Comments on LDC dated 3-31-09

Jay Jasnoch

General Comments: Articles 1-3

1. Can you demonstrate how this is really form based versus the last version of the Code? Itʼs
really more restrictive than what we had before because of the use table 2.7.2. I can see a few
bits and pieces but not enough to call it a form based code.

2. How will larger scale apartment projects be accounted for within the code as it is described?
(Senior units, market rate, etc.) As I read the code, I get the feeling that the scale of buildings in
new neighborhoods is intended to be smaller, 3-8 units per building. This is counter to what is
going on in that market. How will this fit into the requirements of the adopted rental code.
Spreading units in such a fashion is not currently economically feasible for construction cost and
in terms of long term management and maintenance. Can you clarify again what has happened
in the R2-B and R3-B districts, specifically “Applications for amendments to the Official Zoning
Map for the R3-B district shall be prohibited after the effective date of this code”?

3. How does section 3.5 relate to existing higher density zones? What happens if infill occurs on
those sites?

4.C2-B language overall is slanted to control larger site development at the expense of the
smaller more appropriate sized developments. The buffers are pretty large, parking screening is
a bit much, trash enclosure screening, etc. I think these requirements are going to push smaller
projects further from the street with larger setbacks and planted areas on larger sites. I would
look to intensify uses on the land we have available.

5. I would have liked to see the inclusion of more controls for C1-B infill, buffer and compatibility
issues. I see a lot of exemptions, with regard to parking, building guidelines, landscape
requirements, etc. Table 2.2-2 combines the old C-1 and C-2 into the C-1B. May need to
consider the impact of redevelopment projects within this newly expanded area.

6. Street widths as indicated by Table 3.11-3(LDC) in comparison to Comprehensive

Plan Street types as depicted in section 4.2(CP). This needs attention. Are street
widths and ROWʼs meeting the requirements of the CP? I would like to see other street width
options then the standard 60-66 ft ROW as proposed in the LDC.

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Article 2 Comments:
Use Table 2.7.2 - Needs a lot of work. These are a few things I can see quickly.
• Many existing uses are not recognized.
• No real incentive for Floating Zone NC-F due to building size restrictions. May not make
economic sense without some more synergistic commercial uses clustered together of
more significant size.
• Too many uses require a Conditional Use permit or process. Not very pro-development or
business growth.
• Do PE uses allow new uses as well i.e, would a new drive thru business be permitted in
downtown core?
• Contractorʼs office not allowed in C2-B, but we have several.
• Conflicting use of terms Industrial & Commercial use when one use is defined under
industrial and allowed under commercial, but others are not or are restricted (conditional).
Lumberyards would be an example of this.
• Light assembly or Industrial uses not allowed in C2-B, but we have several.
• Mixed use is back? But only use by underlying base zone seems counter productive.
Could you explain a possible project this would work for? How would mixed use be
encouraged by the LDC as defined on p32? What is the process for developing? If we
want mixed use why did we take it out of the comp plan as a potential zone?
• No bus or transit stops downtown? Doesnʼt seem right.
• Please refer to uses previously allowed under existing code in C-3. (see below) The chart
needs to reflect the uses currently permitted under the zone or...
Sec. 34-848 (b) Permitted uses. Permitted uses in the C-3 gateway district are as follows:
(1) All non-residential permitted uses in the C-2 district.
(2) Office showrooms and office warehouses.
(3) Motor vehicle sales and service.
(4) Recreational equipment sales and service.
(5) Boat and trailer sales and service.
(6) Auto/truck washing services.
(7) Farm implement sales and service.
(8) Lumberyards and construction material sales.

Sec. 34-847. Downtown fringe district (C-2).

(b) Permitted uses. Permitted uses in the C-2 district are as follows:
(1) All non-residential permitted uses in the C-1 district.

Sec. 34-846. Downtown district (C-1).

(b) Permitted uses. Permitted uses in the C-1 downtown district are as follows:
(1) Commercial establishments of no more than 30,000 sq. ft. on the ground floor offering merchandise
or services to the general public. Such establishments include but are not limited to the following:
a. Retail establishments such as antique stores, second hand goods stores, grocery stores, hardware
stores, drugstores, department stores, clothing stores, furniture stores, restaurants, and on and off sale
liquor establishments. Drive-through facilities shall not be allowed for restaurants in this district.
b. Personal services such as laundromats, barbershops or beauty shops, shoe repair shops and
photography studios.
c. Professional services conducted in offices of a general nature, such as medical and dental clinics,
veterinary clinics, finance, insurance, research and development, E-commerce businesses, publishing,
software development, real estate, architects' or attorneys' offices.
d. Repair services such as jewelry and radio and television repair shops.
e. Entertainment, cultural facilities and services, and amusement services such as motion picture
theaters, concert or music halls, and bowling alleys.
f. Hotels.
g. Dance, health, and fitness studios.

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h. Artisans' workshops.
i. Light, limited manufacturing of goods that are sold at retail on the premises.
(2) Public and semipublic buildings such as a post office and fire station and park space and plazas.
(3) Private clubs.
(4) Apartments (new or converted from other uses), provided they are located above the street level
uses or behind a commercial use on the street level and are no more dense than allowed in the R-5
district.
(5) Automobile parking lots.
(6) Public utility facility that has the following characteristics:
a. Is not intended for human occupation;
b. Occupies an area of less than or equal to 500 square feet; and
c. Does not exceed the height of the highest building on an adjoining lot or an average grade to peak
height of 17 feet, whichever is less.

Section 2.9.11 - Mixed use. First you put it in under the previous comp plan - include it in the
Land Development Code, but donʼt define it so I canʼt use it. Now you take it off of our site in
the comp plan and put it back in the LDC? You guys are killing me...
Really, whatʼs the intent? How does it get used and whatʼs the process for it.

Having a mixed use development, but separating adjacent lots by use and then encouraging
mixed use just seems wrong. If your going to have mixed use make the whole site mixed use
otherwise its just hot air and more of the same separate uses by lot. Really no different than
what weʼve had all along - in my opinion.

2.9.12 Multi Family Dwellings in N1-B District needs some discussion. Certain product and size
are constraints for this market. Will Table 2.9-3 Replace park dedication requirements?

2.10.2 Accessory Uses. General Uses (2)(a)-Not that I see myself doing a lot of these, but it
may be a bit difficult to stay under 10ft for roof height in some cases. Really depends on how
you are measuring and if you are thinking the structure is less than 10x12 or so. Looks like a
big dog house.
Figure 2-4 p.63 not the best picture.

Table 2.10-1 Permitted Accessory Uses and Structures. Why canʼt we have a porch on a
building in the C2-B zone, or C1-B for that matter. (See 1531 Clinton below.) Buildings on
some C2-B sites that are near or adjacent to residential areas really should be able to be more
sensitive to the residential scale and character. A porch works great for this and also is an
excellent way to dress up an entryway.

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2.11.4 (D) Model home language regarding number of models per builder or developer
restricted to one.
Only allowed on lots approved by development agreement. This language is not very flexible or
clear. Is it one model per developer/development or one for each builder in a development or
totally negotiable via the development agreement? I think this section needs a bit of refinement
to relate to our local climate and construction statistics. Maybe Steve has some input on this.

2.12.2 (B) Determination of Nonconformity status. Burden rests on the owner. See next.
2.12.3 (A) (1-2) Nonconforming pre-existing uses. We have a few uses currently in our
developments that were allowed under the existing or previous code. According to the new
code these will be considered nonconforming. I have some serious concerns about this, as the
buildings have been designed for the specific use allowed as well as the IBC (International
Building Code). To remove the use allowed makes the building not marketable for the intended
purpose. Due to location, building configuration and design constraints what options will we
have. Obtaining uses by conditional use permit/process is really inflexible and time consuming.
This should be cleared up by the use Table 2.7.2.

Article 3 Comments:

Table 3.2-1- Multiple Items to consider.

• N1-B Multi family dwellings min. and max. lot size may not be correct for larger buildings.
Really establishing a limited Multifamily product of 3-6 units. Will this scale be appropriate
within the N1-B, and how does it incorporate into the current rental code.
• Table 2.3-1 Multi family dwelling may need to be under 6 per site based upon max width of
150 feet. Or can they be 2 story with units above and below for around 12 units per lot? This
could use some investigation.
• Min. 18 inch finished ground floor should be reconsidered for multifamily as State and
Federal building codes control accessibility of units. At least for units required to be
accessible (2007 State Amended Building code IBC -requires 1 unit to meet accessibility
requirements in each unit between 1-25 units).
• 30 foot front yard setback does not allow Multifamily units in R2-B or R3-B to engage the
street. Any incentive to create units in a more compact ʻurban town homeʼ configuration may
be helpful. More on this under Architectural Standards.

3.2.2 Will redevelopment projects in the C1-B district be required to adhere to the 75 feet
maximum lot width requirement. How would this play out on the River Park Mall site or Econo
Foods? Just curious.

3.2.3 C2-B District Site Development Standards

(A) Still have a hard time with 20,000 sf minimum lot size. Commercial lot prices are pretty high
for smaller businesses to purchase land. Requires a multi-tenant building or commercial
condo.
(C) “front build-to line shall be within 30 to 65 feet of a lot line” is actually greater than what the
previous C-3 setback used to be. The use of “within” is a bit confusing. I assume 30 feet is the
closest we can have a build to line. Maybe you could clarify it. If your intending to get the
building closer to the street then the language should reflect that more clearly. We have several
buildings in the Schilling Business Park that have a 20ʻ setback and may also be located on a

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corner. (As in the case of River Valley Professional building.) The 30ʼ setback (or build to line)
will be counter productive in some instances, where the creation of an interesting street scape
and a pedestrian “friendly” environment are needed. Iʼve attached that previous code section
for reference.

Sec. 34-848. Gateway commercial district (C-3).

(1) Lot area: 20,000 square feet.
(2) Lot width: 66 feet.
(3) Front yard: 20 feet from service street.
(4) Rear yard depth: 20 feet.
(5) Side yard, interior lot: One-half of building height (minimum of ten feet).
(6) Side yard, corner lot: 20 feet.
(h) Maximum height and building size.
(1) Height. 50 feet, unless authorized by conditional use permit.
(2) Ground floor building size. 80,000 sq. ft. Larger ground floors shall only be allowed through the approval of a
planned unit development.

3.2.7 ED-F District Site Development Standards - Same lot comments as above. This section
reminds me a lot of the old mixed use in the previous code. Itʼs obviously written with a specific
site in mind. What happens if it needs to be applied to a smaller infill site? Has anyone from
the EDA really read this - isnʼt this their baby? Will it be flexible enough to allow something
other than what you define it as on page 20? What is the implied scale of “corporate
administrative offices and medium size research and development firms”? For an “urban
campus” it really doesnʼt have many permitted uses that would make it urban - most are by
conditional use.

3.3 General Development standards.

3.3 (D) Retaining walls
(2) “Over 48 inches, measured from the top of the footing to the top of the wall” would be about
a 12” retaining wall with a frost footing. Most retaining walls require a significant foundation
unless they are a modular unit like an anchor block wall system.
Figure 3-14 - limits height to six feet per terrace, Is the same system of measurement to be
applied?

3.4.2 Reverse Frontage Prohibited -Strictly for residential?

(2)&(4) Will be interested to see how this plays out in new developments, may create a larger
ratio of alley configurations around the perimeter. Some of this may depend on the existing
street types and developed abutting parcels. I assume the cost of maintaining the alley will fall
back on the home owner at some point, these lots will be more expensive for some housing
types.

3.4.3 Architectural Design Requirements for Multi-Family Dwellings.

(B) Orientation of primary entrances. Figure 3-17 depicts a town home development not a multi-
family apartment ʻcomplexʼ. Requiring larger Multi-Family primary entrance to orient to the
street may be not fit existing site layouts, irregular configurations or street layouts. I would
also note that the street layout shown is a combination of public and private streets. In other
than looks to the street, I am not sure you can change how ownerʼs and their guests will
enter the building. My guess is most people are not going to park on that outside street to
enter the apartment or town home. What will the guidelines be that dictate private street
width and design?
(C) Design of Front Facades
• These standards and wall offsets are all really too Norman Rockwell for me.

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• Figure 3-18 is funny since the image on the right still meets three of the design features listed
in the design standards.
(D) Design Features of Side Facades
(1) “Side facades within 25 feet of vacant land zoned for residential uses shall incorporate a
minimum of 15 percent facade area glazing.” Why? This number is pretty high, especially for
larger buildings that may actually face south. Why donʼt you offer some incentives for 4 sided
articulation and architectural detail/finishes? Maybe reduce or offset development fees.

(E) Building Foundations (1)&(2) - Raised finished floor - What about slab on grade structures?
Also not always great for an aging population. Not making these affordable.
3.4.4 Architectural Design for Nonresidential Buildings
(A) Applicability- This section shall apply to development in the C2-B and ED-F districts. What
about redevelopment in the C1-B district which now includes the old C-2 district.

B(4) Building Design and Mass - All architectural elevations of principal buildings shall consist of
a base, a body, and a cap. Not sure I like the proportions as set for in the next section.
Language defines a particular style by percentages and ratios based upon building height. Not
sure all buildings need to fit under this, sure hope mine donʼt. How does this apply to new
school construction or public buildings? New Middle School would not have fit these
requirements.

(5) Roof styles- “The height of any pitched roof shall not exceed one-half of the overall building
height.” This is a dog house generator. Are you saying the pitch can only be one half of the
height (i.e. a 12ʼ tall building can have a maximum of a 6:12 slope) or that the roof can only
be 6ʼ-0” tall? Either way for buildings of any size, this will lead to lower appearing sloped
roofs. Also not very practical for Churches. Why are we restricting roof pitch?

3.4.5. Design Requirements for Large-Scale Nonresidential Buildings- Will this section be
applied to redevelopment projects in the C1-B ? (i.e. Grocery, Liquor Store, Library, Safety
Center, ʻQʼ block redevelopment etc.

(2)(b) “Roofline changes shall be vertically aligned with corresponding wall offset” will not allow
for asymmetrical design.
Figure 3-22 This image really scares me. I understand using it to illustrate offsetting the roof
edge in order to create an interesting building edge condition. Itʼs the fake second floor that
gives me the willies. It also illustrates the symmetry of a certain design style. The same is true
of Figure 3-23.
(3) Flat roofs - “When used shall be concealed with three-dimensional cornice treatments.
Cornice shall include an 8” perpendicular projection from the facade plane.” There may be
instances where this would be appropriate based upon context, but certainly not always the
case. Also adding a considerable expense in order to match a certain historic style is not, in
my opinion, very sustainable or responsible. Not sure how these would apply to the range
of different building scales this code may regulate.
(4) Asymmetric or Dynamic Roofs- allowed as long as they have fake 8” cornice projections.
This may actually defeat the purpose of having a “Dynamic” roof.

3.4.5 (5)(a) 25% Glazing for building elevations directly fronting public streets. What about
buildings that have 2 or 3 sides facing public streets? Thatʼs a considerable amount of glazing
with obvious heating and cooling load requirements in our climate. For some building types

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this may work, but certainly not all. Most of the sections here really point to commercial strip
buildings and are treating all buildings the same. Not even sure that the commercial buildings of
the last decade are that far off base. Can we get to the fundamental intent of this requirement
and then see if there are some other methods to pull it off?
(b) Not sure design by equation is going to help here. Now we need to have Staff and or
the PC, determine the acceptable design for client. This could lead to some project delays and
additional process time for what?

(d) Description implies masonry construction by use of terms like ʻlintels and sills,ʼ not all
buildings will use masonry at windows and doors. Are you expecting all brick construction?
This is also not optional but as written states “ All doors and windows shall be articulated
through the use of lintels, sills, and thresholds.” The statement limiting windows to 20 sf
(unless for display) without dividing mullions has no relation to overall building scale or
design concept. Thatʼs roughly a 3x7 foot side light next to an entry door. These are
stumbling blocks for dealing with buildings/projects of different scales. What may be
appropriate for one may not be on a larger building.

(6) Customer Entrance Design. Language again implies strict retail business buildings. List of
features may not always yield the result you want. Use of unique landscape, concrete walk/
pathways, site lighting, building massing and other scale appropriate details should be
credited. Not sure the design features fit all building types. May be fine for strip buildings
and controlling bigger boxes but thatʼs about it.

3.5.3- Exemptions from Neighborhood Compatibility Standards-

(C) Define or locate “existing mixed use developments” as we have none recognized by our
zoning ordinances.

3.5.4 (C) (1)(a) Staff to confirm validity of data presented? What level of certification or
documentation will be required. Survey?

3.5.5 - Standards for Development in NC-F district will not work for previous Mixed-Use guided
sites. What District will?(Behind Target) It was my understanding early on that this would work,
but it is clear that as it has come forth itʼs really a different smaller animal. How do you
proposed to remedy the change that has occurred from the previous comp plan to the current
on this and St. Olafʼs site?

3.6.3 - Assume submitted to and approved by DRC?

3.6.4. -(2)(a)-not all commercially bought plants come with a ʻlabel.ʼ

3.6.4.-5 (a&e) - Deciduous trees of 2.5 diameter are too large to support on larger scale
projects. Require a significant amount of water for a considerable time after planting. Could
this be on a sliding scale similar to diversity table? Maybe form 1.5 - 2.5 based upon # of trees
planted. Also has to do with sequencing of projects and obviously how much money you sit on
in escrow from developers. Shrubs of 2 feet minimum tall are too large for some planted areas.
Also require significant water support.

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(f)- Grass like lawn turf on larger scale projects may not be the most sustainable plant material.
Language such as ʻnormally grown as permanent lawns in Minnesotaʼ implies turf grass. Is
Prairie grass and acceptable substitute? And if so...
(g) If Prairie grass is considered ground cover, its hard to have a ʻfinishedʼ appearance after only
one growing season.

3.6.5 (E)(1) 30% paving could be tough for 3 car garages on certain lot types.
(4) Single dwelling parking, can you define ʻtemporaryʼ here? Are you saying you canʼt leave
your car in your driveway (which is street side setback) for...a week, without moving it? Who
will enforce this?
3.6.6 (a) one tree per 50ʼ required for all zones, on all public streets? Not super clear here.

3.6.7 Tree and Woodland Preservation - Iʼll do it if you have to...oh wait, youʼve exempted the
City again. 3.6.7 (D) I say lead by example.

3.6.7 (2)(a-c) Especially (b) I can cut the tree and you can have its replacements, yeah right...or
(c) if trees are cut, you canʼt develop until you replace them. I wonder how this would pan out
for the trees cut by the dam on the Cannon River last Summer? This section could use a bit of
help.

3.6.8 Parking Lot Landscaping

(c)(1) (a) 10ʼ landscaping strip between parking lot and city right of way, seems a bit much on
certain streets pending R.O.W and street type.
(b-e) - Are we going to have a lot of screens or gates between property lines that act like
barriers rather than encourage connections, pedestrian or other. Fast forward 10 years.
Maybe should encourage smaller parking zones, tighter lots or smaller vehicle parking choices
as options as well.
3.6.8(2) Side or rear property lines 6ʼ landscaped buffer still apply in downtown zero lot line
configurations for redevelopment?

3.6.8(C)(3)(a)Parking Lots Adjacent to Residential Uses - Barrier design mentality - A four-foot

high solid decorative masonry wall or fence, is this really what you want? Seems like we should
be encouraging more scale sensitive buildings in those areas. The use of appropriate setbacks,
landscaping and smaller parking or better yet on street parking to connect the land rather than
divide it - may also promote better design. I am not sure a 4ʼ wall is better than a sensitive
design.

3.6.8(D)(1)(a) Needs a diagram - 5% of gross parking and drive area landscaping within each
parking area. Are you saying islands? Will this apply to C1-B redevelopments or City/School
projects? If not, why?

(b&c) These numbers are significant for landscaped Islands. 10% of gross area for a 10,000 sf
building with 40 stalls(15,850sf) will require a 10ʼx150ʼ ʻlandscaped area. Your trees sizes are
vastly different then those required in other sections. How do these numbers relate to buffer
areas in section 3.6.9? Will this apply to C1-B redevelopments or City/School projects? If not,
why?

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3.6.9 “Define properly mitigate the negative effects of contiguous incompatible uses?”
Thought the intent of the code (or form based code) would allow multiple uses to coexist without
“mitigating.” Can you explain or provide and example in the City? Why is C1-B exempt, see
section 3.6.9(A)(2) and then shown in table 3.6-3: required Buffer Areas. What will dictate
redevelopment within the core abutting residential? Will that also be the case for
redevelopment along the Hwy #3 near the core?(say ʻQʼ block)
(C) Structures- Structures not allowed within a Buffer area. Does that also include a place
holder for public art and or gazebo/sidewalk resting area, bike rack, etc. Thinking about the
space near the front of the property close to the sidewalk but between properties.
3.6-3: Required Buffer Areas: NC-F shows no buffer required yet P.113 calls for screening with
4ʼ high fences and plantings.
Table 3.6-4: Minimum Planting Requirements “B” calls for 3 Evergreens every 100 lineal feet.
For downtown to R1-B or N1-B residential uses. Are evergreens the right tree for this in the
downtown assuming you forgot you were exempt?

3.6.10(c) Screening at least one foot higher than the item to be screened but not less than six
feet in height along 3 sides. This is a substantial “screen”, are we screening trash enclosures to
that height? Typically these have to match the construction of the primary building which will
require foundations, and matching finish material. Does this also apply for ground mounted air
conditioner condensers?(3.6.10(B)(5)) When is a wall required versus just planted material.
Again an issue of scale for some of the smaller commercial properties.

3.8.3 General Provisions (E) Vehicles for Sale- This could be problematic for a resident to just
sell their car. What are we getting at here?

3.8.4(1) Why canʼt on street parking be “credited” at a certain rate. You should be able to count
stalls along building lot street frontage.

3.8.4(3) Implies you know the intended uses prior to construction which is not always the case.
Usually come up with a best guess scenario of possible uses, then discuss with DRC. Will this
still be possible as this section is worded? ʻUnless otherwise noted or approvedʼ by who?

3.8.5 Off-Street Parking Space Requirements - (C) Uses in the C1-B are exempt from these
requirements. What about redevelopment within the C1-B. River Park Mall area, Lansingʼs
Block, etc. Are you encouraging much larger buildings and potential parking needs without
addressing how the parking will be accounted and paid for? What about a parking ramp fund?

Table 3.8-1: Number of Parking Space Requirements

Multi-family uses still require 2 stalls per dwelling for the most part, no credit for on street
parking. General Office space lost one space per thousand based on previous code, and
Medical picked up one. This also implies that the use is always known before building
construction, or that parking will be easy to add when a use is changed, which is not easy to do.
Will the requirement to meet this chart cause problems when use changes occur? (i.e.
Northfield Urgent Care Clinic at Heritage Retail) This table could use some discussion.

3.8.7 (A)Bicycle Parking one space for every five parking spaces. Is there a cap on this? It
could get a bit out of hand for a larger scale project. (185 parks requires 37 bikes.)

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3.8.8(A)(1)(a-c) Particularly (c) Are only additional spaces above the 10 percent by right
required to be pervious? Or all additional spaces? What if the siteʼs surface water runoff
retention has already accounted for the additional parking? Just not installed until needed.
3.8.9(D) 8ʼ Distance from building to parking lot curb, 3ʼ min. landscaped area with 5ʼ min. walk.
Can this have some wiggle room? Be an average along the face. Have a bit of variation?

3.8.10(A)(2) 20ʼ queuing area before parking stall or parking lane. Tighter sites will find this
difficult. Figure 3-36 shows a building in a zero lot line or build to line configuration without
setback from property and street. I do not believe this is possible in the C2-B. It does not reflect
the queuing area from the street to the property within the Right of Way. Can this be counted as
on site queuing?

3.8.10(D)(2) Compact parking stalls only when 50 or more total stalls min 5% - max 20%. This
range is fine but why canʼt we encourage compact parking in some of the smaller lot
configurations < 50?

3.8.11(C) “Additionally all sidewalks and crosswalks shall be constructed of an impervious

surface and shall be visually distinct from the driving surface by use of pavers, bricks or scored
concrete” Figure 3-38 doesnʼt actually show what your asking for. As written this will require
concrete or pavers through the bituminous drive lane. This is excessive for smaller
developments.

3.8.11(D) 8ʼ wide side walk at customer entrances with clear passage equal to the 8ʼ with means
car overhang. This would be about a 10ʼ walk in front of smaller commercial buildings.
“Additionally, such sidewalks shall connect all customer entrances and to other internal
sidewalks” is a lot of concrete! This scale is off for smaller buildings. Why is this size the
standard for all? Is this also intended for professional/service related businesses besides
straight retail?

3.9(D)(2) Side walks 7ʼ from back of curb in all street configurations? May want some possible
options in mixed use or higher intensity areas.

3.10.3 Energy Conservation Design. Specific to residential lot layouts or... Can you translate
how increased concrete, impervious surfaces, increased glazing requirements regardless of
solar orientation, larger site dimensions - translates into Energy Conservation? This is for land
subdivision, but some of our design guidelines are counter productive.

3.10.4 Development Agreement (C)(3)(a-e) No grading until plat is filed at County Recorders
Office. Not even rough site grading and preliminary street layout. I think this will greatly impact
construction schedules and the development of feasible projects in our climate. This needs
more discussion.

3.10.4(D) (2&5)Time of Performance - 6 months may not adequately cover an extension from
Nov. 15 to April 15 is 5 months off for Winter. Really only gives you 1 month to finish. Canʼt
these terms be addressed in the development agreement. You have a lot of paper work to redo
for no reason.

3.11.2 (G) Double Frontage Lots- Does this also apply to commercial subdivisions? Doesnʼt
seem like it should.

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Table 3.11-2 Access Spacing - 660 feet is not really helpful for infill projects.

3.11.8 Sidewalks installed at time of street construction. Type of project and phasing should be
considered. Also inclusion of public plazas and or points of interest along the walk or integrated
in the walk during construction of the project may be beneficial. Difference between commercial
and residential projects. Also a question of resources and when to provide them. All walks
need to be maintained at a considerable expense if there is no construction or use to support
them. Not exactly energy conscious.

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