We support the new Chapter 13 (Rural Planning and Development) proposed as an amendment to Horizon 2020. Short of actual annexation, we believe this proposal would answer some of the most serious problems associated with unincorporated development in Douglas County. The material that accompanies this Draft (8a) is helpful in giving an understanding of how this amendment could be applied to facilitate transition from rural subdivision to urban neighborhood.

There are, however, some serious planning issues that haven't been addressed here. The first is stormwater management planning that includes the complete watersheds and drainage basins. The recommended minimum-sized tract that can be platted in the UGA is forty acres. In order to be effective, stormwater management should be planned for the total drainage basin and its watershed area, which could involve a section in size or larger. This should be done prior to any subdivision platting.

A requirement for advance neighborhood planning is another critical policy to add to this chapter. Forty acres is only a fraction of a total neighborhood area, and there should be a larger planned area into which this smaller subdivision can fit. Sections of 640 acres bounded by arterials have traditionally been considered as neighborhood planning areas. Planners are now considering half-sections as appropriate for neighborhood planning because the 320-acre area is more within comfortable walking distance to non-residential uses. The larger neighborhood area should be planned with collector and connector streets and include reserved areas for non-residential uses. Unless there is an already established pattern into which these 40-acre subdivisions can fit, their random scattering could result in dysfunctional and disconnected growth patterns that would be difficult or impossible to fit into an urban pattern. With advance plans in place for storm drainage, streets and utilities in a neighborhood context, into which these UGA rural subdivisions can fit, a healthy and functional city could ultimately result.

A third issue is the size of residential lots permitted in the unincorporated rural area outside of the Urban Growth Areas. The proposed Horizon 2020, Chapter 13 (Policy 8.1) recommends 20 acres. The League recommends 40 acres based on our recent study of rural development in Douglas County, because, among many reasons, this is more likely to preserve tillable tracts. In support of our position to preserve farms and farmland, we encourage your adoption of the larger acreage.

It would also help to clarify such words as "reasonable,"(Strategies. No. 8),"considered," (Policy 2.6b.) and "unduly" (Policy 2.6c&d.) and other terms where standards rather than general terms would eliminate ambiguities.

We appreciate the study and careful thought that has gone into this Chapter on Rural Planning and development, and encourage the Planning Commission to adopt it as it has been written, with additions mentioned above. Thank you.

Alan Black, Chairman, Land Use Committee

League of Women Voters of Lawrence-Douglas County

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