The URL can be used to link to this page

Home My WebLink About07-22-26 Public Comment - W. Rankin - Comment on Application 25779From:Will Rankin To:Bozeman Public Comment Subject:[EXTERNAL]Comment on Application 25779 Date:Wednesday, July 22, 2026 12:56:08 PM Attachments:Rankin Application 25779 Comment.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. Good afternoon, Attached is a public comment regarding application 25779. Best regards, Will Rankin, MS Public Comment Regarding Application 25779 July 22nd, 2026 Department of Community Development City of Bozeman PO Box 1230, Bozeman, MT 59771-1230 Re: Comment on Proposed Subdivision at Laurel Meadows, Application 25779 Dear Department of Community Development, I submit these comments concerning the proposed subdivision at Laurel Meadows, application 25779. Based on the administrative record currently available, I am concerned that the application does not yet demonstrate compliance with applicable Bozeman Municipal Code provisions, including sections 38.750.090, 38.710.010 through 38.710.050, and 38.750.080(D), nor with Montana Code Annotated sections 76-25-4 and 76-25-408(8)(c). The subdivision review record must support findings that the proposal complies with the applicable zoning and subdivision standards, that the decision rests on facts in the administrative record, and that any conditions or mitigation are supported by the regulations and statutes cited in the decision. Under MCA 76-25-408(13)(b), the written decision must identify all facts supporting each finding and each condition, along with the regulations and statutes used in reaching those findings. At present, the environmental analysis appears incomplete and, in important respects, unreliable. The record appears incomplete and unreliable with respect to wildlife and vegetation conditions, because it does not account for all species both currently and reasonably present on or near the site, including upland game birds, amphibians, small mammals, and matured trees that are distinctly visible and/or clearly heard on the proposed site from public roadways surrounding the proposed project site. The omission of species reasonably expected to occur on the property undermines the factual basis needed to determine whether the proposal complies with the applicable subdivision standards and whether additional impacts have been adequately identified and analyzed. I am also concerned that the applicant has relied on distant drone imagery captured in winter to support their claims that the wetland areas are not highly functional and that vegetation is limited and/or absent. That is not a sufficient basis for factual findings regarding vegetation, habitat conditions, or wetland character. Seasonal, long-distance imagery may obscure deciduous trees, understory vegetation, riparian buffers, and other site conditions that are material to environmental review. The applicant’s conclusions are not adequately supported by site-specific evidence, and the City should not rely on generalized or seasonally limited imagery in lieu of a proper field investigation. I am also concerned that the wetland delineations being referenced were conducted in 2006 and 2021 and therefore do not reflect the status of the wetlands in 2026. The application documents site conditions as they existed at the times the delineations were conducted, but cannot by themselves establish the present extent, function, or ecological condition of the wetlands after several additional years of altered hydrology, seasonal change, and site disturbance. Indeed, later project materials indicate that wetland boundaries and hydrologic conditions have changed over time, which emphasizes the need for current, site-specific field verification before the City relies on any earlier delineations in making findings or approving fill, conversion, or mitigation of project sites. The permanent fill and conversion of Wetland #3, identified as the largest wetland in the project area, should not be approved absent a rigorous, current, and independent assessment demonstrating both the wetland’s functional condition and the necessity of any proposed impact. I am also concerned that the proposed filling and conversion of Wetland #3 would unnecessarily eliminate an existing and apparently flourishing wetland resource. When viewed from public roadways surrounding the proposed project site, many trees and other vegetative species can be observed surrounding what is now a pond, that also supports many visible and audible animal species. This is especially evident during spring, summer, and fall. The record should not treat the permanent loss of a functioning wetland as a routine mitigation issue, especially where the applicant has not provided a credible, site-specific, and current analysis demonstrating that the wetland lacks meaningful ecological function as of 2026. Given the deficiencies in the applicant’s environmental analysis, including the reliance on misleading or seasonally limited imagery, seasonally limited and dated assessment periods, and the failure to account for all relevant site conditions and species, I request that the City independently reassess the wetland’s functionality before accepting any conclusion that fill, or conversion is appropriate. The City should require a current, field-based evaluation of wetland functions, vegetation, hydrology, and habitat value, rather than relying on dated, unsupported assertions that minimize the resource. I also object to the applicant’s characterization of the proposal as “much-needed housing.” That claim is incomplete and potentially misleading considering recent reporting that Bozeman’s overall housing vacancy rate is approximately 11%, a level above what experts consider healthy. While the City may still consider whether certain housing segments remain constrained, the existence of substantial vacant inventory means the applicant should not be permitted to rely on generalized housing-shortage rhetoric as a substitute for a project-specific showing of need, affordability, and public benefit. Given that the applicant is designating the proposed housing as non-deed restricted affordable housing, I request that the City require the applicant to provide exact descriptions of individual house layouts, square footage per each individual unit, and projected sale pricing for each unit. Following this, I request that the City determine whether these metrics fall within the City and state standards for affordable housing granted the lack of deed restriction prevents limiting pricing and determining who is allowed to purchase these units regardless of individual and/or family income. Because public comment that provides evidence of noncompliance or new or significantly increased impacts requires further review under MCA 76-25-408(8)(c) and 76-25-408(9), I request that the City require the applicant to submit additional data and analysis addressing the following: • Wildlife resources present or reasonably expected to be present on the site, including previously undocumented upland game birds, amphibians, small mammals, and vegetative species. • Wetland boundaries, vegetation, riparian conditions, and tree cover, verified by current site-specific field observations. • Stormwater, drainage, erosion, and sedimentation impacts. • The functional condition of Wetland #3 and the necessity of any proposed fill or conversion. • Any new or significantly increased environmental impacts not previously identified in the record. • The specific basis for any claim that the project provides “much-needed housing,” including what type of housing is alleged to be needed, who the units are intended to serve, and how the project advances affordability rather than merely adding units to an already substantial vacancy market. In addition, I request that the City make explicit findings supported by the record before approving the subdivision, and that any approval include conditions sufficient to ensure compliance with the applicable municipal and state requirements. If the applicant cannot provide a complete and credible environmental analysis supported by current, site-specific observations, I request that the application be denied or returned for substantial revision. For these reasons, I request that the City defer action until the applicant submits a complete, accurate, and site-specific environmental record sufficient to support the findings required by law, along with fulfilling all other requests made in this comment considering the evidence of non-compliance. Sincerely, William Rankin, MS 5073 Dragon Fly St, Bozeman, MT 59718 wrankin250@gmail.com, 307-250-6752