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HomeMy WebLinkAboutPZ - Narrative DEVELOPMEHT CLARK WARDLE Geoffrey M.Wardle (208) 388-3321 gwardle@clarkwardle.com Via Electronic Submission July 9, 2024 City of Meridian 33 E. Broadway Ave. Meridian, ID 83642 RE: The District at Ten Mile Applications CW File#: 24101.0 Dear Staff, Planning and Zoning Commission, and City Council, In support of our client's BVA Development, LLC and Ten Mile West Commercial, LLC (collectively the "Applicant"), we provide the following analysis in support of the Applicant's application seeking, (1) modification of all of the 118 Property DA/118 Property DA Modification and the Black Property DAs, with the integration of the Additional Property to create a single consolidated development agreement for the entirety of the Property; (2) a comprehensive plan future land use map amendment (if determined to be required, but without the Applicant conceding that such is in fact necessary); (3) the rezoning of certain portions of the Property; and (4) a preliminary plat application incorporating all of the presently unplatted portions of the Property that are not subject to pending plat applications (collectively the "Application"). All prior narratives can be disregarded as this document incorporates all of the Applicant's supporting analysis in furtherance of its Application. To assist Staff and Decision makers in their review of this Submittal, we incorporate the following Table of Contents: Table of Contents A. Summary of Applications.....................................................................................................................3 B. Background of Existing Approvals Necessitating this Application .....................................................4 C. Standards Applicable to the Application Elements.............................................................................6 T.Hethe Clark Geoffrey M.Wardle Joshua J.Leonard Preston B_Rutter 1 208.388,1000 251 E Front St.Suite 310 F 208.388.1001 PO Box 639 clarkwardle.com Boise ID 83701 Revised Application Narrative Page:2 1. Standards for Modification of Development Agreement.................................................................6 2. Standards for Comprehensive Plan Map Amendment.....................................................................6 3. Standards for Rezone.........................................................................................................................7 4. Standards for Preliminary Plat...........................................................................................................8 D. Analysis of Modifications Sought in Application.................................................................................8 1. Analysis of Relevant Provisions of Comprehensive Plan and Ten Mile Plan ...................................8 (a) Meridian Comprehensive Plan Considerations.............................................................................8 (b) Ten Mile Plan Considerations........................................................................................................9 (c) Application Consideration and Implementation of Plans.......................................................... 12 2. Application—Development Agreement Amendment.................................................................... 19 3. Application -Comprehensive Plan Map Amendment ....................................................................20 (a) A Comprehensive Plan Future Land Use Map Amendment is Unnecessary..............................20 (b) The Existing Future Land Use Maps Support the Zoning Requests Made Hereafter ................22 (c) The Existing Zoning District Compatibility Matrix in the Ten Mile Plan Supports the Application without Amending the Map..............................................................................................23 (d) Staff Requested Additional Analysis of Ten Mile Plan Elements...............................................25 (e) If Required, Future Land Use Map Amendments Should Retain the Ten Mile Plan Land Uses, but Align their Boundaries with the Approved and Designed Infrastructure.....................................34 (f) Standards Applicable to Amendments of the Land Use Map ....................................................35 4. Application—Zoning Modification ....................................................................................................37 (a) Requested Amendments to Existing Zoning Districts.....................................................................37 (1) The map amendment complies with the applicable provisions of the Comprehensive Plan...41 (2) The map amendment complies with the regulations outlined for the proposed district, specifically the purpose statement; .....................................................................................................41 (3) The map amendment shall not be materially detrimental to the public health, safety, and welfare;..................................................................................................................................................41 (4) The map amendment shall not result in an adverse impact upon the delivery of services by any political subdivision providing public services within the City including, but not limited to, schooldistricts.......................................................................................................................................41 4. Application—Preliminary Plat.........................................................................................................42 E. Conclusion ..........................................................................................................................................43 Revised Application Narrative Page:3 A. Summary of Applications The subject site, spanning approximately 163 ± acres, is earmarked for The District at Ten Mile development and is located at the northwest corner of the Ten Mile Road and Interstate 84 interchange. The concept envisions a network of mixed-use districts interconnected by well-designed streetscapes, pedestrian walks, pathways, and bike lanes. These districts, as outlined in the Design Standards, each with its unique character, include a commercial/retail village along Ten Mile Road that will include uses such as restaurant, service, grocery, entertainment, recreation, office, retail, hotel, and flex space; a residential neighborhood in the northwest; a commercial/hospitality core that will include uses such as childcare, office, and hotel; and medical along Interstate 84. This development is not proposed to be phased. Details on the applications are outlined below: Development Agreement Modification Application: The request is to integrate multiple existing development agreements into a single development agreement with Design Standards governing the entirety of the Property applying to Parcels S1215427850, 51215417409, S1215417217, S1215142250, 51215142300, 51215131401, and R6733720500 (Outer Banks Subdivision Lot 2 Block 2 only). This new development agreement is necessary to reduce confusion and provide consistency. This request does not include Parcel S1215244200 in which Development Agreement H-2021-0081 will still apply. Existing Development Agreements include: Development Agreement File/Case Name Ordinance Instrument Name and Parcel Number Approval Recorded Number The 10 at Meridian H-2021-0025 21-1948 9-7-2021 9-8-2021 2021-132704 (R6733720500) Fedrizzi Ten Mile, LLC 112073618 (S1215417217) AZ-11-001 Janicek Properties LLC Ten Mile 12-1520 2-7-12 7-25-12 112073616 (S1215131401/S1215142300) Annexation SJJV, LLC (S1215417409) 112073617 Vanguard Village Subdivision H-2021-0081 (51215427850) Vanguard Village 22-1979 5-10-22 5-25-22 2022-049799 Subdivision Included with the proposed Development Agreement are Design Standards with a conceptual plan. The Design Standards identify three (3) areas: • Area 1 accommodates a mix of multi-family residential uses such as townhomes and multi-family with an anticipated density of 8-12 DU/AC. • Area 2 accommodates predominately commercial uses, including but not limited to large format/anchor and specialty retail, casual and fine dining, entertainment, recreation, hospitality, childcare, and office. • Area 3 accommodates medium to higher-density office, commercial/retail, recreation, medical, and hospitality uses. Revised Application Narrative Page:4 Comprehensive Plan Map Amendment Application:The applicant requests to shift the future land use designations applying to Parcels S1215427850, S1215417409, S1215417217, S1215142250, S1215142300, S1215131401, and R6733720500 to align future land use designations with the proposed development plan and zoning as was requested by City staff. Future Land Use Approximate Existing Acreage Proposed Acreage Med-High Density Residential 2.79 0 Mixed Use Residential 32.11 33.62 Mixed Use Commercial 21.61 41.37 High Density Employment 60.68 76.15 Mixed Employment 0 2.26 Rezone Application: The applicant requests to rezone portions of the development by shifting the existing boundaries to align with the conceptual plan.The rezone acreages proposed include the following: Zone Approximate Existing Acreage Acreage Change New Acreage TN-C 25.94 7.48 from C-C 33.42 R-40 0.62 0.62 from R-40 to C-C 0 C-C 80.36 12.96 from R-40 and H-E 59.11 C-G 0 25.97 from WE and C-C 25.97 H-E 55.72 9.13 from C-C 34.82 M-E 8.82 1.37 from H-E to M-E 10.19 The proposed zone changes are supported by the existing and proposed future land use designations of the TMISAP. Preliminary Plat— District Ten Mile Application: Request for a preliminary plat applying to Parcels S1215131401, R6733720500, S1215142300, S1215142250, S1215417217, and S1215417409 totaling 108.773 acres. The preliminary plat includes 38 lots and one (1) common lot. No variance is requested as part of this application. The proposed development will meet the requirements of the zoning code as determined by the zoning designation. Vehicular and pedestrian circulation is provided throughout the subdivision, and bicycle circulation is provided along Villaggio Way. 30 acres of qualified open space (27%) with 18% landscape coverage is provided.The subdivision may be accessed via four public roads: W. Cobalt Drive,Villaggio Way,S. Umbria Hills Avenue, and W. Navigator Road. Internal access consists of private drive aisles. B. Background of Existing Approvals Necessitating this Application The Applicant is the owner of certain real property, commonly referenced as the "118 Property," that is subject to the development agreement for Vanguard Village Subdivision (H-2021-0081) between Meridian 118, LLC and the City of Meridian, recorded as Instrument No. 2022-049799, on May 25, 2022, in Revised Application Narrative Page:5 the Official Records of Ada County, Idaho ("118 Property DA"). The Applicant's affiliate sold approximately 40 acres of residentially zoned property that was subject to 118 Property DA. The Applicant initiated a modification to the 118 Property DA in November of 2023, seeking certain textual modifications to that agreement and certain design modifications desired thereunder ("118 Property DA Modification"). At the time of this submittal, the 118 Property DA Modification has yet to be heard. We proceed in parallel with the 118 Property DA Modification due to the fact that the initial development of the 118 Property will commence with the area that is being addressed therein. We intend for the 118 Property DA Modification to be incorporated into the resulting development agreement approved pursuant to this Application. The Applicant is the contract purchaser of real property commonly referenced as the "Black Property." The Black Property consists of four(4) separate parcels, and is subject to the following existing development agreements("Black Property DAs"): • Development Agreement — Fedrizzi Ten Mile, LLC (AZ 11-001) between Fedrizzi Ten Mile, LLC, and the City, recorded as Instrument No. 112073618, on July 25, 2012, in the Official Records of Ada County, Idaho; • Development Agreement—SJJV, LLC (AZ 11-001) between SJJV, LLC and the City, recorded as Instrument No. 112073617,on July 25,2012, in the Official Records of Ada County, Idaho; and • Development Agreement —Janicek Properties, LLC (AZ 11-001) between SJJV, LLC and the City, recorded as Instrument No. 112073616,on July 25, 2012, in the Official Records of Ada County, Idaho. The "Additional Property" as defined below, is a portion of the Black Property, but is not presently subject to a Development Agreement. The 118 Property, the Black Property, and the Additional Property are collectively the "Property" for purposes of the applications set forth herein. The totality of the Property is depicted as follows: t t; + e t t �t'"� • Kart m _, r .I✓ 'cruet: ; ,ern et• : t••`;.`�� _ $..__mot tt IC?—6 r � �. +' tt t• t--•sa-ra � ' r Revised Application Narrative Page:6 The Applicant proposes developing the Property as a master planned mixed use development commonly referenced as "The District at Ten Mile" ("Project"). In furtherance of an integrated design for the Project, the Applicant has developed design standards Pursuant to the Ten Mile Interchange Specific Area Plan (TMISAP) ("Ten Mile Plan"). The Architectural Standards Manual for the Project is referenced hereafter as "The District at Ten Mile Design Standards" or"Project Design Standards." C. Standards Applicable to the Application Elements Pursuant to the Meridian City Code, the following standards have been adopted by ordinance relating to each of the elements contained in the Application. 1. Standards for Modification of Development Agreement The Applicant seeks to modify the Development Agreements by consolidating each of the four (4) existing agreements plus the additional property into a single Development Agreement. This is treated as an amendment thereto,the process for which is set forth in Meridian City Code 11-513-3F as follows: 1. The city and/or an applicant may request a development agreement or a modification to a development agreement consistent with Idaho Code section 67- 6511A. The development agreement may be initiated by the city or applicant as part of a request for annexation and/or rezone at any time prior to the adoption of findings for such request. 2. A development agreement may be modified by the city or an affected party of the development agreement. Decision on the development agreement modification is made by the city council in accord with this chapter. When approved, said development agreement shall be signed by the property owner(s) and returned to the city within six (6) months of the city council granting the modification. 3. A modification to the development agreement may be initiated prior to signature of the agreement by all parties and/or may be requested to extend the time allowed for the agreement to be signed and returned to the city if filed prior to the end of the six (6) month approval period. 2. Standards for Comprehensive Plan Map Amendment The Applicant believes that no amendment to the Comprehensive Plan Future Land Use Map is required, however, at the direction of Staff, the Applicant has requested an amendment and modification to Meridian's Comprehensive Plan Future Land use map it such is, in fact, required as a prerequisite to the requested amendment of the Development Agreements and the amendment of the zoning. The requested modifications to the various zoning districts within the Property are in accordance with and consistent with both the Comprehensive Plan and the Ten Mile Area Plan. They do not require a Future Land Use Map modification due to (a) the text of both the Comprehensive Plan, (b) the text of the Ten Mile Area Plan, and (c)the consistency of the resigned zoning design late with the underlying plows. Revised Application Narrative Page:7 The standards for amending the future land use map set forth in the Comprehensive Plan are set forth in Meridian City Code 11-5B-7D: Upon recommendation from the commission, the Council shall make a full investigation and shall, at the public hearing, review the application. In order to grant an amendment to the comprehensive plan, the council shall make the following findings: 1. The proposed amendment is consistent with the other elements of the comprehensive plan. 2. The proposed amendment provides an improved guide to the future growth and development of the city. 3. The proposed amendment is internally consistent with the goals, objectives, and policies of the comprehensive plan. 4. The proposed amendment is consistent with this Unified Development Code. 5. The amendment will be compatible with existing and planned surrounding land uses. 6. The proposed amendment will not burden existing and planned service capabilities. 7. The proposed map amendment(as applicable) provides a logical juxtaposition of uses that allows sufficient area to mitigate any anticipated impact associated with the development of the area. 8. The proposed amendment is in the best interest of the City of Meridian. 3. Standards for Rezone The Applicant is requesting amendment to the zoning districts applicable to the Property. The requirements for amending zoning districts are set forth in Meridian City Code 11-513-3E E. Required findings. Upon recommendation from the commission, the Council shall make a full investigation and shall, at the public hearing, review the application. In order to grant an annexation and/or rezone,the Council shall make the following findings: 1. The map amendment complies with the applicable provisions of the Comprehensive Plan; 2. The map amendment complies with the regulations outlined for the proposed district, specifically the purpose statement; Revised Application Narrative Page:8 3. The map amendment shall not be materially detrimental to the public health, safety, and welfare; 4. The map amendment shall not result in an adverse impact upon the delivery of services by any political subdivision providing public services within the City, including, but not limited to, school districts; and 5. The annexation (as applicable) is in the best interest of the City. 4. Standards for Preliminary Plat The Applicant is requesting approval of a preliminary plat for the Property in Meridian City Code Section 11-613-6 In consideration of a preliminary plat, combined preliminary and final plat,or short plat,the decision-making body shall make the following findings: A. The plat is in conformance with the comprehensive plan and is consistent with this Unified Development Code; B. Public services are available or can be made available and are adequate to accommodate the proposed development; C. The plat is in conformance with scheduled public improvements in accord with the city's capital improvement program; D. There is public financial capability of supporting services for the proposed development; E. The development will not be detrimental to the public health,safety,or general welfare; and F. The development preserves significant natural, scenic, or historic features. D. Analysis of Modifications Sought in Application We now turn to the Application, addressing first the relevant planning documents and then turning to the substance of the individual elements of the Application. 1. Analysis of Relevant Provisions of Comprehensive Plan and Ten Mile Plan In initiating this application, we have taken care to review and evaluate both the City of Meridian's Comprehensive Plan and the "Ten Mile Interchange Specific Area Plan, A Strategy to Enhance Meridian's Prosperity, City of Meridian, Idaho" ("Ten Mile Plan"). We will address each of those here in detail. (a) Meridian Comprehensive Plan Considerations Meridian's Comprehensive Plan incorporates the Ten Mile Plan and further sets forth certain additional goals and considerations that are further advanced by the Application. The Ten Mile Plan was Revised Application Narrative Page:9 expressly incorporated into the Comprehensive Plan and is considered an "addendum". Comprehensive Plan, p. 1-12 and 3-21. However,the Ten Mile Plan governs the consideration of the mixed use designations it contains. Comprehensive Plan, p. 3-21. Development of the area around the Ten Mile interchange has long been a goal of the City. Comprehensive Plan, p. 1-7. This area is intended to have a mix of uses have,jobs, shopping and residential areas in close proximity to each other to minimize impacts on infrastructure; and because developed to provide diverse economic opportunities. Comprehensive Plan, p. 1-11, and p. 2-12. The Comprehensive Plan establishes as a goal, establishing diverse, destination type activities; within designated centers; contemplating mixed use areas; with significant design consideration; and expressly identifying Ten Mile as an activity center where growth is intended. Goal 2.09.03,Goal,2.09.03A, and Goal 2.09.0313,Comprehensive Plan p. 2-15. This promotes Meridian's goal to pursue light industry and professional services, retaining high quality businesses, and developing a talented workforce, capitalizing on the City's central location promoting growth at one of its key entries and corridors, all as contemplated by Goal 2.08.02, Goal 2.08.02A, and Goal 2.08.0213, Comprehensive Plan, p. 2-14. The Comprehensive Plan contemplates exactly what the Applicant proposes implementation of a special area plan, located along a primary transportation corridor, with express design standards, incorporating a mix of land uses. Goal 3.03.00, Goal 3.03.01, and Goal 3.03.01A, Comprehensive Plan p. 3- 5. This is the very prioritization and encouragement of growth and development that is consistent with the City's vision. Goal 3.03.02, Comprehensive Plan p. 3-5. To further that,the Application and the requested approvals herein,we are propose higher density housing in "proximity to employment centers" consistent with Goal 2.01.01H, Comprehensive Plan p. 2-4, "near employment, large shopping centers, public open spaces and parks, and along major transportation corridors" consistent with Goal 2.02.01E, Comprehensive Plan p. 2-45. The Applicant proposes for connectivity and enhanced pedestrian access within residential areas and large commercial mixed-use developments consistent with Goal 2.02.01 and Goal 2.02.01D, Comprehensive Plan p. 2-5, Goal 3.07.02A, Comprehensive Plan, p. 3-25. This Applicant proposes the previously identified for parks and pathways along the easement corridors within the Property consistent with Goal 4.02.011), Comprehensive Plan, p. 4-5, and Goal 4.04.00, Goal 4.04.01, Goal 4.04.01A; and Goal 4.04.0113, Comprehensive Plan, p. 4.6. Moreover, the development plan supports and furthers the design and extension of complete streets with significant pedestrian facilities as contemplated by Goal 6.01.01 and Goal 6.01.01J, Comprehensive Plan, p. 6-7. The Application's commitment to these goals and furtherance of them is demonstrated by the requested incorporation of the Project Design Standards,which are express design standards contemplated by the Ten Mile Plan, implemented through the Development Agreement encumbering the Property, as contemplated by Goal 2.09.03A, Comprehensive Plan, p. 2-15. (b) Ten Mile Plan Considerations The Comprehensive Plan incorporates the Ten Mile Plan as set forth above. The Ten Mile Plan established laudatory goals for the Ten Mile area when adopted in 2007. However, planning documents Revised Application Narrative Page: 10 are not self-effectuating. They require the adoption of ordinances implementing their goals by codifying objective standards. The Ten Mile Plan itself recognized this, noting that: To implement this plan, a set of guidelines that address the design goals of the plan and a series of zoning code amendments will be developed to facilitate and enhance the speed with which development applications can be processed. The development of sound design guidelines and zoning to implement the plan will not happen overnight. Knowing the private sector may want to act more quickly to move the plan forward, the City encourages developers and key land owners to take the initiative and begin the implementation program, bringing forward detailed design guidelines and zoning, and infrastructure financing proposals based on the concepts presented in this plan. The City stands ready to support your efforts and will be moving forward rapidly to implement the recommendations in this plan. Ten Mile Plan,June 2007, p. 1-3 (emphasis added). The Ten Mile Plan laid out the additional efforts that would need to be undertaken to implement it in the future, noting that: To address these challenges and work within the framework of the existing zoning code,the City should undertake one or more of several actions: • Minimum density and intensity standards should be incorporated into the existing zoning districts, • New land use districts should be developed for the Lifestyle and Mixed Commercial land uses; • A mechanism should be developed to transfer development uses to other sites so that the desired mix of uses can be achieved; • Incentives for planning cooperatively among adjoining owners should be created;or a minimum site area for development review and annexation should be established. Alternatively, the City could look beyond the existing development regulations to new development provisions.The Study Area for this plan(or some sub-set area) could be defined as its own Development District, with a series of new zoning categories to address the use types and mixed-use districts contemplated in the plan.These regulations could be linked to the design guidelines and should be written expressly to promote and guide the types of mixed-use development that the community wishes. Revised Application Narrative Page: 11 Ten Mile Plan, pp. 2-2 to 2-3 (emphasis added). Unfortunately,the guidance proffered by the authors of the Ten Mile Plan did not come to pass and was not implemented in the manner that had been contemplated in 2007. Why? We note and agree with the history and analysis of the Ten Mile Plan provided by the owner of Ten Mile Crossing (H-2020-0114) in it is submittal regarding its similar request to consolidate multiple development agreements, amend the zoning, establish its own design standards and undertake a preliminary plat application for the properties immediately to the east of Ten Mile from this Property. While the TMISAP has laudable goals, it was conceived at a point in time and in a public process that didn't recognize the Treasure Valley's population and income demographics, or other market realities. As an example, the Treasure Valley does not command the rents that would support some of the loftier goals of the TMISAP, such as FAR ratios of 1.00- 1.25 minimum.These realities have since been acknowledged by staff and elected officials, alike, as each new project was brought forward. And yet, each new application continues to be measured against the TMISAP as the governing document; hence, a constant entitlement tug-of-war of words between the Comprehensive Plan text and the modified FLUM. Much has changed since the TMISAP was conceived, including the Great Recession and the COVID Cessation. For example, drive-throughs have become as much a necessity to the survival of local businesses as a convenience — perhaps more so going forward. These need to be well designed and executed but should not be viewed as a blight or an impediment to social progress or engineering. In addition, the TMISAP emphasis on pedestrian-friendly, pedestrian-scale development needs to be put into context. First, the original concept of a TMI lifestyle center went away when The Village at Meridian was constructed. Second, the idea that Ten Mile and Franklin Roads, major arterials providing regional access to the Ten Mile interchange, will be pedestrian-scale corridors is simply unrealistic. Will businesses rely on pedestrian traffic from Franklin or Ten Mile for their support?Absolutely not. The success of . . . businesses will depend in part on internal employment and housing, but in larger measure by a regional draw. Are there physical features we can include in the development to make pedestrian mobility more functional and enjoyable? Yes-absolutely! Revised Application Narrative Page: 12 A robust, integrated pathway, sidewalk and amenity plan-unique to the Treasure Valley-will be the model for future, large-scale commercial development. Mike Wardle,Application Narrative, H-2020-0114, pp. 3-4, February 16, 2021 (emphasis added). The Ten Mile Plan is important; its goals are laudable; its goals relating to land uses and design have been thoroughly reviewed and incorporated into this Application as appropriate. Consideration has been given as set forth herein to the future land uses designated in the maps adopted with the Ten Mile Plan. Market conditions and actual implementation of the underlying zoning, as well as the deficiencies that have come to be identified in the Ten Mile Plan, need to be recognized as the Property has been previously annexed and zoned. Now that it is time to proceed with the actual development of the Property as an integrated project and with an integrated site plan, reflecting the actual location of the infrastructure, the need to implement modifications to the Development Agreement is evident. Our goal is to appropriately consider the intent of the Ten Mile Plan while complying with the actual requirements of the zoning code and ultimately facilitating the actual development of the Property. (c) Application Consideration and Implementation of Plans We are respectful of the Ten Mile Plan and the efforts that went into its creation, as well as the Comprehensive Plan. However, we respectfully provide the following analysis of the Application and its interplay with both the Comprehensive Plan and the Ten Mile Plan. (1) The Comprehensive Plan and Ten Mile Plan are Plans, not Development Ordinances. It is disconcerting when statements are made that the Ten Mile Area Plan is a "zoning overlay," or is an "overlay zone," or is "codified" in this area of Meridian. It is none of those. When jurisdictions inappropriately attempt to elevate their comprehensive plans "to the status of a zoning ordinance."' We seek to politely remind them of the law, we act to address staff's concerns in a manner that does not adversely affect the constitutional rights of that applicant, and we work to avoid a dispute which will be unnecessary and costly for the jurisdiction. That said,the unfortunate trend in Idaho for municipalities to spend time adopting plans that their staffs then fail to codify through the implementation of objective standards codified in ordinance as required by the Local Land Use Planning Act, must come to an end. A comprehensive plan is "a guide to local government agencies charged with making zoning decisions," it is "not a legally controlling zoning law."' But rather it is an aspirational document, allowing a city to plan for anticipated future uses of land and set goals for future development.3 In Bone v. Lewiston, the Idaho Supreme Court prohibited the city of 1 Bone v.City of Lewiston, 107 Idaho 844,849(1984). z Evans v.Teton Cty., 139 Idaho 71, 76. 3 Bone, 107 Idaho at 850. Revised Application Narrative Page: 13 Lewiston from "elevat[ing] the comprehensive plan...to the status of a zoning ordinance."4 In other words, if a jurisdiction's zoning ordinance and its comprehensive plan dictate different outcomes, then uses and improvements authorized by the zoning ordinance cannot be barred by the application of the comprehensive plan. In interpreting the language of "in accordance with" or "not in conflict with," Idaho's courts have repeatedly held that a city errs when it elevates its comprehensive plan to the status of a zoning ordinance. In Urrutia v. Blaine County, 134 Idaho 353 (1999), the Supreme Court reviewed Blaine County's denial of a subdivision plat application that met all of the use and dimensional standards of the Blaine County Code, complying with the underlying zoning ordinance, because Blaine County found that the application did not comply with the comprehensive plan. Id. at 357. Recognizing that the Blaine County code stated that subdivision applications shall "conform to the Comprehensive Plan," the Court held that requirement merely requires the applications to"generally comport[]with the overall goals of the comprehensive plan." Id., at 358. Ultimately,the Court held that: It is to be expected that the land to be subdivided may not agree with all provisions in the comprehensive plan,but a more specific analysis, resulting in denial of a subdivision application based solely on non-compliance with the comprehensive plan elevates the plan to the level of legally controlling zoning law. Such a result affords the Board's unbounded discretion in examining a subdivision application and allows the Board to effectively re- zone land based on the general language in the comprehensive plan. As indicated above,the comprehensive plan is intended merely as a guideline whose primary use is in guiding zoning decisions. Those zoning decisions have already been made in this instance and land subdivided into twenty- acre lots and used for single family residences is specifically permitted in this agricultural area. Id., at 358-59 (emphasis added). Why did the Idaho Supreme Court rule this way? It did so because of a large body of case law which states that comprehensive plans do not themselves operate as legally controlling zoning law, but rather serve to guide and advise the various governing bodies responsible for making zoning decisions. See Theobald v. Board of County Commissioners, Summit County, 644 P.2d 942, 949 (Colo.1982); Barrie v. Kitsap County, 613 P.2d 1148, 1152 (Wash.1980); Holmgren v. City of Lincoln, 199 Neb. 178, 256 N.W.2d 686, 690 (1977); 82 Am.Jur.2d, Zoning and Planning, § 69; 3 Anderson, American Law of Zoning 609. Bone, 107 Idaho at 850. The lesson to be learned from these cases is that the comprehensive plan is to "guide and advise" decision makers in making land use decisions, it is not in and of itself the actual ordinance or policies that 4 Id. at 849. Revised Application Narrative Page: 14 are being enforced. A comprehensive plan may identify standards which the jurisdiction desires to implement. However, if the jurisdiction fails to adopt an ordinance implementing those standards,then the jurisdiction may not invoke "compliance with" a plan as a means to circumvent its failure to enact appropriate standards in accordance with Idaho law. (2) The Goals of the Comprehensive Plan and Ten Mile Plan must be Expressly Codified to be Effective. Unfortunately, many jurisdictions in Idaho have failed to acknowledge that for planning to effectively guide land use decisions,they must then take the next step of actually adopting ordinances that implement those planning decisions. When these jurisdictions do not codify the standards,they desire from their comprehensive plan,they squander the resources put into the planning exercise,they fail to give their planning staffs appropriate guidance, they confuse the public about the commitment they are making to the planning exercise, and they create unnecessary disputes with applicants frequently causing acrimony and litigation. The Idaho Legislature has been absolutely clear that for any standard to be enforceable, it has to be enacted via an ordinance and it has to be objective. The Idaho Legislature has required that land use decisions must be based upon standards adopted by ordinance. Idaho Code Section 67-6518 provides that: Each governing board may adopt standards for such things as: building design; blocks, lots, and tracts of land; yards, courts, greenbelts, planting strips, parks,and other open spaces;trees;signs; parking spaces; roadways, streets, lanes, bicycleways, pedestrian walkways, rights-of-way, grades, alignments, and intersections; lighting; easements for public utilities; access to streams, lakes, and viewpoints; water systems; sewer systems; storm drainage systems; street numbers and names; house numbers; schools, hospitals, and other public and private development. Standards may be provided as part of zoning, subdivision, planned unit development, or separate ordinance adopted, amended, or repealed in accordance with the notice and hearing procedures provided in section 67- 6509, Idaho Code. Whenever the ordinances made under this chapter impose higher standards than are required by any other statute or local ordinance, the provisions of ordinances made pursuant to this chapter shall govern. (Emphasis added.) The requirements of Idaho Code Section 67-6518 date from the original adoption of the Local Land Use Planning Act by the Idaho Legislature. More importantly,this section of the Idaho Code and its requirements have never been amended in the dates from the original adoption. Moreover, Idaho Code Section 67-6535(1) requires that (1) The approval or denial of any application required or authorized pursuant to this chapter shall be based upon standards and criteria which shall be set forth in the comprehensive plan, zoning ordinance, or other Revised Application Narrative Page: 15 appropriate ordinance or regulation of the city or county. Such approval standards and criteria shall be set forth in express terms in land use ordinances in order that permit applicants, interested residents and decision makers alike may know the express standards that must be met in order to obtain a requested permit or approval. Whenever the nature of any decision standard or criterion allows,the decision shall identify aspects of compliance or noncompliance with relevant approval standards and criteria in the written decision. Some in Idaho have attempted to argue and, in fact, may believe that the foregoing language does allow a comprehensive plan to impose development standards. Such an argument or belief, is belied not only by the plain language of the statute but also by the Idaho Supreme Court's rejection of such. While the comprehensive plan will guide initial zoning decisions and is a tool for evaluating subsequent applications, its policies and standards are not self-enabling. As set forth in Idaho Code Section 67-6535(1), the requirement "approval standards and criteria shall be set forth in express terms in land use ordinances" relates to the content of a jurisdiction's land use ordinance. The "express" approval standards and criteria identified in Idaho Code Section 67-6535(1) are those set forth in the municipality's land use ordinances to "permit applicants, interested residents and decision makers"to know"the express standards that must be met in order to obtain a requested permit." The policies and standards of a comprehensive plan, if intended to be applied to development applications, must be reduced to "express standards" through implementation by ordinance. The requirements that an application "comply with" or be "consistent with" or "adhere to" the elements of a comprehensive plan, does not elevate such a plan to an enforceable zoning ordinance if its elements have not been objectively incorporated into the jurisdiction's code by ordinance. As found by the Idaho Supreme Court, a requirement, even one incorporated in a zoning or subdivision ordinance, that applications shall "conform to the Comprehensive Plan" merely requires the applications to "generally comport[] with the overall goals of the comprehensive plan." Urrutia, 134 Idaho at 358. (3) The Ten Mile Plan Recognizes the need for Express Enforceable Standards. The Ten Mile Plan announced that the subsequent zoning decisions and amendments to Meridian's ordinances would be the means by which the goals of the plan would be implemented, not the Ten Mile Plan in and of itself, Notifying that: Achieving results from the plan requires an entirely new way of doing business forthe private and public sectors.The plan will not happen simply through the filing of development applications on behalf of the private sector or amendments to the comprehensive plan and adoption of new codes by the City. Ten Mile Plan, p. 2-2 (emphasis added). Additionally,the Ten Mile Plan recognized that Revised Application Narrative Page: 16 The City's existing development regulations provide elements of some, but not all,of these tools.As with most communities,the focus of the City's regulations is on zoning, separation of uses, and what is not desired. Implementation of the plan will require a shift in focus to the pattern and form of development and building detail. The City's Zoning District regulations provide the basic development tool for implementation of the Specific Area Plan. The code currently has fourteen zoning districts with associated standards and allowed uses for each district.The Ten Mile Plan, p. 2-2 (emphasis added). To accomplish this, the Ten Mile Plan's "Action Plan", not only identified adopting "the Ten Mile Specific Area Plan as an amendment to the City's Comprehensive Plan" as the number one priority that the City should have, but also identified amending the City's zoning ordinance to be the number two priority through "Adoptfingl revisions to the City's zoning Ordinance", and then next establishing design standards either through the City itself or by encouraging the "development community to work together to prepare a set of design guidelines that will accomplish the intent of this plan." Ten Mile Plan, p. 6-2 (emphasis added). (4) Meridian has Implemented some, but not all of the Ten Mile Plan Goals and Desired Policies. Additionally,the City initiated an amendment to its zoning code with Ordinance 08-1372 in 2008 to implement new zoning districts, new use definitions, modified use requirements, and dimensional standards derived from the Ten Mile Plan. As noted by then Planning Director, Anna Canning, Ordinance 08-1372 was intended in part to add: Two new districts and those are the ME and the HE. The MEHE. And they are mixed employment and high density employment. So, you will see the mixed employment--and these are directly related to the Ten Mile specific area plan. The mixed employment corresponds with the land use designation of that name and would allow a mix of light office, light industrial, any employment center are basically -- they typically were envisioned as not - not the tallest buildings in the Ten Mile specific area plan, so we picked the height limits similar to the C-G zoning currently. Meridian City Council Minutes, May 27, 2008, p.45. Although Ordinance 08-1372 was not effective until July of 2008 after additional revisions were made to elements of that amendment that related to elements not directly arising from the Ten Mile Plan, the extensive discussion on May 27, 2008 by staff and the city council evidenced the fact that the implementation of the Ten Mile Plan was a driving consideration of the 2008 ordinance amendments. At its core, Ordinance 08-1372 was the extent of the City Council's implementation of the Ten Mile Plan through the adoption of ordinances establishing standards as both contemplated by and required in Revised Application Narrative Page: 17 Idaho Code 67-6518 and 67-6535. The City Council acted to create two new commercial zoning districts,to establish new use definitions relating to those districts, to modify the then existing use requirements consistent with the new districts and definitions, and then to identify that landscape buffers and building sizes were "Subject to design guidelines in Ten Mile Interchange Specific Area Plan."' Since the adoption of the Ten Mile Plan and Ordinance 08-1372 in 2007 and 2008, the following have occurred: • US Population has grown from 303M to 341M • Meridian's population has doubled from 64K to more than 130K • Boise State won three Fiesta Bowls, in 2007, 2010, and 2014 • Ada County Median Home price fell from $239K in Summer 2007 to $133K in Winter 2011 and then increased to $546K today • The Great Recession in 2008 and COVID19 Recession in 2020 What has not occurred since 2007 and 2008? The following have not occurred: • There has been no other ordinance expressly establishing Ten Mile Area specific design standards; • There has been no other ordinance expressly establishing Ten Mile Area specific dimensional standards; • There has been no other ordinance expressly establishing "build to lines" • There has been no other ordinance expressly imposing setback limitations "to hold the corners"; and • There has been no other ordinance expressly requiring vertically integrated residential mixed use. A hope or an aspiration set forth in a comprehensive plan developed under Idaho law relating to height, design, density, intensity, transitions, setbacks, parking, or any of the other relevant standards adopted in S Express language from Ordinance 08-1372 referencing the Ten Mile Plan in regards to Footnote 4 of Table 11-213-3 was subsequently amended with today's generic reference in Footnote 4 of Table 11-26-3 to"adopted specific area plans", reflecting the City's adoption of other specific plans. However, based upon the plain language of Idaho Code Section 67-6518,such a reference in and of itself is insufficient to establish an express and enforceable design or development standard. Revised Application Narrative Page: 18 Idaho Code 67-6518 will not be binding or enforceable on a property owner, unless and until it is incorporated into a zoning ordinance pursuant to the notice and hearing provisions of Idaho Code 67-6509. We provide the foregoing as it clearly supports the conclusions that: • The City Council recognized that for the Ten Mile Plan to be effective that it required implementation by adoption of actual ordinances establishing the standards it advocated; • Thus Ordinance 08-1372 was enacted to further the plan; • The City Council modified certain other zoning districts and the standards associated with them at that time, but largely left intact the zoning structure it had adopted prior to approving the Ten Mile Plan in 2007; • The City Council's subsequent amendments to its zoning code have not materially modified the 2008 Ten Mile Plan amendments and have not subsequently amended the Ten Mile Plan, ostensibly evidencing comfort with both the zoning code and the Ten Mile Plan itself, and • The City Council, in approving the 118 Property DA Modification as well as approving the Black Property DAs, was generally comfortable with the zoning districts established upon the properties and their consistency with both the zoning code and the Ten Mile Plan. And we reiterate, that this Application does not materially seek to modify the land uses and the prior decisions relating to the 118 Property or the Black Property, rather,this Application: • Integrates four existing development agreements into a single development agreement; • Promote zoning designations identified as the "Best Choice"or as a"Possible Choice" in the Zoning District Compatibility Matrix established in the Ten Mile Plan; • Retains and adheres to the existing land use designations on the Future Land Use Map, while conforming them to the actual infrastructure plans and the pre-existing zoning; • Rezones a limited portion of the property currently designated C-C to be T-NC to more appropriately transition to the residential uses to the north and the west, and as the "Best Choice" within both the Mixed-Use Residential and Mixed Use Commercial land use designations in the Ten Mile Plan; • Reconfigures the existing C-C zoned property within the Black Property to reflect the ultimate infrastructure plans and requirements developed subsequent to the initial planning exercise in the Ten Mile Plan, while not materially increasing the acreage of C-C zoned property; • Preserves and promotes the importance of the High Density Employment land use and the intent associated with it, while retaining the existing C-C, H-E, M-E zones and adds the C-G Revised Application Narrative Page: 19 zone, all of which are permitted within and consistent with that High Density Employment land use; and • Proposes "a set of design guidelines that will accomplish the intent of the Ten Mile Plan. Finally,we remind Staff of the fact that in this instance,with very little exception,the existing zoning of both the 118 Property and the Black Property permit the uses and the development that the Applicant proposes. As the Idaho Supreme Court noted in Urrutia v. Blaine County, 134 Idaho 353 (1999), where the underlying zoning has been established in accordance with a valid comprehensive plan,then the comprehensive plan is intended merely as a guideline whose primary use is in guiding zoning decisions. Those zoning decisions have already been made in this instance . . . Id., at 358-59(emphasis added). The Applicant's requests are focused on conforming the underlying zoning to the approved infrastructure and the realities of the market. This Application seeks to be very surgical and precise to ensure that the overall goals of the Ten Mile Plan are adhered to, with there being no net change or immaterial change to the overall goals relating to densities and uses, while making the necessary modifications to the underlying planning designations, zoning districts,and development commitments to permit its current development. That said,the Ten Mile Plan and Meridian's Comprehensive Plan are not zoning ordinances and should not be utilized as such. For the reasons set forth below, the Application is in accordance with and in furtherance of the Comprehensive Plan and the Ten Mile Plan. 2. Application—Development Agreement Amendment As noted above, the purpose of this Application is to integrate multiple existing development agreements into a single development agreement governing the entirety of the Property. In this instance, there should be no question as to the propriety for an amendment to the existing development agreements. Development agreements are not sacrosanct,they can,should, and will be amended from time to time, and as set forth herein, were contemplated to be so amended in this instance. Previously, the Property was held in separate ownership and was subject to multiple development agreements. Consistent with the provisions of Meridian City Code 11-513-3F we seek a new Development Agreement consolidating and replacing the prior individual agreements. We turn to the specific elements of this Application which are incorporated into the Development Agreement. A draft of the proposed Development Agreement is attached for your reference. It is important to note, that each of the Development Agreement — Fedrizzi Ten Mile, LLC (AZ 11- 001) recorded as Instrument No. 112073618;the Development Agreement—SJJV, LLC(AZ 11-001) recorded as Instrument No. 112073617; and the Development Agreement — Janicek Properties, LLC (AZ 11-001) recorded as Instrument No. 112073616, not only contemplated but required future amendments to include development site plans. Each of these were intended to be amended to evidence implementation of the specified infrastructure improvements and alignments as elements of the site plans that were to be incorporated through such amendments. Revised Application Narrative Page:20 There should be no question as to the sufficiency and propriety for the requested amendment to the development agreements under either Idaho 67-6511A or Meridian City Code and integration into a single agreement. Integrating multiple development agreements into a single development plan with comprehensive Project Design Standards, reflects the ultimate goal and implementation of the Ten Mile Plan and the intention of the City Council when approving the annexation of those parcels. The Development Agreement will integrate all of the Property in a single agreement and will facilitate the implementation of the requested comprehensive plan map amendment, zoning modification, and preliminary plat together with the Project Design Standards. 3. Application -Comprehensive Plan Map Amendment Throughout the development of the Application, we have been sensitive to both the Meridian Comprehensive Plan as well as the Ten Mile Plan, the work that the various agencies put into it, and the individuals who worked on its development and approval in June 2007. We have reviewed, analyzed, and contemplated the content of the Ten Mile Plan,as well as the City's subsequent zoning decisions,that relate to the Application we have presented herein. We address the request to modify the Comprehensive Plan Future Land Use Map below. (a) A Comprehensive Plan Future Land Use Map Amendment is Unnecessary. We note that the Applicant has previously initiated a request to modify the Comprehensive Plan Future Land Use Map at the behest of Staff,this submittal is intended to supplement and support that prior request. Staff previously indicated that the desired zoning amendment to rezone the portion of the Property south of Villaggio/Vanguard and north of Navigator from the WE zone to the C-C zone necessitated a future land use map amendment. We disagree, however, we proceed with this request not because we believe Staff is correct, but rather out of the Applicant's recognition of procedural economy. The Future Land Use Map found in the Comprehensive Plan does not require modification or amendment to implement the requested zoning and development agreement modifications set forth herein. Moreover,we note that the Comprehensive Plan itself acknowledges that map amendments are not necessary in this instance. We take seriously the recognition by the Ten Mile Plan, that with respect to future land use maps, that the goal of the plan was to identify a mix of appropriate uses not to establish unchanging barriers or lines to implementation, specifically: Next,we are respectful of those allocations of uses, but are also cognizant of the guidance afforded by the Ten Mile Plan regarding its land use map and its planning district identification: No more lines! Unfortunately, a map cannot be reasonably presented without lines defining the boundaries between various land use designations. While the Land Use Map still uses lines to identify specific areas for employment, industrial, mixed-use residential and commercial, and high, medium and low-density residential uses, the goal of the plan is to promote more organic and holistic development patterns, to mix uses more than to obey lines on a map. The idea behind this Land Use Map is Revised Application Narrative Page:21 not to separate uses by area, but to promote the best use of each area in concert with the others. The Land Use Map provides the geographic context for the development of the Ten Mile Interchange Area over the next 30 years.While proposed land uses are mapped to specific locations, the land use recommendations presented in the Land Use Map are still relatively broad, and the exact shape of many of the land use areas is necessarily somewhat conceptual. The Land Use Map recommends the general locations for specific types of land uses and illustrates how these uses are related to each other geographically.While the fine-grained intermixing of land uses is not shown at this scale and level of generality, the map is not intended to emphasize the segregation or separation of uses, but suggest the areas in which certain types of development are most likely to flourish, given the location of other development and transit options. Most areas will typically be comprised of a variety of different land uses in relatively close proximity to each other. The Land Use Map is not intended for application on a parcel-by-parcel basis; nor should it be interpreted as similar to a zoning district map. Ten Mile Plan, p. 3-15 (emphasis added). Moreover, the subsequently adopted Comprehensive Plan addresses that same concept noting in the provision designated as "General Guidance"that: Future Land Use designations are not parcel specific. An adjacent, abutting designation,when appropriate and approved as part of a public hearing with a land development application, may be used.A designation may not be used however, across planned or existing collector or arterial roadways, must not be used on a parcel not directly abutting the designation, and may not apply to more than 50% of the land being developed. All other changes to designations must be approved through a Comprehensive Plan Map Amendment. Sample zoning listed in the future land use designation descriptions does not preclude the use of other zoning districts provided the proposed project is consistent with the description of the land use designation. Meridian Comprehensive Plan p.3-11(emphasis added). As is set forth in detail below, no map amendment should be required based upon the General Guidance since the Applicant (a) is proposing zones consistent with "adjacent, abutting designations"; (b)which are sought to be approved as part of a public hearing with a development application; (c) are not extended across existing collectors or arterial roadways, but rather Revised Application Narrative Page:22 merely seek to align with the actual collectors that are now designed and being constructed; and (d) the proposed extensions of uses do in fact comprise less than 50%of the land being developed. (b) The Existing Future Land Use Maps Support the Zoning Requests Made Hereafter First,we highlight the future land use designations that were actually assigned to the Property prior to its annexation and zoning. The Ten Mile Plan Land Use Map initially identified and designated the Property as follows based upon the anticipated locations for the various roadways: MUR MUC MUC PARK ~ o HDE HDE Ten Mile Plan, p. 3-16. Of note, the actual location of the Villaggio/Vanguard right of way was dedicated significantly farther to the north than what was originally contemplated within the Ten Mile Plan. Regardless, the Ten Mile Plan identified various future land uses on the Property, including Mixed Use Residential (MUR), Mixed Use Commercial (MUC), High-Density Employment(HDE),and Mixed Employment (ME). As set forth in the Future Land Use Map adopted in conjunction with Meridian's Comprehensive Plan, similar designations were incorporated therein as follows, although they still were not aligned with the actual dedicated rights of way: Revised Application Narrative Page:23 RRIf- .; _ s � Fit q�xx�c�i�ca it � i it • i i Density Employment The takeaway from this is that ultimately, the land uses of Mixed Use Residential (MUR), Mixed Use Commercial (MUC), High-Density Employment (HIDE), and Mixed Employment (ME), set forth the desired mix of uses within the Property, but they do not and were not intended to be the actual zoning districts for those related uses. Insisting upon such belies the warning that these maps do not require strict devotion to their boundaries ("No more lines"Ten Mile Plan, p. 3-15) and that the underlying uses should be extended to conform to the actual approved infrastructure plan ("adjacent, abutting designation . . . may be used . . . [but] may not be used however, across planned or existing collector" Comprehensive Plan p. 3-11). W The Existing Zoning District Compatibility Matrix in the Ten Mile Plan Supports the Application without Amending the Map Additionally, as we have analyzed the Ten Mile Plan and the Comprehensive Plan, it is important to note the guidance that the City of Meridian has provided in implementing these land use designations when it is time to actually zone properties. Land use designations are not zoning classifications.' ' The lack of precision in various definitions and terminology among the City's various planning documents and policies is problematic. The Ten Mile Plan utilizes the terminology "Mixed Use Residential," which is variously referenced as "MUR" or"MUR-Res"; meanwhile,the Comprehensive Plan utilizes "Mixed Use Regional (MU-R)". The Ten Mile Plan also utilizes the term, "Mixed Use Commercial", which is variously referenced as "MUC" or "MU-Com"; meanwhile, the Comprehensive plan utilizes the term "Mixed Use Community (MU-C)". Unfortunately, none of these terms are synonymous and merely create confusion,which could have been avoided due to the timing and sequencing between the Ten Mile Plan and the Comprehensive Plan. It also would be better explained if the Ten Mile Plan had been implemented into the UDC as this would have forced a conversation about how these designations overlap; however, that has not occurred and so these inconsistencies remain a challenge. The note on p.3-21 of the Comprehensive Plan is insufficient in this regard as it does not explain how MU-C is to be applied in the areas subject to the Ten Mile Plan. Additionally, there is consistent confusion between the High Density Employment (HDE) land use designation and the High Density Employment(H-E)zone. The High Density Employment land use designation authorizes various zones, which include and are not limited to the WE zone. The land use designation and the zoning designation are clearly not identical in what they contemplate. Imprecise utilization of such terms,which have different purposes and different definitions,creates unnecessary confusion and conflict between Staff and property owners. Revised Application Narrative Page:24 With respect to the Mixed Use Residential (MUR/MU-RES) land use designation, the City has provided the following guidance establishing that appropriate zones within that land use designation include R-15, R-40, C-C,TN-R, and TN-C: Page I MUMMIXED USE RESIDENTIAL (MU-RES) TEN MILE SPECIFIC PLAN LAND USE MAP DESIGNATIONS M1. nap Color ❑ Ioning K-15 1 R-401 C-C I TN-R ITN-C Sample Use(s) ❑ Vertically integrated residential,live-work,office,retail,recreation,parks,multi-family,and townhouses This is derived from the zones identified in the Zoning District Compatibility Matrix for the Mixed Use Residential land use designation in the Ten Mile Plan: Residential Commercial Industrial Tradihional Exist rig CityZo-r@ Di=.trick �-2 ?d r g R-15 R-40 N C-C G L-0 -H C�-- `4-:' TN-t MIXED-USE RESIDENTIAL De-,sih E-12 D,1.A- ti Ten Mile Plan, p. 2-5. With respect to the Mixed-Use Commercial (MUC/MU-COM) land use designation the City has provided the following guidance establishing that appropriate zones within that land use designation include C-C, C-G,TN-C, and C-N: Page I MUC.1 MIXED USE COMMERCIAL (MU-COM) TEN MILE SPECIFIC PLAN LAND USE MAP DESIGNATIONS I I I i nap Color ❑ Zoning C-C I C-G ITN-C I C-N Sample Use(s) ❑ Commercial,vertically integrated residential,live-work,employment entertainment,office,multi-family,and townhouses This is derived from the zones identified in the Zoning District Compatibility Matrix for the Mixed- Use Commercial land use designation in the Ten Mile Plan: Residenlial I Commercial Industrial Tradihional E Ar)gCitY2oning Di<iricts t-2 t4 R-B R-15 R-43 I _N C-C _. L-O -H TAR MDfE�RCIAL De,)situ,.&12 DLYAC Revised Application Narrative Page:25 With respect to the High-Density Employment(HDE) land use designation the City has provided the following guidance establishing that appropriate zones within that land use designation include C-C, C-G, TN-C, and H-E: Page I HDE.1 HIGH DENSITY EMPLOYMENT (HDE) TEN MILE SPECIFIC PLAN LAND USE MAP DESIGNATIONS I• nap Color ■ Zoning C-C I C-G ITN-C I H-E Sample use(s) ❑ Office,research,conference centers,accessory restaurants,ancillary convenience retail,and daycare This guidance is clearly derived from the Zoning District Compatibility Matrix for the High-Density Employment land use designation in the Ten Mile Plan. In 2008, the HE zone was created as well, but as noted above, HE and HDE are not coterminous, and the City contemplated a variety of commercial oriented uses within the HDE Residenlial Commercial Industrial Traditional EmAr)g City=onira DiWict,, R-2 1 t4 1 F,8 I f115 I FIX �IJ I C-C I �G I L-O -H T'+ HIGH DENSITY EMPLOYMENT v' 4+ The fact that the Ten Mile Plan utilized a "Check Plus" to indicate that the C-G zone was the most preferred zoning classification that the City had identified at that time, reaffirms its importance and its compatibility. (d) Staff Requested Additional Analysis of Ten Mile Plan Elements. Staff has requested that the Applicant provide additional analysis of the requested modifications under these Applications and their impact upon the Ten Mile Plan. We will address each of those in detail below,after we provide some clarification regarding the Ten Mile Plan,as adopted and implemented by the City of Meridian, and its impact upon our very narrow request to modify the Future Land Use map as set forth above. (1) The Application is in Accordance with the Intended Allocation of Uses under the Ten Mile Plan. After the initial submittal of this Application, Staff has made the following specific request of the Applicant: Include justification as to why the proposed change is more appropriate than the existing designation understanding the balance of jobs/housing within the amended area, as well as the overall balance in the Ten Mile Area, is critical.The District was originally intended first as an employment center with supportive residential, but the opposite is occurring. Consider Revised Application Narrative Page:26 offsets and mitigation opportunities.Traffic impacts, backed up by a traffic analysis should be addressed. The inquiry mischaracterizes the Applicant's proposal. The Application does not seek to fundamentally change the balance of jobs/housing in the areas being amended based upon the existing underlying and requested zoning. Rather, the Application conforms the land use designations in the Ten Mile Plan and the Future Land Use Map to the actual zoning of the underlying properties that the City previously undertook in conjunction with the 118 Property DA Modification as well as approving the Black Property DAs. The Application also seeks to align the zoning along Ten Mile Road with the actual locations of Cobalt and Voyager and ensuring that the primary residential properties to the north and west of the Property are buffered from the commercial areas. Moreover, as set forth based upon the proposed mix of uses, there is a significant but not predominate amount of housing. The Application contemplates approximately 33.42 acres of residentially developed property, zoned TN-C, which under both the MUR designation and TN-C zone contemplates a density of 8-12 units per acre. We do not understand Staff's concern that the addition of 7.48 acres of TN- C zoning within a property that has been designated as MU-RES on the Future Land Use Map is somehow not "supportive residential". As set forth in the table below, resulting TN-C zoned area is less than 20% of the total site, while various employment intensive zones comprise the remaining 80%of the site: ZONING DISTRICT ACRES COMMUNITY BUSINESS DISTRICT—(C-C) 59.11 HIGH DENSITY EMPLOYMENT—(H-E) 34.82 TRADITIONAL NEIGHBORHOOD COMMERCIAL—(TN-C) 33.42 MIXED EMPLOYMENT—(M-E) 10.19 GENERAL RETAIL&SERVICE COMMERCIAL—(C-G) 25.97 The resulting TN-C does not materially impact or reduce the importance of the Property and Project as an "employment center". As set forth in the following table of programmed uses, office is identified for more than 750,000 square feet of uses within the Project; retail and service commercial are programed for approximately 500,000 square feet of uses; and hospitality and recreational uses are contemplated to be in excess of 400,000 square feet of uses: Revised Application Narrative Page:27 USES SQFT GENERAL OFFICE 536,800 MEDICAL OFFICE 250,000 RETAIL 414,329 HOTEL 210,000 ENTERTAINMENT, RECREATION, FITNESS 134,770 RESTAURANT AND CAFE 63,206 GROCERY 53,500 SERVICES (BANK, DAYCARE,SALON, SPA, ETC.) 29,200 RESIDENTIAL 268-402 UNITS It is clear from not only the proposed acreages of the various zones, as well as the program of proposed uses,that the TN-C is in fact "supportive residential" and the Project remains an "employment center"with the balance of employment and housing consistent with what is set forth in the Ten Mile Plan. -C-C \ m C-G Rit_ g C-G �® 184 — Revised Application Narrative Page:28 Additionally, the existing land use designations have significant overlap in the zoning designations that they are compatible with, and in fact, this area of the Ten Mile Plan that is at issue utilized mixed use land use designations of Mixed Use Residential (MUR/MU-RES) and Mixed-Use Commercial (MUC/MU- COM) that both identified TN-C and C-C as zones designations identified as the "Best Choice" or as a "Possible Choice" respectively on the Zoning District compatibility Matrix. The existing implementation of the TN-C zone and the C-C zone, the reconfiguration of each zone as proposed in the Application,together with the realignment of the Mixed Use Residential (MUR/MU-RES) and Mixed-Use Commercial (MUC/MU-COM) land use designations to conform with the underlying zoning districts, does no violence to the Ten Mile Plan. The Ten Mile Plan and the City have already previously made the determination that these land use designations and their associated compatible zoning districts will have the mix of jobs and housing desired here. If that were not the case then why would the Ten Mile Plan and the City have identified these zones and their uses be compatible with and in accordance with the Land Use designation in terms of the mix of jobs and housing? We further note that with respect to these proposed revisions that none of the Black Property DAs incorporated site plans and that all were required to present site plans consistent therewith for adoption and implementation. This exercise has been driven by the development of a site plan that is consistent with the underlying zoning districts, the Ten Mile Plan, and the infrastructure planning that has occurred since the approval of the Black Property DAs. As depicted on the existing Future Land Use Map there are three land use designations impacted by this Application are the MU-Res,the MU-Com, and the High Density Employment depicted below,which were established as general areas of compatibility:' 1 I 1 ae�tk�i I I li 1 I II'I 11 1 1 II 1 JJ L The Application proposes a reconfiguration of the land use areas that"is more appropriate than the existing designation" because it reflects both the location of the planned and approved infrastructure as well as the 'The Ten Mile Plan specific notes that while"the Land Use Map still uses lines to identify specific areas . . . the goal of the plan is to promote more organic and holistic development patterns,to mix uses. .. not to separate uses by area,but to promote the best use of each area in concert with the others."Ten Mile Plan, p.3-15(emphasis added). Revised Application Narrative Page:29 underlying zones compatible with each of the land use designations.The reconfiguration is consistent with the Comprehensive Plan and the "General Guidance" provisions therein. As set forth in the Application, rather than reflect the aspirational areas that were established prior to the identification and placement of the infrastructure serving the properties, we are proposing designations that reflect the compatible zoning designations that have either already been established by the prior development agreements, or we are proposing designations that conform with the minor rezonings that have been proposed as well as the design of the actual roadways: I I +I 1 I I MU-RES TNT MU-COM _ � rr ac o FM'�E HDE I � .�.��..n�.�H H E —— LAND USE MAP ZONING MAP Both the Mixed Use Residential (MUR/MU-RES) land use and the Mixed-Use Commercial(MUC/MU- COM) land use contemplate a residential density of 8-12 units to the acre. Ten Mile Plan, p. 2-5. Both the Both the Mixed Use Residential (MUR/MU-RES) land use and the Mixed-Use Commercial (MUC/MU-COM) land use contemplate TN-C as a "Best Choice" with a "Check Plus" on the Zoning District Compatibility Matrix. Ten Mile Plan, p. 2-5. The Application merely seeks to take the band of Mixed Use Residential (MUR/MU-RES)that was indiscriminately identified before,and then relocating it into a cohesive residential neighborhood, centered on Umbria, north of Villaggio/Vanguard. The approximately 33 acres of Mixed Use Residential (MUR/MU-RES), with an ultimate build out of 296 to 444 dwelling units, in no way is hostile to "the balance of jobs/housing." There is no basis with respect to this Application for Staff's assertion that the Property "was originally intended first as an employment center with supportive residential, but the opposite is occurring." If Staff believes that the Application potentially will result in too much residential development, which adversely affects the intended balance between jobs and housing,then we believe that is not due to the Application, but rather due to the fact that not only does the City's zoning code expressly allow residential development in both the TN-C zone and the C-C zone, but that of the property located south of Cobalt and north of Villaggio/Vanguard more than 50% of it is in fact designated Mixed Use Residential (MUR/MU-RES),which the Applicant is merely trying to respect. Revised Application Narrative Page:30 (2) The Application need not Abandon the Ten Mile Plan, as it Supports the Type of Commercial Development Proposed. After the initial submittal of this Application, Staff has made the following additional request of the Applicant: Include analysis on how the proposed development is consistent with the proposed FLUM designation(s). At the pre-app meeting, we discussed that the Commercial FLUM designation might be more appropriate than MU-COM for some of the development proposed (i.e. single-level big box).The MU-COM calls for vertically integrated, no setback, hold the corners, cohesive,traditional neighborhood design. Did you review the Plan and feel the development proposed can fit within the MU-COM designation? Again, we believe that Staff misunderstands what the Applicant has proposed. The Applicant has been attentive to Staff by guidance throughout this process. However, it appears that Staff is elevating the Ten Mile Plan above the existing zoning ordinance as to specific design aspirations. To do so would be a violation of Idaho law. As such, we disagree with Staff's characterization that the land use designation in and of itself mandates something different from what is permitted by the underlying zoning, and in a manner rejected by the Idaho Supreme Court in Urrutia, 134 Idaho at 358-59,while simultaneously ignoring the plain language of the Ten Mile Plan. First, in light of the intensity with which Staff has defended the implementation of the Ten Mile Plan, it is inconsistent to simultaneously argue that the existing MU-Com land use designation should be abandoned for a generic Commercial land use designation. It was our understanding that Staff wanted us to work within the confines of the Ten Mile Plan. We recognize that is what the property owner to the east of Ten Mile Road did just that, propose the generic Commercial Land Use with respect to modifying most of land use designation of Lifestyle Center. However, that land use designation never had any meaningful incorporation into the zoning code with specific use and design standards being established, and the Black Property DAs did implement C-C zoning throughout much of the MU-Com designated area without any articulated concern that C-C was somehow inconsistent with it. Second,the Applicant requested that the MU-Com designated area be aligned,for the convenience of Staff and future development administration,with the C-C zoned area of the Project. We note that within all three of the primary land use designations applicable to the Black Property, that each of the Mixed Use Residential (MUR/MU-RES), Mixed-Use Commercial (MUC/MU-COM), and High-Density Employment (HDE) land use designations are compatible with the C-C zone as proposed by the Applicant. This is addressed in detail in The District at Ten Mile Land Use Application Analysis, pp. 16-17, where the applicant notes that both the Ten Mile Plan and the City prepared cut sheets indicate these land use designations are compatible with C-C zoning, which has already been applied over a significant portion of the MU-Com designated land area. Revised Application Narrative Page:31 Third, the Ten Mile Plan specifically encourages property owners to develop their own implementation plan for the aspirational design goals identified therein. The Ten Mile Plan recognized that the City had a significant obligation to develop and establish the necessary development and design standards to effectively implement it: Implementation of the Ten Mile Interchange Specific Area plan will require that the City have a robust toolbox of zoning, development and design standards to carry out the intended mix of uses, patterns of development, and form that are proposed in the plan. Implementation of the plan will be accomplished through the City's existing development codes, through amendments to those codes, or by the development of new provisions, such as new zoning districts, overlay districts, design guidelines and development standards. Ten Mile Plan, p. 2-2 (emphasis added). However, as part of the Ten Mile Plan's "Action Plan", it not only identified adopting"the Ten Mile Specific Area Plan as an amendment to the City's Comprehensive Plan" as the number one priority that the City should have, but then identified amending the City's zoning ordinance to be the number two priority through "Adopt[ing] revisions to the City's zoning Ordinance", and then next establishing design standards either through the City itself"Develop[ing] a set of design guidelines for the Ten Mile Interchange Area; or Encourag[ingl the development community to work together to prepare a set of design guidelines that will accomplish the intent of this plan." Ten Mile Plan, p. 6-2 (emphasis added). In fact,the Ten Mile Plan actually identified the likelihood of the City not moving quickly enough to develop the necessary "robust toolbox of zoning, development and design standards" to implement it, foretelling that: Knowing the private sector may want to act more quickly to move the plan forward,the City encourages developers and key land owners to take the initiative and begin the implementation program, bringing forward detailed design guidelines and zoning, and infrastructure financing proposals based on the concepts presented in this plan. The City stands ready to support your efforts and will be moving forward rapidly to implement the recommendations in this plan. Ten Mile Plan, p. 1-3 (emphasis added). It should not be discounted that the Applicant has taken significant steps to develop detailed design guidelines for the entirety of the Property, including the MU-Com area based upon the Ten Mile Plan. Not every desired design element identified in the Ten Mile Plan can be implemented nor were they ever intended to be applicable everywhere. If the City had in fact desired to impose the requirements that Staff intimates, then as set forth in Urrutia, it would have adopted ordinances establishing mandatory "build-to- lines", materially expanding the existing standards for vertically integrated residential development,as well as traditional neighborhood design as defined and discussed throughout the Ten Mile Plan, and not merely attempt to use its planning document to circumvent the actual ordinances that presently exist. If a jurisdiction in Idaho desires to impose specific design standards, it may do so pursuant to Idaho Code 67- Revised Application Narrative Page:32 6518 if it does ordinance.The fact that the City has not acted to adopt ordinances materially implementing those over the last seventeen years since the adoption of the Ten Mile Plan belies the insinuation that this Application is in opposition to or inconsistent with the Ten Mile Plan. We also note that when the City of Meridian looked for examples of what the Ten Mile area would look like, it identified in its cut sheets to guide development, well recognized projects as the basis for an example of the desired "Site Pattern." In fact, the Applicant recognizes these projects intimately, why? Because the Applicant's team was responsible for their design,their development,and their operation. The Applicant's team takes pride in the work they have done, has learned from those opportunities, and has implemented that knowledge, here in this Application. When the City of Meridian looked for examples of what the Ten Mile area High-Density Employment (HDE) land use designation to use as an example of the desired "Site Pattern", its cut sheets identifies Portico, a project developed by the Applicant's office and medical team in a prior partnership as well as Scentsy Commons a project upon which the Applicant's medical team advised: Ail k- ri When the City of Meridian looked for examples of what the Ten Mile area Mixed Use Commercial (MU-COM) land use designation to use as an example of the desired "Site Pattern", its cut sheets identifies the Village, a project developed by the Applicant's retail team in a prior partnership, as well as the Gateway in Salt Lake City,which the Applicant's office and medical team had been involved through its prior development partnerships. Revised Application Narrative Page:33 Similarly,when the City of Meridian looked for examples of what the Ten Mile area Mixed Use Residential (MU-RES) land use designation to use as an example of the desired "Site Pattern," its cut sheets identifies only one development from Ada County,which happens to be a mixed use project that the Applicant's counsel represents. r The Applicant has assembled a team that has largely been responsible for the most significant office, retail, and mixed use developments in Ada County in the last twenty years. The projects of the Applicant's team are the projects in Ada County and elsewhere that the City of Meridian looks to as examples of what it wants. From these experiences,the Applicant knows what types of development work, what types do not work,what tenant mixes are healthy,what tenant mixes are bad,what office users want, what retailers need, and what creates actual, walkable and useable neighborhoods. Staff's invocation of"single level big box" is unfortunately reductive of the Applicant's work and is disingenuous. "Single level big box" absolutely is an element of this Project,why? Because some uses inherently require "single level big box", no matter how much people wish they did not exist will continue and are necessary. "Single level big box" is at most 10 to 15%of the total Project and is necessary to provide the types of community services as were contemplated here in this site. The request from Staff puts the Applicant in an unnecessary and unfortunate dilemma:to either work within the confines of the Ten Mile Plan and be accused of not adhering to the Ten Mile Plan or request a modification that abandons the Ten Mile Plan and be accused of ignoring the City's prior planning decisions. The Ten Mile Plan and Meridian's Zoning Code clearly permit"single level big box" in the Ten Mile area and within Meridian's commercial zoning districts. The Ten Mile Plan clearly invites applicants to develop large master planned projects like the Applicant does here. The Ten Mile Plan also Revised Application Narrative Page:34 invites property owners to develop the requisite design standards in the absence of the City's codification of suggestions from the Ten Mile Plan. Ultimately developer initiated "detailed design guidelines and zoning: are exactly how we ensure that the "development proposed can fit within the MU-COM designation". We have been sensitive to and incorporated the design elements from the Ten Mile Plan as appropriate. We acknowledge that it appears that Staff has not spent time reviewing the development standards that we propose implementing as set forth in the Application in a manner that is, in fact, enforceable and not merely aspirational. The request from Staff ignores Idaho's jurisprudence, ignores the Applicant's long history of mixed use development of the type desired under the Ten Mile Plan, mischaracterizes the role that "single level big box" plays in this Project, and would force the Applicant into a longer and more contentious process rather than undertake a good faith evaluation of the totality of the Application and the Applicant's efforts. (e) If Required, Future Land Use Map Amendments Should Retain the Ten Mile Plan Land Uses, but Align their Boundaries with the Approved and Designed Infrastructure. To address Staff's concerns noted above,we disagree that there needs to be an amendment to the Future Land Use Map, however, if the decision-making bodies believe that it is needed, then we propose certain adjustments to the Comprehensive Plan Future Land Use Map to better align the land use planning maps of both the Comprehensive Plan and the Ten Mile Plan to the actual zoning and development of the Property. These requests, are in accordance with and conform to both the Comprehensive Plan and the Ten Mile Plan as they reflect a reorientation of these land use designations while retaining the overall area allocable to each one. If the decisionmakers determine that an amendment to the proposed larger Future Land Use Map is provided herewith, but for reference, the requested Future Land Use Map modifications are depicted as follows: �� IIII � I \ \ MU-RES MU-COM _ W.VILLAGGIO WAY 0 A I � h HDF 7NN'WI'7fIIIIIIIPIIFiFgmlNill^'11-1f-0wN= - W.NAVIGATOR WAY INrER'TATE", Revised Application Narrative Page:35 That said, in light of the plain recognition that the High-Density Employment land use designation is compatible with the zoning of property Community Business District (C-C) and General Retail & Service Commercial (C-G), we do not believe that rezoning a portion of the High-Density Employment (HE) to Community Business District (C-C) and General Retail & Service Commercial (C-G), in fact, requires the modification of the Future Land Use Map since C-C and C-G is an acknowledged compatible zone within the High-Density Employment Land Use Designation. Moreover, as the Mixed-Use Commercial land use designation is compatible with the zoning of property as Community Business District (C-C), or Traditional Neighborhood Commercial (TN-C) and Mixed Use Residential land use designation is compatible with the zoning of property as Medium High-Density Residential (R-15), Community Business District (C-C), or Traditional Neighborhood Commercial (TN-C), we do not believe that rezoning a portion of the Community Business District(C-C)to Traditional Neighborhood Commercial (TN-C), in fact requires the modification of the Future Land Use Map since those zones are all acknowledged as compatible zones within either the Mixed-Use Commercial. However, to address the concerns of Staff and to address ambiguities that exist between the Ten Mile Interchange Specific Area Plan (TMISAP) and the Comprehensive Plan, we have initiated this request. As we realign the boundaries of the various land use designations, we do so solely to ensure that there is no material deviation from the underlying land use planning designations that have previously been made. We cannot guarantee that there is not some net change in the area, but we do note that we have attempted to be surgical in the following modifications. (f) Standards Applicable to Amendments of the Land Use Map The Applicant is requesting amendment and modification to the comprehensive plan future land use map. As such, we acknowledge that to assist Staff, the Commission, and the City Council in evaluating and approving this Application, this Application satisfies the requisite standards set forth in Meridian City Code 11-513-7D as set forth below. (1) The proposed amendment is consistent with the other elements of the comprehensive plan. The requested amendment to the future land use map is a realignment of the locations of the existing land use designations, with an attempt to ensure that the general area of which and the contemplated zoning are not materially modified. The Comprehensive Plan Future Land Use Map adopted the Ten Mile Plan Land Use Map as its own. However, as discussed above, the Ten Mile Plan noted that its "Land Use Map is not intended for application on a parcel-by-parcel basis; nor should it be interpreted as similar to a zoning district map." Ten Mile Plan, p. 3-15. As such this request is the very type of amendment that was contemplated. As we are not seeking to modify the actual future land use designations and not materially relocate them,the requested amendment is inherently consistent with the other elements of the Comprehensive Plan. (2) The proposed amendment provides an improved guide to future growth and development of the city. The requested amendment is brought forward as part of an omnibus application that addresses the development of this property which has been previously subject to various disparate Development Agreements due to the disparate ownerships. With the unification of ownership and the development of Revised Application Narrative Page:36 a comprehensive development plan by the Applicant, the modification of the boundaries of the zoning districts within the Property in a manner that is consistent with future land use map will facilitate the expansion of utilities and infrastructure and with an integrated development plan for a large property that is implementing the goals of the relevant plans. Additionally, see the detailed analysis set forth in Section 3(c) and 3(d)(2) above. The proposed amendment to the land use map will simplify future land use applications. (3) The proposed amendment is internally consistent with the goals, objectives,and policies of the comprehensive plan. The requested amendment reflects merely a reconfiguration of the land use designations previously identified in the Ten Mile Plan. As noted therein, "While proposed land uses are mapped to specific locations, the land use recommendations presented in the Land Use Map are still relatively broad, and the exact shape of many of the land use areas is necessarily somewhat conceptual." Ten Mile Plan, p. 3-1S. Additionally, see the detailed analysis set forth in Section 3(a)-(e) above, which demonstrate the internal consistency of this request. This amendment is the implementation of the goals, objectives, and policies set forth in the Ten Mile Plan. (4) The proposed amendment is consistent with this Unified Development Code. As discussed above, even with the reallocation and realignment of the various land use designations on this requested amendment to the future land use map, the underlying zoning districts that are not being sought to be modified by this Application remain consistent with the land use maps based upon the City's compatibility matrices. (5) The amendment will be compatible with existing and planned surrounding land uses. The realignment of the various land use designations in this requested amendment will not materially affect the surrounding land uses, whether existing or planned. Consistent with the Ten Mile Plan and similar to this Application the property immediately to the east across Ten Mile underwent a significant realignment of comprehensive plan land use designations and zoning as part of a consolidation of multiple development agreements in Ten Mile Crossing (H-2020-0114). Additionally, the properties to the north have been the subject of various land use applications which have implemented the contemplated land use and zoning designations for this area as a mixed-use node with a variety of intensive commercial and residential uses. (6) The proposed amendment will not burden existing and planned service capabilities. Care has been taken to ensure that the realignment of the various land use designations in this requested amendment will not materially affect the underlying density or intensity of development that was contemplated in the Ten Mile Plan. The existing and planned service capabilities have always been predicated on the type and intensity of development that is proposed in this Application. Revised Application Narrative Page:37 (7) The proposed map amendment (as applicable) provides a logical juxtaposition of uses that allows sufficient area to mitigate any anticipated impact associated with the development of the area. In recognition of the original planning efforts under the Ten Mile Plan, this Application seeks to align the ultimate development plan for the Property in a manner that provides adequate mitigation of the various impacts. With the existing development approvals for residential properties north and west of the Property, the realignment of these land use designations better buffers the less intensive residential uses to the north from the more intensive commercial uses that have been long contemplated. The proposed map amendment is merely a realignment of land use designations, not a material change, as set forth in our detailed analysis in Section 3(a)-(c) above. Even with the realignment of certain land use designations, in those areas which are adjacent to residential properties, the modifications are not coupled with more intensive zoning requests. (8) The proposed amendment is in the best interest of the City of Meridian. In evaluating what is "in the best interest" of a city, the Idaho Supreme Court has acknowledged that there is a certain degree of discretion afforded to a decisionmaker when posed with such a standard. North West Neighborhood Association v. Boise, 535 P.3d 583, 594. However, such a decision must be articulated in terms of the existing codes and standards as required by the application of existing ordinances. In this instance,the requested amendment is in furtherance of the implementation of the Ten Mile Plan and is, in fact,the type of application contemplated therein. Having adopted the Ten Mile Plan and having recognized therein the importance of permitting the private sector"to act more quickly to move the plan forward,the City encourages developers and key land owners to take the initiative and begin the implementation program, bringing forward detailed design guidelines and zoning,and infrastructure financing proposals based on the concepts presented in this plan." Ten Mile Plan, p. 1-3 (emphasis added). That is exactly what the Applicant seeks to do here. It is certainly in the best interest of the City for its existing development plans to be implemented especially after seventeen years. 4. Application—Zoning Modification The Applicant is requesting amendment to the zoning applicable to the Property. The rezoning of certain portions of the Property is hereby undertaken to conform the existing zoning to the revised development plan to incorporate additional property into the Development Agreement and to address the concerns raised by Staff regarding the applicability of certain land use designations to certain zoning district designations. (a) Requested Amendments to Existing Zoning Districts In conjunction with this Application, we respectfully request certain amendments to the existing zoning districts applicable to portions of the Property. We will identify each of these in detail below: (1) Rezoning of a portion of the WE zone to C-C zone. Applicant respectfully requests the rezoning of a portion of the High-Density Employment (HE)to Community Business District(C- C). The legal description of the resulting modified Community Business District (C-C) zone is incorporated herein. As discussed above, at the request and requirement of Staff, the proposed amendment of the Future Land Use Map has been undertaken to facilitate the rezoning of this portion of the Property Revised Application Narrative Page:38 comprising approximately 12.34 acres. The resulting C-C zoned portion of the Property and the southern boundary between the C-C and WE zoned parcels is as follows: (om) / POINTOF 6EGINNINGNG i I GC 1 1 1 (WE) ZONE C-C p 7234 AC O I _ I 1 � Ig 16 O __ WE (WE) GS EXISTING CC ZONE PROPOSED CHANGE RESULTING CC ZONE (2) Rezoning a portion of the C-C zone to the WE zone. Applicant respectfully requests the rezoning of an existing portion of the Community Business District (C-C) zoned property to High-Density Employment (H-E). The legal description of the new to High-Density Employment (H-E) zoned property is incorporated herein. This rezone is requested to reflect the fact that the additional retail contemplated above in the Community Business District (C-C) 12.34 acre expansion is essentially offset by this 9.13 acre modification, and the important WE zoning designation is ensured to be preserved. The resulting change in the WE zoned portion of the Property and the northern boundary between the WE and the C-c zoned parcels is as follows: POINT OF(n'�C) P !16 Rmes o>lFARI Nosarc/1a 1�1 EXISTING CC ZONE PROPOSED CHANGE RESULTING CC ZONE (3) Rezoning of a portion of the WE and C-C zones to the C-G zone. Applicant respectfully requests the rezoning of a portion of the High-Density Employment (H-E) and the Community Business District (C-C)to General Retail and Service Commercial District (C-G). The legal description of the resulting modified General Retail and Service Commercial (C-G)zone is incorporated herein. The C-G zoned portion of the Property is entirely within the HIED land use, and is presently zoned C-C and H-E. As noted above in Section 3(c), within the HED land use designation, the C-G zoning designation is a "Check Plus". This rezone is requested to ensure that certain intense commercial uses, which provide both significant employment opportunities, but serve the employees working in the vicinity, have the types of retail and Revised Application Narrative Page:39 service opportunities they require. The resulting C-G zoned portion of the Property, comprising formerly C- C and WE zoned parcels is depicted as follows: G,N I K9 IWE i C-G ��f I C G H-E EXISTING C-C AND WE ZONE PROPOSED CHANGE RESULTING C-G ZONE (4) Rezoning a portion of the C-C zone to TN-C zone. Applicant respectfully requests the rezoning of a portion of the Community Business District (C-C) to Traditional Neighborhood Commercial (TN-C) with the intention that this will permit the intensity of mixed-use residential development contemplated in the relevant planning documents. The resulting TN-C zoned portion of the Property and the boundary between the C-C and TN-C zoned parcels is as follows: TN-C off Mc C-G EXISTING TN-C AND C-C PROPOSED CHANGE RESULTING TN-C AND C-C (5) Rezoning the Additional Property from R-40 to the C-C zone. Subsequent to the execution of the prior development agreements, Hotel-SLC acquired .62 acres north of its property but south of Cobalt that had been subject to certain prior applications ("Additional Property"). We respectfully request the rezoning of the Additional Property as Community Business District(C-C). The legal description of the Community Business District(C-C) zone including the Additional Property is incorporated herein. Revised Application Narrative Page:40 The Additional Property was not incorporated into the development agreements that Hotel-SLC had executed, however, it is the desire of the parties that it be subject to the Development Agreement and that it be zoned so as to be consistent with the other property south of Cobalt. The Additional Property is presently designated Mixed Use Residential (MUR)on the Future Land Use Map,which, as discussed above, supports a zone which would include R-15,R-40,C-C,TN-R,and TN-C. Upon the approval of the amendment of the Future Land Use Map, if required as set forth above, the Additional Property would be designated as Mixed-Use Commercial (MUC), which would support a zone of C-C, C-G, TN-C, and C-N. Moreover, this is the very situation where the underlying land use should be viewed as what is adjoining the property and aligning it with the existing collector Cobalt, as contemplated in General Guidance provision of the Comprehensive Plan. Meridian Comprehensive Plan p. 3-11. As such under either the existing Future Land Use Map or the proposed amendment thereto, a zoning designation of the Additional Property as Community Business District (C-C) is in accordance with either of the Future Land Use Map designations. The Additional Property is the extreme north eastern corner of the Property immediately south of Cobalt at its intersection with Ten Mile Road and is depicted as follows: ZONE C-C 0.02 is I sl F. N1116 C-C „ 15a14 POINT OF (C-C-) BEGINNING PROPOSED CHANGE RESULTING CC ZONE (6) Additional Zoning Modifications. Finally, to align the resulting zoning districts with the roadways and the various plat applications,several other small parcels are proposed to be rezoned, again to conform the zoning districts to the proposed roadways and infrastructure. The total acreage of these changes is less than 2 acres and are intended to better align the boundaries of the existing M-E zoned parcel with the proposed C-G zoned parcel. Those parcels are depicted as follows: (N-E) �` INT1-7 OF 'rZEN7/ � BEGINNING POINTOF (H-E) BEGINNING (H-E) (b) Relevant Standards for a Zoning Map Amendment. In evaluating each of these requests and their impact upon the zoning map, the relevant standards are set forth in Meridian City Code 11-513-3E. We will address each of these standards as follows, with the exception of the considerations regarding annexation, as the Property has previously been annexed. Revised Application Narrative Page:41 (1) The map amendment complies with the applicable provisions of the Comprehensive Plan. As discussed above, both the current Future Land Use Map and the proposed amendment thereto, support the requested zoning map amendments. The requested zoning districts are all consistent with and comport to the land use consistency matrix. (2) The map amendment complies with the regulations outlined for the proposed district,specifically the purpose statement; The purpose statements are relevant in that they identify the purpose for these zones. In this instance, with respect to the Community Business District (C-C), the Application seeks to reconfigure the existing Community Business District (C-C) to conform to existing or planned infrastructure improvements as well as to conform to the proposed preliminary plat. As for the expansion of the Traditional Neighborhood Commercial (TN-C), such reflects a use consistent with the relevant planning documents and one that encourages and permits residential density consistent with the underlying land use designation. As further noted above, the implantation of the General Retail and Service Commercial District (C-G), is necessary to address certain employment and service uses that otherwise would not be undertaken, adversely affecting the desired mix of uses within the Project. As these parcels are presently undeveloped, there is no issue or concern with creating nonconforming uses or structures as may exist when developed parcels are rezoned. Moreover, the relevant purpose statements and the relevant provisions of the Comprehensive Plan and the Ten Mile Plan are consistent with, and contemplate these uses. (3) The map amendment shall not be materially detrimental to the public health, safety, and welfare; In consideration of the impact on "public health, safety, and welfare," it is important to consider not only the existing zoning of property, but also the existing planning for an area. As discussed above, this site has been the subject of the master planning set forth in the Ten Mile Plan prior to 2007, which contemplated a degree of intensity in the development of the larger area,which has guided various other decisions made thereafter relating to the underlying public welfare and service. As further noted above, we are seeking to realign and reconfigure the zoning districts, not to fundamentally change the underlying zoning. In light of the initial evaluation of the zoning of the various parcels when the Property was annexed and made subject to the original development agreements,the proposed map amendments will not be materially detrimental to the public health, safety, and welfare. (4) The map amendment shall not result in an adverse impact upon the delivery of services by any political subdivision providing public services within the City including, but not limited to,school districts. As set forth in the preceding paragraph, the proposed rezone and zoning map amendment is in furtherance of and in accordance with the Ten Mile Plan. The realignment and reconfiguration of the zoning districts will have no material impact upon the identified public services. There is no intensification of the proposed and permitted uses beyond what was contemplated in the original adoption of the Ten Mile Plan in 2007. The prior planning was implemented through the annexation and zoning of each of the parcels Revised Application Narrative Page:42 comprising the Property. There will be no adverse impact upon the delivery of services, by this Application, as there will be no material change or increase in the underlying uses that have long been the basis for assumptions relating to this Property. 4. Application—Preliminary Plat The Applicant is also initiating a plat for the Property, recognizing that various preliminary plats for various portions of the Property have previously been submitted. This preliminary plat is proffered to incorporate the ultimate configuration of public streets,the location of utilities, and the current ownership of the various parcels. The design team has worked to ensure compliance with the plat requirements set forth in Meridian City Code Section 11-613-6. Due to the existing approved plats and the technical nature of the review of plats, we will forego a discussion of the individual standards applicable to the consideration of a plat and reserve those, if necessary, to address specific concerns articulated by Staff. The portion of the Project that is subject to this preliminary plat consists of the Black Property and the Additional Property and is outlined as follows: Pw� iL IL I i1 : � .ui.c ay.c :e. � w.a x.•,mM'�""'w�� 3 I i I C 1 31 _ I r � �w+wlP1T ICI: _ If a' 1 +i# Revised Application Narrative Page:43 The preliminary plat presented herewith has been undertaken to create additional buildable lots and to clarify the location of private access drives, to ensure that individual elements can proceed, on individual parcels, in a timely manner. It replaces prior preliminary plats and supplements the current plat that is being processed relating to H-2021-0081 as modified. Any applicant must balance the requirements of a municipality's land use regulations, with market realities, as well as future development considerations which may not even be known. Moreover, due to the present ownership of elements of the Property, its parcelization necessitates the implementation of lot lines, which coincide with the present vesting of ownership. In the future, such parcels most likely will be consolidated in the implementation of the development plan presented herein. To afford the jurisdiction with the assurance that necessary public utilities and facilities will be extended while permitting the property owner to take the first development steps necessary to address the requirements of end users,there needs to be flexibility in the platting process,which unfortunately for what is functionally a ministerial action under Idaho law, is technical and gets bogged down in administrative processes which have nothing to do with its validity. Potential users for various uses that the Applicants have identified will require timing of parcelization that may not conform with a phasing or parcel plan set forth in a development agreement. As such, it has become a reasonable practice to propose more lots in a plat that will likely be developed so that parcels may be reconfigured in the future to meet the needs of users in a manner that is timely, and does not unnecessarily involve the various governmental entities who must review and sign a plat, even before it goes through the technical rival review of the County Surveyor and Engineer prior to its recording. E. Conclusion We believe this Application satisfies the requirements of the Meridian City Code and we look forward to proceeding with this Application as expeditiously as possible. Please feel free to reach out to me or to the Applicant with any questions. This Application furthers the Ten Mile Plan by respecting its development patterns while actually proposing cohesive and enforceable development standards across the entire nearly 163 ± acres that are subject to this Application. In conclusion, yes, the Applicant did review the Plan and does feel the development proposed is consistent with the MU-Com and HIDE designation. Sincerely, i Geoffrey M. Wardle