concurring and dissenting: I concur with the majority on the issue of standing, but I respectfully disagree with the analysis and holding of the majority in affirming the Topeka City Council’s (Council) action to override the opinion of the State Historical Preservation Officer (SHPO) and would affirm the district court.
Our legislature has proclaimed that the “historical, architectural, and cultural heritage of Kansas is an important asset of the state and that its preservation and maintenance should be among the highest priorities of government.” K.S.A. 2008 Supp. 75-2715. To that end, the legislature has created a comprehensive program of historic preservation “to foster and promote the conservation and use of historic property for the education, inspiration, pleasure and enrichment of the citizens of Kansas.” K.S.A. 2008 Supp. 75-2715.
The SHPO Opinion Explained
Here, the SHPO found — in accordance with federal standards— that the proposed parking lot would encroach upon, damage, or destroy Bethany Place, property listed on the Register of Historic *213Kansas Places, and asked that the project be redesigned to take advantage of the City of Topeka’s right-of-way. Upon request of the Grace Cathedral and The Episcopal Diocese of Kansas (collectively the Church), the SHPO later reconsidered its initial report and issued a more detailed explanation of its opinion. Due to a technical agenda requirement, the Council refused to include this letter of reconsideration in its record, and the members of the Council apparently were deprived of any opportunity to see the more detailed explanation and basis for the SHPO’s opinion. The letter of reconsideration and explanation would have provided a more compelling analysis of the historic aspects of the area under consideration. I recognize that this letter of reconsideration technically may not be included in the record on appeal, but the express reference and discussion of the letter by the district court warrants our consideration of the letter on appeal. Excerpts include:
“Since the legal boundaries of the nomination include the property that is being considered for a parking lot, the May 8, 2007 SHPO comments used the 1995 edition of The Secretary of the Interior’s Standards for the Treatment of Historical Properties with Guidelines for Preserving, Rehabilitating, Restoring b- Reconstructing Historic Ruildings (Standards) as required by K.A.R. 118-3-8(a). On page 13 of the Standards it states (emphasis [by SHPO]):
The building site consists of a historic building or buildings, structures, and associated landscape features within a designed or legally defined parcel of land. A site may be significant in its own right, or because of its association with the historic building or buildings. The relationship between buildings and landscape features on a site should be an integral part of planning for every work project.
“The guidelines make the following recommendations on page 102 (emphasis [by SHPO]):
Identifying, retaining, and preserving buildings and their features as well as features of the site that are important in defining its overall historic character. Site features may include circulation systems such as walks, paths, roads, or parking; vegetation such as trees, shrubs, fields, or herbaceous plant material; landforms such as terracing, berms or grading; furnishings such as lights, fences, or benches; decorative elements such as sculpture, statuary or monuments; water features including fountains, streams, pools, or lakes; and subsurface archeological features which are important in defining the history of the site.
Retaining the historic relationship between buildings and the landscape.
*214. “To our knowledge the property in question has historically been characterized as an open space with landscaped features. It is these aspects that define the historic nature of the property, not the age of the mature trees. The Secretary of the Interior’s Standards for the Treatment of Historical Properties toith Guidelines for Preserving, Rehabilitating, Restoring ir Reconstructing Historic Buildings does not recommend ‘removing or radically changing buildings and their features or site features which are important in defining the overall historic character of the property so that, as a result, the character is diminished.’ One of the key factors here is the historic relationship between the buildings and the landscaped open space. The parking lot as proposed would damage this relationship.
“If we were to interpret the original nomination (1978) of Bethany Place to the Register of Historic Kansas Places as only including the two historic structures, then the proposed parking lot would be reviewed under the environs of the historic property as characterized in K.S.A. 75-2724. The proposed parking lot would be within the environs of both Bethany Place and Topeka High School. Standards and Guidelines for Evaluating the Effect of Projects on Environs (1998) were adopted under K.A.R 118-3-8 and have been consistently followed. Page 1 of this document reads (emphasis [by SHPO]):
The character of a historic property’s environs should be retained and preserved. The removal or alteration of distinctive buildings, structures, landscape features, special relationships, etc. that characterize the environs should be avoided.
The environs of a property should be used as it has been historically or allow the inclusion of the new uses that require minimal change to the environs’ distinctive materials, features, and spatial relationships.
Demolition of character-defining buildings, structures, landscape features, etc. in a historic property’s environs should be avoided.
New additions, exterior alterations, infill construction, or related new construction should not destroy character-defining features or spatial relationships that characterize the environs of a property.
“Accordingly, historic landscape features and the spatial relationships between features on the property must be taken into consideration when making SHPO comments. As proposed the parking lot does change the spatial relationships on the property.
“The Standards and Guidelines for Evaluating the Effect of Projects on Environs specifically addresses parking lots. On page 5 it states that ‘when newparking areas are required, design them to be consistent with the character of the environs and to include as litde as possible.’ It specifically states, that ‘wholesale modification of traditional, character-defining parking patterns’ is not recommended. The area proposed for the new parking lot is not consistent widi traditional parking patterns on tire site.”
*215Based upon the majority opinion, the template for a city council to override the SHPO’s opinion is an easy one: (1) Place the item on the public agenda; (2) Allow everyone to speak to the proposal; (3) Ignore the opinion of SHPO, especially the requested letter of reconsideration and explanation; (4) Have a council member make a well-stated motion (probably provided by legal staff); and (5) Vote to override the SHPO. Should it really be this easy for a municipal governing body to override the well-reasoned opinion of die SHPO?
The District Court Opinion
The district court clearly believed that the process was flawed. Although our focus is primarily on the action of the Council, Lawrence Preservation Alliance, Inc. v. Allen Realty, Inc., 16 Kan. App. 2d 93, 102, 819 P.2d 138 (1991), rev. denied 250 Kan. 805 (1992), here the district court opinion provides a valuable guide to the flaws in the process. After a comprehensive review of the record, tire court noted a number of procedural irregularities, among them:
“[TJhere may be a question of whether the judgment presented for review is presented in sufficient form such that it may be judicially reviewed in accordance with the above standards. The Topeka City Council’s ultimate decision was initiated in the form of a motion. . . .
“Thus, without a writing summarizing the reasons or some expression of the reasons on the record, the record itself is the only evidence available for deducing the reasons for the Council’s vote on the permit and is, therefore, the determinant of both the Court’s ability to review the record and its sufficiency to support the judgment made. Whether this record, such as it is, is sufficient in questionable, at best. See, Board of County Comm’rs v. City of Olathe, 263 Kan. 667, 668 (1998).
“The presentations made and the documents submitted to the Topeka City Council identified alternatives to the Diocese’s parking lot proposal. These alternatives involved cutback parking along Polk Street, on Eighth Street, or an adjacent alley and/or the use of vacant property belonging to the Diocese located proximately on Eighth Street for the additional parking desired. Information was also provided about reassigning or reconfiguring Grace Cathedral’s current parking just to the west and adjacent to the church or along its current drive on the *216east or reconfiguring the alleyways. No other alternatives were presented by any participant or commentator.
“The Topeka Planning Department recommended disapproval of the Diocese’s request based on the viability of the ‘cutback’ parking alternative presented; however, whether the other alternatives suggested were investigated and compared is unknown from the record. The Shawnee County Historical Society supported the alternative. The Historic Old Town Neighborhood Improvement Association opposed the parking lot in favor of the alternatives presented.
“The record is substantially devoid, except as to the stated need to cross Eighth Street and the overall safety of the ‘neighborhood,’ of an explanation or proffer as to placing parking lots on the Diocese’s other owned and proximate property. No comment was made as to expansion of its east drive. The Diocese argued to the Court, not the Council, that reconfiguration of its existing lot on the west of the church to create more handicap spaces would reduce the parking spaces available in that lot. In addition, the Topeka City Council was given pictures, diagrams, and the state preservation officer’s opinion and those of others in writing, but principally only from opponents. Also, a video of the Grace Cathedral area in aid of the alternatives was delivered to the Council by a speaker in opposition, but not played, but, for some reason, it is not part of the record.
“What then would be the ‘substantial evidence’ relied upon to support a no feasible and prudent alternative existed finding unless one is required to treat each alternative proposed as mutually exclusive of any other alternative proposed and the common place solutions employed universally elsewhere throughout the City are ignored? Such would not seem the intent of the Kansas Historic Preservation Act or a proper implementation of it.
“Other than the Topeka City’s Planning Department’s brief statement in the record in support of an alternative to the parking lot, the record is devoid of any evidence that would show any comparison or planning that would measure other alternatives or assess, objectively, the Diocese’s purported need. As noted, if any alternative proposal had been seen as not entirely feasible and prudent simply because it did not adequately address Grace Cathedral’s expressed need for more handicapped or elderly parking, which certainly stands as worthy, if needed, it, nevertheless, calls into question why Grace Cathedral would need forty to forty-three parking spaces if not all were to be used for that category of attendees and why other alternatives would not suffice to fill the balance of the expressed needs. This, itself, reflects that this second tier or phase of the statutory inquiry was never addressed from the perspective of the City, or by the Diocese as the parking lot proponent, at any point in the process. Certainly a ten slot parking lot ostensibly serves as a mitigated consideration in and of itself. However, it also opens inquiry into why ten slots could not be opened along the Cathedral’s east side drive or in *217the western lot, with a ramp added, in satisfaction of this specific need, while yet allowing the other alternatives to serve those attendees without special needs.
“Accordingly, the Court is of the opinion, particularly when noting all these latter considerations, that ‘in light of the record,’ ‘[the Topeka City Council] [did not take] a hard look at all relevant factors, and using plain common sense, [base] its determination on the evidence.’
“The importance of [the SHPO letter of reconsideration and explanation] was that it was generated after the Diocese itself requested the State Historic Preservation Office to reconsider its opinion, so it, accordingly, should have been an official part of the statutory process precedent. . . .
“In a judicial or quasi-judicial proceeding, if a litigant referenced an item not in evidence, then an objection would be had, or the typical hearing practice would require that the speaker and proponent be advised that the document that was referenced was not in evidence or had not been made available to the trier of fact. However, no one with knowledge of this omission spoke up at Council meeting, thus further leaving the Council with the opinion, then on the floor, that the State Historic Preservation Officer’s opinion was less than sound.
“Another incidence where a speaker might have thought his materials proffered would be in the record, but do not now appear in the record, is the circumstance noted involving the video by Alex Kovalchuck of the Grace Cathedral’s environs where alternative parking was thought available. Again, Mr. Kovalchuck was not advised that his video was not being received. Notwithstanding, although Mr. Kovalchuck did provide a copy of his video to the Council at that time, it is clear it never made the record and was never viewed before the Council's decision.
“Also, here, from review of the transcript and video of the City Council’s meeting, it is obvious some Council members were dubious of their authority to challenge the Diocese’s plans based on First Amendment religious grounds and knowledge of Mount St. Scholastica, Inc. v. City of Atchison, 482 F. Supp. 2d 1281 (D. Kan. 2007)____
“Here, no evidence exists before the Court that would remotely indicate that either the Kansas Historic Preservation Act, or the Act’s particular implementation here by Kansas Historical Society, was grounded other than on the sound premise of securing historic environs for benefit of future citizens. Accordingly, any consideration of deference to the Diocese or Grace Cathedral because of their status as religious entities would have been a wholly improper consideration and would not have been a ‘relevant factor’ in approving or disapproving the Diocese’s requested permit to build a parking lot on the Bethany Place environs.
“Here, the Court has scrutinized, as carefully as it can, the record presented such as to attempt to accord a basis to sustain, and thus give deference to, the Topeka City Council’s decision. The record is one that is not only difficult to *218follow, but one that is marginally evidential. It is a record that does not lend itself to extrapolating any cogent reason or reasons for the Topeka City Council’s decision. As such, the Court has been unable to locate that necessary basis for deference to its finding for all of the reasons heretofore discussed.
“Notwithstanding, here, it seems clear that while each alternative proposed to the Intervenors’ parking lot proposal is not required to separately satisfy the whole of the Intervenors’ needs, but rather each may be considered collectively and in combination, the Topeka City Council, nevertheless, failed to do so. As a consequence, the record evidences a lack of substantial evidence to support the statutory finding necessary that no feasible and prudent alternative existed. The record further lacks substantial evidence to support a conclusion that all possible planning was done to minimize the damage that would occur to the Bethany Place. These considerations, as noted, operate to make the Topeka City Council’s decision stand as arbitrary, capricious, and unreasonable. Accordingly, the decision of the Topeka City Council is set aside.”
Did the district court overstep its limited boundaries here? I respectfully suggest that it did not and that its judicial decree was soundly based upon a thorough review of the record and a careful application of controlling authorities.
The Applicable Statutory Standards as Interpreted by Our Supreme Court
The applicable statute, as interpreted by our Supreme Court, sets a far higher threshold for overriding the SHPO than has been recognized by the majority here. K.S.A. 2008 Supp. 75-2724(a) provides in material part:
“[S]uch [a proposed] project shall not proceed until:
“(1) . . . the governing body of the political subdivision . . . has made a determination, based on a consideration of dll relevant factors, that there is no feasible and prudent alternative to the proposal and that the program includes all possible planning to minimize harm to such historic property resulting from such use.” (Emphasis added.)
In Reiter v. City of Beloit, 263 Kan. 74, 947 P.2d 425 (1997), our Supreme Court examined this statute and provided guidance on the question what constitutes a “relevant factor.” It concluded:
“ ‘[A] proposed alternative would be a relevant factor if it included sufficient factual information to support a conclusion that such alternative was feasible and prudent. A proposed alternative unsupported by such factual information could *219not form the premise of such a conclusion and would not be relevant.’ [Citation omitted.]
“However, the term ‘relevant factors’ is not necessarily limited to proposed alternatives. The term ‘relevant factors’ authorizes the governing body to take into consideration all relevant factors relating to the project under consideration. This authorization extends to all those factors logically connected to the ultimate decision of whether there is a feasible and prudent alternative to the proposal and whether the program includes all possible planning to minimize harm to the historical property at issue ....
“Another relevant factor that we believe may be considered by the governing body is the report and reasoning of the SHPO. As we noted above, the Kansas State Historical Society and SHPO play a major role in any determination concerning the preservation of historic property. . . . The SHPO’s report and the information or lack thereof used by the SHPO in making such a determination may be considered by a governing body as a relevant factor under K.S.A. 75-2724.” 263 Kan. at 89-91.
The court then further stated:
“We believe that tire information relied upon by the SHPO is a relevant factor that may be considered by the governing body under K.S.A. 75-2724 and that its relevance does not end with the initial determination made by the SHPO that triggers the need for a determination by the governing body.
“... [T]he ultimate question for appellate review is whether the governing body took a hard look at all relevant factors and, using plain common sense, based its determination upon the evidence. [Citation omitted.]” 263 Kan. at 92-94.
Applying These Statutory Standards to the Record of Council Action
My chief disagreement with the majority is that these statutory standards as interpreted require far more than a routine determination of whether substantial competent evidence supports the Council’s determination. The entire premise of the majority opinion is that our role starts and stops with such a determination, even though the majority gives lip service to the three-prong standard embraced in Reiter — under which the substantial evidentiary support test is but one prong. Neither our appellate courts nor the federal courts applying similar standards have ever reduced the appellate task to such simplicity.
*220As noted by our court in Allen Realty, the legislature has patterned the standards contained in K.S.A. 75-2724 after a nearly identical federal act governing projects of the U.S. Department of Transportation, see 49 U.S.C. § 303 (2006). Allen Realty, 16 Kan. App. 2d at 100-01. These same or nearly identical standards also appear in other federal administrative enactments. See, e.g., National Environmental Policy Act of 1969, 42 U.S.C. § 4321 (2006) et seq. Accordingly, federal case law is helpful in applying the Kansas standards. See Allen Realty, 16 Kan. App. 2d at 101.
In fact, it appears that our courts took a page from federal courts in embracing die “hard look” test as the ultimate question on appeal of such matters. See Allen Realty, 16 Kan. App. 2d at 102 (quoting Hickory Neighborhood Defense League v. Burnley, 703 F. Supp. 1208, 1219 [W.D.N.C. 1988], modified on other grounds 893 F.2d 58 [4th Cir. 1990]); compare Reiter, 263 Kan. at 94. There is a host of federal law explaining and applying both the “relevant factor analysis” and the “hard look” test in circumstances notunlike that before us. These federal cases — as well as our own appellate opinions — demonstrate that the simplistic approach of the majority opinion is inappropriate in this context.
First, our appeüate courts and federal courts have concluded that the relevant factor test is an integral part of the “arbitrary and capricious” test and that the record of the administrative proceedings must affirmatively show consideration of the relevant factors. Allen Realty, 16 Kan. App. 2d at 103; see In re Dept. of Energy Stripper Well Exemption, 520 F. Supp. 1232, 1269 (D. Kan. 1981), rev’d on other grounds 690 F.2d 1375 (Temp Emerg. Ct. App. 1982), cert. denied 459 U.S. 1127 (1983). Thus, our task in these cases extends to a rather unique examination beyond a mere determination of substantial evidence support; indeed, the district court applied the correct standard and found the Council’s actions arbitrary and capricious.
Second, federal courts have concluded that the application of the relevant factors test requires that agency action be set aside if the agency has relied on factors which the legislative branch has not intended it to consider, it entirely failed to consider an important aspect of the problem, or it offered an explanation for its de*221cisión counter to the evidence before the agency or was so implausible that it could not be ascribed to a difference in view or the product of agency expertise. Motor Vehicle Mfrs. Assn. v. State Farm Mut., 463 U.S. 29, 43, 77 L. Ed. 2d 443, 103 S. Ct. 2856 (1983); Ross v. Federal Highway Admin., 162 F.3d 1046, 1050-51 (10th Cir. 1998).
Third, although there is no statutory requirement in Kansas for formal findings by the governing body in this context, the federal Administrative Procedure Act (APA), 5 U.S.C § 706 (2006), requires at least a brief statement of the grounds for an agency decision, the statement must be sufficiently detailed that the reviewing tribunal can appraise the agency’s determination under the appropriate standards of review, and it must be sufficiently detailed so that the appellate court can determine whether the relevant factors were determined and that the decision was based on those factors and otherwise reasonable. Friends of the Bow v. Thompson, 124 F.3d 1210, 1215 (10th Cir. 1997).
Finally, in applying the hard look test, courts have set aside “agency actions” when the agency failed to assess or study the feasibility of a proposed alternative (International Snowmobile Mfrs. Ass'n v. Norton, 340 F. Supp. 2d 1249, 1259 [D. Wyo. 2004]); when the agency failed to consider the possible availability of public funding for a proposed alternative (Benton Franklin Riverfront Trailway v. Lewis, 701 F.2d 784, 791 [9th Cir. 1983]); and when the agency failed to allow meaningful participation of the State Historical Society in a demolition project (Allen Realty, 16 Kan. App. 2d at 108).
Our appellate courts have suggested that relevant factors must include sufficient factual information to support a conclusion that such alternative is both feasible and prudent. Reiter, 263 Kan. at 89-90; Allen Realty, Inc. v. City of Lawrence, 14 Kan. App. 2d 361, 373, P.2d 948 (1990). The majority concludes that none of the myriad of alternatives proposed to the Council “includes sufficient factual information to support a conclusion that it constitutes a feasible and prudent alternative to the Church’s proposal,” applying the criteria of K.A.R. 118-3-l(e). See Friends of Bethany Place, 43 Kan. App. 2d at 207. In so concluding, the majority would have *222each citizen proponent of the alternative present a fully documented plan including technical issues, design issues, the project’s relationship to the community-wide plan, and economic issues.
With due respect, this paradigm turns the regulation and the statutory standard on its head. If the law expects a citizen proponent to present such a fully documented proposal of an alternative to the demolition of historic property, there will certainly be no feasible alternatives to worry about. The majority places entirely on the citizen proponent the burden that belongs to — or at least shared with — tire governing body; that is, our courts and federal courts have consistently set aside proposed actions because an agency or governing body — here the Council — failed in its duty to investigate, study, assess, or otherwise look into the technical, design, and economic issues of alternative proposals. See Benton Franklin, 701 F.2d at 791; International Snowmobile Mfrs., 340 F. Supp. 2d at 1259. Indeed, the proponent of the project has the burden to prove no acceptable alternative exists, and the governing body has the duty to determine whether alternatives presented are feasible and prudent. K.S.A. 2008 Supp. 75-2724 (duty of governing body); Reiter, 263 Kan. at 89 (burden on proponent); Lawrence Preservation Alliance Inc. v. Allen Realty, Inc., 16 Kan. App. 2d 93, 95, 819 P.2d 138 (1991), rev. denied 250 Kan. 805 (1992). Here, the governing body was fully capable of calling on a host of internal departments for assistance in evaluating the alternatives; instead, the only internal department advice that it received was completely ignored. The view of the majority renders meaningless the hard look standard, which most courts have held to place a significant duty on the agency or governing body. See, e.g., Hickman Trust v. City of Clay Center, 266 Kan. 1022, 1040-42, 974 P.2d 584 (1999).
Was the Council’s Decision Arbitrary, Capricious, and Unreasonable?
Applying this guidance to the entire record before us, I would conclude that the Council’s action in overriding the opinion of the SHPO was arbitrary, capricious, and unreasonable for the following reasons:
(1) The detailed letter of reconsideration and explanation from the SHPO was clearly a relevant factor that should have been fully considered by the Council, particularly because it provided a *223comprehensive basis for the SHPO’s determination. See Reiter, 263 Kan. at 90-91 (the report and reasoning of SHPO is a relevant factor to be considered). The exclusion of the letter from consideration by the Council based upon a technical agenda requirement was wholly unreasonable, especially given the city attorney s statement that had the letter simply been handed out at the Council meeting, it would have been received. One of the highest priorities of our government, historic preservation, should not be overridden without a full consideration of the underlying bases for the SHPO’s determination. Where the governing body entirely fails to consider the report and reasoning of tire SHPO in this context, I would hold the resulting action to be inherently flawed. See Motor Vehicle Mfrs., 463 U.S. at 43; Ross, 162 F.3d at 1050-51.
(2) Given the importance of factual information to support a proposed alternative, the failure of the Council to view, consider, and receive the Kovalchuck video may be viewed as at least unreasonable and possibly capricious. Although it is impossible for this court to know what may have been included in the video, it is clear from the record that Kovalchuck intended to present a video demonstrating the feasibility of numerous detailed alternative proposals, including the “cut-in” parking, additional “cut-in” parking, two lots owned by the Church that could be converted to parking, and multi-level parking, all of which were characterized by Kovalchuck as “feasible, reasonable proposals.” As noted by the district court, “[I]t is clear [the video] never made the record and was never viewed before the Council’s decision.” This procedural flaw fatally contaminated the proceedings, especially if one agrees with the majority in placing principal responsibility on citizen proponents to document alternatives.
(3) As noted by the district court, the numerous alternative proposals listed by the district court were never considered in combination as being either feasible or prudent. I agree with the district court in concluding that a failure to consider in combination the alternative proposals, or any subset of them, and to test or analyze any combination of these alternatives for feasibility and prudence is highly problematic. In its duty to determine whether “there is no feasible and prudent alterna*224tive to the proposal,” surely the governing body is not to view each alternative in isolation. See K.S.A. 2008 Supp. 75-2724.
(4) The imprimatur of the City’s Planning and Engineering Departments for the feasibility of “cut-in” parking seems not to have been given its inherent weight. These departments recommended “DISAPPROVAL” of the Church’s proposed parking lot “in light of alternative and feasible alternatives that will not encroach upon or damage the listed property,” including angled parking that the district court noted would result in 150% more space dedicated to parking than the Church’s proposal. Although there was a brief presentation to the Council regarding this recommendation, there was no further investigation or assessment of cost or possibility of cost sharing, and there was absolutely no questioning or discussion by Council members thereafter to demonstrate a hard look at the City’s own departmental recommendation and alternative proposal.
(5) The record is completely devoid of any evidence to establish that the Church’s proposal reflected “all possible planning to minimize harm to such historic property resulting from such use.” (Emphasis added.) Granted, the Church’s representatives mentioned a “plan” to plant new trees along Polk Street, but I remain unconvinced that this unenforced suggestion adequately reflected “all possible planning to minimize harm.” As fully documented by the district court, a host of potential ideas to further minimize harm were never addressed by the Church or the Council. This should be contrasted with the steps taken by the municipality in Reiter, where 12 specific steps to minimize harm were “raised and addressed” by the planning commission and council and thereafter legally enforced as conditions in the motion to approve the project. See Reiter, 263 Kan. at 81-84. This statutory requirement, that all possible planning be executed to minimize harm, was not met with a mere idea or unenforced notion to plant some new trees along a narrow strip of land adjoining the street.
(6) Did the governing body here truly “take a hard look” at relevant factors and base its determination on the evidence of such alternative proposals and plans to minimize harm? Like the district court, I conclude the answer to this “ultimate question for appellate review” (Reiter, 263 Kan. at 94) is no. Thorough *225examination of the record does not convince me that there was any hard look at the relevant factors, and there was clearly no consideration of plans to minimize harm. Instead, I am convinced that the determining factor for the Council was concern of litigation based on First Amendment issues, and this is most evident not only in the clear weight of the discussion by Council members but in the city attorney’s response to Councilman Harmon that “a denial of the parking permit could create some legal issues.” As noted by the district court, this consideration was not only legally incorrect, it was totally outside the considerations required by Kansas law. Where an agency or governing body has relied on a consideration beyond those specified by the legislature, this alone can render the resulting action arbitrary. See Motor Vehicle Mfrs. Assn., 463 U.S. at 43.
(7) Although the majority correctly notes that detailed findings of fact and conclusions of law are not required to be made by the governing body under these circumstances, it is clearly the better practice for the governing body to explain its action. Where no such findings have been made, at least to the extent of explaining the basis for the action of approval, I believe we should subject the action of the governing body to a higher degree of scrutiny. It has long been the law in Kansas that quasi-judicial action requires some explanation of its basis in order for the reviewing court to determine whether the decision reached has met the applicable legal standards. See, e.g., Neeley v. Board of Trustees, Policemen's & Firemen's Retirement System, 205 Kan. 780, Syl. ¶ 5, 473 P.2d 72 (1970). This general precept is clearly recognized in the federal cases within this context. See, e.g., Friends of the Bow, 124 F.3d at 1215. It is generally recognized that the necessity for findings is to facilitate judicial review, avoid judicial usurpation of administrative or legislative functions, assure more careful consideration to protect against careless and arbitrary action, assist the parties in planning or preparing cases for rehearing and judicial review, and keep such agencies or governing bodies within their jurisdiction as prescribed by the legislature. In re Tax Appeal of Bernie’s Excavating Co., 13 Kan. App. 2d 476, 478, 772 P.2d 822, rev. denied 245 Kan. 784 (1989). Here, a complete review of the record leaves one with more questions than *226answers. What did the Council think of the alternative proposed and approved by the City’s Planning and Engineering Departments? Was the Church’s concern for safety in the angled parking shared by the City’s Planning, Traffic, or Public Safety Departments? Why were some combinations of the myriad alternative proposals not considered? Was the City willing to bear some or all of the cost of one or more alternative Eroposals? Was there other public funding that might have een available to share in the costs? Were there specific concerns that the Council felt rendered some or all of the alternatives neither feasible nor prudent? Were there other steps that could have been taken to minimize harm to the subject property? Why did the City not enforce some concern for the historic aspects of the property in approving the parking lot or at least enforce, through conditions of approval, other possible steps to minimize harm? Would consideration of the detailed letter of reconsideration and explanation from the SHPO have made a difference? In the absence of such findings, we are left to mere speculation as to the basis for the Council’s decision. Our appellate courts have required that the record of such land-use planning and control proceedings “affirmatively show consideration of the relevant factors.” Allen Realty, 16 Kan. App. 2d at 103. There is no such affirmative showing in this record.
In summary, I conclude that the entire process was materially flawed, that we simply do not know what the Council’s decision was based upon, that the statutory considerations were never adequately addressed by the governing body, that there was no hard look at the relevant factors including alternative proposals, that there was absolutely no discussion of exhausting “all possible planning to minimize harm,” that perhaps the most relevant factor— the oasis for the SHPO’s opinion — was never considered, that the decision of the governing body was heavily influenced by inappropriate legal concerns, and that the ultimate determination of the Council was not based on the evidence of feasible and prudent alternatives or the minimization of harm, but rather on apparent extraneous factors that should have played no role in whether to override one of the highest priorities of government in Kansas: historic preservation under K.S.A. 2008 Supp. 75-2715.
I would affirm the district court’s decision setting aside the Council’s action as arbitraiy, capricious, and unreasonable.