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• The project will locate additional dwellings within walking distance of the
Transfort bus route, and within and already established bicycle and
pedestrian network of street sidewalks and on street bike lanes.
• Providing additional dwellings in this location will reduce energy
consumption by allowing new dwelling units to be located nearer to
destinations, thereby reducing the trip lengths.
• Providing this development where there are no known enviro�ental
issues, allows development to minimuze adverse invironmental'I impacts.
• Providing additional dwellings in this location will foster a rational pattern
of relationship among residential, business, and industrial uses for the
mutual benefit of all because it is within walking distance of nearby
businesses, and within a s iort commute of industrial uses.
• This project is similar to developing on vacant land because it creates her h� G
additional lots out of portions ota larger lot that is not currently built on.
• The development is sensitive to the character of the existing neighborhood
because the new lot size is similar and consistent with much of the
surrounding neighborhood. 5csv�h�c tU i�,siz,,� e"& r ra01-;'U;,C,
• The development is sensitive to natural areas and features because it is
located far from either, thereby having no impact on them.
Thank you for your consideration of this modification request.
(incerely
W Jonet
P., A.I.T.
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public good, because the city has already determined in Section 3.8.8(B) of
the LUC that reduction in minimum lot size by 25% for the purpose of
increasing the size of a public street right-of-way is not detrimental to the
public good.
Will Not Diverge Except in Nominal/Inconsequential Way: The only reason
the lots are proposed to be smaller than otherwise required is because the
property owner is giving a strip of land to the City for potential future street
widening projects. As called out in section 3.8.8(B) of the LUC, the City is
allowed to reduce the minimum lot size of affected lots up to 25% when they
acquire additional land from lots for the purpose of increasing the size of the
street right-of-way. This. reduction in lot size is written into the code and has
established a threshold of what is a"nominal an inconsequential" impact to a lot
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is taKen from lots ana aiven over
We suggest that the hearing officer use the following finding regarding the
divergence the plan in a nominal/inconsequential way: Because the City has
established this threshold of no more than 25% deviation of the minimum
.ot size for this purpose, and because this project only reduces the
minimum lot size by no more than 93% as a result of this modification
request, the plan as submitted does not diverge from the standards of the
LUC except in a nominal, inconsequential way when considered from the
perspective of the entire development plan.
Advancing the Purposes of the LUC: The plan will continue to advance the
purposes of the Land Use Code as contained in Section 1.2.2 because:
• The development will be consistent with City Plan and its adopted
components, in that it develops in an infill location rather than sprawling to
the edge of the community;
• The development will encourage innovations in land development and
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renewal by efficiently using space while providing quality architectural
design;
• Efficient and economic use of the land, the City's transportation
infrastructure, and other public facilities are achieved because this site
puts new residences in the heart of the City, where there are already
public facilities to serve those residences;
• There are already adequate public facilities serving the project;
• Inappropriate development of lands will be avoided by directing
development to an appropriate location, and adequate drainage will be
provided.
• The pattern of land use of this project will reduce trip lengths because it
will allow more residential units to be located near downtown and campus,
which are both frequent automobile trip destinations.
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streets adjacent to developments, in this case we argue that there is no
proportional nexus between the value of the reduction in allowed development
intensity, and the impacts this development would cause. The loss of the land to
the wider street right of way, in this case, reduces the number of lots that are
allowed by code, from four to three. Generally speaking, buildable lots in this
neighborhood are conservatively worth around $80,000 each. The value of the
taking is thus approximately $80,000. There is clearly a nexus, in that the City
has a regulatory interest in obtaining enough right-of-way to meet current street
standards, however, the be loss of $80,000 in value to the project far exceeds
any "rough proportionality" between the City's interest, and the impacts of the
development. We argue that in this case, because there is no proportional
nexus, a required donation of land to this magnitude is a taking. If a modification
is granted, there would be a rough proportionality between the City's interest, and
the impacts of the development in that the City would get the right-of-way it'
needs, without exceeding the "rough proportionality" test as established in Dolan
v. City of Tigard.
Requested Modification. We think it is only fair to be allowed to compute the lot
size measurements with regard to density calculations prior to any additional
right-of-way dedications. Essentially, what we request is permission to
reduce the minimum lot size to a minimum of 93% of the minimum lot size.
Review Criteria. This modification is requested in accordance with the review
procedures set forth in Section 2.8.2(H) of the Land Use Code as follows:
The Public Good: Having street right-of-way widths in accordance with City
standards is for the benefit of the general public. The project, as proposed, is not
allowed to be "detrimental to the public good." The LUC does not define the
terms "detrimental," nor does it define the term "pubic good." Webster's
Dictionary defines "detrimental" as "causing damage or harm, injurious," and
"public good" as "the well being of the general public." Section 3.8.8(B) of the
LUC states, "Reduction for Public Purpose. When an existing lot is reduced as a
result of conveyance to a federal, state or local government for a public purpose
and the remaining area is at least seventy-five (75) percent of the required
minimum lot size for the district in which it is located, then that remaining lot shall
be deemed to comply with the minimum lot size standards of this Land Use
Code." If it's not detrimental to reduce the lot size of an existing lot to increase
the right-of-way width of the public street, it is clearly not detrimental to the public
good to allow the minimum lot size of a developing property to be calculated prior
to dedicating additional right-of-way to the City for the purpose of increasing the
size of a public street.
We suggest that the hearing officer use the following finding regarding the public
good: The granting of the modification would not be detrimental to the
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We have attached 3 diagrams. A site plan reflecting the modification request, a
site plan that conforms to code, and a context map that shows other lots in the
vicinity that are also less than 6000 square feet. As exemplified by the context
map, lots that are less than 6000 square feet are a frequent occurrence in this
neighborhood within this zone district. Allowing the modification would not create
an occurrence that is different than what already frequently exists in the
neighborhood.
As diagrammed with the loss of land to street right-of-way, Lot 1 would be
reduced from 6011.5 to 5813.9 square feet; Lot 2 would be reduced from 6003.9
to 5874.7 square feet; Lot 3 would be reduced from 6000.7 to 5878.4 square
feet, and Lot 4 would be reduced from 6013.7 to 5602.6 square feet. In other
words, Lot 1 is reduced to 96.8% of the minimum lot size, Lot 2 is reduced to
97.9% of the minimum lot size, Lot 3 is reduced to 98.0% of the minimum lot
size, and Lot 4 is reduced to 93.4% of the minimum lot size.
One point neighbors brought up in the neighborhood meeting is that the small
lots throughout the neighborhood have small houses on them, not big houses.
We propose to make the massing of the houses on this project sensitive to that
issue, so we propose to voluntarily restrict the height of any buildings on these
lots to 1.5 stories.
Another point that must be considered is that the requirement for the project to
donate land for additional street right-of-way, in this case, is a taking. Whenever
local jurisdictions impose conditions on land use permits, they must be aware of
constitutional limits, particularly the "nexus" and "proportionality" requirements of
the Fifth Amendment's takings clause. According to the U.S. Supreme Court,
while local governments can place conditions on land use permits, the
Constitution requires a "nexus" between the permit conditions and a legitimate
regulatory interest. A "nexus" exists where the permit conditions are connected to
and further the regulatory interest. Even if there is a "nexus" between the
conditions and the regulatory interest, the Constitution also requires that the
permit conditions be "roughly proportional" to the projected impacts of the land
use development. "Proportionality" does not require a precise mathematical
calculation, but jurisdictions "must make some sort of individualized
determination that the required [condition] is related both in nature and extent to
the impact of the proposed development." The "nexus" requirement was
established in Nollan v. California Coastal Commission, 483 U.S. 825 (1987). In
Nollan, the United States Supreme Court held that permit conditions must be
sufficiently related to the government's regulatory interests. The Court added the
"proportionality" requirement in Dolan v. City of Tigard, 512 U.S. 374 (1994). In
Dolan, the Court held that when governments impose permit conditions, there
must be "rough proportionality" between the condition's requirements and the
impacts of the development. Although the City has traditionally required property
owners (as part of the development approval process) to dedicate additional
right-of-way to bring street widths up to current Fort Collins street standards for
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Administrative Hearing Officer
Current Planning Department
281 N. College Ave.
Fort Collins, CO 80525
October 18, 2004
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Re: Request for Modification of Standards to Section 4.6(D)(1) of the
LM [Revised]
This letter is intended to formally request a modification to Section
4.6(D)(1) of the Land Use Code regarding the minimum lot size in the
NCL zone district.
Code Language. Section 4.6(D)(1) of the Land Use Code states the
following: "Density. Minimum lot area shall be equivalent to at least three
(3) times the total floor area of the building(s). but not less than six
thousand (6,000) square feet. For the purposes of calculating density,
"total floor area" shall mean the total gross floor area of all principal
buildings as measured along the outside walls of such buildings and
including each finished or unfinished floor level plus the total gross floor
area of the ground floor of any accessory building larger than one
hundred twenty (120) square feet. plus that portion of the floor area of
any second story having a ceiling height of at least seven and one-half
(7'/2) feet located within any such accessory building located on the lot.
(Open balconies and basements shall not be counted as floor area for
purposes of calculating density)."
Background Information. The site has street frontage on three sides. On
the south, it abuts LaPorte Avenue, on the west, it abuts McKinley
Avenue, and on the north, it abuts Leland Avenue. The gross area of the
site is 24,031 square feet, however, in order to approve the project, the
City requires an additional right-of-way dedication along all three
abutting streets. Prior to any land being dedicated to the City for
additional requested right-of-way, the site consists of just enough land to
make 4 lots. Although the City is not planning to widen any of the 3
abutting streets anytime within the foreseeable future, the additional
street right-of-way will be required to be dedicated as part of this
development. The property owner is willing to dedicate the additional
right-of-way, however requests that he not be penalized by doing so.
2113efferson
Fod Collins, CO 80524
970.416.7431
1.888.416.7431
lax: 970.416.7435
Email: mikal@orchilex.com
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