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HomeMy WebLinkAbout09-16-19 Public Comment - Gallik, Bremer & Molloy, P.C. - Medical Arts Parking Lot Zone Map Amendment GALLIK, BREMER & MOLLOY, P.C. ORIGINAL Attorneys at Law 777 East Main Street, Suite 203 PO Box 70 Bozeman, Montana 59771-0070 (406) 404-1728 September 16, 2019 City Commission BY HAND City of Bozeman 121 North Rouse Bozeman, Montana 59715 RE: Proposed Zone Map Ainendinent, Medical Arts Parking Lot. Honorable Members of the Bozeman City Commission: "Beyond a doubt, the most frequently litigated zoning issue involves the validity of rezoning decisions." "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. Ziegler, 3 The Law of Zoning and Planning, (2018 ed.) § 38: 1 at 38-2. I submit this letter on behalf of myself, and other landowners who live near and rightfully oppose the Medical Arts parking lot zone change application from R-4 to B-3. I join them in respectfully requesting that the City "recognize that the real heart of Bozeman is its neighborhoods, all of them, together, historic or not," and that you be "accountable to all community interests, not just a segment of developers." Otherwise, as I predicted during a public comment period before this Commission two (2) years ago, the existing neighborhoods impacted by the "incremental" (staff's word, not mine) extension of B-3 zoning into our neighborhoods, both north and south of Main Street, coupled with relaxation of standards applicable to "neighborhood conservation overlay districts," will continue to suffer "death by a thousand cuts," allowing in turn the further expansion of B-3 deeper into our downtown neighborhoods. 1 I live at 316 North Third Avenue, where I already see the squeeze of intensification of development (and corresponding densities) spreading from Downtown and now Midtown into our neighborhoods. Several of my neighbors have recently picked up stakes and fled to other areas, where they can find again, and at substantially less tax rates, a residential neighborhood similar to what they called once called "home" -- where they raised families for decades, while being able to walk to neighborhood schools, walk downtown, park in front of their homes, and enjoy relative peace and quiet. Other neighbors are likewise considering leaving their homes for these same reasons. Having read the Application, the Staff Report's recommendation of approval, viewed the Zoning Commission meeting and comments I realistically hold no expectation that the result of tonight's meeting, with or without a super majority, will be anything but an "affirmance" of the Developer's application. Accordingly, I offer these comments for purposes of preserving the record upon appeal to the District Court. To this end, I incorporate by reference all public comment submitted in opposition to and in favor of the Application, as well as the proceedings before the Zoning Commission. 1. The Application Seeks to Upzone the Property To a Use More Profitable to the Landowner at the Expense of the Neighborhood And Without the "Careful Study and Strategic Relocation of the -3 Boundary Line" Required by the Recently Adopted Downtown Bozeman Improvement Plan. The application before you seeks to change the zoning on a portion of the Medical Arts Parking Lot from R-4 (Residential High Density District) to B-3 (Downtown Business District). This request is properly characterized as "upzoning," i.e., "rezoning or reclassification to a more intensive use category — usually one that is more profitable to the landowner." 3 Ziegler, The Law of Zoning and Planning, § 3 8:11 at 38-10. As Ziegler explains, "[i]n the nature of things, upzonings nearly always occur on only a piecemeal basis and in response to a request by the zoned property owner to be reclassified." Id., p. 38-1. He continues, The desire of nearby property owners to maintain neighborhood lands in lower-intensity use and the desire of local government officials to get reelected virtually guarantee, as a matter of politics, that a local governing body will rarely upzone land on a comprehensive basis. 2 Rather the tendency will be to upzone land only on the specific request of a property owners seeking rezoning and, then, only if the upzoning is not met by too much neighborhood resistance or is thought necessary to defeat a potential claim of confiscatory zoning by a property owner. Id., p. 38-11, n. 1. The parcel of the land at issue is 0.7 acres in size. Staff Report at p. 19 [423]. "The [requested] change is an incremental expansion of the entire B-3 district and is physically contiguous to the B-3 district." Id. at 9[2 (emphasis added). While the City's future land use map, for the subject property, designates this as "Community Core" the City's recently adopted Downtown Bozeman Improvement Plan (DBIP), a Neighborhood Plan, classifies this property as outside "the Community Core" and, instead, part of the neighboring "Residential" land use designation. Staff explains: The proposed amendment is adjacent to but not within the area of the Downtown Bozeman Improvement Plan (DBIP) adopted in 2019. The DBIP is a neighborhood plan. A neighborhood plan considers in greater detail than possible in the growth policy in the future development of a subset of the community. A neighborhood plan must be consistent with the overall direction of the growth policy." Id., p. 11 [415] (emphasis added) (Excerpt attached). Note, Staff acknowledges that the neighborhood plan need only be consistent with the "overall direction" of the growth policy. Montana law makes clear that a "growth policy is not a regulatory document and does not confer any authority to regulate that is not otherwise specifically authorized by law or regulations adopted pursuant to law." MCA § 76-1-605. To this end, because a growth policy and future land use map is simply "general policy," the fact that a future land use map designates a piece of property in a particular fashion is only one (1) part of the analysis, not the entire analysis as it appears the zoning commission was led to believe. To be clear, the law requires only that this Commission "be guided by and give consideration to the general policy and pattern of development 3 set out in the growth policy in the . . . adoption of zoning ordinances or resolutions." MCA § 76-1-605(1)(c) (emphasis added). 2 There has Not Been "Careful Study and Strategic Location" of the B-3 Boundary as Required by the Recently Adopted. Staff and the Applicant seek to justify the piecemeal, upzoning of this small piece of property by claiming the "need to correct a discrepancy between he residential land use classification for the property of"Community Core" and the Bozeman Community Plan's Future land use map." Staff Report, p. 2 [4061. This is misleading, inconsistent with state law and ignores the plain language of the City's recently adopted plan for this area. As explained, the growth policy and future land use map is simply sets forth general policy, which this Commission uses as a guide. It is not a regulatory document. The DBIP, as staff explains, "considers in greater detail than possible in the growth policy the future development of a subset of the community." Staff Report at 11 [415]. The DBIP, adopted by this Commission only months ago, recognizes the conflict between the growth policy designation for this lot and the DBPI. Rather than brushing that conflict aside in this application, like the Applicant and Staff attempt to do as a mere "housekeeping matter," your own plan makes clear that "careful study" of the zoning associated with this property is required before moving the B-3 boundary, including the boundary appurtenant to this property: The Downtown B-3 district is primarily surrounded by residentially zoned neighborhoods as well as anchored by less intense commercial zoning on the east and west ends. It is important that the zoning regulations and land use projections designated in the community plan are aligned so that future development or changes is predictable, objective, and coordinated. Id., P. 110. The DBIP recognizes that there are several locations within its planning area, "where land uses and zoning designations are in conflict." Id., p. 111. One of these areas is the property subject to this application. Id. The DBIP makes clear that resolution of this conflict is properly addressed through careful study and strategic relocation of the B-3 boundary line: 4 Each of these areas should be addressed through careful study and strategic relocation of the B-3 boundary line. Care should be taken to keep the changes to the boundary as minimal as possible so that they maintain and reinforce the existing downtown and neighborhood areas on either side. Funclannentalli, the Downtown. district should not he reduced in area. Likewise, this f•ecornrnenclation is also not intended to ineaningfidly expand the district. Rather the hope is that minor boundary adjustments will address potential land use conflicts and reduce the potential for future challenges. M., p. 11 (first emphasis added, second emphasis part of original emphasis). While Staff recognizes the need to remove the conflicts, it ships the most important part of the Study's analysis, by ignoring the plain language of the plan, requiring study and analysis before moving a boundary. Here, there has been NO study, let alone "careful study" of a "strategic" relocation of the B-3 boundary area for this piece of property. Instead, Staff reports that "[t]he application indicates the intent of the zone map amendment is to correct a discrepancy between the residential zoning and the land use classification for the property of "Community Core." Staff Report, p. 2 [406]. Staff blindly accepts that rationalization, id. at p. 9, [413] even though neither it, nor the Applicant has undertaken the "careful study" mandated by the DBIP to ensure a strategic relocation of the B-3 boundary line. Such a "careful study" would surely include neighborhood notice and an opportunity to be heard. However, that has not happened. Instead, both Applicant and Staff declare by fiat, without "careful study," that with the elimination of the boundary conflict as a simple housekeeping measure, "no conflicts with the Growth Policy have been identified. M., p. 12 [416]. See also, Staff Report at p. 16 [420] (same). Resolution of the boundary conflict, by careful study, as the DBIP mandates, is intended to address many of the concerns raised by neighboring landowners in their comments to the Zoning Commission and this Commission in their written and public comments. As the DBIP states, alignment of zoning and growth policy objectives help ensure that "future development or change is predictable, objective and coordinated." M., p. 110. The need for a "careful study," is further demonstrated by the dearth of substantive information or analysis in Application and Staff Report, which is justified by kicking the can down the road as "part of the development review 5 process if the property is proposed for redevelopment." Staff Report, p. 12 [416]. This is nonsense and turns the DBIP's analysis on its head. The time for analysis of these issues is now, as part of the careful study mandated by the DBIP. For example, under Section D of the Staff Report, concerning whether the amendment would "facilitate the provision of transportation, water, sewerage, schools, parks, and other public requirements, Staff writes: Yes. Adoption of the requested amendment does not require a change in use from the existing function as a parking lot. No additional facilities are required for the parking lot to continue. Any redevelopment of the property will be required to meet city standards for water, sewer or transportation system upgrades or restrictions resulting from proposed future development. The adequate provision of public requirements is addressed as part of the development review process if the property is proposed for redevelopment. Icy. p. 12 [416]. Assuming the land in question will remain a parking lot for purposes of upzoning is naive at best, disingenuous at worst. This Commission knows the land at issue will not remain a parking lot. Regardless, as part of the analysis required to evaluate the proposed amendment, including the careful study that should proceed any adjustment of the boundary under the DBIP, Staff(and this Commission) should assume the maximum potential buildout of the property at the densities allowed under B-3. To simply defer that analysis until a later date is inconsistent with the standards adopted by the DBIP and state law governing adoption of zoning regulations. The same analysis applies with respect to Staff's shallow analysis on the "effect on motorized and non-motorized transportation systems. Id. at p. 14 [418]. Staff writes: "A change in the zoning from R-4 to B-3 will not itself change the use of the property from a parking lot for the . . . Medical Arts building. Therefore, there is no anticipated immediate effect on transportation systems from the change in zoning designation." Id. Just as the Staff Report offers no analysis on the foregoing issues to reach conclusions supportive of the end result, because it must assume the land may simply stay a parking lot, it likewise offers no study or analysis on how it can conclude, that if the property "is to be redeveloped" that the "most appropriate uses are those allowed in the proposed B-3 district, some of which would not be 6 allowed in the existing R-4 district." Id., p. 15 [419]. Which uses is Staff referring to? Why are they most appropriate? How does that justify the change in boundary, even though the DBIP urges careful study to "strategically" locate the boundary between residential and business. The same criticism applies with equal force to the "character of the district analysis," located in Section H, including deferring analysis of the interaction between the Neighborhood Conservation Overlay District, because "[m]ost of the NCOD standards are not applicable to the present use of the site as there are no buildings associated with the use." Id., p. 17 [421]. The same criticism applies to Section I (Peculiar suitability for particular uses"). Section J (conserving the value of buildings, arbitrarily limits its analysis to the effect of the amendment on buildings "within the boundary of the amendment." Id., p. 17 [421]. The analysis is broader and requires that one look across the street and across the alley. This analysis and conclusion is arbitrary and capricious. In sum, the information in the Application and Staff Report are so lacking in fact and foundation that is it clearly unreasonable to base approval of the application upon that information, and if relied upon would constitute an abuse of discretion." Lake County First v. Polson City Council, 2009 MT 322, 9132, 352 Mont. 489, 218 P.3d 816. Id, 133. The Application is properly rejected in favor, in the first instance, of the "careful study" the DBIP mandates before adjusting boundaries. 2. The Agenda Item Type is Quasi-Judicial in Fact and Law. Second, I respectfully disagree that the action by this Commission is "legislative." Staff Report, p. 1 [405]. Instead, and with due respect to decisions by the Montana Supreme Court, which modified prior holdings, the act of upzoning small pieces of property, like the property at issue is properly characterized as quasi-judicial in fact and law. The property at issue is 0.7 acres in size. The owner wants to upzone the property because it will increase its value to him or her. The land to the north and west are residential neighborhoods. The vast majority of the land to the northeast is also residential. The overwhelming majority of property owners in the area have expressed their opposition to the City's incremental destruction of their neighborhoods through the process of B-3 creep. 7 There are statutes governing zoning and rezoning, a comprehensive plan and future land use map that has already been adopted and, most recently, the DBIP, all of which inform this Commission's decision. Montana, by virtue of the decision in Lowe v City of Missoula, 165 Mont. 38, 43, 525 P.2d 551, 554 (1974) (overruled on other grouncls by Greens at Fort 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 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, 218 P.3d 816. While the current "black-letter" law in this state suggests that the act of rezoning is a legislative act, that conclusion is a legal fiction and properly subject to further review by the Court. The adoption of growth policies and future land use maps, of general applicability, or rezoning of large areas, are properly considered legislative in 8 nature. This is because initial zoning and large rezonings "bear the indicia of traditional legislative action, i.e., they are acts establishing policy and have effect on the entire community or large portions thereof." Ziegler, § 40:21 at 4051-52. On the other hand, "characteristics primarily cited in identifying a rezoning as quasi-judicial are the facts that: (1) A decision has great impact on a limited number of persons or property owners while having comparatively little impact on the community at large; (2) The proceeding is aimed at arriving at a fact-based decision between two distinct alternatives, i.e. pro or con; (3) The decision, viewed functionally, and analytically presents an instance of policy application rather than policy setting. Id. at p. 40-52-53. "Under these criteria, the clearest case of a quasi-judicial rezoning is that of a rezoning sought by a single property owner for a comparatively small parcel of property." Id. at 40-54. The application before this Commission is the "clearest case of quasi- judicial rezoning" under the foregoing standards. This is important, because it offers individuals, like neighbors, with greater procedural protections. While some of these enhanced protections exist under existing law, there are additional procedural protections such as the right to discover and seek disqualification from the decision making body of persons who have conflicts of interest or have had improper ex parte contacts with the Applicant or his or her representatives, to ensure the decision made is based solely on matters of record. See, Ziegler, § 40:23. 3. 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. Board of County Comnnrission.ers, 2010 MT 155, IT 58-66 , 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 "upzoned" to 9 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 think 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, 181 N.E. 312, 313-314 (Ill. App. 1932). a The Proposed Use is &nificantly Different From The Prevailing Uses of Land in the Area. 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. Staff concedes that the prevailing land uses immediately to the north and wast of the subject property are residential. To the south and immediatel to the east, for one (1) block, the land is B-3. In addition to significantly higher density, another important difference from the prevailing land uses "in the area," is that the B-3 zoning, allows commercial uses not allowed in the adjacent residential neighborhoods. The site has been used as a parking lot, primarily during business hours (8- 5). At night, there are no customers and few (if any cars). Traffic to and from the 10 lot is greatly diminished after hours, with traffic associated, primarily, with that going to and from the adjacent residential neighborhoods. b. Size and Numbei-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 acknowledges the property is very small (0.7 acres) but creates, out of whole cloth, a justification not found in law: "The change is an incremental expansion of the entire B-3 district and is physically contiguous to it." Id. at 19, [4231. This argument, if understood correctly, is similar to the subterfuge argument, often rejected by courts, that looks to rezoning two (2) or more parcels as a means to obscure the actual purpose of according special treatment on one particular landowner. Ziegler, at 41:8 (citing cases). The facts are that we have one (1) parcel of property, 0.7 acres in size. It is zoned R-4, and has been R-4 for decades. The land to the north, west and vast majority of northeast is burdened by substantially greater restrictions than the Applicant seeks with this parcel. C. The Change Is In The Nature of Special Legislation Designed To Benefit One Landoivtter at the Expense of the Surrounding Landowners. 1 "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, 164. "The number of landowners 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 concludes, by citation to its flawed analysis, discussed above, and without discussing the many objections by neighboring landowners, that "no substantial negative impacts or `expense' to the surrounding landowners or the general public have been identified in staff's analysis. . . ." It talks about 11 additional commercial uses as appropriate, simply because city plans say it is so. If that is the case, why have a hearing? Why undertake any analysis? In a vague concluding sentence, Staff states: "The existing use of the site may continue without interruption with the new zoning designation in place." Id., p. 19 [423]. Is staff suggesting that the limit of the analysis, for a zone map amendment that increases density and introduces commercial uses not otherwise allowed on the property or in surrounding neighborhoods, is a parking lot? The proper analysis, ignored by Staff, includes an inquiry on the benefits of the proposed rezone to surrounding landowners. Plains Grains, 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." Id. (emphasis added). Viewed in its proper light — impact on the surrounding landowners -- because of the high density, coupled with commercial uses are not otherwise allowed in the immediate areas to the north and east, and the majority of the northeast, the Applicant is the primary beneficiary of the zone map change. There is no discernible benefit to that accrues to the neighbors with B-3 zoning. Finally, staff's analysis seeks to delay "review of demands and impacts from future development . . . at the time development is proposed and mitigation of impacts as justified and required by law." Id. p. 19 [423]. The law requires an analysis now, under what is possible under proposed zoning if adopted, not some nebulous time in the future. CONCLUSION. The application is properly denied. RESPECTFULLY SUBMITTED this 16"' day of September, 2019. GAL 7RIEMER & MOLLOY, P.C. Brian K. Gallik Attachment C: City Attorney 12 Downtown Bozeman s sa ws Improvement Plan � May 2019 � �� Study Area WHERE IS DOWNTOWN? LU w Downtown Bozeman contains and is surrounded > Q w Q w > by residential neighborhoods,historic districts, w Q Z Worth Q w Q Q Q = U and growing employment centers.One of the best Q Z � Tracy Y 2 w U Q features of Downtown is that its boundaries are Q �_ Q N D j J M O O X open,rather than closed,allowing a direct,walkable VILLARD ST m 0 co 3 transition from the core to nearby neighborhoods. ---- -; No highway,river,or bridge separates downtown _ businesses from the surrounding community. j Instead,a change in scale,architectural styles, W9 land uses,streetscape language,and ground LAMME ST fill �� *' « •c---- -----——— LAMME ST !—— sir *. 4 floor treatment signals that one is moving from I � ,• � �n•�.-� � Downtown Bozeman into another neighborhood. ! Ma ! ! • , �� MENDENHALL Beyond the in Street historic district,it is > r—— • —-_ sometimes hard to draw an exact line and identify Q L x ��� 1[ Iwo'; l; where Downtown stops and starts.For purposes of f i �11 III Jr T MAIN ST this plan,the area shown by a red dashed line refers <'-Male Street to Downtown and the"Core Area"is, smaller area r I ddm centered on Main Street from Grand to Rouse,and AB north and south to the alleys. 19.dim � � w — While there may be a red dashed line to define the 31-1 — — Will I study area,the plan looks beyond these boundaries Lindley I I to understand Downtown in the context of the Place community.The DB1P considers Downtown `COOIJer Park Q ; ; in relationship to surrounding neighborhoods, W Q Z 3Y w Q g �i B3 Zone existing regulatory boundaries and historic districts. . Q Q U a Ij > O O At the same time,it is focused on a specific = z J South Tracy/ w I r area that is defined by combining the City's B-3 �`/i l m =� South Black _ = l7 pp I i zoning district with the Urban Renewal District. U i This area encompasses the Main Street Historic ,/�, Bon Ton District and extends-at its widest points-north to Villard Street,south to just past Olive Street 1 west to 5th Avenue and east to North Broadway Urban Renewal District! O / Avenue.Downtown is not a homogeneous area so there are sometimes discrepancies between zoning boundaries and the underlying growth policy land use des gnatlons. ID-2019 Downtown m)—,—ont Plan 11-2019 Downtown Bozeman Improvement Plan ti� ri DE F Design new buildings for sustainability, - durability and design G DOWNTOWN RE AREA excellence. CO h.1 N Growing in Place Inconsistencies can lead J As Downto-wn Continues to evolve,growth to greater challenges and preservation need to be carefully balanced. ra n d uncertainty during h' Downtown zoning is designated as"Downtown district(downtown B-3),"which encourages redevelopment for density,a mix of uses,a pedestrian-oriented residents, city staff, and environment,and urban building forms.The B-3 code also notes that"reinforcing the area's developers. historical pedestrian-oriented context are very density residential uses exist in the residential a street or alley,creating greater sensitivity for LAND USE AND ZONING ALIGNMENT districts surrounding the B-3 zone.However,along development on adjacent parcels indicated by ' important."While these goals are in line with b 6 P )r P• (� DBIP principles,downtowns like Bozeman have The Downtown B-3 district is primarily surrounded the perimeter,there arc a few locations where land dashed lines on map). unique development histories that can lead to by residentially zoned neighborhoods as well as uses and zoning designations are in conflict.The Each of these areas should be addressed through some inconsistencies among regulations,use,and anchored by less intense commercial zoning on the map above points out Ivey areas of conflict: careful study and strategic relocation of the B-3 scale.Varied patterns,streetscapes,and massing are east and west ends.It is important that the zoning Three sites where a small amount of boundary line.Care should be taken to keep common,valuable elements of all urban settings, regulations and land use projections designated commercial core land uses extend beyond the the changes to the boundary as minimal as and it is important to both encourage variety and in the community plan are aligned so that future B-3 zone(A,B,C); possible so that they maintain and reinforce balance it with clarity and predictability. development or change is predictable,objective, the existing downtown and neighborhood and coordinated. Three sites where there are future residential areas on either side.Fundamentally,the To the extent possible,the DRIP seeks to land uses that are zoned as B-3(D,E,F);and resolve conflicts in planning and zoning,clarif}' Adjust the B-3 District Boundary to Downtown district should not be reduced in height limits,reduce overlapping regulations, Eliminate Land Use and Scale Conflicts Three sites where community commercial area.Likewise,this recommendation is also and strengthen the ability of zoning and design mixed use future land uses either extends not intended to meaningfully expand the standards to ensure sensitive transitions between For the most part,the Downtown B-3 zoning within the B-3 area(G,1-1)or is adjacent and- district.Rather,the hope is that minor boundary boundary contains designated community core incompatible with existing zoning adjustments will address potential land use conflicts buildings of different scales.Any changes P g(I)• ) or public institutional land uses,consistent with suggested in the DBIl will need to be refined for Several areas where the B3 zoning changes to and reduce the potential for future challenges. integration into the UDC. 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