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HomeMy WebLinkAbout2019-11-08 Geoffrey M. Wardle (BVA Comments) Geoffrey M. Wardle 208.388.1000 GWardle@ClarkWardle.com Sent via Email to: cityclerk@meridiancity.org November 7, 2019 Mayor Tammy de Weerd Meridian City Council - Joe Borton, President; Luke Cavener, Vice President; Anne Little Roberts; Ty Palmer; Treg Bernt; Genesis Milam c/o Meridian City Clerk (cityclerk@meridiancity.org) City of Meridian, Community Development Department 33 E. Broadway Avenue Meridian, Idaho 83642 Re: Modifications to draft FLUM & Meridian Comp Plan – SW Corner of Meridian Road and Victory Road, and NE Corner of McMillan Road and Locust Grove Road CW File No. 23699.0 Dear Mayor and Council Members, We appreciate the opportunity to comment on the proposed draft Comprehensive Plan (“Comp Plan”) and Future Land Use Map (“FLUM”) changes. We want to thank each of you, and the City’s Planning and Zoning Commission, the steering committee, and City staff for all of the hard work expended to reach this point of the process to amend the City’s Comp Plan and FLUM. We have had meetings with City staff on the sites identified herein starting in Fall 2018 and continuing through the process that has occurred during 2019. In August we submitted written comments to City staff about proposed land use designations in the draft Comp Plan and FLUM for several areas of the City of Meridian . In September we had follow up meetings with City staff. In October we provided additional comments to the Planning and Zoning Commission. We testified at the Planning and Zoning Commission’s October 17, 2019, public hearing, in which we focused further on these two specific sites identified herein: ▪ the Southwest corner at the intersection of Victory Road and Meridian Road, and ▪ the Northeast corner at the intersection of Locust Grove Road and McMillan Road. We request the two following modifications to the proposed FLUM: November 7, 2019 Re: Southwest Corner of Meridian Road & Victory Road, and Northeast Corner of McMillan Road & Locust Grove Road Page 2 of 11 S:\Docs\BVA - Victory SW\BVA - Victory SW - General\LTR\ltr to Meridian City Council re FLUM and Comp Plan requests, v.2 (11-7-2019).docx Southwest Corner, Intersection of Victory Road & Meridian Road Northeast Corner, Intersection of Locust Grove Road & McMillan Road Existing Use Designations in the Current FLUM → Use Designations Proposed in the Draft FLUM → Our Requested Modifications to Proposed Use Designations → either Commercial or Mixed Use Community Commercial November 7, 2019 Re: Southwest Corner of Meridian Road & Victory Road, and Northeast Corner of McMillan Road & Locust Grove Road Page 3 of 11 S:\Docs\BVA - Victory SW\BVA - Victory SW - General\LTR\ltr to Meridian City Council re FLUM and Comp Plan requests, v.2 (11-7-2019).docx Our requested modifications to the proposed land use designations for each of these sites are discussed below, and are supported both by the existing Comp Plan and the proposed draft Comp Plan. I. SOUTHWEST CORNER, VICTORY ROAD AND MERIDIAN ROAD A. Site Description and Current Condition An affiliate of Ball Ventures Ahlquist (“BVA”) owns five parcels at the southwest corner of Victory Road and Meridian Road (those depicted with red boundaries), totaling 15.38 acres. The five parcels, together with a separately-owned, adjacent 4.03 acre parcel (shown in orange on the aerial depiction to the right), have not been annexed into the City of Meridian. BVA has been evaluating these parcels for development. The existing FLUM designates these parcels as Medium Density Residential and Low Density Residential, and they would be continue to be designated as Medium Density Residential under the proposed draft FLUM revisions. Neither Medium Density Residential nor Low Density Residential is appropriate for this site. The other three corners of this intersection have developed more intensively than the existing Low Density Residential and Medium Density Residential designations, with zoning designations of C-G, R-15, and L-O, in recognition of the fact that the intersection of a major arterial and a state highway inherently encourage s more intensive development. B. Requested Use Designation: Commercial We believe that the appropriate use designation for the five unannexed parcels at this location is Commercial (or, alternatively, Mixed Use Community), which would provide an improved guide to future growth and development in this area of the City by recognizing existing development patterns. A Commercial designation would be compatible with the proposed November 7, 2019 Re: Southwest Corner of Meridian Road & Victory Road, and Northeast Corner of McMillan Road & Locust Grove Road Page 4 of 11 S:\Docs\BVA - Victory SW\BVA - Victory SW - General\LTR\ltr to Meridian City Council re FLUM and Comp Plan requests, v.2 (11-7-2019).docx Medium Density Residential developments to the south and west, as this is essentially the same land use pattern that already exists on the northeast corner of this intersection. Several significant topographical and physical limitations prevent effective integration of these properties with the existing residential subdivision to the south. For example, an elevation change along the southern boundary of the BVA parcels creates a natural ridge and barrier between this site and the existing homes, and limits opportunities for connectivity between the two sites. Also, the existence and location of irrigation facilities bisecting this site significantly limits the possibility for residential development. Currently, connectivity options linking the existing Meridian Heights No. 2 subdivision and the BVA affiliate-owned properties are limited. Only one street (S. Peoria Way) was stubbed north from the existing subdivision, and it does not align with the properties owned by the BVA affiliate. Ultimately, access will need to be improved in this location , with enhanced connectivity from the existing subdivision to the south, and north to Victory Road, to ensure that left-hand turning movements will occur at the signal located at the major intersection and not at Bloomington Drive, which serves the existing residential subdivision. We believe that development at this location should have the following general layout: This layout would ensure that the existing Meridian Heights subdivision to the south and future residential development to the west would be buffered from the major intersection at Meridian Road and Victory Road. This layout also greatly improves connectivity: November 7, 2019 Re: Southwest Corner of Meridian Road & Victory Road, and Northeast Corner of McMillan Road & Locust Grove Road Page 5 of 11 S:\Docs\BVA - Victory SW\BVA - Victory SW - General\LTR\ltr to Meridian City Council re FLUM and Comp Plan requests, v.2 (11-7-2019).docx ▪ Peoria Way could be extended north, to connect to Victory Road and align with S. Alfani Way; and ▪ Access to the site from Meridian Road could be located between Victory Road and Bloomington Drive, as a private commercial drive with restricted (right-in, right-out) access to Meridian Road. This configuration would minimize congestion on Meridian Road, with vehicles making northbound movements doing so by accessing the traffic signal at Victory Road. C. Planning and Zoning Commission’s October 17, 2019 Public Hearing As outlined above, a year ago our clients desired to submit a development application for this site, but City staff encouraged us to await the outcome of this process, unwilling to recommend approval of any applications for changes to use designations while the process of amending the Comp Plan and FLUM was underway. Our clients were informed that they would have an opportunity to request modifications to the FLUM for specific sites during this process, precipitating our original August submittal once the draft Comp Plan an d FLUM were circulated. During the Planning and Zoning Commission’s October 17, 2019, public hearing, Commission Chair Jessica Perreault asked City staff if they would support a change “from medium density to commercial” at this site. City staff hedged, noting that it didn’t have a development application to review, but staff ultimately replied: Yeah, I think staff could support a map change here with the right project and the right -- you know, if it works still within the neighborhood, yea, I could see u s supporting it for sure. Transcript of Meridian Planning and Zoning Commission, October 17, 2019, p. 100 of 107. As a result of City staff’s stated desire for a project-specific development application, however, the Planning and Zoning Commission recommended approval of the proposed draft FLUM update without approving our request to change the use designation for this location. Notwithstanding City staff’s claim that it “could” support a map change, based upon prior experience with map amendments, comprehensive plan amendments, and zoning code rewrites, we fear that “amendment fatigue” will set in and neighbors, City staff, the Planning and Zoning Commission, and the Council will be reticent to entertain amendments in the near future citing the lengthy nature of this this process. City staff confirmed as much at the October 17, 2019, Planning and Zoning public hearing, stating further that: November 7, 2019 Re: Southwest Corner of Meridian Road & Victory Road, and Northeast Corner of McMillan Road & Locust Grove Road Page 6 of 11 S:\Docs\BVA - Victory SW\BVA - Victory SW - General\LTR\ltr to Meridian City Council re FLUM and Comp Plan requests, v.2 (11-7-2019).docx I think we are going to heavily scrutinize any map amendments, right, because we have -- we are going through this process. Transcript of Meridian Planning and Zoning Commission Minutes, October 19, 2019, p. 99 of 107. D. Action and Next Steps We believe that the modification to the FLUM requested above is supported not only by the existing Comp Plan, which could have justified this application last year when we first inquired about it, but also the draft Comp Plan. The justification for such is attached hereto in more detail in Exhibit A, our prior submittal to the Planning and Zoning Commission. We are in fact amenable to making applications for comprehensive plan map amendment, annexation, zoning, development agreement and preliminary plat for this site and have held off doing so for more than a year with the promise that our concerns would be addressed through this planning process. At the Planning and Zoning Commission he aring it was implied that our client has been unwilling to make an application for this site and to make commitments to the proposed access and other elements. That is not the case. Applications have not been submitted in deference to and consideration of City staff’s direction. We respectfully request that the southwest corner of the intersection of Victory Roa d and Meridian Road be given a Commercial or Mixed Use Community use designation on the FLUM, which would permit a commercial zoning designation (C-C, C-G, or M-E) upon annexation of these properties into the City of Meridian. These uses would be compatible with adjoining uses and could facilitate future connections that would enhance the flow of pedestrian and vehicle traffic in the neighborhood. We strongly believe that re-designating this site as Commercial will provide an improved guide to future growth and development of the City. II. MCMILLAN ROAD AND LOCUST GROVE ROAD. A. Site Description and Current Condition In the existing FLUM, the area located immediately northeast of the intersection of McMillan Road and Locust Grove Road is designated as “Mixed Use Neighborhood.” These parcels have been annexed and are zoned Neighborhood Business (C-N). Two of the subject parcels are owned by an affiliate of BVA Development, which has had difficulty attracting users due to: (a) the existing land use designation, (b) the existing zoning, (c) the small size, (d) the difficult configuration of the site, and (e) other complicating factors. November 7, 2019 Re: Southwest Corner of Meridian Road & Victory Road, and Northeast Corner of McMillan Road & Locust Grove Road Page 7 of 11 S:\Docs\BVA - Victory SW\BVA - Victory SW - General\LTR\ltr to Meridian City Council re FLUM and Comp Plan requests, v.2 (11-7-2019).docx In 2008, the plat of the Woodland Springs No. 1 subdivision (above, right) was approved and recorded affecting a portion of the property. The pink overlay above demonstrates the extent of the “Neighborhood Business” (C-N) zoning that currently exists on the properties and the purple outline depicts the location of the phase 1 plat . B. Requested Use Designation: Commercial We respectfully request that the use designation of this site be changed to Commercial. If the Mixed Use Neighborhood designation remains on this site, several circumstances make it difficult, if not impossible, for development here to achieve the goals and objectives contained in the Development Agreement, or the existing Comp Plan or in the proposed draft Comp Plan. Moreover, the Mixed Use Neighborhood designation precludes meaningful opportunities to further refine the Development Agreement or to obtain appropriate zoning for the site due to the requirements that such be “in accord with” or “comply with” or “in conformance with” the comprehensive plan. Meridian City Code Sections, 11-1-2, 11-5B-2, 11-5B-3(E), 11-6B-6. The circularity of this issue is evident. Because the property has been designated Mixed Use Neighborhood, any amendment to the existing development agreement or to the underlying zoning can only occur if “in accord with” the comprehensive plan and map. Because of the requirements associated with Mixed Use Neighborhood, no modification can satisf y that requirement. November 7, 2019 Re: Southwest Corner of Meridian Road & Victory Road, and Northeast Corner of McMillan Road & Locust Grove Road Page 8 of 11 S:\Docs\BVA - Victory SW\BVA - Victory SW - General\LTR\ltr to Meridian City Council re FLUM and Comp Plan requests, v.2 (11-7-2019).docx Although City staff intimated that because an area designated across the street a s Mixed Use Neighborhood there is a meaningful opportunity for this site, we respectfully disagree. Small, disconnected parcels that lack meaningful integration with the preexisting transportation connections and that are dimensionally unworkable for the density and type of residential development required in the Comp plan, should not be designated as Mixed Use Neighborhood. More intensive commercial uses should be permitted and encouraged at these locations without the impractical limitations that exist under the Mixed Use provisions of the Comp Plan. The developable land at this site is insufficient for the range of uses required in the MU-N designation and the existing Development Agreement encumbering the property evidences such. The text of the existing Comp Plan describes the purpose of MU-N as follows: The purpose of this designation is to assign areas where neighborhood-serving uses and dwellings are seamlessly integrated into the urban fabric. The intent is to avoid predominantly single-use developments by incorporating a variety of uses. Land uses in these areas should be primarily residential with supporting non-residential services. … Developments are also encouraged to be designed according to the conceptual MU-N plan depicted in Figure 3-1. Meridian Comp Plan, p. 24, in pertinent part (emphasis added). The following figure, taken directly from the current Comp Plan, depicts the variety of uses expected in an area with a Mixed Use-Neighborhood designation: November 7, 2019 Re: Southwest Corner of Meridian Road & Victory Road, and Northeast Corner of McMillan Road & Locust Grove Road Page 9 of 11 S:\Docs\BVA - Victory SW\BVA - Victory SW - General\LTR\ltr to Meridian City Council re FLUM and Comp Plan requests, v.2 (11-7-2019).docx Although there is a small area southwest of this site also designated MU-N (kitty corner across the intersection), the subject site is too small to accommodate the range of uses required on property designated MU-N. There is also a significant lack of connectivity from existing residential developments to the site. The only stubbed street from Sheridan Place is in a location, north of the site, that connects to a parcel not in common ownership that remains in unincorporated Ada County. That street, when constructed and extended, may allow the subject parcels to connect to the Sheridan Place subdivision, but the timeline for its construction is unknown (and outside our clients’ control), making coordination impossible. Pursuant to the existing Comp Plan, “[r]esidential uses should comprise a minimum of 40% of the development area…” in an area designated MU-N (Comp Plan, p. 25), which would be impossible on the subject site. In addition, the subject properties are located in an area that already is inundated with existing residential developments. The existing zoning designations in the area are shown in the aerial depiction to the right. C. Planning and Zoning Commission’s October 17, 2019 Public Hearing During its October 17, 2019 public hearing on the proposed Comp Plan and FLUM amendments, the Planning and Zoning Commission recognized that the size of the site, existing easements, and other factors should preclude a Mixed Use Neighborhood designation. Commission Chair Jessica Perrault stated: November 7, 2019 Re: Southwest Corner of Meridian Road & Victory Road, and Northeast Corner of McMillan Road & Locust Grove Road Page 10 of 11 S:\Docs\BVA - Victory SW\BVA - Victory SW - General\LTR\ltr to Meridian City Council re FLUM and Comp Plan requests, v.2 (11-7-2019).docx …I am in agreement with the -- the gentleman who testified that the area off Locust Grove and -- and McMillan is too small of an area to have as a mixed use designation. Transcript of Meridian Planning and Zoning Commission Minutes, October 19, 2019, p. 97 of 107. As with the other site, City staff wanted to see a development proposal before committing to support our clients’ request to re-designate this area Commercial, but staff also recognized that this site is small: We aren’t necessarily going to pound our fists for high -density residential or that residential component on your property, realizing it isn’t overly large. Transcript of Meridian Planning and Zoning Commission Minutes, October 19, 2019, p. 98 of 107. Importantly, though, City staff mischaracterized the type of development that our clients desire at this site and the limitations on rezoning City staff has previously articulated: Not necessarily opposed to it, but we think [a development proposal and development agreement modification is] maybe a better path forward to make sure that there is still some neighborhood-serving commercial there and it doesn’t become, you know, a four-story box or something that just doesn’t fit in well with the neighborhood. Transcript of Meridian Planning and Zoning Commission Minutes, October 19, 2019, p. 98 of 107. We unfortunately believe that City staff has misunderstood the request and concern that we raise here. If there is a desire to have neighborhood-serving commercial at this location, then the appropriate land use designation is in fact Commercial and not Mixed Use Neighborhood permitting amendment to the development agreement and zoning of the site to truly permit neighborhood serving commercial. D. Action and Next Steps Again as set forth above, we would be amenable to seeking to modify the zoning and the development agreement encumbering this site, but only if the land use designation is changed to Commercial. We have suggested alternative courses of action to City Staff for this site, but again have been discouraged from doing anything out side of this process. November 7, 2019 Re: Southwest Corner of Meridian Road & Victory Road, and Northeast Corner of McMillan Road & Locust Grove Road Page 11 of 11 S:\Docs\BVA - Victory SW\BVA - Victory SW - General\LTR\ltr to Meridian City Council re FLUM and Comp Plan requests, v.2 (11-7-2019).docx We believe that the modification to the FLUM requested above designating this location as Commercial is supported by both the existing Comp Plan and the draft Comp Plan. The justification for such is attached hereto in more detail in Exhibit A, our prior submittal to the Planning and Zoning Commission. Re-designation of the area northeast of McMillan and Locust Grove as Commercial will enable development that will supports the existing housing and complement and serve existing residential developments in the area. We respectfully request that the use designation of this site be changed to Commercial. IV. CONCLUSION. At each of these two sites, the use designations on the updated FLUM are not supported by the goals and objectives of either the current Comp Plan or the proposed draft Comp Plan. We respectfully ask for the use designations in each of these locations to be changed as follows: ▪ Southwest corner of Meridian Road and Victory Road: Commercial (or, alternatively, Mixed Use Community); and ▪ Northeast corner of Locust Grove Road and McMillan Road: Commercial. We strongly urge the City to re-evaluate the future land use designations for these two sites, and to re-designate them as requested herein. Sincerely, Geoffrey M. Wardle Cc: Tommy Ahlquist Tonn Peterson Cortney Liddiard Brian McClure (bmcclure@meridiancity.org) Caleb Hood (chood@meridiancity.org) ENCLOSURE Exhibit A EXHIBIT A October 8, 2019 Letter to Planning and Zoning Commission Geoffrey M. Wardle 208.388.1000 GWardle@ClarkWardle.com Sent via Email October 8, 2019 Brian McClure (bmcclure@meridiancity.org) Caleb Hood (chood@meridiancity.org) City of Meridian, Community Development Department 33 E. Broadway Avenue Meridian, Idaho 83642 Re: Modifications requested to the proposed draft Future Land Use Map – Meridian Comprehensive Plan - Southwest Corner of Meridian Road and Victory Road CW File No. 23699.0 Dear Brian and Caleb, We want to express our gratitude for the opportunity to submit additional comments on the proposed draft Comprehensive Plan and Future Land Use Map. We also want to thank you, and everyone involved, for your hard work in the long and difficult process of amending Meridian’s Comprehensive Plan. Previously, we submitted written comments about the proposed land use designations in the draft Comprehensive Plan for several areas of the City of Meridian. Today our comments focus on future land use designations of two very specific sites of the City and specific requests related to the following locations: ▪ First, the southwest corner at the intersection of Victory Road and Meridian Road, and ▪ Second, the northeast corner at the intersection of Locust Grove Road and McMillan Road. In each of these locations, we believe, as we previously communicated, that the use designations proposed on the updated Future Land Use Map are incongruous not only with existing development patterns in these areas but also with the goals and objectives of the proposed draft Comprehensive Plan. At the suggestion of City staff, we deferred Comprehensive Plan amendments relating to each of these two sites to enable the City to complete its planning process. However, the uses that would be ascribed to each of these two areas in the proposed draft of the Future Land Use Map are inconsistent with existing development patterns and with both the existing and draft Comprehensive Plan, thereby immediately necessitating applications to amend the Land Use Map. Instead, we request that City staff, the Planning and Zoning Commission, and the City Council re-evaluate the future land use designations for each of these two properties. Southwest Corner, Intersection of Victory Road and Meridian Road Northeast Corner, Intersection of Locust Grove Road and McMillan Road Existing Use Designations in the Current Future Land Use Map Use Designations Proposed in the Draft Future Land Use Map Our Requested Modifications to Proposed Use Designations either Commercial or Mixed Use Community Commercial The modifications to the land use designations for each of these sites are discussed below, with support from provisions both of the existing Comprehensive Plan and of the proposed draft Comprehensive Plan. I. SOUTHWEST CORNER, VICTORY ROAD AND MERIDIAN ROAD An affiliate of Ball Ventures Ahlquist (“BVA”) owns five parcels at the southwest corner of Victory Road and Meridian Road (those depicted with red boundaries), totaling 15.38 acres. The five parcels, together with a separately-owned, adjacent 4.03 acre parcel (depicted in orange), have not been annexed into the City of Meridian. BVA has been evaluating its affiliate's parcels for development. Based on the proposed draft Future Land Use Map, this area would be assigned a future land use designation of “Medium Density Residential.” While the existing Future Land Use Map designates these parcels as “Medium Density Residential” and “Low Density Residential,” we do not believe either designation is appropriate for this site. Ultimately, access needs to be improved in this location with connectivity being enhanced from the Meridian Heights property to the south, north to Victory Road, in order to ensure that left hand turning movements are at the signal and not at W. Bloomington Drive. As depicted below, we believe that the appropriate solution to future development at this location ensures that the residential uses to the south and west are buffered from the intersection and that improved connectivity is created by extending South Peoria Way, north to Victory Ro ad, aligned with S. Alfani Way, via a public street with a restricted right in right out access to S. Meridian Road via a private commercial drive, located between Victory Road and W. Bloomington Drive. Such a configuration would minimize congestion on Meridian Road as vehicles making northbound movements would be able to access the signal at Victory Road. We believe that the appropriate designation for the five unannexed parcels at this location is “Commercial.” This would provide an improved guide to future growth and development in this area of the City by recognizing existing development patterns and either would be compatible with the proposed Medium Density Residential development to the south and west, as this is essentially the same land use pattern located to the northeast. Although an aerial map without topographic data would make it appear logical to continue the existing “Medium Density Residential” designation that exists for the Meridian Heights No. 2 subdivision, located to the immediate south of four of the five parcels owned by BVA’s affiliate, there are several significant topographical and physical limitations at this site that prevent effective integration of these properties with the existing subdivision. For example, the southern boundary of the subject property consists of a ridge that creates a natural barrier with the existing homes and limits opportunities for connectivity between the two developments. Also, there is only one street that was stubbed to the north from the existing Meridian Heights No. 2 subdivision. That stubbed street, S. Peoria Way, would extend onto the separately-owned parcel (depicted in orange) that is located adjacent to the parcels owned by the BVA affiliate. No existing streets from the Meridian Heights No. 2 subdivision were stubbed to the properties owned by BVA's affiliate, so connectivity options linking the existing subdivision and the subject property, and the availability of connectivity or shared access between the two developments are presently available. Additionally, the location of irrigation facilities that bisect the property significantly limits the use and development of the property for residential purposes. Additionally, the other three corners of this intersection have developed more intensively than the existing Low Density Residential and Medium Density Residential designations, with zoning designations of C-G, R-15, and L-O, in recognition that the intersection of a major arterial and a state highway will inherently encourage more intensive development. As a result of the topographic limitations of this site as well as existing development on the other corners of this intersection, this site would appropriately be designated as “Mixed Use Community" on the proposed draft Future Land Use Map, which would support commercial zoning designations (C-C, C- G, or M-E) at the corner at the intersection and commercial or residential zoning designations to the west that could integrate with the existing residential development, thus reflecting a location that already is developing as a more intensive neighborhood commercial node. This will facilitate the development of service, commercial, and employment opportunities to support the existing residential and future residential uses contemplated in the immediate vicinity. As discussed below, a future connection to Victory Road and the residential properties to the south would support and integrate a mixture of uses at the site and improve connectivity. A. Supports Objectives of Existing Comprehensive Plan The checklist entitled, “Future Land Use Map Changes: Considerations when Requesting a Different Future Land Use Designation” (the “Checklist”), which was produced and promulgated by the City, includes the following key references to items in the existing Comprehensive Plan, all of which support modifying the proposed draft Future Land Use Map as we are requesting, if we were independently amending the existing Comprehensive Plan: 1. “Plan for and encourage services like health care, daycare, grocery stores and recreational areas to be built within walking distance of residential dwellings.” (Comprehensive Plan, Item # 2.01.01C, quoted from the Checklist.) The term “walking distance” is not limited to the number of steps required to walk from one place to another - it also takes into account the ease and safety with which one can walk from his or her home to nearby services. As previously mentioned, there are no properties south of Victory Road designated for “Commercial” use on the draft proposed Future Land Use Map. Residents of the Red Tail Apartments and the Meridian Heights No. 2 subdivision who want to walk to “services like health care, daycare, grocery stores and recreational areas,” even those located relatively nearby, will have to cross Victory Road. This poses a potential safety concern. Crossing a major intersection also creates psychological barrier that inhibits the number of residents south of Victory Road from walking to destinations located north of Victory Road. To achieve this item, the City must “plan for and encourage services… to be built” south of Victory Road. The subject properties are a perfect location for these services, but the development of services on the subject properties would be limited if the future land use designation remains “Medium Density Residential.” 2. “Use the Comprehensive Plan, the Unified Development Code, and the Design Manual to…encourage clustered, landscaped business or residential development on entryway corridors.” (Comprehensive Plan, Item # 2.01.02D, quoted from the Checklist.) Changing the designated use from “Medium Density Residential” to “Commercial” or "Mixed Use Community" on the proposed Future Land Use Map would support this objective by promoting development of the subject properties as “clustered, landscaped business…development” on Meridian Road, which is designated as an “entryway corridor” on the Current Zoning Map. 3. “Designate land for a variety of uses.” (Comprehensive Plan, Item # 3.05.01K, quoted from the Checklist.) In the subject area, particularly south of Victory Road, most (if not all) property has been designated for residential development. To achieve the desired variety of uses, in this area, it is necessary to change the use designation of the subject properties to “Commercial” or "Mixed Use Community." 4. “Plan for a variety of commercial and retail opportunities within the Area of City Impact.” (Comprehensive Plan, Item # 3.05.01J, quoted from the Checklist.) As mentioned above, very little (if any) property located south of Victory Road is designated “Commercial” or "Mixed Use Community." To ensure “a variety of commercial and retail opportunities [exist] within the Area of City Impact” requires an increase in the “Commercial” or "Mixed Use Community" use designations, particularly in the area of subject properties. B. Supports Objectives of Proposed Draft Comprehensive Plan We believe that a land use designation on the Future Land Use Map recognizing the commercial capacity of the portion of this site located at the intersection of Meridian Road and Victory Road more correctly reflects the policy direction contained in the proposed draft Comprehensive Plan. 1. “The City realizes that the 21st Century economy requires flexibility...The City is striving to strengthen its competitive position by creating an environment and infrastructure where industries can create, respond, and adjust rapidly.” (Proposed Draft Comprehensive Plan, p. 2-9.) Designating this property as “Commercial” or "Mixed Use Community" on the proposed draft Future Land Use Map would offer the increased flexibility necessary to adapt to changing economic conditions, without sacrificing the oversight the City feels is necessary to guide sustainable growth and development. Changing to a “Commercial” or "Mixed Use Community" designation would better reflect current (and future) development patterns in the area and promote the flexibility sought in the proposed draft Comprehensive Plan. 2. “Meridian looks to maintain a balanced mix of land uses based on a holistic understanding of community character, transportation systems, market realities, and utility use.” (Proposed Draft Comprehensive Plan, p. iv.) Existing land uses located near the intersection of Meridian Road and Victory Road include high density multi-family housing (Red Tail Apartments) and several single family residential developments. Additionally, within the block in which the subject property is located (bounded by Victory Road on the north, Amity Road on the south, Meridian Road on the east, and Linder Road on the west), approximately one-half is designated as “Medium Density Residential,” approximately two-fifths is “Low Density Residential,” approximately one-sixteenth is “Med-High Density Residential,” and there’s a sliver of “High Density Residential.” Only approximately one-sixteenth of the block has anything other than a residential designation, and that’s “Mixed Use Community” (at the northwest corner of the intersection of Meridian Road and Amity Road). There is no expressly “Commercial” designation on that square mile, and there is no “Commercial” designation located anywhere south of Victory Road. To put that in perspective, if a person drives east on Victory Road, they cannot turn right to access any property designated “Commercial.” Within this block, the proposed Future Land Use Map fails to achieve the “balanced mix of land uses” sought by the Proposed Draft Comprehensive Plan. 3. “The intent is to… provide the flexibility to accomplish a developer’s vision without compromising the larger community’s vision and goals.” (Proposed Draft Comprehensive Plan, p. 1-9.) Designating the southwest corner at the intersection of Meridian Road and Victory Road as “Medium Density Residential” fails to achieve the goal of flexibility. A residential designation like this handcuffs the options for successful development of this corner, at an intersection that already developed as a commercial node. Applying a designation of “Commercial” or "Mixed Use Community" here would be much more effective in ensuring that the strategic pattern of development in this area continues. 4. “Providing expanded opportunities and access to neighborhood shopping and live- work units could result in reduced pressure on highways.” (Proposed Draft Comprehensive Plan, p. 1-12.) Designating the southwest corner at the intersection of Meridian Road and Victory Road as “Medium Density Residential” eliminates the opportunity for the development of neighborhood shopping, services, or employment within this block. Including the Red Hawk Apartments (located immediately east of the site, across Meridian Road), there are hundreds of existing residential units located south of Victory Road, and with the designations contained in the proposed draft Future Land Use Map, there will be hundreds (thousands?) more residential units in the immediate vicinity of the site. With the prior changes at this intersection, neighborhood services/commercial uses should be encouraged here. 5. “High-density housing must be strategically located [close] to public transportation, community services, and employment areas.” (Proposed Draft Comprehensive Plan, p. 2-2.) The high-density housing currently located on the southeast corner at the intersection of Meridian Road and Victory Road (Red Tail Apartments) is underserved by the lack of significant commercial, retail, and employment nearby, in violation of the proposed draft Comprehensive Plan. Designating this site as “Medium Density Residential” will limit the availability of nearby sites on which commercial, retail, and employment centers otherwise could be developed to serve existing residential uses. 6. “Avoid the concentration of any one housing type or lot size in any geographic area; provide for diverse housing types throughout the City.” (Proposed Draft Comprehensive Plan, Policy 2.01.01G.) As previously discussed, the proposed draft Future Land Use Map would label nearly all property located within the block on which this site sits (bounded by Victory Road on the north, Amity Road on the south, Meridian Road on the east, and Linder Road on the west) as either “Low Density Residential” or “Medium Density Residential,” which easily could qualify this particular block as a concentration of one housing type or lot size within a geographic area. 7. “Encourage the development of high quality, dense residential and mixed use areas… along major transportation corridors, as shown on the Future Land Use Map.” (Proposed Draft Comprehensive Plan, Policy 2.02.01E.) The goal and objective identified above (to encourage dense residential and mixed use areas along major transportation corridors) is poorly served by a designation of “Medium Density Residential” at this site, which is located adjacent to Meridian Road. 8. “Keep the Future Land Use Map current by defining appropriate locations for industrial, commercial, and office businesses.” (Proposed Draft Comprehensive Plan, Policy 2.08.03A.) This site, located at the southwest corner of the intersection of Meridian and Victory Roads, is a perfect location for commercial development. Failing to designate this site on the Future Land Use Map as an appropriate location for commercial development, in light of existing development trends evidenced at the other three corners of this intersection, will negatively affect the perceived legitimacy of the use designations shown on the Future Land Use Map. 9. “Create positive, vibrant, and accessible commercial activity centers within the community.” (Proposed Draft Comprehensive Plan, Policy 2.09.00.) Designating this site as “Medium Density Residential” on the Future Land Use Map fails to achieve the policies, goals, and objectives related to developing commercial activity centers in the community. As previously discussed, there is no land with a “Commercial” designation south of Victory Road. Designating this site as “Medium Density Residential” will limit developers’ interest in using the site to create “positive, vibrant, and accessible commercial activity centers within the community,” which is a key goal and objective in the proposed draft Comprehensive Plan. We respectfully request that the southwest corner of the intersection of Victory Road and Meridian Road be given a “Commercial” or "Mixed Use Community" use designation on the Future Land Use Map, which would permit a commercial zoning designation (C-C, C-G, or M-E), upon annexation of these properties into the City of Meridian. As depicted below, such uses would be compatible with adjoining uses and could facilitate future connections enhancing overall flow in the neighborhood of pedestrians and vehicles. Based on the use designations of adjacent properties at this intersection, the location of the site on an entryway corridor, the objectives of both the existing Comprehensive Plan and the proposed draft Comprehensive Plan, and the arguments and reasons set forth above, we strongly believe that the above modifications to the proposed Future Land Use Map will provide an improved guide to future growth and development of the City. II. NORTHEAST CORNER, MCMILLAN ROAD AND LOCUST GROVE ROAD. In the existing Future Land Use Map, the area located immediately northeast of the intersection of McMillan Road and Locust Grove Road is designated as “Mixed Use Neighborhood.” These parcels have been annexed and already are within Meridian’s city limits, zoned “Neighborhood Business” (C-N). Some neighborhood-serving commercial uses are excluded from the C-N zoning district. Two of the subject parcels are owned by an affiliate of BVA Development, which has encountered difficulty in attracting users for the property consistent with the existing land use designation and its existing zoning, due to the small size, difficult configuration, and other complicating factors. In 2008, the plat of the Woodland Springs No. 1 subdivision was approved and recorded (above, right). The area within the subdivision is depicted with purple boundaries in the above left aerial depiction, which also shows (in pink overlay) the extent of the “Neighborhood Business” (C-N) zoning designation that currently exists on the properties. A. Circumstances Limiting Development in this Area Several circumstances involving this area make it difficult, if not impossible, for development to achieve the goals and objectives contained in either the existing Comprehensive Plan or in the proposed draft Comprehensive Plan property with a “Mixed Use Neighborhood" use designation: 1. Small size of the subject area. The remaining developable land in this area is insufficient to support the range of uses required in the MU-N designation. The text of the existing Comprehensive Plan describes the purpose of this land use designation as follows: The purpose of this designation is to assign areas where neighborhood- serving uses and dwellings are seamlessly integrated into the urban fabric. The intent is to avoid predominantly single-use developments by incorporating a variety of uses. Land uses in these areas should be primarily residential with supporting non-residential services. Non-residential uses in these areas tend to be smaller scale and provide a good or service that people typically do not travel far for (approximately one mile) and need regularly. Employment opportunities for those living in the neighborhood are encouraged. Connectivity and access between the non-residential and residential land uses is particularly critical in MU-N areas. Tree-lined, narrow streets are encouraged. Developments are also encouraged to be designed according to the conceptual MU-N plan depicted in Figure 3-1. Meridian Comprehensive Plan, p. 24. The following figure, taken directly from the current Comprehensive Plan, depicts the variety of uses expected in an area with a “Mixed Use-Neighborhood” designation: Moreover, for Mixed Use – Neighborhood it is contemplated that residential development will “comprise a minimum of 40% of the development area,” that public or quasi spaces “should comprise a minimum of 10% of the development area,” and that “should comply with the items listed for development in all Mixed Use areas.” Id., at 25. Although there is a small MU-N designated area southwest of this site, the subject area is far too small to accommodate the type of development expected on property designated MU-N and is far too small to comply with the Mixed Use requirements under the existing or future Comprehensive Plan. Properties designated as mixed use either need to be of substantial enough size to be able to legitimately and economically permit the mixture of uses and densities called for, or larger areas containing all of those elements in some form of development be so designated so as to ensure that small parcels are not evaluated independently of the larger neighborhood for zoning pursuant to such land use designations. 2. Configuration and Ownership of the Existing Woodland Springs No. 1 Plat. The configuration of the Woodland Springs No. 1 plat previously approved by the City of Meridian further limits the type of mixed use development contemplated above makes development makes it doubly difficult to size the type and intensity of development expected on property designated MU-N. In particular, although configuration of the common parcel (designated on the plat as its parcel 2) achieves the desired connectivity, it uses a significant amount of property (1.184 acres). Additionally, the location and extent of utility and other easements hampers the type of development ostensibly sought through the MU-N land use designation. The following depictions, taken from a recent record of survey of the subject parcels, show the location and configuration of these easements on the properties: Additionally the remaining developable parcels, including the platted property to the north within the area designated MU-N, are not owned by a single controlling entity, meaning that even if sufficient property existed in this area to achieve the requirements of the MU-N designation, developing that property would be difficult. The fact that there are relatively small parcels owned by different parties makes utilization and development of the undeveloped portion of this site difficult. 3. Lack of stubbed streets. To the extent that there are residential areas to the north and to the east, there is presently a significant lack of connectivity to the MU-N designated areas from the properties that it ostensibly is to serve. The only stubbed street from Sheridan Place is in a location that will enable its future connection to a parcel that remains in unincorporated Ada County, with a “Medium Density Residential” use designation in the FLUM and that is north of the MU-N designated areas. That street, when constructed and extended, may allow the subject parcels to connect to the Sheridan Place subdivision, but the timeline for its development will make coordination and certainty difficult to achieve. 4. Sufficient existing residential use in the area. Pursuant to the existing Comprehensive Plan, “[r]esidential uses should comprise a minimum of 40% of the development area at densities ranging from six to 12 units /acre” (Comprehensive Plan, p. 25.) in an area designated MU-N. In addition to the problem of fitting a development that includes 40% residential, the subject properties are located in the midst of an area that already is inundated with residential designations and existing housing developments. The existing zoning designations of nearby properties are shown in the following aerial depiction: In fact, if the City would allow developers to apply the nearby residentially-zoned properties (and the existing residential developments are so prevalent in this part of the city) in calculating the “40% residential” element required in developing properties designated MU-N, it might be possible to meet the goals and objectives of the Mixed Use Neighborhood designation on this property. However, that is not how either the existing or the future Comprehensive Plans designate this site and the larger areas. B. Supports Objectives of Existing Comprehensive Plan Again referring to the City’s checklist entitled, “Future Land Use Map Changes: Considerations when Requesting a Different Future Land Use Designation” (again, the “Checklist”), the following items in the existing Comprehensive Plan support modifying the proposed draft Future Land Use Map as we are requesting: 1. “Designate land for a variety of uses.” (Comprehensive Plan, Item # 3.05.01K, quoted from the Checklist.) In the area surrounding the subject properties, nearly all properties have a residential use designation on the current FLUM. To achieve variety in this area, it is necessary to change the use designation of the subject properties to “Commercial”, which would provide flexibility in the types of commercial uses allowable on the subject properties without materially diminishing the significant inventory of properties designated Residential in this area. 2. “Provide a walkable community through good design.” (Comprehensive Plan, Item # 2.01.01A, quoted from the Checklist.) Because nearly all parcels located in the area around the subject properties are designated “Residential,” there is very little land that can be used to provide the types of services that ensure a community is truly walkable. Pedestrian facilities are not the only requirement for walkability, but commercial uses that are of the type that serve the neighborhood help to ensure walkability by providing services that are immediately required. The subject properties are among the best remaining options for commercial services in an area that needs commercial services. Our request to redesignate the subject properties would enable “a walkable community through good design,” a key goal of the current Comprehensive Plan, by ensuring that true neighborhood serving commercial services could be provided at this site. 3. “A mixed use project should include at least three types of land uses.” (Comprehensive Plan, p. 24.) As previously mentioned, the subject site is very small - it would be very difficult to accommodate three types of land uses on such a small site, especially with the anticipated public areas and residential coverage. Redesignating this area as Commercial would remove the requirement to shoehorn three uses onto this site, recognizing the existing commercial development that has happened at this location. 4. “Supportive and proportional public and/or quasi-public spaces and places including but not limited to parks, plazas, outdoor gathering areas, open space, libraries, and schools are expected; outdoor seating areas at restaurants do not count.” (Comprehensive Plan, p. 24.) Again, the small size of the subject site precludes the meaningful allocation of property to public and/or quasi-public spaces within any project proposed for the site. There just is not room, particularly if the site also is expected to accommodate three types of land uses. By loosening the requirement for three uses, redesignating this area as Commercial could free up property that potentially could be used as public and/or quasi-public spaces and places. 5. “All mixed use projects should be directly accessible to neighborhoods within the section by both vehicles and pedestrians.” (Comprehensive Plan, p. 24.) As discussed above, this site is not accessible from the adjacent neighborhood (Sheridan Place subdivision), because the only street stubbed from that neighborhood is stubbed into property that is not within the Mixed Use Neighborhood designation and has not yet been annexed into the City. Perhaps that future street may provide connectivity to the subject site, but the unknown timeline for development of the as yet un-annexed adjacent parcel causes uncertainty, which often results in less intense (and less desirable) placeholder uses that often become permanent. However, it clearly was not the intention of the City of Meridian for this intersection to be a significant mixed use node in light of the fact that only two, small, disconnected parcels were given the MU-N land use designation. C. Supports Objectives of Proposed Draft Comprehensive Plan The proposed draft Comprehensive Plan also supports our request to modify the use designation of the subject area to Commercial. We believe that a Commercial designation on the Future Land Use Map better serves the policies and objectives of the proposed draft Comprehensive Plan. Several examples of such policies and objects follow, with a brief explanation of each. 1. “Meridian looks to maintain a balanced mix of land uses based on a holistic understanding of community character, transportation systems, market realities, and utility use.” (Proposed Draft Comprehensive Plan, p. iv.) As previously mentioned, most of the land surrounding the subject area is designated for residential use, and much of it already has homes (predominantly single-family residences) on it. Under the designations proposed for the draft FLUM, this area does not represent the “balanced mix of land uses” the Proposed Draft Comprehensive Plan hopes to achieve. 2.a. “The intent is to… provide the flexibility to accomplish a developer’s vision without compromising the larger community’s vision and goals.” (Proposed Draft Comprehensive Plan, p. 1-9.) - and - 2.b. “The City realizes that the 21st Century economy requires flexibility. … The City is striving to strengthen its competitive position by creating an environment and infrastructure where industries can create, respond, and adjust rapidly.” (Proposed Draft Comprehensive Plan, p. 2-9.) Designating this area as “Commercial” on the proposed draft Future Land Use Map would offer the increased flexibility necessary to adapt to changing economic conditions, without sacrificing the oversight the City feels is necessary to guide sustainable growth and development. Changing to a “Commercial” designation would better reflect current (and future) development patterns in the area and promote the flexibility sought in the proposed draft Comprehensive Plan. If the subject properties retain their existing Mixed Use Neighborhood designation, there will be no flexibility for developers to realize their vision. Applying a designation of “Commercial” to these properties would be much more effective in ensuring that the strategic pattern of development in this area continues. 3. “Providing expanded opportunities and access to neighborhood shopping and live- work units could result in reduced pressure on highways.” (Proposed Draft Comprehensive Plan, p. 1-12.) As currently designated in the existing FLUM, and as proposed to be designated in the draft update to the FLUM, the subject properties only would serve to increase the concentration of residential uses in this area. Adding residential uses to property that already is adjacent to existing residential uses does nothing to achieve the objective of the proposed draft Comprehensive Plan to expand neighborhood shopping access and opportunities. As a result, the pressure on highways will continue to grow. We respectfully request a re-designation of these properties to Commercial in the draft FLUM update. These use designations expand developers’ ability to provide the neighborhood shopping that would help achieve this objective in the proposed draft Comprehensive Plan. 4. “Keep the Future Land Use Map current by defining appropriate locations for industrial, commercial, and office businesses.” (Proposed Draft Comprehensive Plan, Policy 2.08.03A.) The subject site is an excellent location for commercial development, which would serve the existing adjacent (but buffered) residential uses, if our request to modify the designation of the subject area to Commercial. 5. “Create positive, vibrant, and accessible commercial activity centers within the community.” (Proposed Draft Comprehensive Plan, Policy 2.09.00.) Designating this site as “Mixed Use Neighborhood” on the Future Land Use Map fails to achieve the policies, goals, and objectives contained in the proposed draft Comprehensive Plan related to developing commercial activity centers in the community. As previously discussed, there is precious little land with a “Commercial” designation in this area. Failing to designate these properties as Commercial or Mixed Use Community will continue the trend of limited interest to use the site to create the “positive, vibrant, and accessible commercial activity centers within the community,” sought by the proposed draft Comprehensive Plan. As a result of these circumstances, it has been difficult to identify a user for this site that could support the types of uses contemplated by the existing FLUM designation and satisfy the mixed use goals for the land use district. Redesignation of the area northeast of McMillan and Locust Grove as Commercial will enable development that provides support to high-density housing and complements and serves existing residential developments. Therefore, we request a Commercial designation on the FLUM, recognizing the existing C-N zoning, which would permit other compatible zoning designations in the future, consistent with the existing use. II. CONCLUSION. In each of these two areas, the use designations on the updated Future Land Use Map are not supported by the goals and objectives of either the current Comprehensive Plan or the proposed draft Comprehensive Plan. We respectfully ask for the use designations in each of these locations to be changed as follows: ▪ Southwest corner of Meridian Road and Victory Road: Medium Density Residential/Commercial or Mixed Use Community; and ▪ Northeast corner of Locust Grove Road and McMillan Road: Commercial. We strongly urge the City to re-evaluate the future land use designations for the properties in each of these two locations and to recommend to the City Council that these two sites be modified as set forth herein. Sincerely, Geoffrey M. Wardle Cc: Tommy Ahlquist Tonn Peterson Cortney Liddiard