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HomeMy WebLinkAbout12-22-23 Public Comment - M. Kaveney - APA- Zoning Practice report, to commissioners and please add to UDC public commentFrom:Marcia Kaveney To:Terry Cunningham; Jennifer Madgic; Jeff Mihelich; Christopher Coburn; Douglas Fischer Cc:Agenda; joey@morrisonforbozeman.com Subject:[EXTERNAL]APA- Zoning Practice report, to commissioners and please add to UDC public comment Date:Wednesday, December 20, 2023 2:25:48 PM Attachments:Zoning-Practice-2023-01.pdf CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Dear Current Deputy Mayor, Future Deputy Mayor, City Commissioners, and City Manager- I hope you are all doing well and looking forward to your holiday break. The attached document from the American Planning Association was forwarded to me recently and I think it includes a well rounded formula for updating a city's UDC with a muchimproved plan to involve the existing residents, one of the 5 major stakeholder groups. While reading it, I found many items of interest such as those listed below. I also think Code Studio,whether taking direction from the city commission or giving direction to the City, followed many of the suggestions in this document but fell far short in utilizing the public's interest andknowledge in truly instrumental ways early and often in the process. One look at the list of "stakeholder" meetings and one can see that the public literally never got even one actual worksession. Items of Interest: Page 3. 5 reasons to update: the third reason, " To provide better and more consistent development outcomes'' and the fourth reason, " To alleviate Scrutiny from the Public and Development community." Page 5. The suggestion to engage community members early during Step 1. Page 6. Including The Public as one of the 5 major stakeholder groups in Step.3. Page 7. The list of questions to use during input meetings- residents can and could have offered a lot of useful information here. Page 8. a "detailed" diagnostic report to "notify the community of ALL issues with the code." Page 9. Code analysis by Topic. Here's where we can address things like the "escape clauses"in development standards, lack of tree and water resource protection in Natural Resources, etc. Page 10. Avoiding public and other "stakeholder" pushback by using the 4 part guidesuggested under Step 6. Draft the New Code. Page 11. Step 7. Revise the Draft Code. utilizing all the stakeholders including the PUBLIC. And then revise again, and again if needed. Page 12. Top of left column: "review the code drafts at a public meeting allowing the publicto interact directly with the drafters and local officials during this code transition step." This is what many residents wanted and were clamoring for during the recent UDC review. I am hopeful this situation will be turned around and greatly improved in 2024 and that afterreading this document you will also find inspiration for leading a truly inclusive UDC update that includes true public involvement. Thank you and Happy Holidays, Marcia Kaveney JANUARY 2023 | VOL. 40 NO. 1 ZONING PRACTICE Unique Insights | Innovative Approaches | Practical Solutions 8 Steps to an Effective Code Transition In this Issue: Reasons to Transition | Key Participants | Code Transition Steps | Conclusion Zoning Practice | American Planning Association | January 2023 2 8 Steps to an Effective Code Transition By Derrick Rhys Wilson Transitioning from an old code to a new code can be an overwhelming process. With endless possibilities of what could be, aggressive timelines, polarized polit- ical circumstances, tight budgets, and competing community interests, it is understandable why municipalities do not update their codes as frequently as they should. These factors can pose barriers to any code transition, making it a chal- lenging, contentious, and lengthy, but ultimately rewarding, process. This issue of Zoning Practice summa- rizes when and why it may be necessary for a city, town, or county to replace an existing development code. It provides an overview of the code-transition process, offering a brief instructional guide on how to organize and complete each step. Reasons to Transition A development code comprises reg- ulations that manage a city, town, or county’s land development practices by determining permissible development patterns and land uses within the local government’s jurisdictional limits. Codes typically include zoning district regulations, subdivision requirements, land-use specifi- cations, development standards, and land development procedural requirements. These regulations work harmoniously to ensure development (1) implements the community’s long-range planning poli- cies; (2) promotes public health, safety, and general welfare; and (3) protects and preserves places and areas of historical, cultural, or architectural significance. How- ever, as time passes, these regulations A development pattern that wouldn’t be permissible under many existing development codes (Credit: Getty Images) Zoning Practice | American Planning Association | January 2023 3 work independently of one another and can become out of step with modern best practices, producing unfavorable development outcomes. This leads to the question, “why does a city, town, or county need to transition from its existing code to a new code?” The simple answer is that there is no single reason why a code needs to transition. Instead, there are at least five reasons why a jurisdiction may need to transition from an old code to a new one. To Prevent Litigation Litigation is right behind baseball as Amer- ica’s favorite pastime. Nothing requires a code to transition quicker than lawsuits and legal threats. With the abundance of new federal and state laws and growing case law, older codes are more suscepti- ble to litigation because they do not reflect these recent changes. For instance, the landmark ruling on the First Amendment in Reed v. Gilbert (2015) regarding signs and free speech sparked a wave of municipal- ities and counties to update their code’s regulations to comply with a new prec- edent. If a jurisdiction did not update its code to meet the Reed v. Gilbert decision’s requirements, then its code would be out of compliance and prone to litigation. To Align Codes with Newly Adopted Long-Range Planning Policies Municipalities and counties typically update their long-range plans every 10 to 20 years. When these plans are updated, they require implementation to achieve policy goals. Codes are a core plan imple- mentation tool that help local jurisdictions translate statements of intent or desire into legal obligations for those who wish to develop or use land. However, old codes are often incongruent with newly adopted long-range planning policies, requiring a code transition. A new code that aligns with the long-range planning policies may be necessary to achieve a jurisdiction’s desired policy outcomes. To Provide Better and More Consistent Development Outcomes A code transition may be warranted when an existing code does not provide the community’s desired development outcomes. If the community constantly receives uninspired or inconsistent devel- opment, planners and local officials may begin thinking about alternative ways to meet local development preferences. This sometimes occurs by changing the code. To Promote Equity, Inclusion, and Accessibility A code transition can occur because of the need to promote equity, inclusion, and accessibility within a community. Older codes struggle with equity, inclusion, and accessibility issues, like fair housing, indiscriminate regulations, and walkability, because these topics were not priori- tized at the time the code was adopted. For instance, codes that do not provide small-lot residential districts and restrict multifamily uses, cause equity issues by only providing preferable housing options for a certain demographic. A code transi- tion can rectify these issues and encourage equity, inclusion, and accessibility by providing regulations that are nondiscrim- inatory, allowing everyone to participate equally in the development process. To Alleviate Scrutiny from the Public and Development Community A code may transition due to increased and constant scrutiny from the public and the development community. Typically, scrutiny revolves around the length of the development process, onerous standards, ambiguous language, and arbitrary regula- tions. These types of comments can make a municipality critique its code to address the issues expressed by the public and development community. If the public and the development community has a con- sistent message, then it may be time for a municipality or county to start thinking about improving its code. Nothing requires a code to transition quicker than lawsuits and legal threats. Zoning Practice | American Planning Association | January 2023 4 Key Participants Every code-transition process relies on a core project team. This team consists of all staff members and external consultants directly involved in drafting regulations or providing quality assurance throughout the effort. For some code transitions, a local planning staff member will serve as the project leader. Often, though, local officials will contract with one or more external planning consultants, either to lead the project or to provide supplemental exper- tise throughout the life of the project. Traditionally, the local planning commission provides project oversight. However, many communities use one or more advisory committees to provide supplemental technical expertise or over- sight. These committees may comprise any combination of staff members, local officials, and members of external stake- holder groups, such as local real estate and design professionals, business own- ers, and nonprofit leaders. Ultimately, the local legislative body is responsible for approving or rejecting any code updates. Code Transition Steps Regardless of how the effort is organized, it is important for all parties to have a clear understanding of the project’s scope before commencing a code-transition process. This scope usually includes the number of hours allocated to the project, the fees associated with work tasks, the project timeline, work task descriptions, meeting dates and public presentations, deliverable materials, and deliverable due dates. Once the parties agree on the proj- ect scope, there are eight key steps in the code-transition process. Step 1: Compile Relevant Documents The first step of the process is to iden- tify all relevant land-use, planning, and development documents and to place those documents into one centralized location. Documents that discuss the community’s planning policies and goals, recount recent hot-button topics and controversial development issues, and address the community’s development Key participants in the code-transition process Zoning Practice | American Planning Association | January 2023 5 rules, practices, and procedures are rel- evant to the code-transition process. For instance, comprehensive plans, special area studies, thoroughfare plans, park and trail plans, subdivision regulations, and zoning ordinances should be placed into an accessible location. Additionally, many communities post board, commission, and council meeting agenda packets on the community’s website, and these docu- ments can also add value to the process. Although this step typically does not involve the public, engaging community members can serve as a good oppor- tunity to foster initial thoughts about the code-transition process. Particularly, the project team can invite members to think about any recent community plan- ning policies and studies that should be examined during the process. Sometimes active neighborhoods and vocal interest groups may provide the team with specific concerns about a plan or have additional information that may be useful for the code transition. While this step is brief, it is an important one because it establishes the foundation for the remaining steps. Without document compilation, the code-transition process becomes dis- rupted and fractured because there is no central reference point. As the process unfolds, this step shows its mettle as participants regularly refer to the original documents to form the new code. Step 2: Review Compiled Documents The second step of a code transition is to review the documents from step one. This step entails reading, annotating, and commenting on all pertinent land-use and planning documents. Start with the com- munity’s long-range planning documents like the comprehensive plan and special area studies to develop a foundation on how it intends to grow. When reviewing these plans, the project team should note the major themes consistent throughout the document. Additionally, the team should note the comprehensive plan’s goals and implementation strategies and determine which ones are pertinent to the code. This will help with steps four and six. After reviewing the long-range plans, the team should begin reviewing the The code- transition process Zoning Practice | American Planning Association | January 2023 6 community’s subdivision regulations and zoning ordinance. For these documents, participants should first assess verbiage, syntax, writing style, and organizational structure. It is important to note whether a regulatory document is clear, concise, and effective or wordy, confusing, and ambigu- ous. This can be determined by examining sentence length and noting instances of jargon-rich text and legalese. Additionally, its critical to examine the code’s organizational structure, meaning the code’s arrangement and sequencing of material. This is an opportunity for the project team to note where text seems out of place or missing and to identify areas of the code where the sequence of materi- als could be improved to strengthen user readability. For instance, if there are multi- ple places that have the same standards, then noting an internal cross-reference to those places may work better to improve the code’s readability. After reviewing the language and organizational structure, start analyzing the document’s content. To effectively assess the code’s content, the team should review with the following questions in mind: • Does the code text make sense? • Where does the code need more specificity? • Where are the regulations more lenient or strict? • Does the code align with the client’s long-range planning policies? • Where are the code’s inconsistencies? • Are regulations clearly defined and explained? • Where are there improvement opportunities? • Which sections of the code are satis- factory and need little or no changes? • Where can the code be modified to better deliver the community’s desired development outcomes? • Which processes need refining? These questions will generate meaningful and necessary comments to help the proj- ect team prepare for the subsequent code process steps. After a thorough review of all compiled documents, the next step can begin. Step 3: Solicit Stakeholder Input The third step of the code-transition process involves gathering information from stakeholders to guide the project team toward a robust and inclusive new code that reflects the community’s val- ues. Typically, in this step, the team asks for input about the code from five broad stakeholder groups: staff, the develop- ment community (design professionals, businesses owners, local developers, etc.), elected and appointed officials (city coun- cil or county board members, planning commissioners, and board of adjustment members), community and nonprofit orga- nizations, and the public. Standard engagement methods include community open houses, public workshops, neighborhood meetings, and planning commission or local legislative body hearings. Additional engagement methods may be necessary to reach the Legalese Term Frequency Foregoing 6 Hereafter 15 Hereby 28 Herein 102 Hereinabove 2 Hereinafter 4 Hereunder 4 In accordance 159 In lieu of 22 In the event 16 Pursuant to 56 Said 84 Set forth 118 Such 657 Thenceforth 3 Thereafter 19 Thereof 61 Thereon 12 Thereto 13 Wherein 6 Total 1,387 Sample Legalese Audit Zoning Practice | American Planning Association | January 2023 7 community’s traditionally underrepre- sented groups. This may occur through online platforms, where surveys, question- naires, and other interactive activities are posted to gain insight about the communi- ty’s thoughts about code reform. Also, the project team should make a concentrated effort to physically meet these groups at places they frequent. For instance, some groups may be especially connected to a place of worship, so engaging the community at that place of worship may increase participation. It is important that the team builds rela- tionships with the stakeholders during this step to create project synergy and a path towards consensus. The team must estab- lish a safe and inclusive environment where the public does not feel unwelcomed, judged, or intimidated. Relationship build- ing is key particularly for those groups that are historically underrepresented. For instance, there are some communities where there is a significant portion of the population where English is not the primary language spoken. In these communities, it is important for the project team to trans- late outreach materials and messages into other languages. This will help build credibility with the community and hope- fully generate more meaningful discourse throughout the code-transition process. For one-on-one interviews and small group meetings with stakeholders that are familiar with the existing code, the following set of questions can generate meaningful input: • What does and does not work well with the code? • Which specific issues routinely arise at planning commission or city council/county board meetings, local business or community-based organization board meetings, or amongst staff? • Where are there poorly written and confusing regulations? • How well does the development process work? • Which, if any, zoning districts need to be reassessed? • How appropriate are the community’s land uses and associated use regulations? • Are the community’s regulations, requirements, or procedures exces- sive or onerous for developers? • What other nearby communities pro- duce better development outcomes? The following questions may be more suitable for surveys and questionnaires aimed at stakeholders who are less familiar with the specifics of the current code: • What types of development would you like to see? • What housing would you like to see? • What does the community need more of? • Which development regulations need improvement? Responses to these questions often furthers discussion about the code and development issues. For instance, the public vocalizing concern about inad- equate parking, lack of trees, waning development quality, and traffic con- gestion, are all common and insightful comments when retrieving feedback from the public about the code and development issues. Once all input is gathered and noted, then the next step can start. Workshop participants playing the Zoning Game in advance of a code transition in Detroit (Credit: Detroit City Planning Commission) Zoning Practice | American Planning Association | January 2023 8 Step 4: Prepare a Diagnostic Report There are few steps more important than this one. During this step, the project team uses the work performed throughout steps one through three to create a holistic diagnostic report that serves as a detailed road map for the new code. This report analyzes the existing code’s successes and failures and its alignment with the community’s long-range planning policies and highlights the input provided by stakeholders. The diagnostic report should be detailed enough to notify the community of all issues with the code. It should be arranged in a format that examines each part of the code and should generally have seven sections: 1. Introduction 2. Zoning frameworks 3. Input summary 4. General code overview 5. Code analysis by topic 6. Conclusion 7. Appendices Introduction The Introduction section should include at least three key components to orient the reader: general project overview, diagnostic process overview, and guiding principles for code revisions. The general project overview notes how readers can access the current code, recounts the code’s adoption and amend- ment history, and provides a brief review of the community’s long-range planning policies and how those policies should interact with the code. The diagnostic process overview explains how the project team developed the diagnostic report. It discusses how the team reviewed the code and other relevant documents, analyzed feedback from stakeholders, and prepared suggestions for the code transition to ensure the new code reflects the client’s vision for the future. The guiding principles for code revisions account for the community’s long-range planning policies and how the code should align with those policies. Typically, the guiding principles include items like providing a right-sized code tailored to the community, establishing clear processes, improving usability, and ensuring the code complies with federal and state law. Zoning Frameworks The Zoning Frameworks section intro- duces the reader to alternative approaches to zoning, such as Euclidean, form-based, performance, and composite zoning and describes zoning tools, like overlay dis- tricts, planned unit development (PUD), and design guidelines. It highlights the advantages and disadvantages of each approach and tool and explains how the community’s current code uses different approaches and tools. Input Summary The Input Summary section summarizes stakeholder feedback from the input step. It recaps who participated (e.g., elected officials, planning board members, staff members, design professionals, commu- nity organizations, etc.); the number of participants; where, when, and how input was gathered; the major discussion topics; and the participants’ critical takeaways. This information is then connected to the recommendations list provided in the Gen- eral Code Overview and Code Analysis by Topic sections. General Code Overview The General Code Overview section is a high-level summary of the current code’s organizational structure and sequence, language and writing style, graphic com- ponents, and terminology. Each item offers a background discussion with an analysis component to help form recommenda- tions on how to improve the code. These recommendations are mostly high-level quick fixes and do not touch much on the code’s substantive issues. The diagnostic report should be detailed enough to notify the community of all issues with the code. Zoning Practice | American Planning Association | January 2023 9 Code Analysis by Topic The Code Analysis by Topic section is a detailed review of the code’s substantive content. This section critically analyzes the code’s zoning districts, land uses, development standards, procedures, subdivision regulations, definitions, and general provisions by providing recom- mendations on how to improve each code part. Unlike the General Code Overview section, this section provides focused recommendations for certain code parts to address specific issues raised by the client. Conclusion The Conclusion section provides a recap of the report’s main points, including key findings, and describes next steps in the code-transition process. Appendices The Appendices section is normally included in the diagnostic report as a section that provides additional infor- mation for the reader. This section can include recommendations lists, a com- plete set of raw data from the input step, and additional specific studies. Once the diagnostic is prepared and delivered to the client, then step five can start. Step 5: Outline the New Code The fifth step of the code-transition involves preparing a clear code structure that incorporates the client’s existing code text and new code topics by arranging them into a proposed format. The anno- tated outline is a great tool that ensures that the new code incorporates existing code regulations, while providing dedi- cated sections for new code text. In short, the annotated outline orients the reader to the code’s new organizational structure. It can be alarming seeing a completely refor- matted code, but the annotated outline accounts for that issue. With an annotated outline, the reader can note the code’s new structure, while tracking the current code’s existing language. For example, the sample annotated outline below is divided into four columns. From left to right, this annotated outline’s columns indicate the proposed article, proposed division, proposed section, and current section. The first three col- umns show the new code’s organizational structure, while the last column shows the existing code text and its proposed location in the new code. The new code proposes a general organizational struc- ture following the article, division, and section format. For instance, the existing code includes a severability clause in Topic Recommendation Use permissions by district Combine the seven use tables into one use table. Use permissions by district Cross-reference the use table in each zoning district section. Use-specific standards Reduce the number of uses requiring specific use permits by implementing use-specific standards Use-specific standards Create context-sensitive use-specific standards that are tailored appropriately for specific zoning districts Use-specific standards Provide graphics for certain use-specific standards (i.e., screening, buffering, distancing requirements). Parking standards Right-size parking regulations by identifying different parking ratios and matching them within certain development contexts. Parking standards For the new downtown zoning district, establish the current parking minimums as maximums. Sample Recommendations by Topic Zoning Practice | American Planning Association | January 2023 10 Section 10-45, whereas the new code suggests the clause belongs in Section 1-9. From this example, the project team accounts for the code’s existing regulations while organizing the new code’s structure. Although annotated outlines can vary in detail, they often arrange codes into the following nine content headers: Gen- eral Provisions, Zoning Districts, Land Uses and Use Regulations, Development Standards, Subdivision Regulations, Administration and Procedures, Enforce- ment, Nonconformities, and Definitions. This sequence helps prepare a code that emphasizes the most substantive parts of the code. Step 6: Draft the New Code Arguably, this step is the most demanding part of the code-transition process. This step takes time as it requires the project team to prepare parts of the code for the community’s review. Typically, the draft- ing step ranges from eight to 18 months. When drafting, the team should develop the most relevant parts of the code first. This includes drafting the zoning districts, land uses, development standards, and subdivision regulations first since most readers frequently gravitate towards these items when using a code. Drafting these sections appropriately relies on four things: 1. Keeping functional parts of the current regulations 2. Tying the goals and objectives of the community’s long-range planning poli- cies to the proposed regulations 3. Sufficiently incorporating stakeholder input into the proposed regulations 4. Ensuring the diagnostic report’s listed recommendations are reflected in the proposed regulations Preparing regulations that account for these four things, will reduce stake- holder pushback because the proposed regulations direction has been clearly communicated with all parties involved in the code-transition process. After addressing those code parts, the project team should begin developing the administration and procedures, enforce- ment, and nonconformities sections. Often these sections will not need wholesale changes but rather minor improvements to streamline processes and clarify the code. The final code parts that should be prepared are the ones that the reader typically glosses over like general provi- sions and definitions. Not only are these parts frequently overlooked, but they are also some of the quickest regulations to prepare. Although the general provisions section typically needs minor editorial Proposed Article Proposed Division Proposed Section Current Section Article I: General Provisions Division 1: Introduction Sec. 1-1: Preamble Sec. 21-1: Preamble Sec. 1-2: Title Sec. 1-3: Purpose Sec. 21-2: Purpose Sec. 1-4: Authority Sec. 21-4: Authority Sec. 1-5: Applicability Sec. 1-6: Consistency With Comprehensive Plan Division 2: Legal Provisions Sec. 1-7: Relationship to Other State, Federal, and Local Regulations Sec. 21-6: Interpretation Sec. 1-8: Private Restrictions Sec. 1-9: Severability Sec. 10-45: Severability Sec. 1-10: Repeal of Existing Ordinance Sec. 1-11: Effective Date Sample Annotated Outline Excerpt Zoning Practice | American Planning Association | January 2023 11 changes, the definitions section needs a thorough revision of terms to check which terms have been omitted and added to the code. This will ensure that there are not any definitions for terms that are not used in the code. Conversely, this will serve as an opportunity to verify any new terms are sufficiently defined in the code. The community is typically eager to receive a revised code, but sometimes this eagerness can negatively affect work quality by rushing the drafting step. Drafting regulations is laborious, and comprehensive, legally defensible, and con- text-sensitive codes take time to prepare. Throughout this step, the project team should provide regular progress reports to local officials and other stakeholders. Step 7: Revise the Draft Code This step is critical for the code-transition process. Draft revisions are suggested textual and graphic revisions to the code. This step is highly involved as the proj- ect team solicits code draft input from staff, elected and appointed officials, the development community, community and nonprofit organizations, and the public. In fact, it’s often helpful to conceptualize this step as a distinct subprocess: 1. The code drafters deliver the draft code to staff members providing quality assurance. 2. Staff members review the code and provide their comments back to the drafters. 3. The drafters receive staff’s comments and revise the draft code accordingly. 4. The revised draft code then goes to any project advisory committees for comments. 5. Project advisory committees provide comments to the project team. 6. The project team makes the appropriate additional revisions. 7. Once revisions have been made, the code goes to the planning commission or local legislative body and is avail- able for public dissemination for review and commentary. 8. Once these entities review the code and provide comments, the code goes back to the project team for final revisions. Typically, the project team allows two to six weeks for project advisors, local officials, and the public to review and pro- vide comments. Often, the project team establishes a forum where the public can view the draft code online, providing an Final approval of the new code Zoning Practice | American Planning Association | January 2023 12 opportunity for the public to comment anonymously. Additionally, the team will review the code drafts at a public meeting allowing the public to interact directly with the drafters and local officials during this code transition step. After all comments have been addressed and accounted for in the code, it can move on to step eight in the code-transition process. Step 8: Adopt the New Code The eighth and final step starts with com- piling all accepted revisions into one clean document ready for final review by local officials and the public. This step should include all the necessary internal cross-ref- erences and important links to other documents that will increase readability. At this point, staff should forward the code to the community’s legal counsel for review. This is a vitally important part of the adoption process because it ensures the community has a legally compliant code. Once the final draft is complete, it is ready for the adoption hearings. The plan- ning commission will review the final draft, provide a recommendation, and then forward that recommendation to the local legislative body, which will approve or deny the final code. If the legislative body denies the final code, then step seven will be repeated until the final code is approved. If the city council or county board approves the final code, then it is adopted and offi- cially recognized as the municipality or county’s code. Conclusion The code-transition process is not quick and easy. It is a process that involves numerous people and frequent com- promise to deliver a code that produces quality outcomes. Because there are so many stakes in the game, it is understand- able why municipalities and counties are hesitant to dive into the code-transition process. However, it is up to the planners and local officials to reduce that hesitancy by understanding the five reasons why a code transition is necessary and, when it is time to start the process, to rely on the eight steps described above to deliver a successful code transition. Acknowledgement: I would like to thank Mark White, aicp, and Tyson Smith, aicp, for refining my technical writing skills and for their continued support. I would also like to honor Brian Lockley, aicp, cpm, my mentor, who left Earth too soon. Brian’s invaluable guidance, steady support, and sage advice continue to mold me. About the Author Derrick Rhys Wilson is an urban planner with zoning analysis, land-use code drafting, researching, and urban design expertise whose services have been utilized in 14 states. He mostly prepares land-use and zoning regulations for clients concentrating on parking, land-use classification, use standards, definitions, procedures, and development standards. Cover credit: scanrail/iStock/ Getty Images Plus ZONING PRACTICE JANUARY 2023 | VOL. 40, NO. 1. Zoning Practice (ISSN 1548–0135) is a monthly publication of the American Planning Association. Joel Albizo, FASAE, CAE, Chief Executive Officer; Petra Hurtado, PHD, Research Director; David Morley, AICP, Editor. Subscriptions are available for $95. © 2023 by the American Planning Association, 205 N. Michigan Ave., Suite 1200, Chicago, IL 60601–5927; planning.org. All rights reserved. No part of this publication may be reproduced or utilized in any form or by any means without permission in writing from APA. American Planning Association Creating Great Communities for All