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HomeMy WebLinkAbout11-26-18 Public Comment - Gallik, Bremer & Molloy, P.C. - Rainbow Creek Annexation and Zone Map Amendment OALLIK, BREMER & MOLLOY, D.C. Attorneys at Law e 777 East Main Street, Suite 203 < (` V—L LA PO Box 70 Bozeman, Montana 59771-0070 (406)404-1728 November 26, 2018 City Commission BY HAND' City of Bozeman 121 North Rouse Bozeman, Montana 59715 RE: Rainbow Creek Zone Map Aniendinent (Amended) Honorable Members of the Bozeman City Commission: This Firm represents a number of concerned residents who own and live on property adjacent to the proposed Rainbow Creek Development. They do not oppose the request for annexation. Instead, as their letter of protest makes clear, they strongly oppose the proposed R-4 zoning (which received a recommendation of approval from the Zoning Commission) which is a modest improvement over the Applicant's first request of R-5, which was denied by the Zoning Commission and tabled by the Applicant followed by this amended request for R-4zoning. As explained below, the proposed R-4 zoning remains inconsistent with the character of the existing neighborhood and surrounding land uses. The Bozeman Uniform Development Code (BUDC), adopted in part to implement the city's adopted growth policy, id. at § 38.100.040.A, supports this conclusion as none of the appropriate existing land use patterns, or existing land use characteristics, support R-4 for this property. Nor is it served by transit. See, BUDC, § 38.300.100.E at p. 139, Exhibit A ("Use of this zone [R-4] is appropriate for areas adjacent to mixed-use districts, commercial districts, and/or served by transit to accommodate a higher density of residents in close proximity to jobs and services."). Moreover, those members of the community, most impacted by this Application— the existing neighborhood -- have done an excellent job 1 The undersigned attempted to hand-deliver this letter on Friday,November 23, 2018. City offices were closed for the Thanksgiving holiday. 1 summarizing why the Application is properly rejected. I incorporate their letters by reference. Unfortunately, Staff continues its recommendation of approval, notwithstanding the plain language of the very document it is charged with applying. See, Staff Report, p. 1, y[ V We ask that the City honor the existing BUDC and listen to those most directly impacted by this Application— the current residents of the area, whose objections are ground in their reasonable expectations with respect to and reliance upon the existing land use documents governing this decision. Cf.. John Vincent, Guest Columnist (`Bozeman's neighborhoods need seat at the table"); https://www.bozemandailychronicle.com/opinions/guest_columnists/bozeman-s- neighborhoods-need-seat-at-the-table/articlede3ee 116-fdd4-5619-974b- 4f6d2de66a35; see also, htmlhttps://www.seattletimes.com/opinion/seattles- headlong-rush-to-upzone-tramples-neighborhood-input/. As explained in the referenced articles, which are attached as Exhibits B & C, it is time for the City "recognize that the real heart of Bozeman is its neighborhoods, all of them, together, historic or not," and to be "accountable to all community interests, not just a segment of developers." While the impacted residents support a lower residential density designation (R-1 or R-2) they oppose the R-4 request as it remains contrary to the BUDC. Accordingly, we respectfully denial of the R-4 designation for this parcel.' A. Background -- Rezoning and the Subject Property "Beyond a doubt, the most frequently litigated zoning issue involves the validity of rezoning decisions." Ziegler, 3 The Lavv of Zoning and Planning, (2018 ed.) § 38:1 at 38-2. "The policy considerations — and, derivatively, the legal principles —governing rezoning can be usefully conceptualized as attempts to reconcile the competing and conflicting goals of promoting, on the one hand, desired stability, and, on the other hand, desired flexibility. The Property at issue is 2.29 acres in size. It is located on Baxter Lane, a minor arterial street, between Harper Puckett Road to the west, and Flanders Mill 2 The citations in this letter are to the Staff's Report to the Zoning Commission. 3 My Clients thank the Applicant and its representative for taking the time out of their busy schedules,in the spirit of cooperation, following the Zoning Commission's initial hearing, where it recommended denial, to meet with them. Unfortunately, the gap was simply too far to bridge. 2 Road and Riata Road to the east. Consistent with the existing low residential density in the area, there is a single-family residence and a shop on the Property. The existing land use around the subject property makes clear that the zoning on the real property to the north and east is R-1 (residential low density); R-S is to the north- east (residential suburban), with PLI to the south and R-3 (residential medium density) some distance away, to the southeast. The land to the west of Harper Pucket is undeveloped, agricultural land, and thus undeveloped. See, Staff Report, Executive Summary, p. 2. None of the zoning on the adjacent properties are developed at medium density standards, but instead are primarily, if not exclusively (depending on how far out you wish to measure) residential low to moderate density). None of the properties allow for offices, let alone medical offices, clinics and community centers as secondary uses, or conditional uses, which are permitted, or conditionally permitted, in the high-density R-4 district. Moreover, R-4 is not consistent with the zoning requirement that "Use of this zone is appropriate for areas adjacent to mixed-use districts, cornmercial districts, and/or served by transit to accommodate a higher density of residents in close proximity to jobs or services." BUDC, § 38.300.100.E at p. 139 (emphasis added). In fact, as the staff report makes clear, "Large areas of single type housing are discouraged." Staff Report, p. 1.7 (emphasis added). Two (2) months ag Staff analyzed the Application and concluded R-5 was appropriate. The majority of the Zoning Commission disagreed. It recommended denial of the R-5 request. That proposal was not presented to this Commission, as it was withdrawn and resubmitted with an R-4 proposal. The Applicant now seeks R-4 zoning. Not surprisingly, the City Planner again agrees. The Zoning Commission, by a 3-0 vote, recommended approval. With the ultimate decision-making vested in this Commission, it is important to remember, when reviewing the pending Application, the Staff Report, the recommendation of the Zoning Commission, and the arguments against its approval, the standards governing that review. Montana, by virtue of the decision in Lowe v City of Missoula, 165 Mont. 38, 43, 525 P.2d 551, 554 (1974) (overrrrled on. other grounds by Greens at Font Missoula, LLC v. City of Missoula, 271 Mont. 398, 897 P.2d 1078 (1995) was considered among the jurisdictions applying the quasi-judicial treatment to rezonings. The Court stated in Lowe: There is under Montana statutes and case law a sound distinction between `zoning' and the act of `rezoning' or granting or refusing a variance. The former constitutes a legislative act while the latter is 3 more of an administrative or quasi-judicial act in applying provisions of existing ordinance and law. In such application the exercise of sound discretion is limited by the provisions of the statute, including such standards as are set forth therein. 165 Mont. at 43. On that basis, the Court held that a grant of rezoning is invalid in the absence of facts and findings showing compliance with twelve substantive standards set forth in what is now MCA § 76-2-304. The Court retreated from this position in Schanz v. City of Billings, 182 Mont. 328, 597 P.2d 67 (1979) where it stated: A review of authorities reveals no elemental distinction between the act of `zoning' and the act of `rezoning.' A rezoning ordinance, like a zoning ordinance, is a legislative enactment, and is entitled to presumptions of validity and reasonableness. . . . [W]e depart here from the distinction expressed in Lowe between the acts of zoning and rezoning." 597 P.2d at 71. The Court stated, however, that Lowe retained continued validity inasmuch as rezonings should still be reviewed for facts and findings showing compliance with the substantive standards, and has been relied upon by the Court in cases since that time, including Lake County First v. Polson City Council, 2009 MT. 322, 352 Mont. 489, 21.8 P.3d 816. In Lake Coitnty First, Wal-Mart obtained an interest in property and sought annexation into the City of Polson, along with a change in zoning. Id., 19. The Court determined that "[t]he applicable standard of review is whether the information upon which the [governing body] based its decision is so lacking in fact and foundation that is it clearly unreasonable and constitutes an abuse of discretion." Id, 133. Coupled with the foregoing, this Commission must apply the plain language of the BUDC to the Application. The BUDC is a separate, binding regulatory ordinance. Lake County First, at 9148. It cannot insert language, ignore what is plainly written or attempt, through fiat, to amend the language of the BUDC. Moreover, as the BUDC states, in "[t]heir interpretation and application, the provisions of this chapter are minimum requirements adopted for the promotion of the health, safety, and general welfare of the community.... Wherever the requirements of this chapter are at variance with the requirements of other lawfully adopted rules or regulations, or wherever there is an internal conflict within this chapter, the most restrictive requirements, or those imposing the higher standards will govern." BUDC, § 38.100.050.A (emphasis added). 4 B. -4 Remains Inconsistent with the UDC, as Adopted. The BUDC establishes individual zoning districts. BUDC, Ex. A, § 38.300, pp. 134-140. "The purpose in having more than one residential district is to provide opportunities for a variety of housing types and arrangements within the community while providing a basic level of predictability." Id., § 38.300.100. Each district, in conjunction with other standards incorporated in Article 3, establish allowable uses of property, separates incompatible uses, and sets standards for use of land." Id, § 38.300.010B (emphasis added). These standards, the BUDC explains, "[p]rovides predictability and reasonable expectation in use of land within particular zoning designations and sites." Id. This predictability benefits present and future landowners of property, including the impacted residents who oppose this Application, as their investment-backed expectations included, when they purchased their homes, the reasonable expectation that the City would follow its standards and policies, which "shall guide interpretation and application of land use regulations within zones and designations...." Id., § 38.300.020B, p. 135. The Applicant amended its request from R-5 (residential mixed-use high density) zoning, which was rejected by the Zoning Commission, to R-4, residential high density, which is now before this Commission. The BUDC explains the intent and standards applicable to adoption of R-4 zoning as follows: The intent of the R-4 residential high-density district is to provide for high-density residential development through a pattern of housing types within the city with associated service functions. The purpose is accomplished by: 1. Providing for minimum lot sizes in developed areas consistent with the established development patterns while providing greater flexibility for clustering of lots and mixing housing types in newly developed areas. 2. Providing for a variety of compatible housing types, including single and multi-household dwellings to serve the varying needs of the community's residents. 3. Allowing office use as a secondary use, measured by percentage of total building area. 5 Use of this zone is appropriate' for areas adiacent to mixed-use districts, commercial districts, and/or served by transit to accommodate a higher density of residents in close proximity to jobs and services. Id. p. 139 (emphasis added). Turning first to compliance with the City's growth policy, see pages 17-28 of Staff Report, staff again concludes (again) that simply because R-4 permits, in part, residential uses, it is consistent with the growth policy designation for this area. Id., p. 16. This is error. While staff discusses at great length, selected policies of the UDC, it ignores the fundamental policy applicable to this request (R-4): Use of this zone is appropriate for areas adjacent to mixed-use districts, commercial districts, and/or served by transit to accommodate a higher density of residents in close proximity to jobs and services. Id., § E (Emphasis added). Not a single designated district is adjacent to the property at issue, nor is it is served by transit, which the regulation requires. In response to this fundamental flaw, it is my understanding that someone at the City contacted someone at Streamline and it (Streamline) may, at some point in the future, put a bus line or stop in this area. This speculation, about some possible future event, at some unknown point in time, ignores the plain language of the applicable regulation, which requires that the area either be adjacent to mixed use or commercial districts and/or "served by transit," not "and/or [may be] served by transit." 5 "As in the case of statutes, zoning ordinances must be given their plain and obvious meaning." Ziegler, 1 The Law of Zoning and Planning, § 5:11 at 5-23. In 4 If something is not "appropriate,"it is,by definition, "inappropriate." According to Merriam-Webster,inappropriate means, "not appropriate; unsuitable." https://www.merriam- webster.com/dictionar. /y inappropriate (emphasis added). 5 This same language, requiring service by transit when determining whether use of a particular zone "is appropriate," is found in the majority of the UDC's discussion of Residential Zoning District Intent and Purpose Statements. See, BUDC, Ex. A,pp. 138-140 (R-2,R-3, R-4, R-5, &RMH) 6 Montana, it is fundamental, that this Commission, like a court interpreting a statute, must apply the plain language of the regulation, not insert what has been omitted or omit what has been inserted. MCA § 1-2-101; Supula v. Montana DOJ, 278 Mont 421, 424, 925 P.2d 480, 481 (1996) ("When a statute is "plain, unambiguous, direct and certain, the statute speaks for itself and there is nothing left for the court to construe." See also MCA § 1-2-106 ("Construction of words and phrases. [W]ords and phrases used in the statutes of Montana are construed according to the context and the approved usage of the language . . . ."). As stated, the plain, unambiguous meaning of the governing policy at issue, requires that the area in question be adjacent to mixed use or commercial districts or "served by transit." There is nothing to construe. The regulation speaks for itself. This Commission cannot insert words that are not there. Use of the R-4 zone is not, under the plain language of the regulation, appropriate for this parcel as none of the designated districts are adjacent to the subject property, and the property is not served by transit. In addition, a review of Bozeman's April 25, 2017 Transportation Master Plan makes clear that it would be improper to rely upon the speculative statements relied upon by Staff, in terms of future transit routes and stops. See, e.g, https://mdt.mt.gov/publications/docs/brochures/bozemantranplanstudy.pd § 2.3.2.3 ("Transit Facilities") at pp. 33-34, 45, 62, 73-79, 117-119. The Plan notes multiple factors that impact the location of transit services, including costs. See, id. at pp 116-119. (Transit Oriented Development"). "As the Bozeman area grows, increased support (funding) for these services will be important . . . ." Id., p. 33. Funding for Streamline competes with numerous other community demands and simply adding one (1) additional route "will cost about $258,000 per year." Id., p. 34; see also, id, § 4.1.2 at pp. 73-79; ("Recommended MSN Improvements"). Coupled with the foregoing issues, the "Residential" future land use designation in the growth policy states, in part: The dwelling unit density expected within this classification varies between 6 and 32 dwellings per net acre. A higher density may be considered in some locations and circumstances. A variety of housing types can be blended to achieve the desired density. Large areas of single type housing are discouraged. Id. at p. 17 (emphasis added). 7 There is not a single word in that definition that implies or contemplates the existence of offices or clinics in an area where residential land use is designated Thus, it cannot be said that the R-4 designation is consistent with the adopted growth policy, when the adopted growth policy, coupled with the zoning classifications applicable to this property, applies to single family residential land uses. The R-4 district also looks to consistency of lot sizes in developed areas that are consistent with the established development patterns. Id., Section E. 1. The proposal is inconsistent with the established development patterns to the north and east. Staff concedes the R-4 zoning is inconsistent with existing uses, id, p. 22, but speculates, without any evidence, that "ate future development of the property would be residential and fit with the character of the overall district, which is residential." Id., p. 22. That is wishful thinking and what community plans are intended to promote. Instead, it is arbitrary and capricious. It not only ignores the adopted growth policy, but injects substantial uncertainty in the value of adopted growth policies, and the reasonable expectation that all of us share in the ability to rely upon the governing documents for land use decisions, as "anything can happen" and potentially fit into whatever district is currently under consideration. In sum, the duly adopted BUDC, a regulatory document, applicable to this Application makes clear that within the comprehensive plan adopted by this community, certain zoning districts are "appropriate" and if not "appropriate," by definition, "inappropriate," and therefore unsuitable. The standards set forth in the BUDC for each district are minimum requirements. BUDC, § 38.100.050.A. Neither Staff or this Commission can ignore or amend on the fly the plain language of its adopted ordinance when applying the ordinance to the Application's request for R-4 zoning, which does not satisfy the adopted standard for "appropriate" use of this classification. As courts have recognized for many years, "[t]lne power to amend is not arbitrary. It cannot be exercised merely because certain individuals want it done or think it ought to be done." Kennedy v. Cite of Evanston, 181 N.E. 312, 313-314 (Ill. App. 1932). C. Character of the District. Staff also concludes that the R-4 designation is consistent with "the character of the district." Again, we respectfully submit this is a result-oriented 8 conclusion -- essentially a "cut and paste" of its prior conclusion, with no substantive analysis and a fair evaluation of the facts reject this conclusion. Staff concedes that "[w]hile the property is immediately surrounded by single-household residential development and the future . . . [and] Sports Park, "the greater area surrounding the subject property is comprised of vacant and developed parcels zoned medium and high density residential, including the developing Flanders Mill subdivision. " Id., p. 23 (emphasis added). As stated before, that statement can be said about any land use in the City of Bozeman. Without any benchmark, Staff simply alludes to the "greater area of the subject property." How large is the "larger vicinity" which can be considered? 300 feet? 1000 feet? One mule? It is undefined and because there are no standards governing the exercise of that discretion, as evidenced by Staff having to look out at least 1/2 a mile from the subject property to find vacant and developed properties to support its conclusion. In considering the character of the district, the R-4 district definition provides at the standard: "Use of this zone [R-4] is appropriate for areas adjacent to mixed-use districts, commercial districts, and/or served by transit to accommodate a higher density of residents in close proximity to jobs and services."). "Use of this zone [R-4] is appropriate for areas adjacent to mixed-use districts and/or served by transit to accommodate a higher density of residents in close proximity to jobs and services." BUDC, p. 139 (emphasis added). Neither of those standards exist in this case. Another standard that exists in the law and helps define the character of the district is MCA § 76-2-305, which governs protests from landowners impacted by the proposed zoning change. Under that statute, only owners of property within the affected area, or within 150 feet of the area affected by the proposal area are allowed to protest, which in turn triggers additional procedural protections for those impacted landowners. Under this standard, the character of the district is properly defined as R-1. In sum, the R-4 designation is inconsistent with the character of the district and Staff's analysis finds no support in the applicable governing document and its interpretation and application of the BUDC to this Application ignores the requirement that ordinance imposes minimum standards. In fact, it is inconsistent with the existing standards governing the "appropriate location" of R-4 districts and the character of the area. 9 D. Spot Zoning/Spot Planning. The Staff Report summarizes the general principals associated with spot zoning analysis and cites to a Montana case outlining the framework of analysis. Whether impermissible spot zoning has occurred presents a fact-specific inquiry that varies from one case to the next. Plains Grains, LP, v. Boarcl of County Commissioners, 2010 MT 155, 1158-66 , 357 Mont. 61, 238 P.3d 332 (discussing standards applicable to spot zoning claims). The Staff Report, however, fails to consider the basic underpinning of spot zoning claims, which applies in this case: the owner of the land in question requests that his or her land be "u zoned" to allow a higher density or more intensive use or development." Ziegler, § 41.2 at 41-3 (citing cases). In this regard, it is important to note, as discussed earlier, that while there are competing interests associated with zoning decisions, and zoning is by no means static, having adopted a comprehensive plan and a unified Ordinance implanting that plan, this Commission cannot simply ignore or amend through legislative fiat, the existing standards which were adopted after notice, opportunity to be heard, and input from the community this Commission serves, "[m]erely because certain individuals want it done or thing it ought to be done." If a general zoning ordinance is passed and persons buy property in a certain district, they have a right to rely upon the rule of law that the classification made in the general ordinance will not be changed unless the change is required for the public good . . . . The power to amend is not arbitrary. It cannot be exercised merely because certain individuals want it done or think it ought to be done. Kennedy v. City of Evanston, 1.81 N.E. 312, 313-314 (Ill. App. 1932). 1. The Proposed Use is Significantly Different From The Prevailing Uses of Land in the Ai-ea. Closely related to actual conformance with a comprehensive plan is the issue of compatibility of the newly zoned parcel with surrounding uses. Compatibility is important not only because it enhances rational planning, but because of the detrimental effect an incompatible use may have on neighbors. Ziegler, § 41:8. "An amendment which reclassifies a small parcel to allow a use which is inconsistent with its neighborhood is likely to be overturned." Id. at 41-33-34 (citing cases). The BUDC recognizes this principle. 10 Staff concedes that the prevailing land uses immediately to the north and east of the subject property are residential, low density. To the south is land designated as PLI, which will be a sports field or park. To reach the types of residential density requested by the R-4 zoning, Staff was forced to look one-half a mile away, where it found R-3 and R-4 zoning. In addition to significantly higher density, another important difference from the prevailing land uses "in the area," is that the R-4 zoning, while primarily residential, allows uses described as "associated service functions" (i.e., "allowing office use as a secondary use"). BUDC, at p. 139. This combination of uses is not presently in existence in the adjacent, low density neighborhoods, which are strictly residential. 2. Size and Ntcfnbef• of Rezoned Parcels. "The size of the rezoned parcel is a significant factor in nearly all spot zoning cases. The reclassification of a small area of land bounded by property burdened with greater restrictions is not likely to advance the purposes of a comprehensive plan." Ziegler, § 41:6 at 41-30; Plains Grains, 163. Staff does not directly address this issue, stating primarily that the area around the property is surrounded by the city on three (3) sides by the City, "but the entire area is proposed for the same district designation." That may be true, but it is substantially different from the land designations around it. The facts are that we have one (1) parcel of property, 2.3 acres in size. The land to the north, south and east of this single, small parcel, is burdened by substantially greater restrictions than the Applicant seeks with this parcel. To the south is a park, with no development allowed. To the north we have residential development at low densities, and no office development within at least one-half mile of the subject property. 3. The Change Is In The Nature of Special Legislation Designed To Benefit One Landowner at the Expense of the Surrounding Landowners. "The number of landowners affected by the proposed rezone must be analyzed in concert with the third factor—whether the proposed zone change constitutes `special legislation." Plains Grains, 9164. "The number of landowners 11 affected relates directly to whether the zoning constitutes special legislation designed to benefit one person. This inquiry should focus on the benefits of the proposed rezone to surrounding landowners, not the benefits — financial or otherwise- that would accrue from the proposed development." Id,( emphasis added). Staff again couched its discussion in the context of the need for additional housing in the community. While such a need exists, that is not the proper focus of the analysis. Plains Gr•ains, 164. Instead, the analysis must focus on the benefits of the proposed rezone to surrounding landowners, not the benefits, financial or otherwise, what would accrue from the proposed development." M. (emphasis added). Viewed in its proper light—impact on the surrounding landowners -- because of the high density, coupled with potential use of a portion of the area for offices, which is not otherwise allowed in the immediate area, the Applicant is the primary beneficiary of the zone map change. There is no discernible benefit to that accrues to the neighbors with R-4 zoning. CONCLUSION. The attached articles, from former Mayor Vincent and the Seattle Times, make clear that issues associated with upzoning, affordability, livability and equity in land use decisions are challenging. Hopefully we can learn from other communities facing similar issues. To that end, it appears that a common fatality in community efforts to balance these interests is to minimize, or disregard, existing land policy documents or interpret them in such a way as to minimize existing neighborhoods, and how the residents of those neighborhoods most impacted by land use decisions, interpret the same policies. The community interests most impacted by this Application — the existing neighborhood -- understand the challenges facing the City, including affordability and livability. With all due respect to Staff and the Zoning Commission, the R-4 designation if approved, disregards the existing plan and ordinance adopted to implement the plan and misapplies the spot zoning analysis. Such as result is arbitrary and capricious and weakens the required predictability associated with planning. The neighborhood simply asks that the City, like the authors of the attached article asked the leaders of that community, to "[b]e accountable to all community interests, not just a segment of developers." M. That can only be accomplished by 12 following the existing land use policies. Applying the plain language of the applicable policies compels a decision rejecting the R-4 request. RESPECTFULLY SUBMITTED this 26th day of November, 2018. GALLI REMER & MOLLOY, P.C. Brian K. Gallik Attachments A, B and C C: Client Planning Office & City Attorney Madison Engineering 13 ARTICLE 3. ZONING DISTRICTS & LAND USES Contents: 38.300 Zones, Maps & Designations 38.310 Permitted Uses 38.320 Form & intensity standards 38.330 Zone specific provisions 38.340 Overlay district provisions 38.350 General land use standards & requirements 38.360 Index of supplemental use criteria 38.370 Wireless facilities 38.380 Affordable housing 38.300 Zones, Maps & Designations FOOTNOTE(S): --- (6) --- State Law reference— Municipal zoning, MCA 76-2-301 et seq. Part I: Zoning Districts & Zoning Map 1:71 Sec. 38.300.010. - Purpose. Individual zoning districts are adopted for the purposes described in section 38.100.040. Furthermore: A. A variety of districts is established to provide locations for the many uses needed within a healthy and dynamic community. B. Each district, in conjunction with other standards incorporated in this chapter, establishes allowable uses of property, separates incompatible uses, and sets certain standards for use of land. C. This provides predictability and reasonable expectation in use of land within particular zoning designations and sites. D. The zoning provisions implement the community goals and objectives that are contained in the city's adopted growth policy. E. Zoning districts and the zoning map communicate the City's expectation for land use in each particular district. Sec. 38.300.020. - Use districts designated, zoning map adopted. A. The city is divided into zones, or districts, as shown on the official zoning map which, together with all explanatory matter thereon, is adopted by this reference and declared to be a part of this chapter. BOZEMAN UDC RE-ORGANIZATION - FINAL 134 March 9,2018 UDC update 3-31-2018 B. The purpose statements for each zone and map designation set forth in part 2 of this division shall be used to guide the application of the zones and designations to all lands in the city. The purpose statements also shall guide interpretation and application of land use regulations within the zones and designations, and any changes to the range of permitted uses within each zone through amendments to this title. For the purpose of this chapter, the city is divided and classified into the following use districts: R-S Residential Suburban District R-1 Residential Single-Household Low Density District R-2 Residential Two-Household Medium Density District R-3 !Residential Medium Density District R-4 Residential High Density District R-S Residential Mixed-Use High Density District R-O Residential-Office District RMH Residential Manufactured Home Community District B-1 Neighborhood Business District B-2 Community Business District B-2M Community Business District- Mixed B-3 Downtown Business District UMU Urban Mixed-Use District M-1 Light Manufacturing District M-2 Manufacturing and Industrial District B-P Business Park District PLI Public Lands and Institutions District NEHMU Northeast Historic Mixed-Use District NC Neighborhood Conservation Overlay District CO Casino Overlay District REMU Residential Emphasis Mixed-use District C. Placement of any given zoning district on an area depicted on the zoning map indicates a judgment on the part of the city that the range of uses allowed within that district are generally acceptable in that location. It is not a guarantee of approval for any given use prior to the completion of the appropriate review procedure and compliance with all of the applicable requirements and development standards of this chapter and other applicable policies, laws and ordinances. It is also BOZEMAN UDC RE-ORGANIZATION - FINAL 135 March 9,2018 UDC update 3-31-2018 not a guarantee of immediate infrastructure availability or a commitment on the part of the city to bear the cost of extending services. Sec. 38.300.030. - Official map availability, certification and authority; changes. (38.07.020) A. The official maps must be available in the community development department and must bear a certificate with the signature of the mayor attested by the city clerk and the date of adoption of the ordinance codified in this chapter. B. This certificate should read as follows: This is to certify that this is an Official Zoning Map referred to in section of Ordinance No. of the City of Bozeman, Montana. Mayor Attested Date of Adoption C. Regardless of the existence of purported copies of the official zoning maps, which may from time to time be made or published, the official zoning maps kept in the community development department must be the final authority as to the current zoning status of!and and water areas,buildings and other structures in the city. Sec. 38.300.040. - Official map replacement conditions. (38.07.030) A. In the event that the official zoning maps become damaged, destroyed, lost or difficult to interpret because of the nature or number of changes or additions thereto, the city commission may adopt and certify new official zoning maps which must supersede the prior official zoning maps. The new official zoning maps may correct drafting or other errors or omissions in the prior map, but no such corrections shall have the effect of amending the original official zoning maps or any subsequent amendment thereof. B. If any changes to the map are made by amendment of this chapter in accordance with division 38.260 of this chapter, such changes must be made to the official zoning maps and signed, dated and certified upon the map or upon the material attached thereto. Interpretations per 38.300.050 and revisions to the map to accommodate annexations and other changes necessitating interpretation must be reflected. C. The new official zoning maps must be identified by signature of the mayor attested by the city clerk. The certificate should read as follows: This is to certify that this Official Zoning Map supersedes and replaces the Official Zoning Map adopted as part of Ordinance No. of the City of Bozeman, Montana. Mayor._ Attested Date of Adoption Sec. 38.300.050. - Boundary interpretation guidelines. (38.07.040) A. Where uncertainty exists as to the boundaries of districts as shown on the official zoning map, the boundaries must be interpreted as following the nearest logical line to that shown: 1. Boundaries indicated as approximately following the centerline of streets, highways or alleys must be construed to follow such centerlines; BOZEMAN UDC RE-ORGANIZATION - FINAL 136 March 9, 2018 UDC update 3-31-2018 2. Boundaries indicated as approximately following platted lot lines must be construed as following such lot lines; 3. Boundaries indicated as approximately following city limits must be construed as following such city limits; 4. Boundaries indicated as following railroad lines must be construed to be midway between the main track or rails; S. Boundaries indicated as following the centerline of streams, rivers, canals or ditches must be construed to follow such centerlines; and 6. Boundaries indicated as parallel to or extensions of features indicated on the official zoning map must be determined by the scale of the map. 7. When a parcel subject to two or more districts is subdivided and the district boundary is near a new parcel boundary the district must be construed to follow the new boundary. B. Where physical or cultural features existing on the ground are at variance with those shown on the official zoning map, or where other circumstances or controversy arise over district boundaries, the community development director must interpret the district boundary. Such interpretation is subject to appeal as set forth in division 38.250 in this chapter. C. Where district boundaries divide a lot or parcel into two or more districts, the following rule applies: For the purpose of determining permitted uses and development form and intensity, the community development director may allow minor adjustments (up to 10 percent increase or decrease in area, not to exceed one acre, of either zone on the applicable lot) to the zoning boundary. The criteria for making such a determination must include an evaluation of site topography, proximity of non- compatible uses adjacent to the subject property, and overall function and integration of the development with the community. Sec. 38.300.060. - Zoning of annexed territory. (38.07.060) A. All territory which may hereafter be annexed to the city must, in conjunction with the annexation, be the subject of a zone map amendment in order to be designated and assigned to a city zoning district. B. Areas of annexed public right-of-way must be considered to be zoned according to the provisions of section 38.300.040.A. The city commission must determine the appropriate zoning for any and all areas to be annexed to the city but must request a recommendation from the zoning commission and must take into consideration the city growth policy. Any ordinance adopting such zoning amendment must not take effect prior to the effective date of such annexation. BOZEMAN UDC RE-ORGANIZATION - FINAL 137 March 9,2018 UDC update 3-31-2018 2. Boundaries indicated as approximately following platted lot lines must be construed as following such lot lines; 3. Boundaries indicated as approximately following city limits must be construed as following such city limits; 4. Boundaries indicated as following railroad lines must be construed to be midway between the main track or rails; 5. Boundaries indicated as following the centerline of streams, rivers, canals or ditches must be construed to follow such centerlines; and 6. Boundaries indicated as parallel to or extensions of features indicated on the official zoning map must be determined by the scale of the map. 7. When a parcel subject to two or more districts is subdivided and the district boundary is near a new parcel boundary the district must be construed to follow the new boundary. B. Where physical or cultural features existing on the ground are at variance with those shown on the official zoning map, or where other circumstances or controversy arise over district boundaries, the community development director must interpret the district boundary. Such interpretation is subject to appeal as set forth in division 38.250 in this chapter. C. Where district boundaries divide a lot or parcel into two or more districts, the following rule applies: For the purpose of determining permitted uses and development form and intensity, the community development director may allow minor adjustments (up to 10 percent increase or decrease in area, not to exceed one acre, of either zone on the applicable lot) to the zoning boundary. The criteria for making such a determination must include an evaluation of site topography, proximity of non- compatible uses adjacent to the subject property, and overall function and integration of the development with the community. Sec. 38.300.060. - Zoning of annexed territory. (38.07.060) A. All territory which may hereafter be annexed to the city must, in conjunction with the annexation, be the subject of a zone map amendment in order to be designated and assigned to a city zoning district. B. Areas of annexed public right-of-way must be considered to be zoned according to the provisions of section 38.300.040.A. The city commission must determine the appropriate zoning for any and all areas to be annexed to the city but must request a recommendation from the zoning commission and must take into consideration the city growth policy. Any ordinance adopting such zoning amendment must not take effect prior to the effective date of such annexation. BOZEMAN UDC RE-ORGANIZATION - FINAL 137 March 9,2018 UDC update 3-31-2018 Part 2: Zoning District Intent & Purpose Statements Sec. 38.300.100. — Residential zoning districts - intent and purpose. P8.08.010) The intent and purpose of the residential zoning districts is to establish areas within the city that are primarily residential in character and to set forth certain minimum standards for development within those areas. The residential districts also allow complementary non-residential uses. The purpose in having more than one residential district is to provide opportunities for a variety of housing types and arrangements within the community while providing a basic level of predictability. There is a presumption that the uses set forth for each district will be compatible with each other when the standards of this chapter are met and any applicable conditions of approval have been satisfied. The presumption of compatibility may be overcome by a showing of specific evidence through the development review process that proves a development to be non-compliant with applicable standards. Additional requirements for development apply within overlay districts. All development is subject to section 38.100.050. Residential density is correlated with many community goals and objectives that are contained in the city's adopted growth policy, as well as many standards and purposes of this chapter. Table 38.320.020 sets standards for minimum densities in residential districts which will advance these goals, objectives, and purposes. A. Residential suburban district (R-S). The intent and purpose of the R-S residential suburban district is to commemorate and preserve existing RS zoning only. These purposes are accomplished by: 1. Subdivision and site plan developments in this district are subject to the provisions of division 38.430 of this chapter, pertaining to planned unit development, and shall be developed in compliance with the adopted city growth policy. 2. Allowing permitted uses in circumstances where environmental constraints limit the desirable density. 3. Providing for a minimum lot size in developed areas consistent with the established development patterns while providing greater flexibility for clustering lots and housing types in newly developed areas. 4. This district is not available for newly created subdivisions, undeveloped land, or any land annexed into the city on or after January I, 2018. B. Residential low density district (R-11). The intent of the R-I residential low density district is to provide for primarily single-household residential development and related uses within the city at urban densities. These purposes are accomplished by: 1. Providing for a minimum lot size in developed areas consistent with the established development patterns while providing greater flexibility for clustering lots and housing types in newly developed areas. 2. Providing for such community facilities and services as will serve the area's residents while respecting the residential character and quality of the area. C. Residential moderate density district (R-2). The intent of the R-2 residential moderate density district is to provide for one- and two-household residential development at urban densities within the city in areas that present few or no development constraints. These purposes are accomplished by: BOZEMAN UDC RE-ORGANIZATION - FINAL 138 March 9,2018 UDC update 3-31-2018 . Providing for minimum lot sizes in developed areas consistent with the established development patterns while providing greater flexibility for clustering lots and housing types in newly developed areas. 2. Providing for community facilities to serve such development while respecting the residential quality and nature of the area. Use of this zone is appropriate for areas with moderate access to parks, community services and/or transit. D. Residential medium density district (R-3). The intent of the R-3 residential medium density district is to provide for the development of one- to five-household residential structures near service facilities within the city. This purpose is accomplished by: 1. Providing for minimum lot sizes in developed areas consistent with the established development patterns while providing greater flexibility for clustering lots and mixing housing types in newly developed areas. 2. Providing for a variety of housing types, including single household dwellings, two to four household dwellings, and townhouses to serve the varied needs of households of different size, aaae and character, while rerducinaa the adverse effect of nonresidential iicec. Use of this zone is appropriate for areas with good access to parks, community services and/or transit. E. Residential high density district (R-4). The intent of the R-4 residential high density district is to provide for high-density residential development through a variety of housing types within the city with associated service functions. This purpose is accomplished by: I. Providing for minimum lot sizes in developed areas consistent with the established development patterns while providing greater flexibility for clustering lots and mixing housing types in newly developed areas. 2. Providing for a variety of compatible housing types, including single and multi-household dwellings to serve the varying needs of the community's residents. 3. Allowing office use as a secondary use, measured by percentage of total building area. Use of this zone is appropriate for areas adjacent to mixed-use districts, commercial districts, and/or served by transit to accommodate a higher density of residents in close proximity to jobs and services. F. Residential mixed-use high density district (R-5). The intent of the R-5 residential mixed-use high density district is to provide for high-density residential development through a variety of compatible housing types and residentially supportive commercial uses in a geographically compact, walkable area to serve the varying needs of the community's residents. These purposes are accomplished by: 1. Providing for a mixture of housing types, including single and multi-household dwellings to serve the varying needs of the community's residents. 2. Allowing offices and small scale retail and restaurants as secondary uses provided special standards are met. Use of this zone is appropriate for areas adjacent to mixed-use districts and/or served by transit to accommodate a higher density of residents in close proximity to jobs and services. BOZEMAN UDC RE-ORGANIZATION - FINAL 139 March 9, 2018 UDC update 3-31-2018 G. Residential-office district (R-O). The intent of the R-O residential-office district is to provide for and encourage the development of multi-household and apartment development and compatible professional offices and businesses that would blend well with adjacent land uses. These purposes are accomplished by: 1. Providing for a mixture of housing types, including single and multi-household dwellings to serve the varying needs of the community's residents. Use of this zone is appropriate for areas characterized by office or multi-household development; and/or areas along arterial corridors or transitional areas between residential neighborhoods and commercial areas. H. Residential manufactured home community district (RMH). The intent of the RMH residential manufactured home community district is to provide for manufactured home community development and directly related complementary uses at a density and character compatible with adjacent development. Use of this zone is appropriate for existing mobile home parks and areas adjacent to commercial or mixed-use districts and/or served by transit. Sec. 38.300.1 10. - Commercial and mixed-use zoning districts - intent and purpose. (38.10.010) The intent and purposes of the commercial zoning districts are to establish areas within the city that are primarily commercial in character and to set forth certain minimum standards for development within those areas. The purpose in having more than one commercial district is to provide opportunities for a variety of employment and community service opportunities within the community, while providing predictability. There is a rebuttable presumption that the uses set forth for each district will be compatible with each other both within the individual districts and to adjoining zoning districts when the standards of this chapter are met and any applicable conditions of approval have been satisfied. Additional requirements for development apply within overlay districts. A. Neighborhood business district (13-1). The intent of the B-1 neighborhood business district is to provide for smaller scale retail and service activities frequently required by neighborhood residents on a day to day basis, as well as residential development as a secondary purpose, while still maintaining compatibility with adjacent residential land uses. Design standards emphasizing pedestrian oriented design are important elements of this district. Use of this zone is appropriate for areas functioning as a center for surrounding residential neighborhoods. B. Community business district (13-2). The intent of the B-2 community business district is to provide for a broad range of mutually supportive retail and service functions located in clustered areas bordered on one or more sides by limited access arterial streets. Multi-household dwellings, townhouses, and apartments are allowed as a secondary use due to their complementary nature and ability to enhance the walkability of these districts. Design standards emphasizing pedestrian oriented design are important elements of this district. Use of this zone is appropriate for arterial corridors, commercial nodes, and/or areas served by transit. BOZEMAN UDC RE-ORGANIZATION - FINAL 140 March 9, 2018 UDC update 3-31-2018 elderly,and children who donated to the rallies.It is pretty clear that she detests Welcome Kit drive to provide refugee President Trump. Bozeman Bozemans neighborhoods need seat at the table Bozema A 27 year-old is your neighborhood.Yes, ordinance but should include eliminated.Residents would Neighborhood Conservation Main Street is a special place, zoning map amendments, no longer have to check at Overlay District(NCOD)is neighborhood,and impor- conditional use permits,mas- the city planning department getting a lot of attention as it tant economic driver.Still, ter plan changes,subdivision to find out what was going goes through a Ion&overdue its just one of our neighbor- or site plan reviews and any on.Instead,they would be update.Bozemads historic hoods.All our neighbor- major alterations or additions actively and fully engaged neighborhoods and build- hoods need protection and to existing buildings totaling from the get go through their ings do need more and better good planning.All need and 10,000 square feet or more. neighborhood associations. protection.But as Kelly Pohl deserve a seat at the table and 6.The developer would Still,all existing city noti- correctly notes in her Nov a real say in their future. be required to provide a fication requirements could 11 Chronicle letter to the So,how to do that?Pass map,visual description,site remain in place and the city editor("City needs balanced a Neighborhood Empower- plan,intended use(s),sizes, could move ahead on the approach with growth")".... ment and Conservation heights,density,elevations, neighborhood notification/ not all buildings or neighbor- Ordinance,(NECO).Here's impacts and any proposed alert system its considering. hoods.....are historic." what one could look mitigation of im- Nothing wrong with either. So,what to do about that? like: pacts at the required But what neighborhoods First,as a former Boze- 1.Through j_ public meeting. really need area t notifica- man citycommissioner and resident input and 7.Public com- ments,questions tions and alerts.They need a ayor,I believe current facilitation as- q legally guaranteed seat at the efforts to plan and accom- sistance from the r and discussion g y modate Bozeman's growth, city,neighborhood would follow the table and a real say in their however well intentioned, boundaries-would applicant's presenta- future. Ern- will fall short of protecting be established to tion. The Neighborhood Em- e aracter inte rity,and include all Bozeman 8.The proposal powerment Conservation va ' of both eaustin and neighborhoods. )ONN ViNCENT would then go to Ordinance can work and eve o m net h orho Os. 2.Each neighbor- the city planning could actually help improve is is not to question hood would form Guest columnist department,along and expedite projects because those efforts,whether it's the an association and with an association neighbors and developers NCOD polling and update, receive funding from the report with public and devel- would have the opportu- 1 the city's'A Seat at the Table" city for qualified and verified oper comments,suggestions nity to work through their outreach initiative and several meeting expenses and public and recommendations fully concerns,questions and others.But it is to say they notices.No paid positions or noted. differences,as well as con- will not,in my opinion, travel. 9.The city planning de- sider ideas for improvements, individually or collectively, 3.All association meeting- partment would then review before project plans reached go far enough to assure that swould be publicly noticed the application and forward the city planning department Bozeman's nei on and conducted under Mon- its findings and recommen- and commission. are o a e uatel _protected tangs open meetings laws. dations to the city commis- I encourage the city com- an ,lus as important,have a' 4.Developers proposing a Sion,along with the associa- mission to take a good hard s re say m w at happens both_ project within or immediately tions report. look at creating a NECO and in and miinedia-te y adjacent adjacent to an neighborhood 10.The city commission I urge residents who think of—tfiiem, association boundary would then notices and holds a it's a good idea to encourage is-there is a way to do be required to mail notice to public hearing and makes a that.But first we have to put property owners within 500 final decision. them to do so. aside the mindset that Main feet of the project and then The bottom line?While the (Important legal distinc- ta- Street,downtown Bozeman, present their proposal in a city commission would retain tion;Neighborhood meetiassocngs, e is the"heart of Bozemad'and noticed public meeting to the its full authority to accept, tions would hold meetings, recognize that the real heart association,before submitting 'deny or conditionally approve not hearings.) of Bozeman is it's neighbor- their application to the city a developer's neighborhood hoods,all of them,together, planning department. project,the oft heard com- John Vincent is a former historic or not.Home is 5.Qualifying projects plaint that public notice was Bozeman city commissioner where the heart is and home would be stipulated in the inadequate would virtually be and mayor. EXHIBIT 11/23/2018 Seattle's rush to upzone tramples neighborhood input I The Seattle Times Cyber Sale! Save go% on a digital subscription for 12 weeks. Subscribe now ,P Search fa.. Seattle's rush to upzone tramples jtieighborhood input f >� Originally published September 11,M8 at 2:22 pm Updoted September 11,2018 nt 3.59 pm .. '� fhiA 7 6, r- e t IQ -41 i An older single-family home between newer, multi-family homes in Seattle (AP Photo /Elaine T'ho 2017) EXHIBIT a C https://www.seattletimes.com/opinion/seattles-headlonq-rush-to-UDzone-tramples-neiahborhood-input/ ,�a 11/23/2018 Seattle's rush to upzone tramples neighborhood input I The Seattle Times In its "grand bargain" to accommodate big developers, the city ignores its obligation to serve the current residents of Seattle who have paid and continue to pay taxes to build and maintain our communities. By I )avid Ward and Maria Batayola Special to The Times We appreciate The Seattle Times' ongoing coverage of Seattle's Mandatory Housing Affordability program. As leaders of the administrative appeal challenging the adequacy of the program's environmental impact statement, we feel it's our civic duty to tell more of the story about the "grand bargain" between the city and big developers and how it impacts the city's decision making. In short, the Mandatory Housing https://wnwwi.seatUetimes.com/opinion/seattles-headlong-rush-to-upzone-tramples-neighborhood-input/ 2/8 11/23/2018 . Seattle's rush to upzone tramples neighborhood input I The Seattle Times Affordability program does not deliver on the city's own stated values of housing affordability, livability and equity. Affordability The MHA program will displace poor and low-income people it is intended to help. Increasing the zoned density inside and outside the urban villages in low, medium, and high-income neighborhoods will drive up land costs, resulting in higher housing and rental costs, and higher property taxes. Many Seattle residents will no longer be able to stay in their affordable homes. Half of the tax returns filed in Seattle are for incomes under $50,000 a year, and many seniors who own their Homes are on fixed incomes. More importantly, the MHA goal to build 6,000 low-income housing units is inadequate, when 6o,000 low-income units are necessary to address the need. The new construction that the MHA upzones will encourage often destroy naturally affordable older buildings, both rental and owned. There are now half as many units available for families of three making under $45,00o as there were in 2012, according to a McKinsey report. Most Read Opinion Stories Trump's excuses for Saudi Arabia are reprehensible I Editorial Save American families: Ban the toxic pesticide chlorpyrifos I OP-Ed Senate should drop investigation into rape allegation against Joe Fain I Editorial Why I fly the flag upside down I My Take Ivanka Trump's email scandal has a familiar moral I Timothy L. O'Brien / Syndicated columnist https://www.seattletimes.com/opinion/seattles-headlong-rush-to-upzone-tramples-neighborhood-inpuU 3/8 11/23/2018 Seattle's rush to upzone tramples neighborhood input I The Seattle Times Also, under MHA, developers are more likely to take the option to pay in-lieu fees rather than build affordable housing on-site. Failure to include truly `Sinclusionary" housing — in new buildings — will accelerate Seattle's economic and racial re-segregation. Solution: The city should adopt policies recommended in the Sohitions to Seattle's Housing Erner,aency repot � to invest more money directly in affordable housing. The city has considerable bonding capacity. Livability Seattle is one of the nation's most livable cities because of its neighborhoods. MHA proposes to upzone broad areas of the city (allowing greater building Height and bulk) without regard to adopted community neighborhood plans. These plans were developed by the city in close cooperation with neighborhood residents, businesses and landowners. They are part of the city's A Plan for Managing Growth 2015 -2035 Seattle Comprehensive Plan. The neighborhood plans establish a community's sense of identity, desired development, character, gathering places, open and green spaces. Such livability components are critical for the physical, social and mental well-being of its residents, particularly children and elders, Solution: Rather than disregard the neighborhood plans, the city should follow them, or update there if desired by neighborhoods. The previous neighborhood planning process made Seattle internationally famous because the city supported residents in guiding changes that directly impacted their lives. The city should again be accountable to all community interests, not just a segment of developers. Equity AD''ERl l S l" https://www.seattletimes-com/opinion/seattles-headlong-rush-to-upzone-tramples-neighborhood-input/ 4/8 11/23/2018 Seattle's rush to upzone tramples neigF}hhborhood inputfJI The Seattle Times it A. - - City policies require that city actions be accountable to race and social-justice issues. The city acknowledged that MHA should be subjected to a race and social-justice review, and appointed an interdepartmental team to conduct a review of the MHA EIS. The reviews by the city departments found that the racial-equity analysis in the EIS was "not considered," "was incomplete" and "was inadequate." The final EIS did not include or directly respond to the reviews by the race and social-justice interdepartmental team. Solution: To address the significant disparate impact problems raised by the race and social-justice review, the city should create an authentic partnership with people of color and affordable and low-income housing advocates, planners and developers. Our Seattle Coalition for Affordability, Livability and Equity (SCALE) represents 29 neighborhoods and organizations that are appealing the EIS. In addition to the above issues, the appeal cites significant errors and omissions in the EIS in terms of the impact to the tree canopy, transportation, parks and open space, infrastructure, historic assets and other considerations. The claimed effectiveness of proposed mitigation measures in the EIS are often inconsistent with the city's own information. In its "grand bargain" to accommodate big developers, the city ignores its obligation to serve the current residents of Seattle who have paid and continue to pay taxes to build and maintain our communities. Besides this injustice, it is maddening to have to pay costly legal fees to get the attention of our elected leaders to redirect these bad housing and land-use policies. In a July column, Seattle Times editorial columnist Brier Dudley wrote, "Seattle should get a better deal from big developers before sticking it to neighborhoods." ["Seattle's affordable-housing bargain will be `grand' when developers foot the bill."] We agree: No one should be sticking anything to anybody. Seattle's grand-bargain- driven Mandatory Housing Affordability program is a bad deal. Let's work together to create good housing and land-use policies that work for all. https://www.seattletimes.com/opinion/seattles-headlong-rush-to-upzone-tramples-neighborhood-input/ rip 11/23/2018 Seattle's rush to upzone tramples neighborhood input I The Seattle Times David Ward is president of Seattle Coalition for Affordability, Livability and Equity (SCALE), which represents 29 neighborhoods and organizations. Maria Batayola is vice president of Seattle Coalition for Affordability, Livability and Equity (SCALE), which represents 29 neighborhoods and organizations. LiJ View 238 Commei its i Recommended in Y � Michelle Obama's Boeing 757's crash- Salmonella Inmate's last words; mother, Marian landing in Guyana contamination in `Is it supposed to Robinson, gave... injures 6... turkey is feel like that?' widespread... Around the Web hfcps://w ww.seattletimes-com/opinion/seattles-headlong-rush-to-upzone-tramples-neighborhood-input/ 6/8