Adopted AS OF 10/9/12
As the Georgia Chapter of the American Planning Association, representing more than eight hundred professional planners, planning commissioners, elected officials and citizens, GPA offers these comments on the most recent draft of local planning requirements to be considered by the Georgia Department of Community Affairs (DCA).
There has been substantial progress as the draft has evolved through the guidance of the Planning Advisory Task Force and GPA appreciates the continued opportunity to provide feedback during this process. As stated earlier this year, GPA understands the vital need for communities to have ready access to planning resources in order to prioritize key investments, policies and strategies. Comprehensive planning is a central component of accommodating change successfully as demographic and economic shifts continue to arise. This is accomplished through a realistic assessment of current conditions coupled with a vision that seeks to properly coordinate decisions to meet community needs as transformation occurs. GPA urges DCA to take into account the following recommendations:
- The discussion of benefits of comprehensive planning under the Purpose section have become too abbreviated. No mention is made of the visioning aspect of a plan with the associated benefits of having defined, future goals although this is a fundamental and required component. This section needs to have additional, meaningful statements that emphasize the reasons planning rules are necessary and critical for all communities.
- The 20-year planning horizon period should be specified within the regulations. Failure to provide this directive means communities are free to plan for only a few years ahead, defeating the purpose of the process.
- Numerous references are made to the Supplemental Planning Guidance, but this information is not included except by reference. The optional plan elements should be included in the rules and not physically separated in the document.
- A summary of general population and demographic trends should be required. Realistic planning goals and policies ought to be based on identified needs that are directly associated with population trends. Since projections are more readily available and various State permits and assistance require projections of need, this element should be required.
- Under the Community Goals Element, it states that this element is the most important part of the plan but regular updates are not required. These should be updated or reaffirmed with every required plan update
- Under the Land Use Element, “equivalent land development regulations” needs clarification.
- Under the Housing Element, it is suggested that the availability of housing options across the life cycle be included as an identified issue.
- Under Character Areas and Defining Narrative, it states that these areas are connected to neighborhoods goals, but character areas are not restricted to this level of a community. The wording needs to be expanded to include sub-areas, districts, etc.
- Under Analysis of Data and Information, it indicates that data will be provided via the DCA website as well as base maps under the Mapping Requirements section. GPA recommends that the scope of information reflect what is currently required in a plan’s Community Assessment.
- Under Analysis of Data and Information, the regulations recommend not including community data, evaluations or maps used to substantiate identified needs or opportunities in the plan. Since a SWOT or similar analysis is to be performed, it is essential that this information be readily available so that the foundational assumptions upon which the plan is based are transparent to all community members.
- Specifics pertaining to plan implementation assistance offered by the Regional Commissions (RCs) need to be included.
- A completeness check performed by the RCs should be necessary prior to plan submission to DCA.
- If RCs will be producing required plan elements for communities who request assistance, it is advisable that they do not review the plans they have created, but enlist another RC to perform this review.
- Intergovernmental coordination efforts should be specified or incentivized.
- A definitive time frame, no longer than 60 days, for Department review of any required plan revisions should be indicated.
- The Required Updates to the Plan section needs clarification. Specifically, if an annual update for a Community Work Program is required due to an impact fee program, when is an update to the Land Use Element and Needs and Opportunities section required?
- The new five year requirement for the Land Use Element and Needs and Opportunities section warrants further consideration if a primary purpose of the current draft is to lessen the burden for mcommunity compliance.
- Will the Service Delivery Strategy update continue to be concurrently required with a full Comprehensive Plan update?
GPA respectfully submits these comments and recommendations for consideration.