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When You're Updating <br />The simplest and perhaps most effective <br />time to test zoning regulations is while <br />they're in the process of being updated. The <br />update process provides the far-reaching <br />latitude to evaluate all aspects of the zoning <br />ordinance and how they may currently be <br />working (or not working) together to achieve <br />the community's development goals. <br />The update process allows for the testing <br />of existing regulations (such as district <br />dimensional standards, maximum heights, <br />parking ratios, landscape requirements, etc.) <br />to ensure that they continue to work within <br />the developed context of a community, and <br />that they continue to work toward achieving <br />the community's vision for the future. <br />The update process also allows new <br />regulations and approaches to be tested <br />before they become the rules for development <br />in a community. Are we proposing smaller <br />minimum lot sizes? Let's test to ensure <br />that they're going to work to accommodate <br />existing homes and facilitate growth where <br />we desire, but that we're not unintentionally <br />allowing existing lots to subdivide and create <br />new density where it may not make sense. <br />Are we proposing moving from regulating <br />side yards as a minimum number to a <br />percentage of lot width? Let's make sure <br />that the percentage is tailored to sensibly <br />accommodate both the small tots to which <br />it would apply, as well as the larger ones. <br />Are we writing a new regulation to limit the <br />height of second -story additions in residential <br />neighborhoods because someone built a <br />terrible one? Let's make sure that we're not <br />unintentionally prohibiting second -story <br />additions in entire neighborhoods where they <br />may be totally appropriate, and pushing home <br />owners into an unnecessary variance process. <br />When You're Not <br />When you aren't updating, it's still important <br />to be putting your ordinance through its <br />paces. Proactively testing allows for an <br />ongoing assessment of the limitations and <br />effectiveness of your ordinance to meet the <br />demands of future development pressure, <br />and to act as a barrier to less desirable forms <br />of development. The first and most obvious <br />place to look for things to test is the pattern <br />of variance requests that you're seeing. If <br />home owners are repeatedly asking for relief <br />related to fences in their side yards, this may <br />indicate a regulation that needs adjustment. <br />Similarly, if a good number of businesses in <br />your general commercial district are asking <br />for relief from ground -floor transparency <br />requirements, you may want to test the <br />requirements to ensure they are reasonably <br />achievable and appropriate. <br />Keeping an eye on development trends <br />and patterns in nearby communities, as <br />well as emerging or nascent regulatory <br />approaches, can also illuminate some areas <br />that would benefit from testing. For instance, <br />is the community next door seeing a number <br />of tear -down redevelopment projects, or <br />new homes on double lots in existing small - <br />lot residential neighborhoods? Now might <br />be a good time to see how your ordinance <br />would handle new residential development <br />of larger homes on larger lots, and if <br />your controls allow for desirable forms of <br />development that also protect current home <br />owners and the fabric of the neighborhood. <br />The brewpub you went to after work the other <br />night —the one in the industrial area next <br />to the glassblowing studio and the gym — <br />could something like that happen in your <br />community? Now might be a good time to look <br />at older industrial areas in your community <br />and see what may be standing in the way of <br />their reuse or revitalization. <br />As new trends, technologies, and tech- <br />niques emerge, how nimble is your community <br />at recognizing and adapting to the demand <br />for change? Proactively evaluating how your <br />ordinance may (or may not) handle something <br />like a roof -mounted wind turbine, a chicken <br />coop, or a tiny house can prepare you forwhen <br />the first permit application arrives at your desk. <br />Knowing where the flexibitities and limitations <br />lie can provide a great basis for working within <br />an existing ordinance, or making the move to <br />update when the tipping point is reached. <br />WHO DOES THE TESTING? <br />During an ordinance update, testing <br />responsibilities may fall to different parties. <br />If a consultant is the primary drafter, the <br />consultant should also be the primary <br />party responsible for testing any proposed <br />regulations. Close coordination with staff is <br />important to ensure that any data being used <br />is the most up to date and accurate, to assist <br />in the selection and prioritization of specific <br />issues to test, and to identify any particularly <br />critical areas within the community to test. <br />In the case of process testing, following any <br />initial "shadowing" or process engagement <br />with the consultant, the staff should be the <br />primary party responsible for testing and <br />evaluating any proposed process changes. <br />WHAT AND HOW TO TEST <br />See the list of "forms of testing" above with <br />some examples of ways in which testing may <br />be used when a community is revising or <br />updating its zoning ordinance. The sections <br />below present more detail. <br />Approach Testing <br />Approach testing is a key step at the outset <br />of any zoning update process, particularly <br />for communities with an older ordinance. <br />Changes in the form of new approaches or <br />techniques, such as the implementation of <br />a generic use approach, or a new manner of <br />handling nonconformities, can often be a <br />larger mental hurdle than changes to specific <br />provisions, such as modified building height <br />or setback requirements. Testing such new <br />techniques can help to ensure that they will <br />work for your community, and that they are <br />supportable by staff, elected officials, and the <br />public. Approach testing is often useful when <br />transitioning from one technique to another, <br />or when attempting to implement a new <br />technique or practice within a community. <br />Testing a new approach requires that <br />all stakeholders understand and support the <br />proposed change of course. For example, <br />many older zoning ordinances subject all <br />nonconformities to the same standards. <br />Meanwhile, contemporary zoning ordinances <br />often define and regulate different types of <br />nonconformities, such as "nonconforming <br />tots," "nonconforming uses," "nonconforming <br />structures," "nonconforming signs," and <br />"nonconforming site elements" (e.g., <br />landscaping, lighting, and parking). The <br />benefit of this approach is that, rather <br />than rendering a structure nonconforming <br />because of a landscape issue, it establishes <br />a separate set of regulations that govern <br />the maintenance and improvement of only <br />the nonconforming element. (However, <br />it is important to note that the enabling <br />legislation in some states does not allow for <br />"nonconforming site element" provisions.) <br />Testing such an approach, depending <br />upon the state in which it is proposed, may <br />first involve getting a legal OK to proceed, <br />then discussing with staff and stakeholders <br />the details of how this approach is different <br />and what exactly it would mean within <br />ZONINGPRAC T ICE 11.17 <br />AMERICAN PLANNING ASSOCIATION Ipagel <br />