Method: Read 9 CC Findings of Fact from Eagle Laserfiche, dated 2024-03-26
(Oakwood) through 2026-04-14 (Aventier, Valnova). Categorized each on whether the
FLUM-consistency analysis under Idaho Code § 67-6511 was SUBSTANTIVE, BOILERPLATE, or
OMITTED. PDFs were converted with pdftotext -layout and the Conclusions of Law
(rezone consistency findings) were read in full. The body Findings of Fact (Comp Plan
provisions section) were also read for sub-area context.
Sample size: N = 9 CC Findings (6 substantive rezone matters + 1 CUP +
2 modifications)
Date range: 2024-03-26 to 2026-04-14
Outcomes in sample: 9 approvals, 0 denials
Headline metric (rezone-only sub-sample, N=6)
| Category | Count | % |
|---|---|---|
| Substantive | 5 | 83% |
| Boilerplate | 1 | 17% |
| Omitted | 0 | 0% |
The CUP (Sunset Stables) and the two modification matters (Aventier DA-mod, Valnova PP-mod) are excluded from the rezone metric and flagged separately at the end of this document. The CUP cites FLUM in support of a use determination; the two modifications carry FLUM consistency by reference to prior approvals.
Annexation vs in-city rezone
| Posture | N | Substantive | Boilerplate | Omitted |
|---|---|---|---|---|
| Annexation + rezone | 4 | 4 | 0 | 0 |
| In-city rezone (already in Eagle) | 2 | 1 | 1 | 0 |
The hypothesis (rigor at annexation, boilerplate at in-city rezone) is partially supported but not cleanly. All four annexation+rezones are substantive. Of the two in-city rezones, one (Whitehurst Village, RZDA-2025-02) is substantive and one (Oakwood Meadows, RZ-11-23) is boilerplate. The split appears to track project size and complexity (Whitehurst is 5.97 ac with a PUD raising design questions; Oakwood is 2.8 ac and a "minor subdivision" under ECC 9-2-3) more than annexation status alone.
A structural pattern: every substantive Findings (5/5) uses the same 8-finding template in the Conclusions of Law (a-h), including a Hazard Area / Special Area finding. The one boilerplate Findings (Oakwood) collapses this to 4 findings (A-D) and omits the Hazard / Special Area determination entirely, along with the sub-area Planning Area citation and any density-math comparison to the FLUM designation's prescribed range.
Structural finding: § 67-6511 is not directly cited
None of the 9 CC Findings cites Idaho Code § 67-6511 by section number. The "in accordance with the comprehensive plan" requirement is reached by Eagle through Eagle City Code Section 8-7-5 ("Action by the Commission and Council"), Eagle's local rezone procedure, which mirrors the Idaho Code requirement. Title 67, Chapter 65, Idaho Code is cited only in the public-hearing-notice sections of every Findings — not in the substantive consistency analysis.
This means the consistency analysis is framed locally (8-7-5) rather than statutorily (67-6511), but the substance of the analysis maps onto the statutory standard in the substantive Findings.
Per-Findings detail
1. Whitehurst Village (RZDA-2025-02) — APPROVED — IN-CITY REZONE
- Category: SUBSTANTIVE
- From / to: A-R → R-1 + R-3-DA-P, 5.97 ac
- FLUM designation cited: Yes — Neighborhood Residential, with Residential Transition Overlay and Scenic Corridor Overlay
- Sub-area cited: Yes — Park Lane Planning Area (§6.5), specifically §6.5.1(D) which calls for an overall density not to exceed 2 du/ac in this sub-area
- Hazard Area check: Yes — "not located within a 'Hazard Area' or 'Special Area'"
- Density math: Project at 2.42 du/ac vs. sub-area policy of 2 du/ac max — narrowly above policy, addressed via PUD clustering and DA conditions
- COL excerpt: "The requested zoning designations of R-1 (Residential) and R-3-DA-P (Residential with a development agreement — PUD) are consistent with the Neighborhood designation as shown on the Comprehensive Plan Land Use Map because the proposed density and land use is in conformance with the principles identified for the Neighborhood designation in the comprehensive plan; ... The land proposed for rezone is not located within a 'Hazard Area' or 'Special Area' as described within the Comprehensive Plan."
- Location: p. 23 of 26, Conclusions of Law ¶1(a)-(h)
2. Flicker Pointe (A-2024-03/RZDA-2024-06) — APPROVED — ANNEXATION + REZONE
- Category: SUBSTANTIVE
- From / to: RUT (Ada County) → R-2-DA-P, 6.88 ac
- FLUM designation cited: Yes — Neighborhood (2-4 du/ac)
- Sub-area cited: Yes — Park Lane Planning Area (§6.5)
- Hazard Area check: Yes
- Density math: Implicit (DA-bounded R-2)
- COL excerpt: "The requested zoning designation of R-2-DA-P (Residential with a development agreement — PUD) is consistent with the Neighborhood designation as shown on the Comprehensive Plan Land Use Map; ... The land proposed for rezone is not located within a 'Hazard Area' or 'Special Area' as described within the Comprehensive Plan."
- Location: pp. 24-25 of 28, Conclusions of Law ¶1(a)-(j) (j adds annexation-contiguity finding)
3. Sintra (A-2025-02/RZDA-2025-03) — APPROVED — ANNEXATION + REZONE
- Category: SUBSTANTIVE
- From / to: RUT (Ada County) → R-1-DA, 9.66 ac
- FLUM designation cited: Yes — Neighborhood (with Residential Transition Overlay)
- Sub-area cited: Yes — Village Planning Area (§6.6); specifically §6.6.1(A)(2)(b): "densities in the Village Planning Area and in the Neighborhood Residential designation, south of Beacon Light Road, should average 1-2 units per acre"
- Hazard Area check: Yes
- Density math: YES — explicit comparison: "0.83 du/ac which is less than the 1-2 du/ac called for within the Neighborhood designations south of Beacon Light Road in the Village Planning Area"
- COL excerpt: Quoted above. Among the strongest density-math examples.
- Location: pp. 21-22 of 24, Conclusions of Law ¶1(a)-(j)
4. Sunset Stables (CUP-2025-05) — APPROVED — CUP, NOT REZONE
- Category: N/A — CUP (excluded from rezone metric)
- Site: R-E zoned, 2.36 ac, FLUM "Large Lot"
- FLUM treatment: "the Large Lot Comprehensive Plan designation supports single-family and agrarian uses and the City Council determined the proposed conditional use is appropriate for the location"
- Notes: FLUM is invoked but in the lighter conditional-use-permit posture under ECC 8-7-3-2 (general standards for conditional uses), not in a rezone-consistency posture under 8-7-5.
5. Reining Horse (A-2022-01/RZ-2022-01) — APPROVED — ANNEXATION + REZONE
- Category: SUBSTANTIVE
- From / to: RUT (Ada County) → R-1-DA, 7.68 ac
- FLUM designation cited: Yes — Large Lot Residential
- Sub-area cited: Body cites Figure 6.7 (Land Use Designations) and Foothills planning policy; COL does not name a Planning Area sub-area for this site
- Hazard Area check: Yes
- Density math: YES — "the adopted Comprehensive Plan defines Large Lot Residential as residential densities that are between 1 dwelling unit per acre (1.0 du/ac) and 1 dwelling unit per 2 acres (0.50 du/ac) ... which complies with the 0.52 du/ac that was approved for the Reining Horse Subdivision"
- Location: pp. 33-34 of 36, Conclusions of Law ¶1(a)-(j)
6. Sagehill (A-2025-04/RZ-2025-05) — APPROVED — ANNEXATION + REZONE (foothills, 736 ac)
- Category: SUBSTANTIVE — most rigorous in the sample
- From / to: RP (Ada County) → R-1-DA-P, 736 ac
- FLUM designation cited: Yes — Foothills Residential (§6.14)
- Sub-area cited: Yes — North Eagle Foothills Planning Area / Eagle Foothills Planning Area (extensive engagement, multiple pages of FoF body)
- Hazard Area check: YES, and AFFIRMATIVELY designated Hazard / Special Area (Wildland-Urban Interface). Addressed via Wildfire Master Plan and natural-features analysis.
- Density math: YES, with explicit constrained-vs-unconstrained calculation: "The subject property is 736.00 acres in size. 336-acres of the site are made up of slopes that are in excess of 25% which leaves 400-acres of unconstrained lands. A requested residential density of 0.50 dwelling units per acre within portions of the property that are unconstrained land is in alignment with the desired densities as stated within the comprehensive plan." Net project density 0.27 du/ac.
- Location: pp. 67-68 of 75, Conclusions of Law ¶1(a)-(j)
7. Aventier / Eventyr (RZ-2021-11-MOD1) — APPROVED — DA MODIFICATION (FLAGGED)
- Category: FLAG_MOD (excluded from rezone metric)
- Posture: Setback-only DA modification for Lot 6, Block 1 — no land-use change
- FLUM designation cited: Yes — Neighborhood Residential
- Sub-area cited: Yes — River Plain Planning Area (§6.8) cited in Findings of Fact body
- COL excerpt: "The zoning designation of R-2-DA (Residential with a development agreement) is consistent with the Neighborhood Residential designation as shown on the Comprehensive Plan Land Use Map, and the proposed modification does not alter the land use, so the property remains in conformance with the R-2 (Residential) zone."
- Notes: Substantive analysis in body, short-form COL by reference because no land-use change is proposed.
8. Valnova Village No. 1 (PP-2025-06-MOD1) — APPROVED — PP MODIFICATION (FLAGGED)
- Category: FLAG_MOD (excluded from rezone metric)
- Posture: Preliminary plat modification within Spring Valley PUMP No. 1
- FLUM designation cited: Yes — Foothills Residential
- Sub-area cited: Yes — North Eagle Foothills Planning Area; Big Gulch Planning Area (67.58 ac); Southwestern Residential Planning Area (35 ac); Northern Residential Planning Area (0.33 ac)
- COL excerpt: "Will be harmonious with and in accordance with the general objectives of Title 11A of the Eagle City Code since the development and proposed modifications are consistent with the Comprehensive Plan Land Use Map designation of Foothills Residential ..."
- Notes: Consistency runs through the prior PUMP. Multiple sub-areas cited in body. Short-form COL because no rezone is proposed.
9. Oakwood Meadows (RZ-11-23) — APPROVED — IN-CITY REZONE (the in-house Cody analog)
- Category: BOILERPLATE
- From / to: R-E → R-2-DA, 2.8 ac
- FLUM designation cited: Yes — Neighborhood Residential (only — no density range stated in COL)
- Sub-area cited: NO — no Planning Area cited in either the Comp Plan Provisions section of FoF or in the Conclusions of Law
- Hazard Area check: NO — Hazard / Special Area finding entirely OMITTED from the COL
- Density math: NO — no comparison of proposed density to Neighborhood Residential 2-4 du/ac range
- COL excerpt (verbatim): "The proposed rezone is in accordance with the Comprehensive Plan and established goals and objectives because the proposed zoning designation of R-2-DA (Residential with a development agreement) is in accordance with the land use designation of Neighborhood Residential as shown within the Comprehensive Plan. The Neighborhood Residential designation, as identified in the Comprehensive Plan land use map, is suitable for single family residential units as proposed."
- Location: p. 17 of 19, Conclusions of Law ¶1(A)-(D)
- Structural note: The only Findings in the sample that collapses the standard 8-finding template (a-h) into a 4-finding short form (A-D). Of all the in-sample Findings, this is the closest match to Cody's procedural posture: small in-city rezone in already-developed neighborhood context, identical FLUM designation (Neighborhood Residential).
What this means for Cody's case
Eagle's CC does perform substantive FLUM-consistency analysis at rezone — when the matter is large, complex, in the foothills, at annexation, or otherwise visible. The standard substantive template is 8 sub-findings (a-h) including a Hazard / Special Area determination, a sub-area Planning Area citation, and (usually) a density-math comparison to the FLUM's prescribed range.
The single boilerplate-coded Findings in the sample (Oakwood Meadows) is the closest in-sample analog to Cody — small in-city rezone, Neighborhood Residential, no annexation. Its Conclusions of Law collapse the template to 4 short findings, omit the Hazard / Special Area finding, omit any sub-area Planning Area citation, and contain no density math. This is one data point but it is directly on point.
The empirical answer to Kelli's hypothesis: Eagle does FLUM analysis at rezone when the project is large, in the foothills, or at annexation; in the closest-match in-house case to Cody (a 2.8-ac in-city rezone in Neighborhood Residential), the FLUM analysis collapsed to a single template paragraph and the Hazard / Special Area finding was omitted entirely.
Internal working document · prepared with ZIG analytics · not for external distribution