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development, development regulations <br />addressing community association respon- <br />sibilities are where the rubber hits the road. <br />A review of a subdivision proposal based on <br />aesthetics, compliance with existing zoning, <br />traffic, the availability of public utilities to <br />service it, and similar <br />criteria is typical. <br />With a large sub- <br />division, a street and <br />trail plan, open space <br />management, parks, <br />schools, and similar <br />facilities add challenges <br />that are nothing unusual. <br />If a community asso- <br />ciation with "normal" <br />improvements —streets, <br />parks, tot lots, and open <br />space —fails in its job <br />or its funding, the place <br />will look bad but won't <br />threaten someone's <br />health orwell-being. <br />When you add to <br />that mix critical flood <br />or stormwater control <br />facilities, the planner <br />must question owner <br />capability. If the development includes engi- <br />neered improvements —dams, levees, land- <br />slide mitigation measures such as debris <br />fences or large retaining walls, recreational <br />lakes that are part of a regional stormwater <br />management system, or any similar im- <br />provement —which, if they fail, will endanger <br />other property or human life, the planner <br />should carefully analyze the situation before <br />responsibility is delegated to lay owners for <br />maintenance and repair. <br />If the planner cannot with confidence say <br />that the future owners of a proposed subdivi- <br />sion can fund the proper <br />maintenance and repair <br />of a critical piece of <br />infrastructure, serious <br />consideration should <br />be given to rejecting the <br />project outright, recom- <br />mending that the mitiga- <br />tion facilities be publicly <br />owned and maintained <br />using broad -based tax <br />revenues, or requiring <br />the developer to post a <br />financial performance <br />guarantee calculated to <br />underwrite at least half <br />of the cost of failure, <br />while bearing interest to <br />guard against inflation. <br />In manyjuris- <br />dictions, any of the <br />foregoing options will <br />elicit objections from <br />the developer, the planning commission, or <br />both. But unless we realistically evaluate the <br />capability of the eventual owner to properly <br />care for critical facilities, the planner will leave <br />too much to chance and the local government <br />may inherit it anyway, but at a much less op- <br />portune time. <br />If the planner cannot <br />with confidence <br />say that the future <br />owners of a proposed <br />subdivision can <br />fund the proper <br />maintenance and <br />repair of a critical <br />piece of infrastructure, <br />serious consideration <br />should be given to <br />rejecting the project <br />outright ... <br />REFERENCE AND RESOURCES <br />Feiden, Wayne, and Burby, Raymond. 2002. Performance Guarantees for Government Per- <br />mit -Granting Authorities. PAS Report No. 508. Chicago: American Planning Association. <br />Available at planning.org/publications/report/9117596. <br />Gadsen (Alabama), City of. 2013. Code of Ordinances. Chapter io8: Stormwater Manage- <br />ment Regulations. Section 108.5: Stormwater system design and management stan- <br />dards. Part g: Maintenance Agreement. Available at: tinyurl.com/hlbabkt. <br />Lake (Illinois) Stormwater Management Commission, County of. 2015. Watershed Develop- <br />ment Ordinance. Available at lakecountyil.gov/DocumentCenter/Home/View/.3445- <br />Rafter, Dan. 2000. "The Messy Business of Maintaining BMPs." Stormwater, March 16. <br />Available at tinyurl.com/gsm8lss. <br />Roanoke (Virginia) Stormwater Advisory Committee, County of. 2014. "StormwaterAdvi- <br />sory Committee." Available at roanokecountyva.gov/index.aspx?NID=1412. <br />Roanoke (Virginia), County of. 2016. Code of Ordinances. Chapter 23: StormwaterManage- <br />ment. Available attinyurt.corn/zyjpa77. <br />ABOUT THE AUTHORS <br />Tyler Berding is an attorney and founding <br />partner of BerdingWeil, LLP, located in Walnut <br />Creek, California. Berding and his firm have <br />represented more than 1,00o community <br />associations over the past4o years. He holds <br />a JD from the University of California, Davis; <br />and an MA and PhD in Government from <br />Claremont Graduate University. He writes <br />extensively about community associations <br />and their role in modern real estate <br />development. <br />Joseph DeAngelis is a planner and researcher <br />with the American Planning Association <br />in Chicago. Previously, he was a resiliency, <br />planner for the New York City Department <br />of City Planning, where he worked on long- <br />term planning and zoning solutions for <br />communities impacted by Hurricane Sandy. <br />Cover: Photo by Dean Terry (A large <br />community in Plano, Texas, near Dallas, <br />Flickr CC-BY-NC-ND-2.o) <br />Vol. 34, No. 3 <br />Zoning Practice is a monthly publication of the <br />American Planning Association. Subscriptions <br />are available for $95 (U.S.) and $12o (foreign). <br />James M. Drinan, JD, Chief Executive Officer; <br />David Rouse, FAICP, Managing Director of <br />Research and Advisory Services. Zoning Practice <br />(ISSN 1548-0135) is produced at APA. <br />Jim Schwab, FAICP, and David Morley, AICP, <br />Editors; Julie Von Bergen, Senior Editor. <br />Missing and damaged print issues: Contact <br />Customer Service, American Planning <br />Association, 2o5 N. Michigan Ave., Suite <br />1200, Chicago, IL 6o6oi (312-431-910o or <br />customerservice@planning.org) within 90 days <br />of the publication date. Include the name of the <br />publication, year, volume and issue number or <br />month, and your name, mailing address, and <br />membership number if applicable. <br />Copyright ©2017 by the American Planning <br />Association, 2o5 N. Michigan Ave., Suite 1zoo, <br />Chicago, IL 60601-5927. The American Planning <br />Association also has offices at 103015th St., NW, <br />Suite 75o West, Washington, DC 20005-1503; <br />planning.org. <br />All rights reserved. No part of this publication <br />may be reproduced or utilized in any form or by <br />any means, electronic or mechanical, including <br />photocopying, recording, or by any information <br />storage and retrieval system, without permission <br />in writing from the American Planning <br />Association. <br />Printed on recycled paper, including 50-7o% <br />recycled fiber and 1o% postconsumer waste. <br />ZONINGPRACTICE 3.17 <br />AMERICAN PLANNING ASSOCIATION i page 7 <br />