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While traditional zoning identifies a regula- <br />tory black box on a lot for the applicant to fill, <br />form -based codes fill that box with a struc- <br />ture that works in the community context. <br />Changes to the way a community mea- <br />sures building form can result in all kinds <br />of questions from applicants, along with <br />some creative interpretations of the code. <br />For example, while height restrictions are <br />standard in traditional regulations and usu- <br />ally expressed in feet, in a form -based code <br />building height is used to ensure that all <br />structures in a specific area "fit" together, <br />and may be expressed in stories rather than <br />feet. Where the form -based code does not <br />specify a measurement range for a story, an <br />applicant may decide to extend the height of <br />each story and ultimately the height of the <br />structure, thus undermining the whole con- <br />cept of "fit." <br />Finally, Public Space Standards regu- <br />late streets and public spaces. Creating <br />walkable communities is a core tenet of <br />form -based coding, so the street standards <br />are both pedestrian- and automobile - <br />oriented. These standards include: (i) the <br />design of individual street types (also called <br />thoroughfares, but that's always harder to <br />spell) with travel lanes, bike lanes, parking <br />areas, and sidewalks; (2) the design and con- <br />nectivity of the overall street system; and (3) <br />required streetscape standards. The active <br />regulation of public spaces may be a new <br />idea in communities with traditional zoning <br />regulations; public space dedication is more <br />typically a function of subdivision design. <br />Explaining the function, size, and design <br />requirements of the various types of public <br />spaces will need to be part of the implemen- <br />tation process. <br />Drafting Tips for Form -Based Codes <br />The best way to head off the angst of change <br />when moving from a conventional code to a <br />form -based code is to take care in the initial <br />drafting of the new code. Code ambiguities <br />resulting from poor drafting are often the <br />subjects of the first code amendments after <br />the initial code adoption. Head off difficulties <br />by addressing the following before adopting <br />the code: <br />Statutorily Defined Terms. Some state <br />and federal statutes use terms that attach <br />specific meaning to land -use requirements. <br />In these cases, it is very important to use <br />those terms (accurately) and to not invent <br />VAIJIOM <br />- <br />aS_- <br />O. <br />Outdoo <br />paceTry.pei <br />i ��� m I Flexible Outdoor <br />_ 'f APlaza - <br />EWFF <br />IAONFORG�E,!" <br />Existing= - - <br />Outdoor- z - i <br />Space. <br />_ mC. BON <br />G <br />. Existing <br />:outdoor' " <br />- Space <br />..�.:J•Outdoor <br />Space Type: <br />} Pocket <br />PEpa . <br />Park. <br />Outdoor Spa"cce Type; <br />Gr�eenway <br />The form based codefor the <br />Boulder Junction area;m Boulder, <br />Coloradospacespecifies required <br />locations forth ferenttypes of; <br />public <br />City of Boulder <br />new ones. For example, state statutes typi- <br />cally use the term "variance" to describe <br />and enable a particular land -use approval <br />that must meet specific statutory standards. <br />In that case, the code should not create a <br />new land -use approval process that does <br />not adopt those same standards while refer- <br />ring to it as a "variance." The same can be <br />true for statutory planning words such as <br />"exceptions" or "consistent." Furthermore, <br />be aware of circumstances where the code <br />language may have been the subject of court <br />interpretation, as that interpretation must be <br />respected if the same language is used. <br />Plain English. While it is true that <br />form -based codes have developed their <br />own "terms of art," the more that the code <br />uses plain English, the more readable, <br />understandable, and usable the new code <br />will be. The reader should not have to take <br />a secondary language course to understand <br />how the code works. Use short declara- <br />tory sentences, avoiding the passive voice. <br />Write like Hemingway, not like Faulkner, <br />when writing a code. Do not use two words <br />when they have the same meaning; as one <br />practitioner has stated: "To add is human, <br />to delete is Divine." Words that are used <br />repeatedly throughout code must retain the <br />same meaning in all contexts. Be very clear <br />about when standards or procedures are <br />mandatory (use the word "shall" or "must"), <br />as opposed to when they are advisory ("are <br />encouraged to" or in many jurisdictions <br />"may"). We counsel clients that advisory lan- <br />guage means that the regulation is optional <br />and the applicant can choose to opt out. <br />Statements of Intent. Statements of <br />Intent, particularly in the introductory provi- <br />sions of the form -based code, can be very <br />helpful to explain the purpose of the form - <br />based code and what it seeks to achieve. <br />Because the new code will often dramatically <br />change the regulatory framework, form - <br />based codes may usefully contain a fuller <br />description of intent than a conventional <br />code. Once the visioning and educational <br />process of community involvement leading <br />up to code adoption is ended, the statement <br />of intent articulates and carries forward <br />this community vision for the future users <br />of the code. For example, the Miamizl code <br />includes an extensive description of purpose <br />and intent, including "guiding principles" <br />that describe goals for the city, the com- <br />munity (including neighborhoods), and for <br />blocks and building (see miamizs.org). The <br />Nashville Downtown Code (DTC) has an <br />extensive introduction section that provides <br />information about both why the code estab- <br />lishes specific regulations and how those <br />regulations will be applied to meet com- <br />munity goals. For example, in support of the <br />goal to "create and nurture urban neighbor- <br />hoods," the introduction explains: <br />To create these distinctive urban neighbor- <br />hoods, the DTC aligns the regulations of <br />each subdistrict with the intended char- <br />acter of the neighborhood. For instance, <br />the South Gulch is envisioned to continue <br />as a high-rise and midrise, mixed -use <br />neighborhood. The DTC codifies mid -rise <br />height in the general subdistrict and allows <br />high-rise buildings on key intersections <br />and along important streets. In contrast, <br />the North Gulch is envisioned to be a low- <br />rise neighborhood — to preserve Capitol <br />views and transition into the Hope Gardens <br />and John Henry Hate neighborhoods. The <br />DTC codifies this vision by capping the <br />overall height, altowing for less intense <br />development such as two story houses and <br />townhouses, and encouraging porch and <br />stoop frontages. <br />ZONINGPRACTICE 4.18 <br />AMERICAN PLANNING ASSOCIATION Ipage3 <br />