League of Women Voters of Lawrence-Douglas County
P.O. Box 1072, Lawrence, Kansas 66044
November 6, 2005
Dr. Terry Riordan, Chairman
Members
Lawrence-Douglas County Planning Commission
City Hall
Lawrence, Kansas 66044
RE: HORIZON 2020 DRAFT CHAPTER 7, INDUSTRIAL & EMPLOYMENT LAND USE.
Dear Chairman Riordan and Planning Commissioners:
Attached please find a list of our suggested changes to the Draft Chapter 7 of Horizon 2020. These are excerpts of the text of this chapter annotated with our suggested wording. Most of these are changes which need clarification in order to reflect what we believe is the intention of this proposed chapter. Below is a list of the subjects, not prioritized.
1. (Page 7-6, paragraph 1, and Map 7-2.) There are two proposals which we suggest should be eliminated: the proposal for locating warehousing on South Iowa, and the proposal for locating an industrial/business park near the Highway 59/56 interchange.
2. (Page 7-7, paragraph 1) The criteria for determining locations of industrial/business parks require clarification.
3. (Page 7-18; Policy 3.1; Page 7-22, Policy 4.3) The language for locating and designing internal and external access for industrial/business parks needs strengthening and clarification.
4. (Page 7-7, Paragraph 2; Page 7-8, last paragraph; Page 7-12, last paragraph; Page 7-16, Policy 2.3.) It must be made clear that industrial/business parks are to be provided with urban utilities, infrastructure, and services. This requires that they be annexed into their adjacent cities and towns prior to development.
5. (Page 7-10, last paragraph) Impact assessments, especially those assessing potential impacts on the Downtown, must be carried out prior to approval of major business/industrial research parks. There should be some indication of the consequences of a negative impact assessment.
6. (Page 7-10, Policy 3.1.4) Wherever a view-blocking screen is needed, it should be required.
7. (Page 7-23, Policy 4.4 d). Provision for pedestrian access to public transportation must be designed into industrial/business parks and all employment uses.
8. (Map 7-2) It should be made clear that the predominant uses for industrial/business parks are manufacturing and non-retail business uses. Supporting retail uses, if allowed, should be primarily for the occupants of the industrial/business parks. We suggest that you add this somewhere in Chapter 7.
9. (Page 7-11, paragraph 1) The appearance of Gateway developments need special attention, perhaps by including special criteria for site planning.
10. (Page 7-13, Policy 1.2) The natural features of a site shall be respected and preserved. It would be helpful to give references to “best management practices,” in terms of methods for ensuring compatibility of developments to the site and surrounding areas.
We refer you to the Attachment for our suggested rewording and comments. We thank you for providing this opportunity to make suggestions for changes to this very important chapter in Horizon 2020.
Sincerely yours,
Alan Black, Chairman Caleb Morse
Land Use Committee LWV L-DC Board
Attachment
ATTACHMENT
The following are excerpts of Draft Chapter 7, Horizon 2020
that we believe should be modified. We have included suggested wording in
bold italics, and suggested deletions in strikeout. We have
tried to narrow and define the wording that might contradict or confuse an
interpretation, and have tried to restate some key words in policies to make
them more clear.
___________________________________________________________________________________
SUGGESTED CHANGES TO DRAFT CHAPTER 7, HORIZON 2020
Page 7-2: First paragraph:
“Identify an adequate amount of
available land in a number of locations throughout in
Douglas County to meet diverse industrial and business related
development needs.”
Explanation: Change the term “throughout” to the less inclusive term “in.”
Page 7-6: First paragraph:
Our comment: South Iowa Street is recommended as a major location for warehousing. We suggest that this location for warehousing be eliminated from Chapter 7. Reason: This location would send heavy through truck traffic directly north to the Turnpike right through the center of town. Lynn Parman, VP for Economic Development of the Lawrence Chamber of Commerce, has stated that direct access to I-70 is preferred for industrial locations by prospective firms seeking sites. The location of warehousing should be carefully assessed for its effect on internal city automobile traffic and, therefore, it should be located as close as possible to turnpike interchanges or to bypass routes that take it directly to the interchanges. Where this is not being considered is the proposed location for warehousing on South Iowa Street. Perhaps it would be appropriate to limit warehouse locations to the North Iowa Industrial area until the SLT and Eastern Bypass have been completed.
Page 7-7; First paragraph:
“General Locational Criteria Characteristics – to assist in the identification
of general locations throughout the City of Lawrence, its Urban Growth Area, and
unincorporated Douglas County appropriate for industrial and business park
development, there are some basic locational criteria characteristics that should
be considered
favorably. These include sites with land
characteristics such as, but not limited to, proximity to the flood
plain, locations outside of flood prone areas,
close proximity to transportation networks, close
proximity to and availability of urban services, and adequate
parcel size, generally over forty acres.”
Explanation: Listing “proximity to the floodplain” doesn’t indicate whether that is a good choice or a bad choice. It sounds as though it is an advantage when it is included without modification with the other locational requirements, and modifiers are also needed for the other criteria.
Page 7-7: Paragraph 2:
Our Comment: Under “Potential Locations for Park Development” it should be emphasized for all of these locations that they must not be developed until they are annexed and furnished with urban utilities, infrastructure and services. This is especially true of any industrial or business location at the intersection of Highway 59 and 56. We believe, in any case, that is a poor choice for an industrial location, because of its distance from Baldwin and negative impact on rural areas.
Page 7-8: We suggest adding the following modifiers and changes shown in bold italics to the following paragraphs, quoted below:
Site-Specific Locational Criteria Characteristics – after identifying a
general location for potential industrial and business park development, further
site analysis and environmental
suitability should be conducted considering site-specific locational criteria.
This These criteria includes, but is
are not limited to, slope and soil
suitability for such development, preservation of vegetative cover and wildlife habitat, avoidance of
class=Section2>potential for flooding and/or standing water (wetlands), appropriate parcel size and ease in assembly, immediate availability and adequacy of municipal utilities, infrastructure and services, and appropriate zoning/land use patterns and positive compatibility with existing and future development.”
Explanation: Without modifiers, these “site-specific locational criteria” to determine suitability have no meaning as to whether a site is suitable or not.
Page 7-8, Last paragraph:
“New industrial uses requiring
municipal level of services in unincorporated Douglas County are not recommended
unless they are designated as future development sites located
within the urban growth area for the City of Lawrence or in defined planning
areas for the Cities of Baldwin City, Eudora, and Lecompton, and
are annexed prior to development. New industrial uses that do not
require an urban level of service such as water or wastewater
treatment may be permitted in appropriately designated
areas of unincorporated Douglas County.”
Explanation: Unless these uses are annexed into the cities before they are developed, the cities would be providing urban services to unincorporated uses, a practice that is not (and should not be for many reasons) the policy of these urban areas. Furthermore, if not annexed prior to development, the site and construction standards would be regulated according to county, not city, standards.
Page 7-10; Last paragraph:
“Downtown Lawrence
“Downtown Lawrence encompasses a
significant number of non-retail employees and geographically represents a major
employment area for the community as well. A substantial number of office and
service employees are located in this area. The development of new major office
employment centers within the community needs to be evaluated to
determine the potential effect on downtown Lawrence. Of specific interest will
be the affect effect on the mix of
uses that makes downtown a vital and unique business center for the community.
A critical assessment shall be made to determine that such proposed
development will not have a negative impact on the Downtown.”
Explanation: The last sentence in this paragraph isn’t clear and needs elaboration. This chapter needs to state positively the Community’s support for the Downtown and avoidance of the type of development that would damage or destroy it.
Page 7-11; First paragraph:
“Office Research ... “Developments occurring at gateways to the community
are encouraged required to be of high-quality design
and visual character utilizing best management principles for site planning and
design...”
Comment: Why not make this a requirement and include standards or recommend standards to be included in the Development Code?
Page 7-12; last paragraph:
“...New employment-related
uses requiring municipal level of services in unincorporated Douglas County are
not recommended unless they are designated for such future use
located within the urban growth area for the City of Lawrence or the
planning areas for the Cities of Baldwin City, Eudora, and Lecompton and
are annexed prior to development. New industrial uses that
do not require an urban level of service such as water or wastewater may be
permitted in appropriately designated areas of unincorporated Douglas
County.”
Explanation: The Urban Growth Areas have been delineated to allow cities to plan ahead and to reserve areas for specific uses as they grow outward. These UGA areas are intended to be annexed as they develop so that they may be provided with urban services. To permit industrial /business park development without annexation would defeat the purpose of the UGAs.
Page 7-13; Under Goal 1:
“Policy 1.2: Ensure Compatibility of Development
“b. Encourage best
management practices for site planning and design that include, but are not
limited to, the consideration of natural site features, building placement and orientation,
vehicular and pedestrian circulation patterns, open space, landscaping,
lighting, stormwater management, and interfacings with adjacent neighborhoods
and development, and appropriate accommodation of the design
to the site’s natural features.”
Explanation: We suggest changing the sentence because it needs to be made clear that the design of a development should protect a site’s natural features.
Page 7-15; Under Goal 2:
“Policy 2.1: Utilize Locational Criteria for All Industrial and Employment-Related
Development
“Utilize the following criteria in reviewing industrial and employment-related
development requests:
“1. Limit development to designated areas as indicated on the land use maps of this Chapter, this Comprehensive Plan, and any relevant area plan applicable to such designated areas.”
Explanation: Area plans should be applicable to the designated areas and not create new areas outside of these designated areas. It should be made clear that area plans are sub-plans of the larger neighborhood- and community scale plans, which, in turn, are encompassed by the Comprehensive Plan. If plans are created for areas outside these neighborhood- or community-scale plans, they will be, by definition, random and scattered, and will lead to sprawl rather than to cohesive, compact urban development. If the meaning of “area plans” is different than the above, the term should be defined.
Page 7-16; paragraph 5:
“Policy 2.3: Adhere to Designated Land Uses
a.. Encourage
Locate the development of planned industrial, office research and
warehouse distribution facilities within the City of Lawrence and the urban
growth areas of unincorporated Douglas County. When sites have
been designated within the Urban Growth Areas, require annexation prior to development.”
Page 7-17; last paragraph:
“Policy 2.5: Ensure Compatibility of Development
“e. Access to individual building sites within industrial and business parks should be from an internal circulation system. Site access from peripheral arterial and collector streets should be limited to major entrances serving the
overall development area. Industrial and employment-related traffic and related conditions should not adversely affect other nearby land use areas.”
Page 7-18; Goal 3:
“Policy 3.1: Use Appropriate Transitional Methods
“d. Compatible transition and appropriate interfacings from industrial and
employment-related development to less intensive land uses should consider:
“1. Site Orientation
“b. Site access should be from
arterial, collector or access/frontage
streets to arterials...
“d. Encourage the consolidation of access and driveways serving two
or more uses within the industrial/business park development.”
Explanation: It should be clearly stated that individual sites within industrial/business parks should not have direct access to arterials, but collectively should have access and circulation confined within the parks. The parks, in turn, should have designated and pre-planned access to arterials.
Page 7-20; Continuing:
“Policy 3.1. Use Appropriate Transitional Methods:
“4. Screening and Landscaping
“e. Unsightly views should be screened from neighboring properties
and the public right-of-way. Building materials or structures
incompatible with the image of a high-quality development, such
as chain-link fences, outdoor storage facilities, etc., should not be
the sole means of
screening areas visible from public streets or
adjacent parcels.”
Explanation: Chain-link fences are protective fences and are not screens. These should not be used for screening areas visible from public streets or adjacent parcels. If used as protective fencing, chain link fences and the like should themselves be screened from sight.
Page 7-22; GOAL 4: Transportation Considerations
“Policy 4.3: Vehicular Circulation and Access
“c. Limit the principal access for industrial and employment-related centers to
arterial, collector or
access/frontage roads. There shall be no curb cuts along on
arterial streets unless a hardship can be shown.”
Explanation: “Along” could imply that a string of curb cuts is not allowed, but that one is. Driveway access should be to streets that intersect with arterials and not be allowed directly to arterials. This statement, above, without clarification, could be a cause of major misunderstanding. We also question the exception due to hardship. The circumstances should be more clearly defined and not be “self-inflicted.”
Page 7-23: Goal 4, continued.
Policy 4.4: Pedestrian Access and Circulation
d. Consider
Include public transit stops and hubs and encourage
pedestrian-related facilities as a requirement of industrial and
business park site design.
Explanation: Public transit and its access to pedestrians by design should not be optional; it should be required.
Page 7-27: Map 7-2, Locations of Future Industrial & Business Park Locations
Comments: The term “Business Park” should be defined as not including retail uses except as very limited supporting uses for those occupying the business/industrial sites. There should be some method for preventing these sites from being taken over by major retail businesses and becoming shopping malls or retail centers.
We also question the location of a major industrial/business park near the intersection of Highways 59 and 56 as shown on the Map 7-2 because of its distance from Baldwin City and the negative impact that it would have on the surrounding rural areas.