet.
A. Background
The property has been zoned I-L Light Industrial since its original annexation into the City of Meridian in
1997 with the development of the Medimont Subdivision. The building has been and continues to be
utilized as “flex space”. It has all of the indicia of flex space.
The building currently has two tenants that occupy approximately 50% of the gross space. A construction
company occupies 3,150 square feet and a classic car broker occupies 750 square feet. The remainder of
the building was previously occupied by the Idaho Division of Vocational Rehabilitation until it vacated the
premises.
In addition to the leasing of the premises to these existing tenants, the principals of Long Dog, LLC, have
certain additional business interests that they own and desire to operate from the property as tenants of
Long Dog, LLC, including their personal offices of Ketlinski & Ketlinski and personal vehicle warehouse
storage. As the owner of the building, Long Dog’s principals derive the benefit and value of it as an
investment property leasing portions to others, as well as for their own permitted purposes within “flex
Date: March 25, 2026
Page: 2
space,” and further desire to operate the principals private offices from the property. That is the essence
of “flex space”, as further described and discussed below.
To that end, they desire to initiate a remodel of the space to reconfigure it from the manner in which
Vocational Rehabilitation utilized it, to add certain additional facilities and spaces, incorporate a roll up
door, and make other improvements. An initial schematic of this proposed renovation is depicted in
Exhibit A attached hereto, and incorporated herein for reference.
B. Application Request and Legal Standards
It is our understanding from our clients’ initial communication with the City of Meridian that they have
been informed that professional services cannot be performed within “flex space” in the IL District. We
believe that this is an incorrect interpretation of the code, especially based on the recent actions of the
City Council. To ensure that the City of Meridian has a fully developed request before it, we make this
application for a Certificate of Zoning Compliance, pursuant to Section 11 -5B-1. We note that there are
no modifications proposed to the property, other than the construction of the proposed roll up door, and
the interior remodel. The property was originally approved for development and platted, more than thirty
years ago. As to this property, except as noted above, there are no exterior modifications to the
landscaping, parking lot, lighting or other exterior elements of the existing structure. As such, in reviewing
the Certificate of Zoning Compliance checklist, various elements are not provided as there is no exterior
change to the property, other than the installation of the roll up door. As such, It does not appear that
there is a need for Trash Enclosure Approval; a Photometric Plat, Landscape Plan, Elevations, Autocad
Files, or Public Utility Plan, as none of the identified work implicates or necessitates modification of the
previously approved documents associated with the original construction of the building.
1. “Flex space” is the Use.
We note, that there has long been confusion on the part of Meridian Staff how “flex space” is intended to
function. That confusion appears rooted in the fact that there is an unwillingness in any zone to
acknowledge “flex space” as an actual use. It is.
“Flex space” is defined in Meridian City Code Section 11-12-1 as “the use of a building or a portion thereof
for small scale warehousing and/or light industry with associated office and/or retail showroom space.
Flexibility in the use of the interior spaces and low scale, attractive exterior appearance characterize flex
buildings.” Thus, “flex space” is clearly defined as a distinct use that combines these other elements.
2. The Use, “Flex Space”, is Subject to Specific Use Standards
Why do we note that “flex space” is the designated use? It is because Meridian City Code Section 11 -4-1
reiterates that the purpose of the “Specific Use Standards” are as follows:
This chapter provides specific standards for all uses as set forth within the
applicable district in accord with chapter 2, "district regulations", of this title.
Moreover, the Specific Use Standards have specified applicability to the entirety of “any property where
the specific use is listed” under Meridian City Code Section 11-4-2:
Date: March 25, 2026
Page: 3
These regulations apply to any property where the specific use is listed as a
permitted, accessory, or conditional use in the tables of allowed uses by district
in accord with chapter 2, "district regulations", of this title. It shall be unlawful
and a violation of this title for any person to use, construct, locate, initiate, alter,
or maintain any structure, land or real property, or cause any structure, land, or
real property to be used, constructed, located, initiated or maintained, in any
manner which violates, omits, or fails to conform to any procedure, standard or
requirement set forth in this chapter.
3. The Use Specific Standards for “Flex Space” Reaffirm it as the Use.
As a specified use, the importance of “flex space” as a such, was reiterated most recently in the City of
Meridian’s adoption of Ordinance No. 25-2099. As implicitly acknowledged in Ordinance No. 25-2099,
once “flex place” is designated as the use, the user must also satisfy the specific use standards found in
Meridian City Code Section 11-4-3-18, which we restate here for convenience:
A. Office and/or retail showroom areas shall comprise a minimum of
thirty (30) percent of the structure and/or tenant space in the C-C District,
fifteen (15) percent in the C-G District, ten (10) percent in the M-E
District, and twenty (20) percent in the I-L and I-H Districts.
B. Light industry and warehousing shall not comprise more than seventy
(70) percent of the tenant space in the C-C District, seventy-five (75)
percent in the C-G and M-E Districts, and eighty (80) percent in the I-L and
I-H Districts.
C. In the C-C, C-G and M-E Districts, roll-up doors and loading docks shall
not be visible from a public street.
D. Retail use shall not exceed twenty-five (25) percent of leasable area in
any tenant space.
E. At a minimum, one (1) parking space shall be provided for every one
thousand (1,000) square feet of gross floor area.
If a “flex space” property complies with the specific requirements of Meridian City Code Section 11 -4-3-
18, and the ratios of the uses set forth above, then the evaluation of what uses take place within the flex
space, except for compliance with building codes and life safety requirements end. Meridian has adopted
ratios of use within the “flex space” use that are independent of the land uses that are otherwise
permitted.
This interpretation is evidenced by Meridian City Code Table 11-2B-2, the table of allowed uses within
commercial districts as well as Meridian City Code Table 11-2C-2, the table of allowed uses within
industrial districts.
Date: March 25, 2026
Page: 4
First, the use “office” is not expressly identified in either Meridian City Code Table 11-2B-2 or Meridian
City Code Table 11-2C-2. There are various uses which certainly necessitate offices therein, but in and
of itself, office is not a use that is specified as prohibited, permitted, accessor or conditional. Yet,
pursuant to Meridian City Code Section 11-4-3-18(A) there are specified minimums within “flex space”
for “office and/or retail showroom areas”. In establishing the minimum of twenty (20) percent in the I-L
District, it is clear that office use and retail use are contemplated to be much more than merely an
accessory use within the I-L District as otherwise designated in Meridian City Code Table 11-2C-2.
Next, although Meridian City Code Table 11-2B-2 demonstrates that “Warehouse” is prohibited within
the C-C District and is authorized only as an accessory use within the C-G District. Moreover, pursuant to
Meridian City Code Table 11-2B-2 the use “Industry, light” is also prohibited within the C -C District while
permitted with a conditional use permit in the C -G District. Notwithstanding those prohibitions, we
note that pursuant to Meridian City Code Section 11-4-3-18(B) that those two uses are actually permitted
within either of the C-C District or the C-G districts up to 70% and 75% of the “tenant space” respectively
when “flex space”.
Thus, we see that because “flex use” is the use, other than satisfaction of the amendments to Meridian
City Code Section 11-4-3-18, further evaluation of additional uses within in the structure are irrelevant.
4. Historic Custom and Practice is Inconsistent with Meridian City Code as Amended.
As noted above, our client has been informed that its request to utilize a portion of 100 S. Adkins Way for
the provision of professional services, in addition to the existing tenancies, is not permitted as “flex
space.” In preparation of this application we have reviewed and evaluated certain prior applications that
have been initiated.
In April 2023, an application for tenant improvements at 50 S. Adkins, next door to this property was
initiated for office and storage space for a professional surveyor. The communication among the applicant
and Meridian Staff is attached as Exhibit B. Although Meridian Staff acknowledged that the space was
“flex space” and did comply with the then-existing “specific use standards,” it rejected the application
because it “appears to be only office space.” Staff did so, invoking the “North American Industry
Classification System”.
However, this appears to be a misapplication of Meridian City Code Section 11-1-5(E), regarding the
interpretation of the code, which provides as follows:
Allowed uses. If a proposed use of property is not specifically listed in
chapter 2, "district regulations", of this title, the use shall be prohibited,
except as follows: The director may determine that a proposed use not
listed in chapter 2, "district regulations", o f this title, is equivalent to a
principal permitted or conditional use. In making the determination, the
Director shall consider the following:
Date: March 25, 2026
Page: 5
1. The impacts on public services and activities associated with the
proposed use are substantially similar to those of one (1) or more of the
uses listed in the applicable base districts as allowed;
2. The proposed use shall not involve a higher level of activity or density
than one (1) or more of the uses listed in the applicable base districts
as allowed;
3. The proposed use is within the same three (3) digit category of an
allowed use listed in the latest edition of the "North American Industrial
Classification System (NAIC)", published by the United States
Department of Commerce;
4. The proposed use is consistent with the purpose of the district in
which the use is proposed to be located; and
5. The proposed use is in substantial conformance with goals and
objectives of the comprehensive plan.
As noted therein, analysis of the “North American Industry Classification System” is but one of five factors
that the “Director shall consider.” Even after acknowledging that the proposed surveyor use was part of
a “flex space” building and with the elements associated with professional surveying, Meridian Staff
clearly invoked Meridian City Code Section 11-1-5(E)(3) without conducting the full, mandatory analysis.
Similarly, in the same building 50 S. Adkin in 2024, a request was raised regarding the ability of a
property management company to occupy space with its office and the remainder utilized for storage
supporting its operations. The communication among the applicant Meridian Staff is attached as Exhibit
C. Again, rather than focusing on the existence and status of the building as “flex space” and the inherent
nature of the proposed use as “flex space”, Meridian staff went through an unnecessarily convoluted,
even if ultimately positive determination, that yes, a property management company was permitted to
operate within “flex space” deeming it to be “warehouse.”
Certainly, at the time of those evaluations, Meridian Staff lacked the benefit of the 2025 amendments
to Meridian City Code Section 11-4-3-18. By acknowledging that a minimum amount of office or retail
activity is required in “flex space” even in zones that otherwise limit them to being accessory uses, and
that warehousing activities are permitted “flex space” activities within zones that clearly prohibit it, it is
clear that the City Council has determined that the analysis of “flex space” begins and ends with the
building as a whole and that Meridian Staff’s ongoing retreat into the depths of the Meridian City Code to
do a secondary evaluation of the use is erroneous.
It does not seem plausible, especially in light of the City Council’s 2025 amendments to Meridian City Code
Section 11-4-3-18, that the City of Meridian seeks to punish so many small businesses and small property
owners with unreasonable and uneven enforcement of its code regarding “flex space”, especially in older
properties like this one that have had several cycles of diverse tenants. The uneven nature of enforcement
Date: March 25, 2026
Page: 6
of limitations on office uses within “flex space” is evident from our review of similarly zoned and
developed properties throughout Meridian.
C. Conclusion.
Consistent with the foregoing and this application, on behalf of our clients we respectfully request the
following:
• Approval of a Certificate of Zoning Compliance requested above for Long Dog,
LLC.
• Approval of the site plan that it has proposed to facilitate its intended leases for
the space.
• Authorization to proceed to obtain a building permit for those improvements.
If Meridian Staff is unable or unwilling to do so, then we request a final written decision on this matter as
soon as practicable so that we may proceed with an appeal to the Meridian City Council.
In support of this Application we provide the following additional documents:
• Application for Certificate of Zoning Compliance and supporting materials
• Exhibit A – Proposed site plan for a portion of 100 S. Adkins
• Exhibit B – April 2023 Correspondence
• Exhibit C – October 2024 Correspondence
Please let me know if you have any further questions or concerns.
Sincerely,
Geoffrey M. Wardle
cc: Client
Stacy Hersch, shersh@meridiancity.org
Paula Middleton, pmiddleton@meridiancity.org
Exhibit A
Proposed Site Plan
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COPYRIGHT C Arch, pllc 2025 DRAWINGS MAY NOT BE REUSED WITHOUT THE WRITTEN PERMISSION OF THE ARCHITECT
A Flex Space Tenant Improvement forLong Dog LLCMeridian, ID
Architecture + Planning
537 E. Forest Ridge DriveMeridian, Idaho 83642
(208) 921.0754
rch, pllc
Exhibit B
April 2023 Correspondence
From:Julia Garofalo on behalf of Julia Garofalo <jgarofalo@meridiancity.org>
To:Chris Anderson
Cc:Nick Napoli; Bill Parsons; Kegan Aman
Subject:RE: C-TI-2023-0046
Date:Tuesday, April 11, 2023 10:54:20 AM
Attachments:image002.png
Hey Chris,
I understand that we approved this space as a Flex Building, under permit C-SHELL-2021-0019, but
when we approved this building it showed space for 5 tenants therefore the proposed use that
moves into that space must comply with the allowed uses chart. As explained previously, the North
American Industry Classification System (NAICS), explains the use and how it would be classified in
our code.
Thank you,
Julia Garofalo | Assistant Planner
City of Meridian | Community Development
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208) 489-0601
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request, unless exempt from disclosure by law.
From: Chris Anderson <canderson@rudeenarchitects.com>
Sent: Tuesday, April 11, 2023 9:53 AM
To: Julia Garofalo <jgarofalo@meridiancity.org>
Cc: Nick Napoli <nnapoli@meridiancity.org>; Bill Parsons <bparsons@meridiancity.org>; Kegan
Aman <kaman@meridiancity.org>
Subject: RE: C-TI-2023-0046
External Sender - Please use caution with links or attachments.
Julia,
It is listed as a ‘A’, which indicates that it is an approved use as an accessory space. This tenant
occupies approximately 20% of the entire building, so it could be looked at as an accessory space to
the building as a whole. According to 11-2C-2A, it defines the types of business that are promoted
to be allowed in a light industrial area:
Light industrial district (I-L). The purpose of the I-L district is to provide for convenient employment
centers of light manufacturing, research and development, warehousing, and distributing. In
accord with the Meridian Comprehensive Plan, the I-L district is intended to encourage the
development of industrial uses that are clean, quiet and free of hazardous or objectionable
elements and that are operated, entirely, or almost entirely, within enclosed structures.
Accessibility to transportation systems is a requirement of this district.
Could we make the argument that survey engineers research information at a site and then develop
solutions for the problems identified at the site. I am just trying to look at the intent of the code to
see if this business can be a fit for the district. If we look at surrounding businesses that were
allowed in the I-L district, within a block from 50 Adkins Way, at 149 Adkins Way there is PermaCold
Engineering, listed as engineering consultants and 100 Adkins Way is Mechanical Drafting Services.
Both of these are similar business types that set a precedence in the area. Please let me know the
process in which the engineering consultants and drafting services went through to obtain a permit
and we would like to use the same procedure. Thank you once again for your time and your help.
Christopher T. Anderson
Project Manager
Rudeen Architects
Tel: +208.338.1413 Ext. 104
Direct: +208.954.8753
Email: canderson@rudeenarchitects.com
“When you abandon freedom to achieve security, you lose both and deserve neither” Thomas Jefferson
From: Julia Garofalo <jgarofalo@meridiancity.org>
Sent: Tuesday, April 11, 2023 9:11 AM
To: Chris Anderson <canderson@rudeenarchitects.com>
Cc: Nick Napoli <nnapoli@meridiancity.org>; Bill Parsons <bparsons@meridiancity.org>; Kegan
Aman <kaman@meridiancity.org>
Subject: RE: C-TI-2023-0046
Hello,
If the use was allowed with a Conditional Use permit approval, it would be listed with a ‘C’ on the
following chart. Please read through Article C. – Industrial Districts, information which I have linked
below.
11-2C-2 Industrial Districts, Allowed Uses
https://library.municode.com/id/meridian/codes/code_of_ordinances?
nodeId=TIT11UNDECO_CH2DIRE_ARTCINDI_11-2C-2ALUS
Thank you,
Julia Garofalo | Assistant Planner
City of Meridian | Community Development
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208) 489-0601
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request, unless exempt from disclosure by law.
From: Julia Garofalo
Sent: Tuesday, April 11, 2023 8:46 AM
To: 'canderson@rudeenarchitects.com' <canderson@rudeenarchitects.com>
Cc: Nick Napoli <nnapoli@meridiancity.org>; Bill Parsons <bparsons@meridiancity.org>; Kegan
Aman <kaman@meridiancity.org>
Subject: RE: C-TI-2023-0046
Hello,
As mentioned on our call yesterday, I needed some time to look into what surveying would be
classified as. The North American Industry Classification System (NAICS) states that this use is also
known as, Geophysical Surveying and Mapping Services. Which falls under the category Professional,
Scientific, and Technical Services. So, unfortunately, in Meridian City code that translates to a
professional service, which is only allowed as an Accessory Use in the I-L zone. We won’t be able to
move forward with your C-TI pending building permit at this time. Please let us know if you have any
questions or further explanation.
Thank you,
Julia Garofalo | Assistant Planner
City of Meridian | Community Development
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208) 489-0601
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request, unless exempt from disclosure by law.
From: Bill Parsons <bparsons@meridiancity.org>
Sent: Monday, April 10, 2023 4:21 PM
To: Julia Garofalo <jgarofalo@meridiancity.org>
Cc: Nick Napoli <nnapoli@meridiancity.org>
Subject: RE: C-TI-2023-0046
I would go to NAICS and see how a surveyor’s office is classified.
Bill Parsons, AICP | Planning Supervisor
City of Meridian | Community Development Dept.
33 E. Broadway Ave., Ste. 102, Meridian, Idaho 83642
Phone: 208-884-5533 | Direct: 208-489-0571
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request, unless exempt from disclosure by law.
From: Nick Napoli <nnapoli@meridiancity.org>
Sent: Monday, April 10, 2023 4:21 PM
To: Julia Garofalo <jgarofalo@meridiancity.org>; Bill Parsons <bparsons@meridiancity.org>
Subject: RE: C-TI-2023-0046
Hi,
While this does meet the requirements for Flex Space in the specific use standards, I don’t think it
actually is being used as a flex space. This appears to be only office space which is an accessory use
in I-L. I think we may to tell them to find a new site.
From: Julia Garofalo
Sent: Monday, April 10, 2023 3:24 PM
To: Bill Parsons <bparsons@meridiancity.org>
Cc: Nick Napoli <nnapoli@meridiancity.org>
Subject: C-TI-2023-0046
Hello,
I need a second opinion. This tenant improvement came through last week in a permitted flex space
building at 50 S. Adkins Way and the proposed plans appear to be a professional service with
accessory storage, however, the applicant is stating that it is more of a dispatch center (11-4-3-45)
for surveyors, and the office space would be more or less the secondary use because the majority of
the time their staff is working in the field. With that, if I have him file a change of use application for
a dispatch center would you agree that this is the primary use? They wouldn’t necessarily have fleet
vehicles, but employees would use their own vehicles and pick up the surveying equipment from the
property. Here is the floor plan submitted with his C-TI application:
Thank you,
Julia Garofalo | Assistant Planner
City of Meridian | Community Development
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208) 489-0601
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request, unless exempt from disclosure by law.
Exhibit C
October 2024 Correspondence
From:Stacy Hersh on behalf of Stacy Hersh <shersh@meridiancity.org>
To:Chris Anderson
Subject:RE: 50 S Adkins Way Suite 140
Date:Monday, October 21, 2024 9:07:04 AM
Attachments:image002.png
Hi Chris,
Prepare the plans for the building department.
Thank you,
Stacy Hersh | Associate Planner
City of Meridian | Community Development Department
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208)-489-0576, Fax: (208)-887-1297
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request, unless exempt from disclosure by law.
From: Chris Anderson <canderson@rudeenarchitects.com>
Sent: Monday, October 21, 2024 8:45 AM
To: Stacy Hersh <shersh@meridiancity.org>
Subject: RE: 50 S Adkins Way Suite 140
External Sender - Please use caution with links or attachments.
Thank you Stacy! I appreciate your help in identifying the use. Do I need to submit anything to Planning & Zoning or just prepare the plans to go directly to the Building Department for a permit?
Christopher T. Anderson
Rudeen Architects
Tel: +208.338.1413 Ext. 104
Direct: +208.954.8753
Email: canderson@rudeenarchitects.com
“When you abandon freedom to achieve security, you lose both and deserve neither” Thomas Jefferson
From: Stacy Hersh <shersh@meridiancity.org>
Sent: Friday, October 18, 2024 4:47 PM
To: Chris Anderson <canderson@rudeenarchitects.com>
Subject: RE: 50 S Adkins Way Suite 140
Then the use would be warehouse.
Stacy Hersh | Associate Planner
City of Meridian | Community Development Department
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208)-489-0576, Fax: (208)-887-1297
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request, unless exempt from disclosure by law.
From: Chris Anderson <canderson@rudeenarchitects.com>
Sent: Friday, October 18, 2024 3:48 PM
To: Stacy Hersh <shersh@meridiancity.org>
Subject: RE: 50 S Adkins Way Suite 140
External Sender - Please use caution with links or attachments.
Stacy,
There will be no company vehicles.
Christopher T. Anderson
Rudeen Architects
Tel: +208.338.1413 Ext. 104
Direct: +208.954.8753
Email: canderson@rudeenarchitects.com
“When you abandon freedom to achieve security, you lose both and deserve neither” Thomas Jefferson
From: Stacy Hersh <shersh@meridiancity.org>
Sent: Friday, October 18, 2024 3:38 PM
To: Chris Anderson <canderson@rudeenarchitects.com>
Subject: RE: 50 S Adkins Way Suite 140
Hi Chris,
It sounds like warehousing with the dispatching of services to locations to repair/clean. Will there be company vehicles? These are permitted uses but will require a CZC Change of Use.
Thanks,
Stacy Hersh | Associate Planner
City of Meridian | Community Development Department
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208)-489-0576, Fax: (208)-887-1297
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request, unless exempt from disclosure by law.
From: Chris Anderson <canderson@rudeenarchitects.com>
Sent: Friday, October 18, 2024 3:25 PM
To: Stacy Hersh <shersh@meridiancity.org>
Subject: RE: 50 S Adkins Way Suite 140
External Sender - Please use caution with links or attachments.
Stacy,
The warehouse space will actually be storage, for cleaning supplies and construction supplies; to take care of and maintain properties that they have invested in. I would argue that it is similar to a construction yard, because they will have
building material like plumbing, electrical, hardware, and finishes. They will also be similar to a mobile cleaning service, and store cleaning supplies back there. Based on the chart, I am not sure how to classify the space, so I was hoping to
get your input. Please let me know if this answers your question.
Christopher T. Anderson
Rudeen Architects
Tel: +208.338.1413 Ext. 104
Direct: +208.954.8753
Email: canderson@rudeenarchitects.com
“When you abandon freedom to achieve security, you lose both and deserve neither” Thomas Jefferson
From: Stacy Hersh <shersh@meridiancity.org>
Sent: Friday, October 18, 2024 3:14 PM
To: Chris Anderson <canderson@rudeenarchitects.com>
Subject: RE: 50 S Adkins Way Suite 140
Hi Chris,
What is the type of use proposed in the warehouse space?
Thank you,
Stacy Hersh | Associate Planner
City of Meridian | Community Development Department
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208)-489-0576, Fax: (208)-887-1297
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request, unless exempt from disclosure by law.
From: Chris Anderson <canderson@rudeenarchitects.com>
Sent: Friday, October 18, 2024 1:55 PM
To: Stacy Hersh <shersh@meridiancity.org>
Subject: 50 S Adkins Way Suite 140
External Sender - Please use caution with links or attachments.
Stacy,
A property management company would like to lease Suite 140 at 50 S Adkins Way and I would like to know if this will be an acceptable use in that zone, before I move forward with the Construction Documents. Attached is a PDF of the
floor plan. The front office is less than 25% of the tenant space and the remaining area will be used for storage of the cleaning and construction supplies. Please feel free to contact me if you have any questions. Thank you for your time
and your help!
Christopher T. Anderson
Rudeen Architects
Tel: +208.338.1413 Ext. 104
Direct: +208.954.8753
Email: canderson@rudeenarchitects.com
“When you abandon freedom to achieve security, you lose both and deserve neither” Thomas Jefferson
Affidavit of Legal Interest
Recorded Plat
Warranty Deed