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Submitted comments will appear below after staff approval.
Nancy Pease 5/20/2024 6:30:14 PM
These comments refer to draft Assembly Ordinance 44, which is the subject of PZC Case 2024-0067. AO 44 should be postponed indefinitely, as recommended by the Planning Department's Memorandum on PZC, dated May 20, 2024. I concur with the Recommendations of the Planning Department for changes and a robust public process for AO 44 before the Planning and Zoning Commission again considers it. AO 44 is intended to create a legal path for areawide rezoning through AO 87(S). Areawide rezoning is specifically not recommended in the 2040 Land Use Plan, per LUP Strategy 6. Neither AO 44 nor AO 87(S) serves the public interest, health, or welfare of the community as required under Title 21.03.070.C.2 AO 44 does not meet the Approval Criteria of Title 21. 03.070.C.2.b or c regarding the public interest, health, safety, convenience or welfare of the community. A. 2024-044 would override neighborhood and District Plans, without due consideration nor collaboration with residents. The resulting inconsistencies among and within plans would violate the Title 21 criteria for Plan Amendments to be consistent (21.03.070.C.2.b), B. 2020 Comp Plan Policy 5 would no longer require rezones and variances to be in scale with adjacent uses and no longer require consistency with the 2020 Comp Plan goals and policies. C. 2020 Comp Plan Policy 49 would no longer require new development to be consistent with the functions and aesthetic character of adjacent development. D. Land Use Policy 2.1 – AO 44 supports sprawl by removing the priority to fund public infrastructure in designated infill area. The amendment allows the prioritizing of public funding to extend infrastructure in outlying areas, which may be cost-inefficient and induce more driving. E. Land Use Policy 4.1 – the amendment proposes neighborhood-scale commercial uses, without defining where or what that entails; thus exposing residential areas to potential impacts such as high traffic and 24-hour operation. F. Land Use Policy 4.4 – the amendment vaguely calls for “diversifying the uses allowed on a property to support financial stability”. This gives no certainty about traffic, noise, lighting, fumes, drainage, which can degrade surrounding uses and properties. G. Land Use Policy 7.2 – the amendment removes the transitions between high intensity uses and low-density residential neighborhoods, allowing greater impacts. H. Land Use Policy Goal 2-6 – the amendment promotes commercial sprawl. It amends Title 21 to allow more commercial activity in all residential neighborhoods, rather than supporting neighborhood commercial centers. AO 44 does not specify how commercial sites will be kept at neighborhood scale and how much residential land will be converted. It does not address the likelihood of increased driving. I. Land Use Policy 6-7 – removes the goal to coordinate and promote housing and public transit corridors. AO 44 does not meet the definition of “necessary” under Approval Criteria A for Comprehensive Plan Amendments (21.03.070.C.2.a) As noted by the Planning Department, the trends and issues in housing needs are not new: they were previously identified through in-depth studies for Anchorage 2020 and the 240 LUP. The issues have remained constant but have been amplified by housing prices and the cost of financing. We support the Department’s finding that the 2020 and 2040 land use plans need more robust, targeted implementation, and that the AO 44 proposed amendments are not necessary to address changed projections, new issues, or omissions from the Comprehensive Plan. (May 20 memorandum). Nancy Pease