Memorandum TO: Peggy Fiandaca and Curt Dunham, Partners for Strategic Action Inc. FROM: Jessica Sarkissian, CMX DATE: September 4, 2008 SUBJECT: Proposed 2008 Draft Comprehensive Plan Comments This memo comments on the proposed Pinal County Comprehensive Plan Update dated 2008. These comments were requested by the County for the document adoption public participation process. Please let me know if you have any questions or comments. Introduction Page 2 the Plan endeavors to conserve resources that can nurture additional development What kind of resources, environmental, capital, or etc.? Chapter 3: Sense of Community Page 39 Medium Density Residential (4-8 du/ac) includes suburban-type development that is intended to be predominantly single-family detached residential development. -Wouldn t town homes, duplexes, attached single-family also work in this density? Page 58 Page 76 Guidelines for Conservation Easements include should be switched with Guidelines for Transfer of Development Rights include, I believe these were accidentally switched the guidelines do not match the headings. All of this planning within the region will set the tone for future development. What is the projected tone, if one yet? The freeway is currently funded to the Pinal County line. Will this cause a bottleneck or be fixed how? Page 77 The parcel includes areas that are very developable and other areas that include more challenges to development. What areas are these? A map showing developable and non-developable areas would be helpful. 1
Page 78 Page 79 intensities at an appropriate scale What is an appropriate scale? densities in an appropriate and complimentary fashion within neighborhoods Complimentary and appropriate according to what? Locate compatible and uses along major transportation routes... What are examples of compatible uses? Utilize a systems approach to environmental planning Please define/ clarify. Page 80 Is the West Pinal Growth Area going to be compatible with adjacent uses located within the Indian Reservation? Chapter 4: Mobility and Connectivity Page 98 Is the Public Access standards section consistent with the Pinal County SATS? Parkway and Enhanced Parkway Access standards could possibly be difficult for commercial corners. Chapter 5: Economic Sustainability Page 134 Need to further define Employment Reserve and land banking. How or would this apply to privately owned lands? Chapter 6: Open Space and Places Page 138 Proposed Open Space areas are those areas that had not been previously identified by any entity as existing or planned open space. This seems like it could generate some possible conflicts or issues. Needs to be more clear. Page 140 Further define what is required in the Site Analysis which is required with the submittal of the OSRP. Chapter 7: Environmental Stewardship Page 157 Encourage reduction in the miles of unpaved roads What about keeping with the rural character as mentioned in other areas? 2
Require the developments in unincorporated areas to be required to demonstrate a 100 year physical availability of water as a condition of zoning approval, and Page 166 Resources should prove the physical availability of water based on the development s proposed plan. How can this be achieved? What kind of physical proof are you looking for? Studies? Pictures or etc? Chapter 8: Healthy, Happy Residents Page 195 Use Development Fees to cover the incremental costs of new facilities and do not attempt to correct existing deficiencies. Why not attempt to fix existing deficiencies? As in the area of Hunt Highway, which is an existing deficiency, developments much further south down the road, would also benefit from such an improvement with decreased traffic and increased mobility to the area. Chapter 10: Implementation The Pinal County Comprehensive Plan s criteria for determining a major amendment to the Comprehensive Plan includes Any change in employment land use classifications of 20 or more contiguous areas to a residential land use classification. Page 202 Does this include decreasing the acreage? Additionally, the following also constitute a non-major amendment Land uses that meet the vision, goals, objectives, policies, and location criteria within the Plan but may not be specifically shown on the Land Use or Economic Development Plans. What about areas less than 100- acres as listed for major amendments? Page 203 The recommended land use pattern identified in the Plan inadequately provides appropriate optional sites for use or change proposed in the amendment. What does this mean? It reads confusing. General Comment Page A1 Explain why unique conditions exist to deviate from the Plan. Suggest deleting the word unique, as this could lead to issues with interpretation in the future as to what is unique... is it unique to the site, unique to the client, or how is it unique? 3
Map C1 Proposed land uses and zoning of already incorporated areas are shown on the map. This may conflict with the incorporated areas and those trying to develop or entitle may develop based on which municipal map they prefer to acknowledge. Suggest also showing areas already incorporated so that the owner/ developer would then know which municipality to speak with to discuss development options and land uses. Something similar to how incorporated areas were shown on the last Pinal County Comprehensive Plan Map as grey areas. A concern is that the Activity Center areas are floating and not set in stone. They still have the underlying zoning which is 1-4 DU under an area they are trying to promote with more intense uses. This is backwards because it would require a Major GPA to occur to get the already intended use on the site. How would this promote the Activity Center to develop? It wouldn t. Suggest an alternative, but they must remain on the map to show intent. Map C1 Suggestion: Place a definitive boundary for the Activity Center as an overlay on the Land Use Map. Call out areas within this boundary (approx. x number of miles surrounding the center of the area) seeking to change to HDR, Commercial or Employment uses as falling under the Minor GPA criteria. Areas outside this area seeking those uses shall follow the previously listed General Plan Amendment Criteria for Amendments (typically requiring Major GPAs). This would then attract businesses and more intense uses to these areas as it would be a faster timeline for development with less resistance. Also list out within the Comp. Plan incentives for these areas to develop so they may be shown to P&Z and Council to further show their compliance when going through a Minor P&Z to avoid NIMBY attitudes and more intense uses from being denied. By having these more intense development areas, it enables more areas of open space/ parks/ trails and etc. to be conserved as the Pinal Public wants GPA Concerns over the major amendment process. What is required and how is it determined what requires a major vs. minor amendment. As it stands now everything except Res. 1-4 DU would require a Major GPA as most of the land is shown at 1-4 DU. How could we meet requirements of an Amendment submittal? It states we need to meet all the goals listed, which are too detailed and demanding to do. Needs to be reworded and toned down. How implement the Comp Plan checklist in the appendix? Is that in addition to the Goals, is it suggestions or a requirement to follow? Water/ AMA Issues Concerns over new listed goals and requirements to show 100-year physical adequate water supply at the zoning stage for all areas in AMA and non-ama areas. Suggest rewording to require this only of areas not within the AMA area. When showing water availability at the rezoning timeframe it should only be required that water be shown to be available and not be required to be shown based on lot counts and final end uses. Continuing as currently written would likely require Pinal County to fund and support an internal water department to review water availability issues because AMA will only review at platting stages. 4
Appendix Individual Activity Center Table listing of uses/ acreages and population should be removed or revised as it is too specific and can be taken literally by P&Z, Council and the public for the types of uses which only MAY occur in the Activity Center. Does not take into account market conditions and individual property owner s development. Need to clarify the HDR density as it is listed in some places up to 18 DU and others up to 24 DU. Currently won t allow for developing in a floodplain. What about if it is engineered to accommodate development? Need to separate Goals a bit more into primary and secondary goals not all the listed goals should be requirements. How determine what is an Environmentally Sensitive Area? Are there criteria, a map or what can be referenced to determine if the site qualifies? How is density calculated? It is not shown. 5