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March 28, 2006
Mr. Ralph Hutchison, Mr. Dennis Gehringer,
Township Manager Land Use Planning Consultant
2205 Old Philadelphia Pike 841 Flory Mill Road
Lancaster, PA 17602 Lancaster, PA 17601
RE: Proposed Amendment to the Zoning Ordinance of
East Lampeter Township
Relating to the Residential-2 Zoning District (As submitted on behalf of the “Warrington Project”)
Dear Messrs. Hutchison and Gehringer:
The Coalition for Smart Growth is pleased to have been requested to review and comment on the above-captioned Zoning Ordinance Text Amendment. We have reviewed the Amendment in accordance with the principles of Smart Growth that are detailed in our Policy/Position Paper, developed in 2003 and summarized in the Executive Summary of same, entitled “Coalition for Smart Growth: Making Progress. Good for Everyone.” A copy of this Executive Summary is attached for your convenience.
We have also provided comments related to specific aspects of the ordinance at the conclusion of this letter.
Adherence to Smart Growth Principles
While our Executive Summary cites some twenty-two basic principles, we believe that the following eleven principles (highlighted in bold typeface) are particularly germane to this Zoning Ordinance Text Amendment. In discussing them below, we have combined several so as to be brief in our comments.
· The Coalition encourages compact development and adaptive reuse of buildings to decrease development pressures on greenfields.
· Designated Growth Areas represent one tool by which communities within a region can plan for growth in a manner consistent with their vision of the future.
· Infrastructure…should be regionally planned and coordinated, implemented, maintained, budgeted, and funded.
·
Transportation issues impact every person and every business in
this County.
· Transportation planning focuses on safety, mobility, capacity, and improved access and is a critical component of regional planning efforts.
· Land use regulations must support a community’s vision for the future while also supporting smart growth. Land use regulations should be consistent, regional in context, and flexible.
· Homeownership and rental housing choices must be affordable for all segments of Lancaster County’s population and uniformly available in every community.
· The housing industry and municipalities should partner to create ordinances that make it easier to build traditional neighborhoods and mixed-use housing communities.
· Subdivision designs containing more affordable housing choices should receive a density bonus and fee waivers from local government.
Commentary: The
Coalition supports the Zoning Ordinance Text Amendment on the basis of its
adherence to the above principles, noting the following:
A. The text amendment would engender the increased density of development that is necessary to fully implement the goals of the Conestoga Valley Joint Comprehensive Plan and the County’s Growth Management Element Update, entitled “Balance.” It is through this increased density that Designated Growth Areas and agricultural preservation can occur simultaneously.
B. The text amendment directs increased density of development to areas of the Township and the Conestoga Valley Region suited for same, as characterized by available infrastructure (including public water and wastewater utilities and transportation networks).
C. The text amendment has been prepared as a direct means of affecting the communities’ vision as depicted in the Conestoga Valley Joint Comprehensive Plan; while prepared by and for a specific development plan, it represents the type of partnership between the housing industry and municipalities necessary to create effective ordinances.
D. We note, however, that the text amendment requires approval of traditional neighborhood, mixed-use developments by conditional use, not by right. We caution that this adds to the cost of the approval process and, ergo, to the increased cost of housing. We believe that projects that are truly compatible with the communities’ vision should be permitted by right. We strongly encourage that the provisions of the Ordinance requiring Conditional Use approval be amended so that the developer is not penalized for endeavoring to do the right thing.
· Regional Planning provides for efficient and coordinated decision-making and delivery of services as well as prudent use of capital when the demand for services increases.
· Strategic Comprehensive Planning is essential to the development of a “preferred future” vision for the County and its communities. Strategic Comprehensive Plans create a framework for adoption of consistent land use policies and regulations and provide a means to systematically update a community’s vision.
· Inter-municipal cooperation is essential to achieve consistency in permitting and taxation processes.
Commentary: The
Coalition commends West Earl, Upper Leacock, and East Lampeter Townships for
having participated in the development of the Conestoga Valley Joint
Comprehensive Plan. However, we encourage the municipalities to now work
cooperatively on a single Zoning Ordinance for the region, as opposed to the
current approach of altering each of the three municipalities’ Zoning Ordinances
individually. We note that the proposed Ordinance text is a modification
applied narrowly to the existing Residential-2 zoning district in East Lampeter
Township. A more proactive, cost-efficient approach would have had this
Ordinance standard become the norm throughout the three Conestoga Valley
municipalities across a range of residential zoning districts.
Specific Comments on the Proposed Text Amendment
In addition to the above comments, the Coalition encourages that the following specific provisions be reconsidered:
1. Are mixed-use structures (apartments over neighborhood commercial uses and live/work units) adequately addressed?
2. Should density bonuses be provided to encourage the provision of affordable housing units?
3. It appears that a number of new terms may have been created within the text of this Ordinance amendment. If so, new definitions may be required.
4. Should accessory apartments (for family members) be a permitted use?
5. We note that banks and financial institutions are permitted, excluding drive-thru functions, even though access to such facilities is required from arterial or major collector streets. Is this a shortcoming of the Ordinance that could potentially exclude banks from wanting to locate to such future neighborhoods?
6. We assume that the “required mix and integration of dwellings” has been tested to assure that these provisions do not negatively impact the goals of increased density within the Residential-2 zoning district. If not, we would encourage that these provisions be tested or eliminated.
7. We would encourage that, in addition to stating the maximum permissible density, the minimum residential density also be prescribed. This could assure that low-density, land-consuming residential development will be discouraged.
8. We believe that minimum rear setbacks of 20’ are too restrictive.
9. Garage setback standards should be separately considered. A front-loaded garage should be provided with a minimum setback of 20’ to provide off-street parking in front of the garage. Similar setbacks should be provided for rear-loaded (alley accessible) garages.
10. Are the unit-to-unit separation distances compliant with the Township’s prevailing building code? We assume that they are, but suggest that they be confirmed.
11. Vehicular access should probably be located further than 20’ from the intersection of street right-of-way lines.
12. As noted in our earlier comments, the Architectural Density Provisions require considerable architectural detail that 1) does not positively impact the affordability of housing and 2) is subject to an unpredictable approval process. We further note that these standards should verify compliance with the above-suggested garage siting provisions.
13. What purpose is served by limiting exterior building finishes to no more than two types of material? This provision is not consistent with indigenous building material usage in Lancaster County. You will often see older structures in the County whose facades consist of three or more material types.
14. Is Street Type A required to have a landscaped median? This is not clear as currently written.
15. Should one-way alleys even be permitted/encouraged? We believe alleys should be 16’ wide to facilitate plowing/shoveling of snow, trash removal, and other vital services.
16. How is the requirement for on-street parking determined? We would encourage that these issues be resolved early on in a project’s planning via the pre-application/sketch plan process.
17. Stub streets should also be permitted where they abut lands zoned for potential future development.
18. Minimum light pole heights of 6’ should be considered in terms of locational requirements and safety. Conversely, minimum pole-height limitations preclude the use of bollard-style lighting.
As noted above, the Coalition for Smart Growth appreciates the opportunity we have been extended to review and provide comment on this Zoning Ordinance Text Amendment. If requested, we look forward to the opportunity to present our comments at upcoming Township Planning Commission and Board of Supervisors’ meetings.
Making progress. Good for everyone.
President
Cc: West Earl Township
Upper Leacock Township
March 17, 2006
The Honorable Dick Shellenberger, Chairman
Board of County Commissioners
Lancaster County Courthouse
50 North Duke Street
Lancaster, PA 17602
RE: Endorsement of the Growth Management Element Update “Balance”
Dear Commissioner Shellenberger:
The Board of the Coalition for Smart Growth unanimously endorses “Balance,” the Update to the Growth Management Element of the County’s Comprehensive Plan. In doing so, we also commend the work of the Update’s Task Force and its Co-Chairs (Lois Herr and Ron Beam), recognizing the considerable efforts of these citizen volunteers who produced a truly “consensus document.” We would be remiss if we did not also commend the Lancaster County Planning Commission (LCPC), its staff, and the Professional Consultants (led by Wallace Roberts & Todd) who completed the work of this visionary document.
We believe that “Balance” provides a clear roadmap to the County’s preferred future with regard to the factors of Agriculture, Economic Development, Community Planning, Human Resources, Affordable Housing, and Natural and Cultural Resources. We note that there are striking similarities between “Balance’s” treatment of these factors and the Position/Policy Paper of the Coalition for Smart Growth, entitled “Making Progress. Good For Everyone,” a copy of the Executive Summary of which we have attached hereto. As detailed in our Paper, these factors are inextricably intertwined and require proper balance to ensure that each advances simultaneously, not at the sake of each another.
As you are undoubtedly aware, many of the Coalition’s board members and constituents served on the Task Force that developed “Balance.” We are therefore duty-bound to identify that “Balance” could easily have been entitled “If.” To wit, the preferred future of Lancaster County requires that new targets, new initiatives, and new strategies be employed to strike the desired balance. If we fail to do so, the work of “Balance” will have been for naught.
This concern is readily apparent when we consider that “Balance” incorporates a “lag-time” between the adoption of the Update and the full implementation of its proposed strategies. As stated in the enclosed Executive Summary of our Position/Policy Paper, “the Coalition is united by a sense of urgency to move forward.” The lag-time acknowledged in “Balance” must be as short as is possible.
Therefore, upon adopting “Balance,” we implore the Board of County Commissioners to take two immediate steps:
· Direct the LCPC to work with the County’s Geographic Information System (GIS) Department and each of the County’s 60 municipalities to revamp our current growth-tracking system. This County urgently needs a state-of-the-art “real time” growth tracking system, capable of measuring our effectiveness in implementing the new targets mandated in “Balance.”
· Direct the LCPC to immediately impanel a Growth Management Implementation Advisory Committee. The first task of this Committee, without fail, must be the development of a realistic budget by which we match the public investment of funds to the implementation of “Balance.” Then, we appeal to you to boldly fund these initiatives over the long-term.
Whether expended to achieve consistency between comprehensive plans and infrastructure plans, to re-write land use codes, to assure that infrastructure is available and maintained, to improve the efficiency of land use inside of Designated Growth Areas, or to encourage the development of affordable housing; the investment of public monies must be linked to the systematic implementation of “Balance.” And, at the end of the day, we will have preserved those resources and institutions that so contribute to our quality of life.
“Balance” serves to provide sound foresight and a solid foundation for the implementation of Lancaster County’s preferred future well into the next 25 years. We are confident that, if fully implemented, the strategies found in “Balance” can yield a future that preserves the resources and quality of life that we enjoy in Lancaster County while providing for managed growth.
The Coalition for Smart Growth looks forward to the opportunity to assist in the advancement of “Balance,” “Choices,” and “Heritage”. Again, we commend all those who have contributed to a job that, thus far, has been well done.
CC: The Honorable Howard “Pete” Shaub
The Honorable Molly Henderson
James Cowhey, Executive Director of the LCPC
Task Force Co-Chairs (Lois Herr and Ron Beam)
Constituent Organizations of the Coalition for Smart Growth
Nancy Williams, LCPC
Mary Frey, LCPC
Wallace Roberts & Todd
C/O Mr.
RE: Haverstick Tract
Dear Mr. Smith:
The Coalition for Smart Growth has been asked by
While our Executive Summary cites some twenty-two basic principles of Smart
Growth, we believe that the following ten principles (highlighted in bold typeface) are particularly germane
to the Haverstick Tract. In discussing them below, we have combined
several so as to be brief in our comments.
·
The
Coalition encourages compact development and adaptive reuse of existing
buildings to decrease development pressures on greenfields.
·
Designated
Growth Areas provide for growth in a manner consistent with communities’
visions for their preferred future.
·
Infrastructure
should be regionally planned and coordinated, implemented, maintained,
budgeted, and funded.
·
Transportation
planning focuses on safety, mobility, capacity, and improved access and is a
critical component of regional planning efforts.
·
Public
and private organizations must work together to protect
Commentary: The Coalition
for Smart Growth
A. Currently at about 3 dwelling units/gross acre, the Concept Plan could provide additional density so as to be more closely in line with the goals/targets of both the County’s Draft Growth Management Plan “Balance” and the Draft Lancaster Intermunicipal Committee (LIMC) Comprehensive Plan “Growing Together.”
B. The site is served by existing public water and wastewater utilities. We understand that the Developer has reserved this capacity for a period of seven years.
C.
The site provides direct access to
D. The Concept Plan would preserve existing natural features (including, but not limited to, steep slopes and floodplains) and the historic home located on the site.
We understand that the landowner/developer will propose deed restrictions assuring as close conformity with the Concept Plan as can be maintained.
·
Regional
Planning provides for efficient and coordinated decision-making and delivery of
services as well as prudent use of capital when the demand for services
increases.
·
Strategic
Comprehensive Planning is essential to the development of a “preferred future”
vision for the County and its communities.
Strategic Comprehensive Plans create a framework for adoption of
consistent land use policies and regulations and provide a means to
systematically update a community’s vision.
·
Land use
regulations must
Commentary: In addition to reviewing the landowner’s/developer’s Concept Plan, we have studied the LIMC’s Comprehensive Plan “Growing Together” and the vision it captures for the communities of the LIMC area. This Plan captures the communities’ hopes and aspirations for its preferred future and then advances them through directed goals and strategies.
Having said this, the Coalition is concerned by several aspects of this tract as addressed in “Growing Together.”
A. The lack of this site’s designation as an “Opportunity Site” when the site would appear to meet the attributes developed for this designation.
B. Absent the designation of “Opportunity Site,” the lack of “triggers” by which this site (or any other similar site) can become designated as such so as to further the goals of the County’s “Balance” and the LIMC’s “Growing Together” plans.
We would appreciate the opportunity to discuss these concerns with Township
representatives.
·
Homeownership
and rental housing choices must be affordable for all segments of
· The housing industry and municipalities should partner to create ordinances that make it easier to build traditional neighborhoods and mixed-use housing communities.
Commentary: As currently zoned, the Haverstick Tract’s potential development as a low-density, sprawling development will not advance the principles of Smart Growth. In doing so, an opportunity would be missed to match this site’s potential mixed-use development with the goals and strategies of the County’s “Balance” Growth Management Plan and “Choices” Housing Plan.
We would encourage that the Township and the landowner/developer work together to effect the tract’s development similar to the Concept Plan, whereby a higher-density, mixed-use development, characterized by housing choices affordable across a wide range of demographics, could become an asset to Manor Township and the LIMC region.
As noted above, the Coalition for Smart Growth would embrace the opportunity to meet with the Township to discuss our comments in further detail.
Making progress. Good for everyone.
Coalition for Smart Growth
President of the Board of Directors
Cc:
John Ahlfeld, Executive Director, LIMC
LIMC Municipalities
Agricultural Preservation Board
of Lancaster County
Associated Builders and
Contractors
Building Industry Association of
Lancaster County
Economic Development Company of
Lancaster County
Housing Development Corporation
Lancaster County Association of
Realtors®
Lancaster County Association of
Township Supervisors
Lancaster Chamber of Commerce
& Industry
Lancaster County Conservancy
Lancaster County Conservation
District
Lancaster Community Indicators
Project
Lancaster County Planning
Commission
Lancaster County Redevelopment
Authority
Lancaster Farmland Trust
Lancaster Housing Opportunity
Partnership