Chairman CitaraManis and Members of the Planning Board:

RE: ZRA95 New density exchange process for R-ED, R-20 and R-12 District neighborhoods - Council member Courtney Watson

The League of Women Voters of Howard County supports ZRA95 which proposes a new density exchange process for the R-ED, Residential -Environmental Development, R-20, Residential Single and R-12 Residential Single zoning districts in Howard County.

The League's position of support is based on the National League's Land Use position which supports land-use planning that reflects conservation and wise management of resources, the Maryland State League's Land Use / Growth Management support for local government's use of land use planning and regulatory techniques such as ... land banking ... transfer of development rights, and timed development ordinances to direct development to designated areas.

The ZRA95 proposes to preserve the existing character of larger lot residential communities by designating three zoning district sending areas R-ED, R-20 and R-12 and six zoning districts receiving areas R-SA8, Residential Attached, R-A-15, Residential Apartments, PGCC, Planned Golf Course Community, CAC, Corridor Activity, TNC, Traditional Neighborhood Center and MXD, Mixed Use districts. All of the sending and receiving districts are in the County's planned service area. The League would oppose, based on its Land Use, Planning and Zoning local position, receiving areas in the rural non-planned Howard County service area, if it meant increased density.

The sending parcel is designated as a preservation parcel of less than 2 net acres with an existing dwelling unit. The parcel would be recorded as a sending parcel on a recorded plat designated as a Neighborhood Preservation Parcel. The Preservation Parcel would require that any new structure on the parcel be restricted in size to no larger than 50% of the footprint of the existing dwelling unit.

The density of receiving areas is different - 10% additional density for R-SA 8, R-A-15, CAC and TNC Districts and 5% for PGCC and MXD Districts. In the PGCC Districts the density could only be used if the comprehensive Sketch Plan or Final Development Plan were amended and approved by the Planning Board. In the MXD District the Zoning Board would have to approve an amendment to the Preliminary Development Plan.

Issues: Balance:
The League did not map out the potential numbers of dwelling units that could be sent from existing residential net acreage parcels and the proposed receiving zoning district parcels that could accept additional density. In order for this proposal to be viable there needs to be some comparative balance between the sending and receiving parcels.

New Town:
The proposal does not include New Town designated parcels. The League knows that additional residential development will continue to support the vitality of at a minimum the New Town Columbia Downtown Master Plan Area. ZRA95 should be amended to permit the approved Downtown Master Plan Area be a receiving area with 5% additional density.

Density %
The rationale for the different % of density for the receiving areas is not explained. In addition, the difference between 5% and 10% density is substantial when applied to larger receiving parcels. What is the impact to height of buildings and lot coverage with the 10% bonus? What impacts will the 10% density make on APFO tests? The League supports a consistent density bonus in all receiving districts of 5%.

Undeveloped R-ED, R-20 and R-12 parcels
Existing undeveloped parcels should be included in ZRA95. The undeveloped parcel size should not be limited. A provision for use of these undeveloped parcels as pocket parks or open space parkland should be considered. These parcels could have an option to send density, be purchased by Howard County Recreation and Parks or land banked by the County.

Transfers to support Preservation Parcels
ZRA 95 does not include the concept of transferring density from existing preservation parcels in the State Farmland Preservation Program as well as other smaller currently preserved but not included in Farmland preservation parcels. The Planning Board and ZRA 95 sponsor should consider the transfer of density from the non-planned service area into the planned service area.

We thank the Planning Board for consideration of our testimony.

Grace Kubofcik
Co-president

Cc: Council member Courtney Watson