On May 9th at 6:30 pm the City of Mill Valley will hold a public information meeting on the proposed "Multi Family Residential, Downtown Residential and Mixed Use Design Guidelines and Development Standards." This meeting was hastily scheduled in response to significant public comments highlighting the flaws in the proposed rezoning plans. However, instead of acknowledging those flaws, the City has decided it just needs to do a better job of marketing, thus, the upcoming community meeting.
This article is about the things they will probably not explain at the meeting, perhaps because they have not been asking the right questions.
Fifteen years, three city managers, three planning directors and scores of Planning Commissioners and City Council members later, our City is now one month away from apparently approving major zoning changes that are virtually identical to the universally despised Miller Avenue Precise Plan of 2007. If approved, this new zoning proposal will dramatically change the character of our town, for decades to come.
Most residents believe that their city government has some kind of “institutional memory” so that matters that were fully vetted, discussed, analyzed, and thoroughly rejected in the past, will not be introduced again and again in the future. However, in Mill Valley, institutional memory is nonexistent.
Simply put, the sweeping zoning changes being proposed will roll out the red carpet for developers wanting to build three-story, high-density, mixed-use development all along lower Miller Avenue (from Willow Avenue to Camino Alto Avenue), along Blithedale Avenue (in all commercial zones) and from Camino Alto to Highway 101.
The plan is filled with layer upon layer of development incentives, generous floor area ratios (“FAR”), square footage bonuses for something called “design excellence,” and greatly reduced parking requirements to entice development at two to three times the current development intensity of our town. However, the new zoning proposals do not just offer the possibility to develop more, but in fact, offer developers the "right" to develop more, removing many application and planning process protections that currently exist – protections that have served the community well for decades.
For Mill Valley residents familiar with its history, all totaled, the results of the proposed zoning changes will pretty much be exactly what was proposed in the 2007 Miller Avenue Precise Plan – a plan which was resoundingly rejected by the residents of Mill Valley.
By the late 1990's, two significant issues arose that began to pressure small Marin cities to think more about future development. The surging stock market and tech boom began driving real estate development, and Mill Valley began to worry that Miller Avenue, which had few cohesive planning regulations in place, might end up being over-developed by cash-rich internet companies and profit hungry real estate developers. At the same time, the State housing agencies, ABAG and the Department of Housing and Community Development ("HCD") in Sacramento, dramatically increased their pressure on cities to build more "affordable housing." All of this, by the way, is exactly where we, once again, find ourselves today.
In 2001, these combined regional and state forces resulted in the City convening the Miller Avenue Citizens Advisory Committee (the “CAC”), which consisted of a half dozen residents: several planning and design professionals, one planning commissioner, and a couple of citizen advocates for better planning.
The CAC held 18 months of public hearings focused on the future development of Miller Avenue, from Camino Alto to downtown. The City spent more than a half million dollars on a series of planning consultants, who flailed about until a proposal was finally put forth, known as the Miller Avenue Precise Plan (“MAPP”). It was narrowly approved by the CAC, but notably, with one of its most experienced planners and its affordable housing advocate member both casting votes against it.
Undeterred, our City planners moved forward and hired David Early, a Berkeley planning consultant, and shelled out another half million dollars to bring the plan to fruition. By 2006, this evolved into a proposal for massive, mixed use (commercial and multifamily residential) development along Miller Avenue, which instantly set off a surge of public protest not seen in Mill Valley before or since.
In March of 2007, a group of three women, current District 3, Marin County Supervisorial candidate, Susan Kirsch, among them, started a community organization called Friends of Mill Valley, to stop MAPP. By the fall of 2007, their group had grown to over 30 core members with a mailing list of over 1,000 registered Mill Valley voters. Catch phrases such as “preserving small town character,” “top down, one-size-fits-all planning,” and “sustainable development” became part of the local lexicon. The rising protest resulted in a house-cleaning November election that brought in three new City Council members and signaled the death knell for MAPP.
MAPP was tried, found guilty and convicted in 2008, and we all hoped it was buried and gone. The only piece of MAPP that survived and moved forward was the need to make roadway improvements along Miller Avenue, which evolved into the current Miller Avenue Streetscape Plan that just began construction this spring.
In the end, even its supporters admitted that MAPP was seriously flawed. But, never underestimate the power of a bad idea.
In the years that followed, the City recognized that its General Plan needed a long overdue update. The impetus to do this corresponded with the State required update of the “Housing Element,” which is one of many pieces of the General Plan. However, by this time, the pressure from State and regional agencies to build more high-density housing had increased significantly. With the adoption of Plan Bay Area in 2013, the push to urbanize Marin County and small towns such as Mill Valley, under the State doctrine of doing “our fair share,” became the law of the land.
In response, Mill Valley undertook its General Plan and Housing Element updates with a renewed emphasis on providing incentives for more high density, mixed use residential / commercial development throughout the city. This new approach meant that our zoning ordinance would also have to be brought into conformance with the new General Plan and its Housing Element (State law requires that our laws have both “horizontal” and “vertical” consistency). To accomplish the task, the City created the Zoning and Design Advisory Committee (“ZDAC”) to craft changes to our existing zoning regulations.
The ZDAC process included suggesting updates to our zoning ordinance and land use maps, and since we didn’t currently have a multifamily zoning ordinance, it also included crafting an entirely new zoning ordinance for multifamily and mixed use development. The result was the proposed "Multi Family Residential, Downtown Residential and Mixed Use Design Guidelines and Development Standards," which through a series of workshops and Planning Commission hearings became the ordinances that are now being proposed for adoption in June, by our City Council.
The fundamental goals of the exercise were simple: to create new multifamily and mixed used (residential with commercial) zoning regulations in order to provide the community and real estate developers more certainty about what could or could not be built.
ABAG and HCD encouraged this approach as part of their push for more high density development, and our City saw this as a way to get good marks on its Housing Element “report card” certification from HCD. This pressure from the State was supported by a long list of financial industry lobbyists, trade unions, housing advocacy groups, and major nonprofit housing developers.
During the ZDAC and the Planning Commission hearings process, Community Venture Partners, ("CVP”), offered exhaustive comments, directly, and through our legal counsel, Edward Yates. Our comments were largely technical and procedural in nature. We argued that the information presented and the methods Planning used to develop and communicate that information were overly complex, poorly organized, confusing, and at times contradictory and misleading. In short, we felt the City had failed to clearly explain to the public, the full extent of what is being proposed, and the possible consequences.
Our comments were largely ignored by the City. It would appear that the fate of our city is now in the hands of the public, to decide.
THE PROPOSED MULTI FAMILY RESIDENTIAL, DOWNTOWN RESIDENTIAL AND MIXED USE DESIGN GUIDELINES AND DEVELOPMENT STANDARDS
As it stands, there is little in the Staff Reports for the proposed "Multi Family Residential, Downtown Residential and Mixed Use Design Guidelines and Development Standards" that truly demonstrate to the public what the potential impacts of these new ordinances might look like, or how the new regulations and incentives might produce unintended consequences that are contradictory to what is being touted.
This analysis will only discuss the combinations of residential and commercial, mixed use, in existing commercial zones. This is because the proposed regulations for new multifamily development in existing residential zones was more thoroughly vetted by the Planning Commission and the public review process, and those proposals will not, in my opinion, be as impactful as the proposed mixed use, multifamily guidelines.
The new multifamily residential and mixed use standards are basically a zoning overlay on top of the existing commercially zoned areas in the City. Most of our city’s existing commercial zoning (office, retail, service businesses, etc.) is found in our Downtown, along Miller Avenue, along Blithedale Avenue, and along the highway 101 corridor. The new zoning ordinance will allow property owners to develop and/or add multifamily housing in addition to the existing commercial development that currently exists. The underlying commercial zoning regulations are not being changed. The new ordinance also proposes that this ability to create mixed use, multifamily, commercial/residential development be “by right.”
At present, a developer can submit a proposal for a mixed use, multifamily development on commercial property. However, the multifamily residential part is categorized as a “conditional use,” meaning that the decision to approve the project and to what extent mixed use residential will be allowed, is determined on a case by case basis, through a series of public workshops and hearings. So a developer does not know how many units he might get approved, how much parking he will need, what percentage of the lot area he can develop, etc. He’s put in a position where he's required to prove his case, regarding why the project should be approved.
However, under a “by right” scenario, the right to get approval for a mixed use, multifamily project would no longer be in question. It would now be assumed to be a property right, and there would not be any public hearings required to approve that right, or any ability to deny that right, unless it egregiously impacts the health, safety and general welfare of the city’s residents (a very difficult impact to prove, legally). Also, keep in mind that contrary to the City’s assurances, design review guidelines cannot be used to deny a developer zoning rights granted under this new ordinance.
The difference between “conditional use” and “by right” is certainly significant. But in truth, it doesn’t matter which method is approved. The real question is if we adopt these new zoning regulations governing unit density and development intensity (lot coverage, setbacks, height, floor area ratio to lot size, parking requirements, etc.) will it result in appropriately scaled development and good things for the community?
I don’t think so.
SO, WHAT IS BEING PROPOSED?
Briefly summarized, the proposed multifamily residential development regulations in commercial zones, would allow the following:
Lot coverage: The total allowable lot coverage for just the multifamily residential units on the site varies as follows:
- Downtown: 100% of the site area;
- East Blithedale Avenue to Camino Alto: 50% of the site area;
- Miller Main Street and Gateway (Camino Alto to Willow): 50% of the site area;
- Alto Center (Blithedale to Highway 101): 40% of the site area;
- Redwood Highway: 45% of the site area.
However, again, this percentage is only for the residential units. The commercial uses, in a mixed use project, can be as much or even more than the entire lot size. Also, a number of things don’t count towards lot coverage, including parking, accessory structures, and outdoor living space for units, so the "undeveloped" portions of the lot are not open space. Also, some items double up. For example, accessory structures can sit in outdoor living spaces so one space counts for both requirements.
Setbacks: Commercial front yard setbacks remain zero in most areas so that storefronts are located along the street. Residential above commercial can also have zero setback for the second story, but are required to step back at a 1:1 ratio in Downtown and in Main Street and the Gateway. On East Blithedale and at Alto Center to Highway 101 there are no setback restrictions. There are also no side yard or rear yard setbacks (interior property line or exterior property line) for residential development in commercial districts.
Building Height: The allowable height in a residential zone would be 35 feet, but in commercial zones the total mixed use building height can be increased to 38 feet (Page 7 of the staff report; Page 45 of the guide/booklet; attachment 5 of the 3/7/16 packet), “to allow for up to a maximum 18 foot plate height for the ground level commercial uses. The upper floors shall have a maximum plate height of 10 feet.”
In almost all instances this means three stories high.
Floor area ratio to lot square footage (FAR): the allowable FAR in downtown multifamily residential zones would be 60 percent of the lot size at a minimum, and allow for a bonus of up to 75 percent of the lot size for “design excellence” (purely discretionary extra development rights that the Planning Commission or the City Council can decide to grant an applicant). However, in existing commercial zones, the FAR for residential development is much higher. It will be 150% downtown, 100% on East Blithedale and on Miller Avenue commercial, 40% in Alto Center, and 75% at Redwood Highway/101.
However, this alone does not really give an accurate picture of what the possible development “intensity” will be because there are numerous exclusions.
For example, the first 250 square feet of covered garage space is exempted for each parking space. This means that apartments can be built over structured parking (on the entire first floor) and none of that will be included in the FAR calculation, even though it would double the development intensity, visually. This is thoroughly analyzed on Page 14 of our comments of March 4, 2016. The new standards also allow a developer to locate “accessory buildings” (such as tenant storage sheds) in “required” usable outdoor living areas, for each dwelling unit. Since outdoor living spaces are categorically not counted in “lot coverage,” or FAR, this exemption is potentially significant, and is without restriction.
Also, keep in mind; this is in addition to the FAR allowed for the commercial portion of the development, which is presently unlimited! This means we are telling potential developers that if they can figure out a way to work the regulations, they can propose to build a three story building on a 40,000 square foot site, on Miller Avenue, that's almost three times the size of the lot. The only thing in the new ordinance, as written, that would preclude trying to do that, would be the parking requirements. But the parking requirements have also been dramatically reduced, to make larger projects possible.
One example of this is shown in the diagram on Page 20, of our March 4, 2016 comment letter.
Parking requirements: Parking requirements are generally being reduced from what is presently required for all multifamily development. As it is now, any residential unit requires two parking spaces for that residence and in many instances, at least one more parking space for guest parking, which can be along the street in front of the residence. That will no longer be the case for multifamily development.
The new regulations will be based on an arbitrary “unit square footage” formula as follows:
One parking space for units up to 825 sf; 1.5 parking spaces for units over 825 sf but less than 1,250 sf; and 2 spaces for units over 1,250 sf. All units between 350 and 450 sf only need ½ parking spaces per unit. Guest parking will also be reduced to only ¼ parking spaces per units instead of 1 parking space per unit.
This effectively means that a developer could propose to build 40 units on a property that would presently only be able to provide parking for 10 units, so long as all those units were between 350 and 450 sf (1/2 space per unit versus needing 2 spaces per unit). In most parts of the country, 350 sf to 450 sf is a reasonable unit size for a one bedroom unit and certainly for any type of studio/loft unit. In fact, in Marin County, the average two bedroom apartment is only 884 sf (U.S. Census), which now requires two parking spaces but will only require one space in the future. What will be the impacts of cutting that requirement in half?
In total, these proposals make up what is supposed to be a 20 year plan for development in our city, that will have dramatic, long term unintended consequences.
One size doesn’t fit all
A major flaw in the entire ZDAC and Planning Commission review process was that participants spent 90% of their time studying the Mill Valley Downtown neighborhoods and commercial areas, with its small lots and limited space for onsite parking. They spend months meeting with downtown neighborhood community organizations, listening to their needs, working on a variety of solutions. Yet not a single neighborhood group meeting or special study session was held for residents of the lower Miller Avenue triangle, East Blithedale or Alto Sutton residents. In fact, the rest of the city’s commercial zones, where most of the new mixed use, multifamily residential / commercial development will most likely occur, and which will be more dramatically impacted by these proposals, were treated as an afterthought and potential impacts were barely analyzed.
Unlike the small parcels found downtown, which the Staff Report diagrams show can only support small projects, the larger parcels on lower Miller Avenue, in Alto Center, and along Highway 101, can support projects larger than anything we’ve ever seen proposed before. The renderings included with this review, show some of the possible consequences of this in those areas not studied in the City’s Staff Reports.
The State Density Bonus Law was never considered
The California State Density Law offers developers of affordable housing and senior housing a project density / square footage bonus of up to 35% more square footage than a city’s zoning regulations allow. This bonus cannot be denied to any development proposal that qualifies and it cannot be denied for its impacts on traffic or for lack of parking. It is virtually automatic. When the dust settles, the public will be left arguing over discretionary “design review” guidelines (what color the siding should be), but design review guidelines cannot be used to deny the State Density Bonus.
This means that all the maximum unit density data shown to the public in the Staff Reports, is incorrect. Neither ZDAC nor the Planning Commission, nor the Planning Department ever considered the impacts of the State Density Bonus law in any of their deliberations or planning proposals.
“A contract is an agreement to negotiate”
Planners typically consider the zoning parameters in their ordinances (lot coverage, floor area ratio to lot size, parking requirements, etc.) as a maximum. Developers on the other hand always consider them as a minimum starting point to negotiate from. The way a developer’s mind works is to try to figure out what they can do, inexpensively, and call it a “public benefit,” so they can use that as a “stalking horse” to see what additional development rights they can wring out of the deal.
Since the new regulations start with so many generous incentives and reduced requirements, already, it won’t be too hard to developer to gain approval for projects that are significantly larger than anything we’ve seen before in Mill Valley.
Assemblages are the future
The City has not really even considered or anticipated the possibility and potential impacts of real estate “assemblages.” An assemblage is when a developer buys multiple lots and combines them into one parcel for one overall development proposal. Over time this will become an increasingly important consideration.
One of the only things holding back larger development, particularly on Lower Miller Avenue, has been the small sizes and odd configurations of building lots. However, rising property values, the way development is being financed these days, the changing types of residential units that are, increasingly, in demand, and other market indicators suggest that the next phase of development in our commercially zoned areas, will involve parcel combinations in order to support mixed use, commercial / residential development projects.
When you apply the new zoning ordinance and building standards to larger parcels, the outcomes are very different than the small lot scenarios shown in the Staff Reports.
Cumulative impacts are not assessed
The "Multi-Family Residential, Downtown Residential and Mixed Use Design Guidelines and Development Standards," and the process that led to their creation, never stopped to consider cumulative impacts. But if we don’t look at those possible outcomes at this time, when we are making decisions that could potentially impact every resident of Mill Valley for decades to come, when will we do that? When, other than now, will we have the opportunity to properly understand the overall, inter-related impacts of the outcomes of these proposals?
CVP and other concerned citizens have continued to ask this question of Mill Valley planners and City Council members, but have yet to receive a response.
No nexus is established between parking reductions and housing affordability
The entire premise for offering development incentives and parking reductions is based on the erroneous belief that there is a connection between unit size and housing affordability. Rental rates and housing prices depend on the market they're in not the unit size or house size.
There is absolutely no evidence, whatsoever, that supports the idea that smaller is categorically less expensive. The news is filled with stories, every day, of people paying outrageous amounts of money for just a bed to sleep in, much less an apartment. A perfect example is found right in the heart of Mill Valley's downtown. The new apartments at 65 Throckmorton, above the Tyler Florence store at Throckmorton and Corte Madera Avenue, currently rent for $3,800 for an 850 square foot, 2 bedroom unit, and $4,100 for a 900 square foot, 2 bedroom unit.
Statistics that correlate smaller unit size to price, are only substantiated in large urban areas, such as San Francisco, but even then it is only because urban areas tend to have more substandard housing, which skews the rental rates. However, new housing, when compared apples to apples, is as un-affordable in San Francisco, as anywhere else, if not more so, unless it is developed with some type of affordable subsidy, like Low Income Housing Tax Credits.
If creating affordable housing is a goal, why are parking reductions tied to unit sizes instead of being tied to unit rents? This is analogous to saying, I want to give scholarships to the best and the brightest, and so I’m going to base it on a person's height and weight. If we want to tie parking reductions to affordability, why not correlate them to recognized HUD Section 8 metrics for very low, low, and moderate income levels? That would at least be a measurable benefit.
Despite any claims to the contrary, there is nothing in the proposed zoning ordinances or development standards that will create any affordable housing in Mill Valley. So we have to ask, if the whole point of the zoning changes is to create affordable housing, but it doesn't accomplish that, why are we making these changes?
It is also interesting to note that the reason given by City Staff for reducing parking requirements and making parking more difficult in Mill Valley is “to force people to not have as many cars.” Ask yourself this. When did our City Staff, who are paid with taxpayer dollars to work for our benefit, decide to become social engineers and dictate how we’re supposed to live?
Conditional use, by right zoning, and the Planned Development (“PD”) process.
The City has consistently argued that the newly proposed zoning doesn't really change anything. Staff even refuses to acknowledge that the creation of an entirely new zoning ordinance for multifamily residential development, as a stand-alone project or mixed use with commercial uses, is “new,” because, as noted above, developers can already apply to build multifamily or mixed use multifamily as a conditional use. So the City contends the new regulations will just “clarify” the process and make things “easier” for all involved. Unfortunately, the realities of development don’t fit that theory.
Developers will consistently attempt to maximize their ability to develop any particular property to its maximum. This is logical since one of their biggest costs, the land cost, is fixed. So the more rentable square footage that cost can be spread over, the better. What history has shown us, in Mill Valley, is that despite the ability to develop mixed use, under conditional a use process, developers have chosen, instead, to apply under a Planned Development (“PD”) process.
Under a PD process, the parameters of development on any particular parcel are pretty much de novo. This means that under PD, a developer presents a proposal with unique combinations of lot coverage, FAR, setbacks, unit density, parking requirements, etc., and asks that the entire proposal be evaluated as one thing. All the major multifamily and/or mixed use, residential / commercial development proposals and approved projects in our City in the past ten years, have used the PD approach. This includes 505 Miller Avenue, the Coopersmith property at 525 Miller Avenue, the Von der Werth project at 500 Miller Avenue, the Miller Avenue / La Goma Street mixed use, 20 unit proposal (not approved), the Richardson multifamily proposal at East Blithedale Avenue and Camino Alto Avenue (pending), and even the ongoing Mill Valley Lumber Yard renovation proposal.
All of these started out asking for projects much larger than what was finally approved. However, under the new proposed "Multi Family Residential, Downtown Residential and Mixed Use Design Guidelines and Development Standards," in almost all instances, they would not only now be approvable, as originally submitted, but the proposals could now be even for even larger projects. If 505 Miller Avenue were to be developed under the new proposed zoning changes, it could include at least 50% more units (32 vs. 21), in addition to the existing commercial space.
Is “by right” vs. “conditional use” beside the point?
The City is proposing that the new zoning standards allow mixed use, multifamily development “by right,” instead of continuing to only allow it as a “conditional use.” But I don’t think it matters. I think the more important considerations are the actual zoning ordinance standards being proposed for lot coverage, FAR, setbacks, parking, etc. Because whatever is finally put in the ordinance, is what developer’s will consider allowable and their starting point, and the proposals we will see will reflect that.
By creating this new ordinance, we may be “clarifying” the rules of the game, but we are also “inviting” developers to use them as a starting point. That said, the proposed standards for lot coverage, FAR, setbacks, parking, in the ordinance may work well in our Downtown area, where the lot sizes are smaller, but they are far too generous when applied to commercial areas with much larger lot sizes and more potential for lot combinations, as are found on Lower Miller Avenue, Alto Center, East Blithedale, and the Highway 101 corridor.
Urbanizing Mill Valley
What the renderings attached to this analysis show is that the ordinance, as it is currently being proposed, will result in oversized, overly impactful development, and significant traffic congestion and parking shortages, far beyond anything the city is revealing to the public. Over the next twenty years, the proposed zoning changes could very easily result in even more intolerable traffic and destroy our city’s essential small town character.
The "Multi-Family Residential, Downtown Residential and Mixed Use Design Guidelines and Development Standards," will push us that much closer to a more urban, Walnut Creek type community.
The demise of commercial uses
Commercial real estate, and particularly retail spaces, are struggling. Market forces are pushing out commercial uses in favor of more lucrative residential development. The old "apartment over the shopkeeper" model has been thoroughly deconstructed by the internet, and it will never come back. When it comes to leasing commercial space in Marin, we are increasingly dependent on our service economy. The only local businesses that will survive are doctors, dentists, healthcare, professional services, personal services, auto repair, some goods for sale that are local specialties, and some food and pharmacy. None of these uses require the kind of square footage that was previously required by larger retailers, such as furniture sales, hardware stores, stationers, etc.
The importance of this is that the new "Multi-Family Residential, Downtown Residential and Mixed Use Design Guidelines and Development Standards," have no minimums for how much commercial is required in a mixed use development, except to say that the street frontage on the first floor must be commercial space. But that could mean storefronts on shallow footprints, no more than 15 to 20 feet deep. That means the rest of the property will likely be developed as multifamily housing.
The resulting development intensity and population increases represent a serious challenge to our quality of life and the character of our town.
Housing is a money maker in Marin
Another one of the major beliefs behind the idea of promoting multifamily, mixed use development is that it will make our city more “walkable,” less reliant on cars, and provide easier access to commercial goods and services. However, as market forces replace commercial property with multifamily residential, not only will this put significant pressure on our schools, roads, infrastructure and public services, but it will actually increase auto use and traffic congestion, not decrease it. With fewer opportunities for businesses to locate here, we ensure that more and more residents will have to drive greater distances to get to their jobs.
No one seems to be considering that this kind of “planning” is capable of setting off a self-reinforcing, vicious cycle; one that will ensure ever worsening traffic congestion and lack of available parking, both of which not only deteriorate our quality of life, but hurt small, local serving businesses.
The City doesn’t even have any baseline data to determine what is needed
How can we plan unless we know what our needs are? When asked, City Staff has admitted that the entire, three year ZDAC and Planning Commission "Multi-Family Residential, Downtown Residential and Mixed Use Design Guidelines and Development Standards" drafting process was conducted without ever having any reliable data on the total amount of commercial space or commercial land available in Mill Valley, or the number of multifamily, mixed use units that presently exist in the City. They have also moved forward without any idea about how many multifamily units might potentially result from the new zoning ordinance standards.
In other words, this entire zoning proposal is one big shot in the dark.
For a more indepth discussion of this issue, please see pages 23 through 25 of CVP's March 4, 2016 comment letter.
Some of the major goals of the Mill Valley General Plan are to “ Maintain the beauty and small town character of our town, “Maintain a strong, healthy economy that supports locally owned and local serving businesses,” and “Minimize traffic congestion.”
Although there was consideration of these goals with respect to potential development in our Downtown, when it came to all the other commercially zoned areas of Mill Valley, they appear to have been completely forgotten.
The proposed "Multi-Family Residential, Downtown Residential and Mixed Use Design Guidelines and Development Standards" are seriously flawed and should not be approved without significant revisions.
Bob Silvestri is founder and president of Community Venture Partners, Inc., a 501(c)(3) nonprofit organization that facilitates and assists community based projects, programs and initiatives that demonstrate the highest principles of economic, social and environmental sustainability.