Date: March 25, 2013
To: Dr. Bruce Liese, Chair, Lawrence/Douglas County Planning Commission
From: Laura Routh, Chair, Lawrence Association of Neighborhoods (LAN)
RE: TA-12-00206 Text Amendment to the Land Development Code – Eliminating Requirement That development projects are required to comply with the Comprehensive Plan
LAN objects to Text Amendment 12-00206, which directs that the Planning Commission and the City drop the current requirement that development plans comply with our community’s comprehensive plan. We request that the Planning Commission reject the proposed text amendment, for the following reasons:
1. Negative Impact: This change to the land development code is significant, deleterious, and we believe it will negatively impact our community’s ability to engage in transparent and rational land use planning. We concur with Staff’s assessment that “The proposed text change could also be seen as a decision to downgrade the community vision and fabric of the plan, and discount the time and effort the community has put into the development of Horizon 2020, adopted future land use plans and other documents based on the comprehensive plan. Removing the requirement could also reduce the certainty and predictability the plan provides to citizens and property owners making improvements in the community.”
The land development code serves as the foundation for all project review.Eliminating the requirement that projects adhere to our comprehensive plan removes crucial public documentation of the planning process, and thus fails the test of due diligence. This change would have long-term and negative effects on our community’s planning processes.
2. Inadequate justification: Staff has not adequately demonstrated the need for this proposed text amendment. While the planning director cites the benefits of this text amendment as “streamlining” and making the development process more “business friendly”, neither claim is substantiated with any objective research or data.
3. Lack of procedural transparency: This text amendment was initially proposed by a select group of people, largely representing development interests. The initial meetings held on this matter occurred without public notice, and did not include the participation or consent of neighborhood and community groups. The process by which this text amendment was brought forth is inherently flawed, thus the amendment should be rejected. Should there be any future consideration of this amendment, the process must include public review and engagement from the outset.