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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
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