Chairman CitaraManis and Planning Board members:

RE:ZRA 96: Amendments to the subdivision and Land Development Regulations to Establish requirements to subdivision and resubdivision infill development of ten or fewer lots within R-20, Residential Single and R-12, Residential Single zoning districts and amendments to the R-20 and R-12 Districts bulk Zoning Regulations in order to establish the density requirement for neighborhood infill developments.

The League of Women Voters of Howard County supports with comments ZRA96 that proposes to establish subdivision and resubdivision regulations related to neighborhood residential infill and establishes density and minimum lot sizes for neighborhood infill subdivisions or resubdivisions in the R-20 andR-12 zoned parcels. Subdivision or resubdivision of property would have to involve 10 or fewer lots and be surrounded by recorded subdivisions with lots improved with existing single family detached dwellings of 20,000 square feet or greater in the R-20 District or 12,000 square feet or greater in the R-12 District.

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 and the Howard County League's Land Use, Planning and Zoning position of support for environmental and sustainable balance in developing property including the protection/restoration of habitat and natural resources.

The League participated on the Department of Planning and Zoning Infill Committee. Along with other participants, we heard many issues related to the impacts of infill development in established neighborhoods. The impacts included poor lot design, storm water management problems, drainage problems, clearing of mature trees, pipe stem issues including the lay out of houses adjacent to the pipe stem and the relationship of the infill homes to each other and the existing neighborhood homes. The Department of Planning and Zoning provided the Taskforce with specific examples in the Planned Service area of extremely poor pipe stem lot design and house placements that technically met the requirements of the Howard County Subdivision regulations but created eyesores of development and impacted environmental features. Another infill issue is safety related the limited access and maneuverability by emergency fire vehicles to homes along pipe stems. Many of the large lot R-20 and R-12 subdivisions were developed prior to current requirements for residential storm water management. Many of the infill lots are substantially smaller in size than the lots in the neighborhood making the current standard homes appear even larger than the existing neighborhood homes. Most infill R-20 lots are 12,000 to 14,000 square feet in contrast to the 20,000 square feet or larger lots in the neighborhood.

Comments:

Applicationof the proposed subdivision regulation changes: the Infill Taskforce was composed of residents representing the Planned Service area of the county as well as builders, developers, real estate and other interests. The dominant discussion was focused on Planned Service area development and subdivision changes to positively affect the Planned Service area. Pipe stems for the rural western part of the County were not discussed except to acknowledge how they are used in the context of much larger parcel development. The League supports the ZRA 96 pipe stem proposals with application limited to the Planned Service area.

Neighborhood Infill: The League supports the concept and Neighborhood Infill definition as well as the proposed zoning regulation special bulk requirements for R-20 and R-12. Density of 2 dwelling units per net acre with a minimum lot size of 20,000 square feet in R-20 is very compatible with development in the older R-20 zoned residential areas. The R-12 neighborhood infill density of 3 dwelling units per net acre and a minimum lot size of 12,000 square feet are also very compatible.

Compatibility: The proposed subdivision regulations ask that infill projects be compatible by dwelling unit type and utilize perimeter landscaping. The League supports this provision.

Disturbance of 2,000 square feet or more require a detailed plot plan: Grading and drainage need to be evaluated to prevent adverse impacts on adjacent homes. This provision also speaks to home additions that cause disturbance of 2,000square feet or more. The League supports both provisions and recognizes as more infill and home additions are made the evaluation to prevent adverse impacts on adjacent homes includes the need for infrastructure retro fitting. The infrastructure changes need to be identified prior to permitting the requested development. There is no question this will add to the cost of a project and consideration should be given to a reduction or waiver of the Department of Planning and Zoning's fee for review if it a home addition.

Protection of Scenic Roads: The League supports the proposed 50 not 35 foot buffer of existing forest or wooded area between the road right-of-way and new development. The League also supports the planting of a forest buffer of at least 50-foot depth adjoining the scenic road right-of-way if there is no preservation parcel of at least 200 feet in depth.

Retention of Existing specimen trees: Finally the subdivision regulations propose that development plans should facilitate the retention of healthy specimen trees of 18inch caliper or greater. The regulations propose both incentive to retain such trees and penalties for removing the trees. The League supports these new provisions.

Thank you for your consideration of our comments.

Grace Kubofcik
Co-president