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72 <br /> <br />de minimus deveJopment is not aJways treas- <br />ured highly by those owning' property within it. <br />A second ar§ument is that it is easier and <br />cheaper to administer a rule.based system, <br />since high-revel administrators with expertise <br />are unnecessary. Third, a rule-based system is <br />less susceptible to the corruption of lobbying <br />and politics, not [n the sense of illegal bdbery, <br />but (n the sense of al(owing improper consider- <br />ations to color a decision. Fourth, rules force <br />planners to decide about planning in a more <br />comprehensive, flature-odented way, rather than <br />making things up as they go a[ong. Fifth, plan- <br />nors too often are co-opted by deve(opers in a <br />discretionary system and concede more than <br />they should. <br /> <br /> The arguments for discretion revolve <br />around a different take on planning and <br />design. Discretion proponents might agree <br />that rules produce certainty, but they deem <br />certafnw a minor virtue, first, discretion advo- <br />cates cite the impossibility of reducing to <br />rules the quaUties that make for well- <br />designed urban environments. When rules are <br />stated, the,/say, developers provide totter-of- <br />the-law compliance or find loopholes that, in <br />either case, produce mediocrity. Second. dis- <br />credon allows for an engagement with devel- <br />opers that, instead of co-opting/he planner, <br />fosters collaborative inventiveness absent <br />from the rule-based approach. Third, discre- <br />tion allows planners to secure exacdy what <br />they want, even if the owner does not wa.hr to <br />produce it. Fourth, discretion is not as dis- <br />liked as rule-based proponents may claim, <br />Oevelopers and their servants (law/ers, expe- <br />diters, architects, pianners, etc.) have invest- <br />ed much time learning the navigation skirts <br />needed for discretionary approval and are not <br />as ready to jettison such skills to the nas~ <br />wind of rule-based zoning as developers' <br />encomia to rules might otherwise suggest. <br /> <br /> In an attempt to secure the virtues, with- <br />out the ,/ices, of each system, some practi- <br />tioners attempt to marry the best of rules and <br />the best of discretion. Here, tile rules are, <br />indeed, set forth clearly in advance, but the <br />issue oi determining whether the developer <br />has met the rules is left to hi§h[y skiUed plan- <br />ners and dost§nets rather than building <br />inspectors or inspection services department <br />bureaucracies. !n theory, the city planner <br />must approve the proiect if it meets the ruies, <br /> <br />but she can urge the developer to do better <br />than simply comply during review of the <br />deve{opment proposal. Zoning laws some- <br />times refer to this process as "certificatio¢." <br /> <br />TO PRESCRIBE OR NOT TO PRESCRIBE: <br />THAT I$ THE QUESTION <br />imagine the omniscient plannerwho lives in a <br />world where zoning mandates precisely what <br />the owner must buiJd on her properb/, in the <br />most extreme version of this world, the owner <br />must build what zoning toils the owner to <br />build, or she loses the property, in a less <br />extreme version, the owner must build what <br />zor~ing tells her to build if he builds anything <br />at alt. Of course, both of these approaches are <br />more intrusive than most of today's zoning. To <br />begin with, today's zoning (for this discus- <br />sion, let's call it conventional zoning) does <br />not interfere with the decision not to develop <br />at all. Put another way, a vacant lot does not <br />offend conventional zoning. Moreover, con- <br /> <br />ventional zonin§ tends toward proscriptive, <br />rather than prescriptive, mandates when the <br />owner chooses to build. The rules most often <br />tett the owner what she cannot do (proscribe), <br />rather than what she must do (prescribe). <br />Maximums beyond which the owner may not <br />.~o are the rule, with more restrictive com- <br /> <br />mands the exception. Thus. the owner may <br />no( exceed ~o FAR. The owner may not devel- <br />op more than to units per acre, The owner <br />may not build higher than tSo feet. <br /> Conventional zoning shows glimpses of <br />being prescriptive;, however. Within the trio of <br />use, shape, and bulk restrictions, use is the <br />one most often treated prescriptively. For <br />example, exclusive(y single-use zoning dis- <br />tricts, rather than so-called "pyramidal" or <br />"cumulative" use districts, constitute a pre- <br />scriptive model, in that their rules dictate <br />specifically what the use must be rather than <br />allow the owner to choose to build, for exam- <br />ple, less intensive uses (residential) in more <br />intensive (manufacturinff) districts. This is not <br />an argument for single-use districts as a mat- <br />ter of good planning; it Js only a factual state- <br />ment that they are more prescriptive than pro- <br />scriptive. Shape rules also provide tastes of <br />prescription when they mandate "but{d-to- <br />the-street-wall" or "zero tot tine" develop- <br /> <br />ment. Compare that with minimum setback <br />rules (stating that the owner cannot build in <br />the first zo feet from the tot tine, but may <br />build.am/where starting from zo feet back), <br />which are proscriptive in nature. <br /> <br /> How may zoning' gravitate toward greater <br />prescription?. A first step would involve <br /> <br />ZONINGPRACTICE o~.o,~ <br />A~ERICAN PLANNING ASSOCIATION I po~e 4 <br /> <br /> <br />