ZD Page 1 of 16 CITY PLANNING COMMISSION CITY OF NEW ORLEANS EXECUTIVE DIRECTOR. City Planning Commission Staff Report.

Transcription

1 ZD Page 1 of 16 CITY PLANNING COMMISSION CITY OF NEW ORLEANS MITCHELL J. LANDRIEU MAYOR ROBERT D. RIVERS EXECUTIVE DIRECTOR LESLIE T. ALLEY DEPUTY DIRECTOR City Planning Commission Staff Report Executive Summary Zoning Docket 049/16 Applicant: Request: Location: Henry D. Fairbanks This is a request for a text amendment to the Comprehensive Zoning Ordinance to add Bed and Breakfast-Principal as a Conditional Use in the HU-RD2 Historic Urban Two-Family Residential District. The proposed text amendment would affect regulations that are applied to all HU- RD2 Historic Urban Two-Family Residential Districts in the City. The Historic Urban designation covers large portions of the city that were developed predominantly in the mid to late 19 th century. The HU-RD2 District is present in numerous neighborhoods throughout the city, including but not limited to Uptown, Carrollton, Central City, Garden District, Mid-City, St. Claude, St. Roch, Desire, Holy Cross, and Algiers. Summary of Proposal: Zoning Docket 049/16 considers a text amendment to the Comprehensive Zoning Ordinance to add Principal Bed and Breakfast as a conditional use in the HU- RD2 Historic Urban Two-Family Residential District. The Comprehensive Zoning Ordinance distinguishes between two types of bed and breakfasts; accessory and principal. Accessory bed and breakfasts must be owner occupied, appear outwardly to be a single-family residence, may have up to four guest rooms, cannot be leased for social events, and are limited to 25% of the total habitable space of the gross floor area of the structure. Principal bed and breakfasts are more commercial in nature, and consequently may be owner or operator occupied, have no limit on floor area, permit up to nine guest rooms, and allow the leasing of common areas for social events. Currently, accessory bed and breakfasts are authorized as a conditional use in the HU-RD2 District and many other lower density residential districts throughout the city. Principal bed and breakfasts are more intensive uses, and thus are permitted in multi-family, mixeduse or commercial districts. Since principal bed and breakfasts are more intensely ZD 049/16 1

2 ZD Page 2 of 16 Master Plan: Recommendation: commercial in nature, the staff believes that they are not appropriate for lower density residential districts, such as the HU-RD2 District. The Master Plan s Land Use Plan does not provide specific recommendations for bed and breakfast accommodations. The staff recommends denial of Zoning Docket 049/16. Reasons for Recommendation: 1. Due to their intensive nature, principal bed and breakfasts are not compatible with lower density neighborhoods such as the HU-RD2 District. Accessory bed and breakfasts, which are currently allowed via the conditional use process, are more appropriate. Therefore, the staff believes that no changes to the text of the Comprehensive Zoning Ordinance are necessary and the status quo should be preserved. 2. The HU-RD2 District is located throughout many historic neighborhoods in the city, where the pattern of development is dense with minimal setbacks. Allowing principal bed and breakfasts as a conditional use may negatively affect surrounding residential properties. 3. The City Planning Commission is in the process of a comprehensive study of short term rental regulations, including changes to bed and breakfast regulations. The initial study did not include recommendations for authorizing principal bed and breakfasts in two-family residential districts. Proposing a change to one zoning district without considering other districts and regulations is ill-advised and would create inconsistencies in the Comprehensive Zoning Ordinance. ZD 049/16 2

3 ZD Page 3 of 16 City Planning Commission Meeting CPC Deadline: 07/23/16 Tuesday, May 24, 2016 CC Deadline: 60 days from receipt Council Districts: All PRELIMINARY STAFF REPORT Zoning Docket: 049/16 To: City Planning Commission From: Robert Rivers, Executive Director Stephen Kroll, Assistant Planning Administrator Prepared by: Brooke Perry Date: May 17, 2016 I. GENERAL INFORMATION Applicant: Request: Location: Henry D. Fairbanks This is a request for a text amendment to the Comprehensive Zoning Ordinance to add Bed and Breakfast-Principal as a Conditional Use in the HU-RD2 Historic Urban Two-Family Residential District. The proposed text amendment would affect regulations that are applied to all HU- RD2 Historic Urban Two-Family Residential Districts in the City. The Historic Urban designation covers large portions of the city that were developed predominantly in the mid to late 19 th century. The HU-RD2 District is present in numerous neighborhoods throughout the city, including but not limited to Uptown, Carrollton, Central City, Garden District, Mid-City, St. Claude, St. Roch, Desire, Holy Cross, and Algiers. Why is City Planning Commission action required? The City Planning Commission is required to make a recommendation on all amendments to the text of the Comprehensive Zoning Ordinance prior to City Council action, in accordance with Article 4, Section 4.2.D.3 Action by City Planning Commission of the Comprehensive Zoning Ordinance. II. ANALYSIS A. What is the reason for the text amendment? What area would be affected by the text amendment? ZD 049/16 3

4 ZD Page 4 of 16 Reason for text amendment The reason for the proposed text amendment is to add Bed and Breakfast-Principal as a conditional use in the HU-RD2 Historic Urban Two-Family Residential District. Currently in the Historic Urban Residential Neighborhood Districts, accessory bed and breakfasts are allowed as conditional uses in all districts and principal bed and breakfasts are only allowed in the HU-RM1 and HU-RM2 Multi-Family Residential Districts. An accessory bed and breakfast is an owner-occupied residence that is allowed a maximum of four guest rooms for lengths of stay up to 14 nights. A principal bed and breakfast is an owner- or operator occupied residential structure that is allowed a maximum of nine guest rooms for up to 14 nights. Adding principal bed and breakfasts as a conditional use in the HU-RD2 District would essentially permit an increase in number of guest rooms from four to nine, eliminate the restriction on gross floor area, permit the leasing of common areas for social events, and would allow operators, rather than owners, to reside at the bed and breakfast. Affected area The text amendment would authorize principal bed and breakfasts as a conditional use in all HU-RD2 Historic Urban Two-Family Residential Districts throughout the city. The Historic Urban designation covers large portions of the city that were developed predominantly in the mid to late 19 th century, after the establishment of the Historic Core neighborhoods (Vieux Carré, Tremé and Bywater). In the Historic Urban areas, major streets typically have more intensive residential or commercial uses, while minor interior streets are developed with single- or two-family residences. Therefore, Historic Urban Non-Residential districts and Historic Urban Multi-Family districts are located along Figure 1: Neighborhood Statistical Areas & HU-RD2 Districts ZD 049/16 4

5 ZD Page 5 of 16 major roads and HU-RD2 Districts are normally located one or two blocks off of major streets and encompass large swaths of residential areas. As shown in Figure 1, the HU- RD2 District is present in numerous neighborhoods throughout the city, including but not limited to Uptown, Carrollton, Central City, Garden District, Mid-City, St. Claude, St. Roch, Desire, Holy Cross, and Algiers. B. What is the existing language of the Comprehensive Zoning Ordinance? The proposed text amendment is to Article 11, Section 11.2 (Table 11-1) of the Comprehensive Zoning Ordinance. Specifically, the applicant is proposing that Principal Bed and Breakfast be allowed as a conditional use in the HU-RD2 Historic Urban Two-Family Residential District. Currently, only accessory bed and breakfasts are allowed, as shown in the table below: Table 11-1: Permitted and Conditional Uses USE 1 DISTRICTS HU-RS HU-RD1 HU-RD2 HU-RM1 HU-RM2 USE STANDARDS Bed and Breakfast Accessory C C C C C Section 20.3.I Bed and Breakfast - Principal C C Section 20.3.I A bed and breakfast is defined in Article 26, Section as a residential structure that provides sleeping rooms for overnight paid occupancy. It distinguishes between two types of bed and breakfasts; accessory and principal. An accessory bed and breakfast is an owner-occupied residence that is allowed a maximum of four guest rooms for lengths of stay up to 14 nights. A principal bed and breakfast may be owner- or operator occupied residential structure that is allowed a maximum of nine guest rooms for up to 14 nights. The current definition for bed and breakfast, accessory bed and breakfast, and principal bed and breakfast is listed in Article 26, Section Definitions, and reads as follows: Bed and Breakfast. A residential structure that provides sleeping rooms for overnight paid occupancy. Bed and breakfast is further defined as follows: A. Bed and Breakfast, Accessory. An owner-occupied building designed as either a single- family or a two-family dwelling that has been converted to a single-family dwelling, which provides no more than four (4) guest rooms for overnight paid occupancy of up to fourteen (14) nights. Common bathroom facilities may be provided rather than private baths for each room. B. Bed and Breakfast, Principal. An owner- or operator-occupied residential structure that provides no more than nine (9) guest rooms for overnight paid occupancy of up to fourteen (14) nights. Common bathroom facilities may be provided rather than private baths for each room. ZD 049/16 5

6 ZD Page 6 of 16 Article 20, Section Bed and Breakfast contains additional standards for all bed and breakfasts. In general, bed and breakfasts are limited to one per block face in residential districts and are prohibited in the French Quarter, the Garden District, and a portion of the Lower Garden District. As mentioned, the Comprehensive Zoning Ordinance distinguishes between Principal Bed and Breakfasts and Accessory Bed and Breakfasts, and accordingly there are different standards for each type. As the name implies, accessory bed and breakfasts are considered a secondary use to a single-family residence. Accessory bed and breakfasts must be owner occupied, appear outwardly to be a single-family residence, may have up to four guest rooms, cannot be leased for social events, and are limited to 25% of the total habitable space of the gross floor area. Principal bed and breakfasts are more commercial in nature, and consequently may be owner or operator occupied, have no limit on floor area, permit up to nine guest rooms, and allow the leasing of common areas for social events. Principal bed and breakfasts may also contain restaurants if permitted in the zoning district. The text of Article 20 relating to bed and breakfasts is copied below: Article 20, Section 20.3.I. Bed and Breakfast In addition to the regulations below, all bed and breakfasts shall comply with the regulations of the Department of Safety and Permits and the Department of Finance, Bureau of Revenue. 1. Bed and Breakfast General Standards (Accessory or Principal) a. In any residential district, only one (1) bed and breakfast, whether accessory or principal, is permitted per blockface. b. Bed and breakfasts are prohibited within the following areas: i. The area bounded by the centerlines of Prytania Street, Pontchartrain Expressway, Magazine Street, and the downside street of Felicity Street from Coliseum Street to Prytania Street. ii. The area referred to as the Garden District, bounded by the centerline of St. Charles Avenue, the downtown side of Jackson Avenue, the centerline of Magazine Street, and the downtown side of Louisiana Avenue, with the exception of those bed and breakfasts grandfathered pursuant to Ordinance No. 14,168 M.C.S., November 12, 1990, subject to confirmation of continuous use and legal non-conforming status. iii. In all Vieux Carré Districts. 2. Bed and Breakfast Accessory Standards a. Proof of owner occupancy shall be established by submission of proof of a homestead exemption submitted to the Department of Safety and Permits. The owner-occupant s ownership interest must be at least fifty percent (50%). b. If more than one (1) principal building exists on a lot, or two (2) or more contiguous lots have been historically acquired together and the second building was originally constructed and has been used for habitable space, as defined by ZD 049/16 6

7 ZD Page 7 of 16 the Building Code, at least five (5) years prior to the establishment of the bed and breakfast, then it may be included in the operation of the bed and breakfast. c. The bed and breakfast shall appear outwardly to be a single-family dwelling, giving no appearance of a business use other than a permitted sign. d. The bed and breakfast may have one (1) attached projecting sign not to exceed four (4) square feet in area. The sign shall complement the architecture of the structure. e. The bed and breakfast is limited to a maximum of four (4) units for overnight accommodation. f. Bedroom rental units are limited to no more than twenty-five percent (25%) of the total habitable space of the gross floor area of the structure. g. Cooking facilities are prohibited in individual guest rooms. h. If meals are provided, only registered guests may be served. i. Leasing of a common dining area for social events is prohibited. 3. Bed and Breakfast Principal Standards a. Proof of owner or operator occupancy shall be established by submission of proof of a homestead exemption (owner) or legal leasing agreement (operator) submitted to the Department of Safety and Permits. b. If more than one (1) principal building exists on a lot, or two (2) or more contiguous lots have been historically used together and the second building was originally constructed and has been used for habitable space, as defined by the Building Code, for at least five (5) years prior to the establishment of the bed and breakfast, then it may be included in the operation of the bed and breakfast. c. All signs shall comply with applicable sign regulations for the zoning district. d. The bed and breakfast is limited to a maximum of nine (9) units for overnight accommodation. e. Cooking facilities are prohibited in individual guest rooms. f. If the zoning district allows restaurants, meals may be served to guests other than those registered with the bed and breakfast, provided the facility meets all other applicable city and state codes for food service. g. Leasing of common areas for social events is allowed, provided the facility meets all applicable off-street parking requirements and complies with the noise ordinance and all other provisions of the City Code. Bed and Breakfasts are currently allowed as a conditional use or permitted use in many of the City s zoning districts. Since accessory bed and breakfasts are required to be residences, they are permitted or conditional uses in most districts that allow residential. Principal bed and breakfasts are typically permitted in multi-family, mixed-use, or commercial zoning districts, as shown in the table below: ZD 049/16 7

8 ZD Page 8 of 16 Zoning District Accessory Bed and Breakfast Bed and Breakfast - Principal Rural Development Districts R-RE Rural Residential Estate District C M-MU Maritime Mixed-Use District P P Historic Core Neighborhoods Districts HMR-1 Historic Marigny/Tremé/Bywater Residential District P C HMR-2 Historic Marigny/Tremé/Bywater Residential District P C HMR-3 Historic Marigny/Tremé/Bywater Residential District P C HMC-1 Historic Marigny/Tremé/Bywater Commercial District P P HMC-2 Historic Marigny/Tremé/Bywater Commercial District P P HM-MU Historic Marigny/Tremé/Bywater Mixed-Use District P P Historic Urban Neighborhoods Districts HU-RS Single-Family Residential District C HU-RD1 Two-Family Residential District C HU-RD2 Two-Family Residential District C HU-RM1 Multi-Family Residential District C C HU-RM2 Multi-Family Residential District C C HU-B1A Neighborhood Business District P P HU-B1 Neighborhood Business District P P HU-MU Neighborhood Mixed-Use District P P Suburban Neighborhoods S-RD Two-Family Residential District C S-RM1 Multi-Family Residential District C S-RM2 Multi-Family Residential District C S-LB1 Lake Area Neighborhood Business District P P S-LB2 Lake Area Neighborhood Business District P P S-LC Lake Area General Commercial District P P S-MU Suburban Neighborhood Mixed-Use District C Commercial Center & Insitutional Campus Districts MU-1 Medium Intensity Mixed-Use District P P MU-2 High Intensity Mixed-Use District P P Central Business District CBD-1 Core Central Business District P P CBD-2 Historic Commercial and Mixed-Use District P P CBD-3 Cultural Arts District P P CBD-5 Urban Core Neighborhood Lower Intensity Mixed-Use District P P CBD-6 Urban Core Neighborhood Mixed-Use District P P ZD 049/16 8

9 ZD Page 9 of 16 C. What is the proposed language for amendment? The applicant proposes that Principal Bed and Breakfast be added as a conditional use in the HU-RD2 Historic Urban Two-Family Residential District in the permitted and conditional use table in Article 11, Section 11.2 of the Comprehensive Zoning Ordinance. The proposed revised table is shown below with new language shown in underlined, bold text. Table 11-1: Permitted and Conditional Uses USE 1 DISTRICTS HU-RS HU-RD1 HU-RD2 HU-RM1 HU-RM2 USE STANDARDS Bed and Breakfast - Principal C C C Section 20.3.I D. Does the text amendment adequately answer the problem that is being addressed; if not, are other modifications necessary? Problem to be addressed Adding a principal bed and breakfast as a conditional use in the HU-RD2 District would essentially permit an increase in number of guest rooms from four to nine, eliminate the restriction on gross floor area, permit the leasing of common areas for social events, and would allow operators, rather than owners, to reside at the bed and breakfast. Thus, the applicant is attempting to address the current restrictions on accessory bed and breakfasts by allowing a more permissive use in the district. The proposed amendment would solve the applicant s problem by adding principal bed and breakfasts as a conditional use. Staff analysis The City Planning Commission staff recognizes the desire of the applicant to be able to operate a principal bed and breakfast in an HU-RD2 District, which would allow more guest rooms, flexibility in ownership structure and layout, and the ability to lease out common areas for social events. However, this would be an increase in the intensity of use that is not appropriate for lower density residential districts such as the HU-RD2 district. Since accessory bed and breakfasts are required to be residences, they are permitted or conditional uses in most districts that allow residential uses. Principal bed and breakfasts are more intense uses and accordingly are limited to higher density residential districts and non-residential districts. Due to their higher intensity nature, principal bed and breakfasts are not compatible with the surrounding single- and twofamily residential neighborhood. Additionally, allowing principal bed and breakfasts in only one two-family residential district would create inconsistency in the Comprehensive Zoning Ordinance as other similar districts would have different regulations. The City Planning Commission is currently in the process of a comprehensive study on short term rental regulations, which also considered changes to the bed and breakfast regulations. The initial staff and City Planning Commission recommendation proposed changes to the bed and breakfast regulations, but did not propose authorizing principal bed and ZD 049/16 9

10 ZD Page 10 of 16 breakfasts as a conditional uses in the HU-RD2 or other two-family districts. Therefore, the staff believes that no changes to the text of the Comprehensive Zoning Ordinance are necessary and the status quo should be preserved. E. Compliance with approval standards The City Planning Commission recommendation and the City Council decision on any zoning text amendment are matters of legislative discretion. In making their recommendation and decision, the City Planning Commission and the City Council are required to consider the standards in Table 4-1: Standards for Zoning Amendments of the Comprehensive Zoning Ordinance. In this section, the staff evaluates the application using those standards. The proposed amendment is compatible with the Master Plan and Future Land Use Map. This standard is not met. A land use action is consistent with the Plan for the 21 st Century (commonly referred to as the Master Plan) if it furthers, or at least does not interfere with, the goals, policies, and guidelines, including design guidelines, in the Land Use Element of the Master Plan and is compatible with the proposed future land use. The Master Plan uses a Future Land Use Map to identify which land uses should fall in each area of the City. Those areas allow certain zones that conform to the future land use designation of the area. The proposed text amendment requests that principal bed and breakfasts be added as a conditional use in the HU-RD2 Historic Urban Two-Family Residential District. Nearly all of the lots zoned HU-RD2 are located in a Residential Pre-War Low Density land use designation in the Future Land Use Map of the Plan for the 21 st Century. The goal, range of uses and development character for that designation are provided below: RESIDENTIAL PRE-WAR LOW DENSITY Goal: Preserve the scale and character of pre-war (WWII) residential neighborhoods of lower density where the predominant use is single and twofamily residential and allow for compatible infill development. Discourage the development of additional multifamily housing that is out of scale with existing character Range of Uses: New development generally limited to single or two-family dwellings, and preservation of existing multi-family buildings. Businesses and traditional corner stores may be allowed where current or former commercial use is verified. Supporting public recreational and community facilities (e.g., schools and places of worship) also allowed. Conversion to multifamily may be allowed for certain existing historic institutional, commercial or other non-residential buildings. ZD 049/16 10

11 ZD Page 11 of 16 Development Character: New development will fit with the character and scale of surrounding residential neighborhoods where structures are typically located on smaller lots and have minimal front and side setbacks. Maximum density of 24 units/acre. The Master Plan s Land Use Plan does not provide specific recommendations for bed and breakfast accommodations. The proposed amendment is compatible with the place designations of this Ordinance. The place designation for Historic Urban Neighborhood Residential Districts do not address bed and breakfasts directly. The proposed amendment promotes the public health, safety and welfare of the City. This standard is met. The proposed amendment is not expected to negatively impact the public health, safety and welfare of the City. Bed and breakfasts are required to comply with all the regulations of the Department of Safety and Permits, which should ensure the public health, safety, and welfare. The proposed amendment is compatible with the intent and general regulations of this Ordinance. This standard is not met. The proposed text amendment is incompatible with the intent of the Comprehensive Zoning Ordinance. The ordinance is intended to preserve and enhance the neighborhoods that constitute the city and to provide for the appropriate use of land. The Comprehensive Zoning Ordinance was developed with consideration of the character of the districts and the suitability for particular uses. As mentioned, the commercial nature of principal bed and breakfasts pose a threat to the character of lowdensity neighborhoods such as the HU-RD2 District. The proposed amendment corrects an error or omission, adds clarification to existing requirements, or reflects a change in policy. This standard is not met. The proposed amendment would allow a use that is permitted in other more intensive residential and commercial districts in a two-family residential district. Principal bed and breakfasts are already an existing use in the Comprehensive Zoning Ordinance and they were intentionally excluded from lower density residential neighborhoods due to their more intense commercial nature. As mentioned, the City Council has directed the City Planning Commission to conduct a comprehensive study of short term rentals, including proposed changes to bed and breakfast regulations. The initial study proposed increasing the number of nights allowed per stay, amending the blockface limitation, reducing the number of guest rooms for principal bed and breakfasts from nine to eight, allowing accessory bed and breakfasts as a permitted use in most ZD 049/16 11

12 ZD Page 12 of 16 residential zoning districts, allowing principal bed and breakfasts as a permitted use in the CBD-4 and CBD-7 districts, and removing the prohibition for bed and breakfasts in the Lower Garden District, Garden District, and Vieux Carré. Authorizing principal bed and breakfasts as a conditional use in the HU-RD2 District was not a recommendation of the initial study. There has been no change in policy that would necessitate the expansion of this use in the HU-RD2 District. Additionally, allowing principal bed and breakfasts in some two-family districts but not all would create inconsistency in the Comprehensive Zoning Ordinance. The proposed amendment benefits the citizens of the City as a whole. This standard is not met. The proposed text amendment may benefit certain citizens who wish to operate a principal bed and breakfast. However, allowing an intensive use in a low density residential district that spans most of the historic neighborhoods in the city may negatively affect many citizens. Historic Urban neighborhoods typically have dense development patterns with minimal setbacks between structures. This further intensifies the impact that principal bed and breakfasts may have on surrounding residential properties. The proposed amendment provides a more workable way to achieve the intent and purposes of this Ordinance and the Master Plan. This standard is not met. As stated in this report, the addition of principal bed and breakfasts as a conditional use in the HU-RD2 Historic Urban Two-Family Residential District is inconsistent with the intent and purposes of the Comprehensive Zoning Ordinance. While the Plan for the 21 st Century does not address bed and breakfasts directly, the language of the Residential Pre-War Low Density designation suggests that a more intensive use is incompatible with a low density neighborhood. The proposed amendment does not create a significant number of nonconformities. The proposed text amendment would add a use that is currently not permitted in the HU- RD2 District as a conditional use. Therefore, it would not create any nonconformities. III. SUMMARY Zoning Docket 049/16 considers a text amendment to the Comprehensive Zoning Ordinance to add Principal Bed and Breakfast as a conditional use in the HU-RD2 Historic Urban Two-Family Residential District. The Comprehensive Zoning Ordinance distinguishes between two types of bed and breakfasts; accessory and principal. Accessory bed and breakfasts must be owner occupied, appear outwardly to be a singlefamily residence, may have up to four guest rooms, cannot be leased for social events, and are limited to 25% of the total habitable space of the gross floor area of the structure. Principal bed and breakfasts are more commercial in nature, and consequently may be owner or operator occupied, have no limit on floor area, permit up to nine guest rooms, ZD 049/16 12

13 ZD Page 13 of 16 and allow the leasing of common areas for social events. Currently, accessory bed and breakfasts are authorized as a conditional use in the HU-RD2 District and many other lower density residential districts throughout the city. Principal bed and breakfasts are more intensive uses, and thus are permitted in multi-family, mixed-use or commercial districts. Since principal bed and breakfasts are more intensely commercial in nature, the staff believes that they are not appropriate for lower density residential districts, such as the HU-RD2 District. IV. PRELIMINARY STAFF RECOMMENDATION 1 The staff recommends denial of Zoning Docket 049/16. V. REASONS FOR RECOMMENDATION 1. Due to their intensive nature, principal bed and breakfasts are not compatible with lower density neighborhoods such as the HU-RD2 District. Accessory bed and breakfasts, which are currently allowed via the conditional use process, are more appropriate. Therefore, the staff believes that no changes to the text of the Comprehensive Zoning Ordinance are necessary and the status quo should be preserved. 2. The HU-RD2 District is located throughout many historic neighborhoods in the city, where the pattern of development is dense with minimal setbacks. Allowing principal bed and breakfasts as a conditional use may negatively affect surrounding residential properties. 3. The City Planning Commission is in the process of a comprehensive study of short term rental regulations, including changes to bed and breakfast regulations. The initial study did not include recommendations for authorizing principal bed and breakfasts in two-family residential districts. Proposing a change to one zoning district without considering other districts and regulations is ill-advised and would create inconsistencies in the Comprehensive Zoning Ordinance. 1 Subject to modification by the City Planning Commission ZD 049/16 13

14 ZD Page 14 of 16

15 New Orleans Neighborhood Statistical Areas & HU-RD2 Districts ZD Page 15 of 16 Neighborhood Statistical Area HU-RD2 Zoning District

16 ZD Page 16 of 16 May 16, 2016 Via Mr. Robert Rivers, Executive Director New Orleans City Planning Commission 1300 Perdido Street, 7 th Floor New Orleans, LA RE: ZD 049/16 CZO Text Amendment Dear Mr. Rivers, This letter is written in very strong opposition to ZD 049/16 to amend the CZO text to make Principal Bed and Breakfast a Conditional Use in any of the Historic Urban Residential zoning districts (HU-RS, HU-RD1 and HU-RD2). Principal Bed and Breakfasts are primarily commercial in nature allowing for up to nine guest rooms, restaurants and leasing for social events. The introduction of such a use in the Historic Urban Residential zoning districts is in direct conflict with the purpose statements to allow for single- and two-family developments with limited non-residential uses such as places of worship and recreational facilities. Further, the requested CZO text amendment is not consistent with the stated range of uses of the Master Plan including the limitation of new development to single- or two family dwellings (HU-RD1) and townhomes and small multi-family structures (HU-RD2). Again, Principal Bed and Breakfasts are primarily commercial in nature and the impacts including parking, social events and restaurants are not consistent with the policy of the Master Plan to Preserve and support the character of successful residential neighborhoods. Further, such a text amendment will violate an overarching goal of the Master Plan to preserve neighborhood residential character. Thank you for your attention to this matter. Sincerely, Shelley Landrieu Executive Director