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From: Your Name <you@example.com>
To: neighborhoodsmatter@gmail.com, shuntington@hhflaw.com
Subject: Support Neighborhoods Role in Philadelphia Zoning Reform
Your Personal Statement
Philadelphia community groups welcome development that improves our neighborhoods. The best forms of development integrate with their surroundings in a positive manner. As civic leaders, we understand the attributes of our neighborhoods and are willing to help shape proposed projects for the enhancement of the projects and the urban environment.
A development review process that supports direct and open dialogue between developers and community groups is the most assured way to achieve positive results for the project, the community and the city. We endorse the efforts of the Zoning Code Commission to improve the Zoning Code in Philadelphia and request that the following points be incorporated into the final recommendations:
1. IMPROVED PARTICIPATION OF COMMUNITY GROUPS
Communities must be heard in the development approval process and the Zoning Code should recognize their right to participate, present evidence and cross examine witnesses at the ZBA. We recognize that the variance review process would be improved if it were more standardized and predictable across all neighborhoods in the City. For example, we endorse suggestions such as the proposal on page 16 to limit conditions (or provisos) on development decisions to "those that will address or mitigate an impact of the proposed development." However, we cannot support the suggestion on page 15 to reconsider the ZBA's established practice of requiring position letters from community groups prior to rendering a variance decision. The first suggestion standardizes community input, the second suggestion disables it.
2. DESIGN REVIEW COMMITTEE
We do not oppose the establishment of a Design Review Committee. However, the relationship and coordination between the activities of the proposed Design Review Committee and neighborhood groups must be clarified. In particular, a role for neighborhoods must be specified in terms of
1. the setting of design criteria;
2. the composition of the decision making group and
3. participation by neighborhood representatives and meetings/deliberations on projects impacting those neighborhoods.
A Committee with a "set" membership cannot possess detailed knowledge of every Philadelphia neighborhood. Therefore, the Committee should include a position to be filled by a representative from the neighborhood in which a project under review by the Committee is located. At present we reserve judgment as to which projects should be subject to Design Review Committee hearings.
3. ADMINISTRATIVE VARIANCE REVIEW
We agree that the ZBA case load should not be filled with minor code variance requests (per page 21 at Section 14-204(9)) and that some of these requests can be processed administratively. However, even minor variance requests may adversely impact immediate neighbors. Consequently, sufficient public notice must be provided to the neighborhood and community input must be part of the administrative decisional process and full rights of judicial review should be maintained. We are concerned with the definition of "minor" and request that it at least be limited to a single dimensional variance.
4. MINIMIZING THE INCIDENCE OF VARIANCES
We concur with the ZCC's observation that, over the years, variances have been issued in the absence of any true hardship. Consideration should be given to mechanisms which might reduce the incidence of variances. One proposal we all agree with is that the ZBA announce the factual bases of a hardship at the time variances are granted. We look forward to working with the ZCC to address this problem.
5. ZONING CATEGORY CONSOLIDATION
We agree there are opportunities to reduce the number of zoning categories as suggested in the table on pg. 27 and 28. However, the overriding objective must be simplification of use which is not necessarily accomplished by reducing the number of categories. No zoning category should be eliminated if it makes the use of the code more subjective. For example, using "contextual" guidelines to accommodate the differences between two current zoning categories and then joining the categories into a single category, as is recommended, would, in the name of simplicity, decrease predictability contrary to the committee's primary goal a "clear zoning approval process" (see pg. 2 of report).
6. MIXED-USE CATEGORY CONSOLIDATION
The report recommends that RC districts (Residential Commercial) be consolidated into similar C (Commercial) districts because commercial districts already contain residential uses. However, there is a significant difference between the commercially dominant mixed-use C4 zone and the residentially dominant mixed use RC4 zone. These differences should be maintained and the categories should not be consolidated.
7. OVERLAY DISTRICT CONSOLIDATION
We are concerned that the reduction of the 14 Center City overlays into a single overlay would lead to more confusion. The current overlays are geographically based and the different regulations reflect the different character of each Center City neighborhood. The recommendation that the overlays be divided into component issues described on five different maps that cover the Center City area requires that applicants review five different maps where currently only one source need be consulted. Moreover, if all Center City communities were included in a single overlay, any change to the overlay would have to be monitored by each of the disparate communities within Center City, not a desirable result for either the City or the communities within Center City.
8. FORM BASED CONTROLS
The discussion of form controls in rezoning (Section 14-507, page 80-81) shows promise in mitigating impacts on neighborhoods, particularly in edge conditions between widely divergent zoning categories. We encourage its further exploration but its ultimate effectiveness will depend upon the scope and circumstances where applied.
9. NEIGHBORHOOD CONSERVATION DISTRICTS
This mechanism for protecting the character of residential neighborhoods has been incorporated into one Center City neighborhood and proposed in the neighborhood plan of another. Depending upon appropriate conditions and local initiative and consent, it should be considered for wider application.
10. EXAMINATION OF BONUS PROVISIONS
We agree with the Recommendation's recognition that the present bonus system is in need of revision and wish to work with the Commission on this topic. At present, the bonus system encourages results which cannot be easily perceived through a review of the zoning map. If the City wishes to encourage trade-offs, it should do so through the remapping process rather than relying on bonus calculations. We can envision exceptions for specific situations.
11. CITIZEN PLANNING INSTITUTE
It is incumbent upon the neighborhoods to improve the productivity and effectiveness of their input into the development process. A role of the proposed Citizens Planning Institute should be to encourage developers and neighborhoods to better understand and appreciate their respective objectives.
12. TECHNOLOGY SUGGESTIONS
The new Zoning Code should require that:
1. developers submit to L&I all rendering and elevations in digital format, which L&I shall post online upon receipt;
2. L&I to timely post on line all by-right permits, and rights to appeal to be linked to the date of online posting;
3. BA to post all transcribed transcripts online.
13. TOPICS OMITTED
In terms of general goals, the report does not enunciate one of the primary objectives of all Center City communities encouraging street level, pedestrian activity. Turning from general goals to more specific issues, we believe the following concerns should be addressed:
1. Regulations to counter blank party walls generated by new high rise buildings adjacent to low rise buildings.
2. Inappropriate density bonuses for building wall set backs
3. Creating strong requirements to ensure that when a historic building is eliminated, the development proceeds as proposed
In conclusion, we consider this the beginning of our various community groups' efforts to articulate our requests and positions regarding the reforming of the Zoning Code and the associated remapping. We look forward to providing additional guidance as the process moves forward and as our work continues. We appreciate the ability to be involved and be heard.
Your Name
Your Organization
123 Your St.
Yousville, YO 12345
Phone: (123)456-7890
Fax: (123)456-7890x123
--
Delivered by CitizenSpeak!
Report abuse to abuse@citizenspeak.org [1896]
To: neighborhoodsmatter@gmail.com, shuntington@hhflaw.com
Subject: Support Neighborhoods Role in Philadelphia Zoning Reform
Your Personal Statement
Philadelphia community groups welcome development that improves our neighborhoods. The best forms of development integrate with their surroundings in a positive manner. As civic leaders, we understand the attributes of our neighborhoods and are willing to help shape proposed projects for the enhancement of the projects and the urban environment.
A development review process that supports direct and open dialogue between developers and community groups is the most assured way to achieve positive results for the project, the community and the city. We endorse the efforts of the Zoning Code Commission to improve the Zoning Code in Philadelphia and request that the following points be incorporated into the final recommendations:
1. IMPROVED PARTICIPATION OF COMMUNITY GROUPS
Communities must be heard in the development approval process and the Zoning Code should recognize their right to participate, present evidence and cross examine witnesses at the ZBA. We recognize that the variance review process would be improved if it were more standardized and predictable across all neighborhoods in the City. For example, we endorse suggestions such as the proposal on page 16 to limit conditions (or provisos) on development decisions to "those that will address or mitigate an impact of the proposed development." However, we cannot support the suggestion on page 15 to reconsider the ZBA's established practice of requiring position letters from community groups prior to rendering a variance decision. The first suggestion standardizes community input, the second suggestion disables it.
2. DESIGN REVIEW COMMITTEE
We do not oppose the establishment of a Design Review Committee. However, the relationship and coordination between the activities of the proposed Design Review Committee and neighborhood groups must be clarified. In particular, a role for neighborhoods must be specified in terms of
1. the setting of design criteria;
2. the composition of the decision making group and
3. participation by neighborhood representatives and meetings/deliberations on projects impacting those neighborhoods.
A Committee with a "set" membership cannot possess detailed knowledge of every Philadelphia neighborhood. Therefore, the Committee should include a position to be filled by a representative from the neighborhood in which a project under review by the Committee is located. At present we reserve judgment as to which projects should be subject to Design Review Committee hearings.
3. ADMINISTRATIVE VARIANCE REVIEW
We agree that the ZBA case load should not be filled with minor code variance requests (per page 21 at Section 14-204(9)) and that some of these requests can be processed administratively. However, even minor variance requests may adversely impact immediate neighbors. Consequently, sufficient public notice must be provided to the neighborhood and community input must be part of the administrative decisional process and full rights of judicial review should be maintained. We are concerned with the definition of "minor" and request that it at least be limited to a single dimensional variance.
4. MINIMIZING THE INCIDENCE OF VARIANCES
We concur with the ZCC's observation that, over the years, variances have been issued in the absence of any true hardship. Consideration should be given to mechanisms which might reduce the incidence of variances. One proposal we all agree with is that the ZBA announce the factual bases of a hardship at the time variances are granted. We look forward to working with the ZCC to address this problem.
5. ZONING CATEGORY CONSOLIDATION
We agree there are opportunities to reduce the number of zoning categories as suggested in the table on pg. 27 and 28. However, the overriding objective must be simplification of use which is not necessarily accomplished by reducing the number of categories. No zoning category should be eliminated if it makes the use of the code more subjective. For example, using "contextual" guidelines to accommodate the differences between two current zoning categories and then joining the categories into a single category, as is recommended, would, in the name of simplicity, decrease predictability contrary to the committee's primary goal a "clear zoning approval process" (see pg. 2 of report).
6. MIXED-USE CATEGORY CONSOLIDATION
The report recommends that RC districts (Residential Commercial) be consolidated into similar C (Commercial) districts because commercial districts already contain residential uses. However, there is a significant difference between the commercially dominant mixed-use C4 zone and the residentially dominant mixed use RC4 zone. These differences should be maintained and the categories should not be consolidated.
7. OVERLAY DISTRICT CONSOLIDATION
We are concerned that the reduction of the 14 Center City overlays into a single overlay would lead to more confusion. The current overlays are geographically based and the different regulations reflect the different character of each Center City neighborhood. The recommendation that the overlays be divided into component issues described on five different maps that cover the Center City area requires that applicants review five different maps where currently only one source need be consulted. Moreover, if all Center City communities were included in a single overlay, any change to the overlay would have to be monitored by each of the disparate communities within Center City, not a desirable result for either the City or the communities within Center City.
8. FORM BASED CONTROLS
The discussion of form controls in rezoning (Section 14-507, page 80-81) shows promise in mitigating impacts on neighborhoods, particularly in edge conditions between widely divergent zoning categories. We encourage its further exploration but its ultimate effectiveness will depend upon the scope and circumstances where applied.
9. NEIGHBORHOOD CONSERVATION DISTRICTS
This mechanism for protecting the character of residential neighborhoods has been incorporated into one Center City neighborhood and proposed in the neighborhood plan of another. Depending upon appropriate conditions and local initiative and consent, it should be considered for wider application.
10. EXAMINATION OF BONUS PROVISIONS
We agree with the Recommendation's recognition that the present bonus system is in need of revision and wish to work with the Commission on this topic. At present, the bonus system encourages results which cannot be easily perceived through a review of the zoning map. If the City wishes to encourage trade-offs, it should do so through the remapping process rather than relying on bonus calculations. We can envision exceptions for specific situations.
11. CITIZEN PLANNING INSTITUTE
It is incumbent upon the neighborhoods to improve the productivity and effectiveness of their input into the development process. A role of the proposed Citizens Planning Institute should be to encourage developers and neighborhoods to better understand and appreciate their respective objectives.
12. TECHNOLOGY SUGGESTIONS
The new Zoning Code should require that:
1. developers submit to L&I all rendering and elevations in digital format, which L&I shall post online upon receipt;
2. L&I to timely post on line all by-right permits, and rights to appeal to be linked to the date of online posting;
3. BA to post all transcribed transcripts online.
13. TOPICS OMITTED
In terms of general goals, the report does not enunciate one of the primary objectives of all Center City communities encouraging street level, pedestrian activity. Turning from general goals to more specific issues, we believe the following concerns should be addressed:
1. Regulations to counter blank party walls generated by new high rise buildings adjacent to low rise buildings.
2. Inappropriate density bonuses for building wall set backs
3. Creating strong requirements to ensure that when a historic building is eliminated, the development proceeds as proposed
In conclusion, we consider this the beginning of our various community groups' efforts to articulate our requests and positions regarding the reforming of the Zoning Code and the associated remapping. We look forward to providing additional guidance as the process moves forward and as our work continues. We appreciate the ability to be involved and be heard.
Your Name
Your Organization
123 Your St.
Yousville, YO 12345
Phone: (123)456-7890
Fax: (123)456-7890x123
--
Delivered by CitizenSpeak!
Report abuse to abuse@citizenspeak.org [1896]
