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Chairman CitaraManis and members of the Planning Board: The League of Women Voters of Howard County opposes ZRA-90 not because the League opposes affordable housing but because ZRA-90 would comprehensively impose Housing Commission residential development as a matter of right in all Howard County commercial/retail/employment zoning districts except for Business Rural, Office Transition, Continuing Light Industrial and the Solid Waste Overlay District without a public process and opportunity for the public to express their support, concerns or opposition to any 2 acre or larger parcel of Housing Commission housing. Housing Commission Housing is defined as housing wholly owned by the Howard County Housing Commission or owned by a limited partnership or limited liability company formed solely for the purpose of obtaining the benefit of low-income housing tax credits and the Housing Commission is the general partner or managing member. The justifications for ZRA-90 are:
The League finds these justifications do not support the sweeping comprehensive change that proposed ZRA-90 would impose on the residents, businesses and planners of Howard County. In addition, the proposed change provides no opportunity for Howard County residents, community associations or businesses to publicly comment, except during the required pre submittal community meeting. The Housing Commission per Section 13.1315 b has tremendous powers. Under this section of the Howard County Code "... a housing development that is wholly owned by the commission shall be a use permitted as a matter of right in any business or commercial zoning district." This code provision has been invoked for a developed project off of Rt. 40, recently was tried on a commercial business parcel near Centennial Lane and Rt.40 and currently on a Planned Office Research (POR) parcel located near the intersection of Rt. 104 and Rt. 108. The 2000 General Plan Balanced and Phased Growth chapter detailed the fiscal impact of housing and employment/job projections to ensure that quality of life is maintained and or improved over the course of the General Plan. The Plan stated that the County had a total of 145,660 acres of residential zoned land and 15,000acres of non-residential commercial/ employment/ retail. A major issue was the scarcity of uncommitted non-residential land approximately 3,000 acres. Therefore, a major policy commitment of the General Plan was to redevelopment and revitalization of employment areas. "Redevelopment will sometimes provide opportunities to introduce residential uses to create small mixed use developments… However, as noted earlier in this Chapter, protecting the County's supply of employment land is also an important priority." (Chapter 4:Balanced and Phased Growth) Redevelopment and revitalization policies resulted in new zoning districts along the Rt.1 corridor that encouraged strong mixes of retail, office, commercial and housing units, after community deliberations and public comments during the County Council comprehensive zoning adoption process. Redevelopment was also given careful consideration by the Rt. 40 Task Force and resulted in a proposed limited to specific parcels overlay district that had a housing component. The focus of New Town -Town Center discussions includes the full spectrum of housing choices and needs, along with employment/ retail/ commercial development. The marketplace has provided Howard County with many age-restricted housing units. The Howard County Housing Commission has provided affordable rental units. Most owned and condo age-restricted units are high end. More age-restricted units are in the development pipeline. It is hard to argue or justify ZRA-90 as a needed for age restricted housing. True the vast majority of commercial/employment/retail zoning districts are in the eastern part of the County. This is not by accident. Planners and Elected Officials have supported and adopted policies establishing the Planned Water and Sewer service area of the County in the County's eastern area. The County has adopted policies to maintain a rural western area of the County. The assertion of location is not a justification for ZRA-90. The League asks the Planning Board to consider the following major amendment to ZRA-90. Restrict the application of the Housing Commission Housing to the Planned Office Research zoning district since it is currently the only non-residential district that the Housing Commission is involved with in partnership with others. Require that the Housing Commission Housing use be a conditional use not a use permitted as a mater of right. A conditional use will provide the opportunity for adjacent property owners, community associations and business to comment in a public process with adequate notice. Establish some conditional use criteria. The Planned Office Zoning District (POR) has almost identical bulk regulations as proposed in ZRA-90. The POR regulations for age-restricted units have a 10% moderate-income requirement. A similar or larger 15% requirement should be established for Housing Commission Housing. A density limit should be established like the Residential Institutional District of 25 units per net acre. Additional requirements regarding open space and perimeter buffering need to be included if the parcel was adjacent to a residential zoned parcel. The League supports the bulk regulation change to the Planned Senior Center District 127.1E.1.c. The League urges the Planning Board to support maintaining the moderate-income housing provisions in the Zoning Regulations for the Corridor Activity Center District, the Traditional Neighborhood Center District and the Mixed Use District. The County Council, the Department of Planning and Zoning and the Planning Board supported the inclusion of these provisions in the recently adopted Comprehensive Zoning Regulations. The reality is that the public and developers look to the Zoning Regulations first to determine what the requirements of development are. Finally, if the Planning Board decides not to support the League of Women's Voters proposed amendments to ZRA-90 how will you reconcile the building height restrictions established in the following non-residential zoning districts with those proposed for the Housing Commission Housing? The proposed Housing Commission Housing building height regulations is 50 feet with a maximum of 80 feet with additional setback. Maximum Heights with no other allowance for additional setback in nonresidential districts are:
The League appreciates the Planning Board's consideration of our comments.
Grace Kubofcik |
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