1. https://www.youtube.com/watch?v=JyxOHLGyCsw

Is Planning a Dying Profession?

            A “debriefing” of the 2011 Camp Sequoia Planner’s Retreat Study Session

 by Robert L. Borchard.

Is Planning a dying profession? I think not! A “morphing” profession, perhaps. That is not to say that the planning profession is not under stress, particularly in these times of our new found “fiscal limits” at all levels of Government. We are, of course, are talking about local government (city and county) planning. At higher levels of government (federal and state) “Planning” seem to be thriving! There always seems to be enough money to fund State and Federal “planning” efforts. At the local level, however, things have been pretty tough these past few years. On the horizon, it looks like things are going to get a lot tougher!

At the San Joaquin Valley Division of Cal. Chapter APA Planner’s Retreat at Camp Sequoia, Planning as a Dying Profession was focus topic for a Saturday morning discussion group. I was fortunate enough to be given the opportunity to lead this discussion at this beautiful retreat located at the gateway to Sequoia-Kings Canyon National Park in Central California.

The work session was inspired by a Web link with the headline “Is Planning a Dying Profession”? It was written by a Planning Professor from Chapel Hill. In this paper, Thomas J. Campanella, traced the decline of planning back to Jane Jacobs and her 1961 “The Death and Life of Great American Cities” linked at (http://www.linkedin.com/groupItem?view=&srchtype=discussedNews&gid=128742&item=52158934&type=member&trk=eml-anet_dig-b_pd-ttl-cn&ut=0-wFXuKPZRtkU1 )

He claims that the “Jacobson movement” has lead to our “profession’s” decline:

·         It diminished the disciplinary identity of planning.

·         The seeming paucity among American planners today of the speculative courage and vision that once distinguished this profession.

·         Privileging the grassroots over plannerly authority and expertise meant a loss of professional agency.

How did we become a profession of Permit Processors? Who ARE the real planners? One of Mr. Campanella’s statements hit home with me and was the spark that inspired Planner’s Retreat discussion session; when local planners were questioned about “why major innovative planning directions were not initiated in the local planning Department”, the answer was that “they were too busy ‘planning’ to come up with any big plans”!

The discussion was far ranging and I could sense the frustration of most my peers. Budget cuts had decimated staff resources in every local government planning agency. The only planners who seemed to be untouched by this new governmental austerity were the “planners” from “above”.

I attempted to “narrow” the discussion to a couple key topics that I felt fairly well defined the issue. They were:

1. ·         Where Do YOU think the planning profession is headed?
2. ·         What do you think distinguishes YOU, as a “planner” from other municipal employees?
3. ·         What do YOU tell your children that YOU do for a living as a planner?
4. ·         The proper role of a City Planning Director; Planner or Administrator?
5. ·         From Permit Processor to Planner, how can we evolve?
6. ·         The proper role/value of “citizen planners” in the planning “process”?
7. ·         The role that our State laws and local codes play in degrading the value “planning”?

I asked the participants to rank the suggested topics so that we could limit the range of the discussion to fit the limits of our time for this subject. The group’s choice was to discuss the role of “citizen planners” (mandated public participation laws) and the impact of State Laws and mandates on local planning. These two topics seemed to go to the heart of my peers concerns and frustrations.

Perhaps the greatest frustration was with our State Rule makers. Their frustration was with the State’s apparent disconnect with the local planning process. Folks staffing State and Regional planning agencies seemed to be going on their merry way issuing new rules and edicts. that were, for the most part, unenforceable. The simple fact is that there are few planners left in the “local” planning trenches to carry out these marching orders issued from above!

Another source of frustration was with “mandated” public participation standards that did not promote good planning but rather promoted “nimbyism” or allowed local planning decision processes to be “hijacked” by politically inspired agendas that bore little or no relationship to local problem solving. For over an hour, the group vented their frustration with the dysfunctional local government “planning system” that local public agency planners were forced to work with.

We talked a little about the changing world that we live and work in and how that impacts our role as local government planning professionals. The concept of paradigm shifts on such a massive scale (global warming, economic, demographic, change, political extremism, etc.) and how that comes to roost in our local communities. The idea that “all planning is local” evolved for me that Saturday morning as I’m sure it did with many other study session participants.

During the Session Wrap-Up, I asked the attendees to describe their most important “planning” project that they were presently working on and what they brought to the table in the name of “planning”? There was a wide range of projects; important projects. All of these projects had a unique and significant impact on local cities or counties within which these planning professionals worked.

Interestingly enough, none of these “local” planning projects had anything to do with the large number of “planning” mandates that had been issued by the State of California or the edicts of any of the “regional” planning agencies in the state. Further more, the role of these “local” planners played in these important “local” planning projects was typically an “administrative”, “collaborative” or “coordinating” role. As the discussion progressed, it became apparent that local planners were the “getter done” players in their respective local governmental agencies.

It was clear that the “planners” role had evolved or morphed into something a little different than envisioned by Mr. Campanella and the other folks who commented on his Essay. It became clear to all of us that “planning was not a dying profession” it had simply changed to fit our changing social, economic and political world. We were part of a New Planning Profession and we were adapting to a changing world as best we could!

One aspect of this “new” planning professional was the “multi-disciplinary” skills that made these “planners” valuable players in the “local” planning game. They were, in a very true sense of the word, “Renaissance” men and women. Unlike their State and Regional Agency peers, these new age planners could not afford to be narrow specialists in any given field or discipline.

The new age local government planner had to have knowledge of traffic and transportation engineering techniques but were not engineers. They had to know how sewer, water and storm drain systems were designed but did not design these necessary infrastructure systems. Air quality, biological/riparian habitats, agricultural and urban economic system, they had a good working knowledge of how these disciplines worked and played a critical role in coordinating these different “schools” of thought to accomplish a “project” goal.

I came out of this Session with a new understanding and appreciation of what we, as planners, have become. I’ve read many of various “rants” about how the “planning” profession had “drifted” from its “design” based “roots” and become a “diluted” profession without a “place based focus”. This, I’ve come to understand, comes from folks, mostly in academia, who have lost (or perhaps never had) any real world involvement with “practitioners” in local planning.

This, in large measure, explains the failure of many of the “one-size fits all” regulatory schemas that have come “down” from our State agencies here in California. Of course, the failure of California’s Housing Element Law is just now beginning to be understood by many but that has not stopped the flow of “formula” types of regulatory laws and standards. Most of these programs have come from State Agencies staffed by individuals schooled in the theories that “planning” is not multi-disciplinary “art form” of civic place. Though these “planners” have been taught theories of “public participation” and understand its techniques, few understand the strengths and weaknesses of the role of “citizen planners”.

As I listened to my peers, over the course of this morning Session, I came to realize how (and why) planning, as a profession, has lost respect among many. The entire organizational “top-down” structure of our State directed” planning system has set US up to fail. The misguided Housing Element law is only one example of “failed” State planning. The decline of our State’s economy to perform competitively may be the direct result of the centralization of power and administrative “authority” in Sacramento. It has killed the “local” innovative spirit that is typically dismissed as “local politics” by academics and State level administrators.

This is not to say that we have problems of “regional” or “statewide” scope; we do! But rather than provide local governments, cities, counties, special districts, with a broad set of guidelines within which to devise solutions to OUR problems, the “one-size fits all” solutions flow down from on high killing “local” oriented solutions and adaptations. This arrogance that assumes that the same solutions, to our problems, apply equally to a jurisdiction of millions of people and a jurisdiction with under 10,000 has destroyed our States economy and undermined our local governments effectiveness to govern. It is killing our creative problem solving instincts as planners and stifled innovation that once was the hallmark of California government.

This arrogance exists at both the legislative and administrative levels of our State Government. The vulnerability of our state elected legislators to the influence of well funded lobbying groups has resulted in many of the misguided laws that have spawned expensive and misguided regulatory systems. At the same time, our state’s bureaucratic system has become completely insulated from direct accountability to any elected Governor or Legislator. It has, in a very real sense, become our “third” governmental estate.

So here we are, a small group of professional “local” government planners, discussing our “dying profession” on a beautiful sunny morning overlooking Sequoia Lake. Maybe it was the thin air at the 5,000 foot elevation, maybe it was the company. At any rate, for me, it was a “watershed” moment. At countless small discussions that occurred throughout the day after our working session was over, I came away from the Retreat with the impression that these feelings were generally shared by my peers. We are not part of a “dying” profession!

One thought that came out of Session that seemed to tie it all together was the phrase “doing things right is not necessarily doing the right thing”. Yes, we are mandated by “State Law” and regulation to do “things” right but that does not relieve us, as Planners from interjecting our voice into the process; do the “right” thing. That “planning” voice is typically heard at our city council or board of supervisor meetings; before the local elected officials whom we serve. Our voice, also, needs to be heard at the State level. We, as local government planners, need to try and educate our peers at the state level. We, through our professional bodies such as APA, the League of Cities, CSAC, etc., need to try and get OUR message through to our State elected officials.

No, “Planning is NOT a Dying Profession”. That does not mean, however, that is can’t be killed if we do not develop a clear understanding of our new role and accept our new responsibilities. Planning, as a profession, has “evolved” from a simple “design” oriented profession into a profession of individuals who understand, and manage, the complex “city building” process. We, as professionals, have grown. Once we understand our new role in local government organization, we can regain the respect that has been lost; we can begin to play and effective role in the organization and direction of our built environments. We can lay claim to the title of “City Planner” in this new Millennium.

 The “Conditional Use Permit” (CUP) in Mariposa County Planning-The BIG LIE!

Introduction

In recent public hearings our Mariposa County Planning Staff have argued that the CUP process give the County more “control” over potentially obnoxious, hazardous and “nuisance” type uses. The reality is that the CUP process DOES NOT GIVE COUNTY OFFICIALS any NEW “controls” but, instead GRANTS THEM NEW POWERS! The CUP process creates the POWER to say NO and is a continuation of a long “backward” tradition “POLITICIZING Mariposa County’s “planning” process. It feeds, what is known as the “ZONING GAME.

The Conditional Use Permit in Law and Practice

A Conditional Use Permit, or “CUP”, is a planning process set-forth in California Government Code Section 65900 to 65909.5 wherein a “legislative body” (Board of Supervisors, City Council, Planning Commission) may (after holding a public hearing or hearings), Approve, Deny or Conditionally Approve a “Use” on a specific piece of property in accordance with local “Zoning Laws”.

There are TWO key provisions added, by a CUP requirement, to the local government “permit” process;

1.      The “Power” to Deny, and

2.      The “Power” to Conditionally Approve, NOTHING ELSE!

A CUP creates a fundamental change in a “Property Right” under the law. While most permit processing agencies are careful with the “deny” aspect of this process and the “takings” implications in any legal challenge, the “conditions” of “approval are an area concern; this is where public agency “extortion” often occurs. It is not uncommon for a CUP to be “conditioned to death” as an alternative to outright denial. “Special” CUP “Conditions”, that is unreasonable or particularly “burdensome” or expensive, are applied as conditions of CUP “special” conditions and make the project uneconomical to pursue.

In some instances, through the “Environmental Review” process, applicants are forced to fund studies that document “problems” that are unrelated to a specific “project” but “might” result in “cumulative” project impacts that “Must Be Mitigated” before a project can be developed. These are “problems” that existed independent of the “project” but the “project” is forced to solve the problem.

All of this adds uncertainty to the “permit” process and acts as a significant “disincentive” to any major community “investment” by the private sector.

A CUP is a “descreationary” permit, like a rezoning or a General Plan Amendment. That means that the decision making body, with some limits, has “discretion” with respect to their actions on the application as opposed to a “Permitted” (Non-Descreationary) permit. Examples of “non-descreationary permits are building permits and MOST zoning permits. These non-descreationary permits are subject to rules and standards that are typically NOT SUBJECT TO CHANGE for an individual permit application.

 “Descreationary” CUP projects are subject to CEQA (Environmental) review where non-descreationary permits are typically exempt. This adds additional costs and time for permit approval.

In the real-world, “discretion” and “public hearings” tend to politicize the permit process and is the primary “planning” tool that empowers the NIMBY (Not In My Back Yard) types of actions that characterize many planning related “public hearings”.

 “The Zoning Game”, (Babcock), written back in the late 1960s, (THE ZONING GAME: MUNICIPAL PRACTICES AND POLICIES. By Richard F. Babcock. The University of Wisconsin Press, 1966.) characterized the way that the “public hearing” process has been, and is, abused by both special interests and public agencies. A recent update to Babcock’s newer book, “The Zoning Game Revisited”– 1985, Babcock added a collection of 11 case studies on local land use politics that offers behind-the-scenes analysis of decision making on zoning controls and land development. This later version of his book is more appropriate for the general reader as well as lawyers and planners, the cases illuminate many lessons that can be learned from well-documented land use disputes in eight states

The Background of the CUP in “Planning” in Mariposa County

The “CUP”, as a planning “tool” in Mariposa County dates back the County’s early efforts at zoning. In the late 1970s, the County had four zoning districts; The “Residential Zone” that encompassed the residential areas of the Mariposa Town site, the “AE or Agricultural Zone” that covered much of grazing land in the south end of the County (Cathay’s Valley, Hornitos, Green Mountain), the “TP or Timber Preserve Zone” for the forested areas in Greely Hill or bordering Yosemite National Park and the “Unclassified” or Ordinance 180 Zone that covered all areas of the County that was not “Zoned” by other Zoning Districts.

The old Unclassified Zone was, jokingly, referred to as the “Anything goes with a CUP Zone” and that is exactly how it was written. “All other uses that, in the determination of the Planning Commission were injurious to public health, safety and the general welfare” were subject to the Conditional Use Permit (CUP) requirements of the County.

There was, in the early days, a strong sentiment in the Mariposa County that Zoning was a “subversive governmental tool to deprive a property owner of their Property Rights”. This “aversion” to Zoning was partially resolved with the required State mandated “update” of the County’s General Plan in the late 1970s by the State Office of Planning and Research and the State Attorney General’s Office. The plan was written with “Use Standards” and after its adoption, these standards became the measure of those “uses” that were deemed to require a CUP under the “Planning Commission” determination of need. It was called “Zoning Creep” but it created some level of protection for the expanding “Rural Residential” development around the County that was threatened with “junk yards”, pig farms” and other “uses that, in the determination of the Planning Commission were injurious to public health, safety and the general welfare”.

In the mid/late 1980s, Mariposa County adopted its first comprehensive Zoning Code, Title 17 but many of the CUP requirements of the old Ordinance 180 “Unclassified Zone” were incorporated into the new code. The code itself did not establish many “performance standards” or regulations except as were established with specific State Laws, like the Surface Mining and Reclamation Act (SMRA) that regulated “surface mining” in the State of California and was “implemented” by the County to create “local control and administration” of these “State Mining Laws”.

In many ways the “evolution” and legally mandated conformance of local regulation and zoning standards has been a “wrenching” experience for local elected officials. Some of the most controversial public hearings in the County’s modern times were on Planning Regulations, Zoning and “permitting” of large projects such as Hotels, Golf Courses and “Mining”.

As a result, it took over 20 years for the County to update the General Plan that was written and adopted in the 1980s. This “aversion” for “planning controversy” played a role in failure of the County up bring its Zoning Codes, Title 17 as required by law. Recent efforts to conform with the law were inspired by renewed interest in “reactivating” Historic Mining properties in Mariposa County.

Where We Are Today

The current Zoning Code “Update” was initiated in response to a proposed large scale “mining” project in Bear Valley, that was a “permitted use”, not subject to a CUP, in the Zone AND General Plan. Like most “project driven” legislation, the Zoning “Update” failed to address overall inconsistency between the General Plan and the County’s Zoning Code but rather focused on one issue; MINING!

Instead of amending the zoning code to conform with the “Use” standards contained in the General Plan, the “Planners”, under pressure from some special interest groups, determined that a Change was in order in the General Plan to conform with SOME of the Mining restrictions that existed in the old Zoning Code. Furthermore, when it was found that Mining was a “permitted” use, in some existing zoning districts (including those reserved for mining) and these “permitted” stamdards were “Amended” out of the existing Zoning Code as well!

This comprehensive approach to restrict mining, in this Mother-Lode-Gold Rush County, is reflected in the actions of the Mariposa County Board of Supervisors, in Mariposa County Resolution Number 2015-543, “A RESOLUTION APPROVING GENERAL PLAN/ZONING AMENDMENT NO. 2015-126, AN AMENDMENT TO GENERAL PLAN POLICIES AND ZONING ORDINANCE REGULATION FOR MINING PERMITTING”. This is the General Plan Amendment part of major action by the Board of Supervisors regarding changes in County Mining Policies was adopted by the Board on November 17, 2015.

The argument, in support of this wholesale reversal of County Policy is based THE NEEDED “CONTROL” provided by new the CUP provisions. The changes from “Permitted” to “Conditionally Permitted” of ALL mining in Mariposa County is necessary, it is argued, to give the County more “Control” over mining operations and eliminate the potential for the creation of “hazardous” and obnoxious “mining” uses in the County. It should be noted that these new regulations ONLY apply to “large scale” mining operation on parcels of 160 acres or more and that not a single new standard or regulation was established to minimize the creation of “hazardous” or obnoxious mining activity on any mine, on any size property.

The General Plan Amendment/Zoning Change-A Step Backwards for Planning In Mariposa County

It is important to understand the different approaches to “planning” and zoning and why this expansion of the “descreationary” permit review authority of the County of Mariposa is a “step backward” in the “evolution” of the County’s Planning program.

As the writings of Richard Babcock, in his “Zoning Games” anthology point out that the abuse of authority, by local governments, in the application and administration of “Zoning” rules and processes have had detrimental effect on our entire “planning” efforts and has diminished the image of our local governmental institutions in the minds of the general public. It is seen as a “GAME” by both applicants and “citizen” participants; the “neighbors” in the NIMBY “Game”.

The CUP process is a big part of the problem, with its “public” focus on “Subjective” issues, as opposed to “Objective” standards. The “public” process interjects opportunities for abuse by various “interests” that can use this process of encourage a “public body” (City Council, Board of Supervisors, Planning Commission, Board of Zoning Appeal, etc.) to “do the right thing” that appears “politically” popular. Sometimes there is out-right corruption in the process.

Most “corruption” cases, in local governments, are based on “planning” and zoning decision making where “public officials” either “block” a development or “approve” as special interest development project that is otherwise inconsistent with established public policy. In his writing, Richard Babcock suggested

In his book, Richard Babcock poses three specific lines of action as the basis of needed zoning reforms:

 (1) more detailed statutory prescription of the required administrative procedure at local levels;

(2) statutory restatement of the major substantive criteria by which the reasonableness of local decision-making is measured; and

(3) creation of a state-wide administrative agency to review the decisions of local authorities in land-use matters, with final appeal to an appellate court.

The Modern Approach to Zoning

In many local government jurisdictions, Planners have taken Babcock’s suggestions to heart. Many Modern Zoning Codes are written to minimize the “descreationary” elements of permit process and rely on “Performance Standards” or “Performance Zoning” to minimize conflicts between competing uses.

Performance zoning is a land use planning concept that has its roots in building codes that established performance standards as opposed to specification standards. An example of a performance standard would be “that walls, floor and ceiling be so constructed as to contain an interior fire for one hour.

This has taken the “political” opportunities out of these codes. Many modern zoning regulations implement “mixed-use” standards that, in highly populated areas, reduce automobile traffic impacts and improve neighborhood “convenience”. Mixed-use zoning is dependent on “performance standards” to minimize or eliminate traditional “Use Conflicts”.

The “Standards” based zoning code uses the CUP process to guide a development towards a community adopted objective or give a developer an opportunity to “innovate” while accomplishing an adopted “community objective”; as established in the General Plan. The most important value of the “Performance” or “Standards” based zoning regulation is that it provides developers, investors, property owners and residents a clear set of “rules” that must be followed on a project. The answer to the question “What do I need to do” is answered at the beginning of the “permit entitlement” process as opposed to a “descreationary” permit process where the “answer” is not available for many months, even years, at the END of the permit process.

It is this “unknown” aspect of the permit/entitlement process that is a major disincentive to development investment in a community. In Mariposa County, like all “local governments” around the State and the Nation, the creation of a healthy economic environment AND a healthy physical environment, requires that we “evolve” our planning and development practices to reflect modern technology, life-style and “standards” of living.

There is an ongoing debate over “control” in all matters relating to permitting and development. This trends, over the past 20 or more years has been to move “planning decision making” to the Regional and State level. Air quality, and water quality are obvious “regional” and State-wide concerns. As the “Zoning Game”, by Babcock, brings to light, economic health and stability are taking on more “regional” and statewide emphasis and there are movements towards “regional” standardization of certain land use practices.

If the concept of “local control”, by locally elected officials, of land use and planning is to be maintained, we need to “evolve” our “local planning” practices to minimize the “political” descreationary permit review system in OUR County and move our system towards “objective” Standards based codes that address REAL issues and potential points of “conflicts” between competing uses.

So, Where Do We Go from Here?

The Planners and Leaders of Mariposa County need to step back from this special interest course of action, as reflected in General Plan/Zoning Amendment No. 2015-126 and take a comprehensive look at how modern application of zoning and development regulatory systems need to be implemented in Mariposa County.

Instead of an overhaul of our General Plan, to restrict and/or eliminate mining as a “Use” in Mariposa County, we need to research an implement Performance Standards for the proper and “same” operation of a mining industry in our County that would expand and enhance our local economy and create “Family Supporting” jobs, unlike the “welfare” supported service industry that that we now rely on as our primary economic “engine”.

We have both the time and the resources to undertake a comprehensive review of or Zoning and general development codes to Implement our General Plan in a manner that was adopted following many years of public review and debate. It’s time of for our Mariposa County Planning program to REVERSE the “regressive” course that it has taken over the past several years and, again, start BACK down the road to “evolving” a Planning program that reflect our modern technology, societal “norms: and preserves and protects the “values” that are part of the cultural fabric of our community.

References:

[PDF] The Code of the City: Standards and the Hidden Language of Place Making

E Ben-Joseph, MJ Kiefer - 2005 - goulstonstorrs.com

... to social reform led to the first zoning codes (based on Prussian precedents) to reduce land use
friction in industrializing cities and to subdivision codes to regulate rampant land speculation.
The public health and sanitation movement also relied on uniform standards, as did the ...

Cited by 141 Related articles All 4 versions Cite Save

Zoning for minimum standards: the Wayne Township case

CM Haar - Harv. L. Rev., 1952 - HeinOnline

... lots of three acres or more, and fire- fighting equipment had all been planned for a density of
population based on the ... 728, 12 NW2d 387 (1943): ruling that each zoning case must be
determined on its own facts and circum- stances ... (Truly a stark comment on the standards of the ...

Cited by 180 Related articles All 2 versions Cite Save More

Performance Standards: A Viable Alternative to Euclidean Zoning

LL McDougal III - Tul. L. Rev., 1972 - HeinOnline

... claims against ordinances that establish broad or almost no standards have in the past been
based on the premise that they constitute an impermis- sible delegation of legislative authority.
See also Mandelker, Delegation of Power and Function in Zoning Administration, 1963 ...

Cited by 39 Related articles All 3 versions Cite Save

[PDF] from tetonwyo.org

Performance-Based Planning Perspectives from the United States, Australia, and New Zealand

DC Baker, NG Sipe, BJ Gleeson - Journal of Planning Education …, 2006 - jpe.sagepub.com

... Second, performance measures within tradition zoning dis- tricts simply apply
performance-based standards to zones defining, for example, floor area ratios,
impervious surface ratios, and other detailed performance measurement. ...

Cited by 44 Related articles All 3 versions Cite Save

Impervious surface coverage: the emergence of a key environmental indicator

CL Arnold Jr, CJ Gibbons - Journal of the American planning …, 1996 - Taylor & Francis

... Schueler (1994a) rec- ommends watershed-based zoning that “is based on the premise that
impervious cover is a superior mea- sure to gauge the impacts of growth, compared to population
density, dwelling units or other factors.” In Alpine Township, Michigan, concern about ...

Cited by 1474 Related articles All 2 versions Cite Save

[PDF] from fltod.com

[PDF] Form first

P Katz - Planning, 2004 - fltod.com

... Unlike use-based zoning, form-based codes also specify a minimum height in order
to maintain a proper street wall. Siting standards control the placement of structures
in relation to fronting streets and adjacent building lots. ...

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[PDF] from growsmartri.org

Form-based land development regulations

RJ Sitkowski, BW Ohm - Urb. Law., 2006 - HeinOnline

... a readily identifiable set of component parts— the elements of a form-based land development ...
A "key map," akin to but very different from a zoning map, showing the sites ... matrix with supporting
diagrams covering bulk, height, coverage, and "in-building" use standards, and are ...

Cited by 27 Related articles All 12 versions Cite Save

[PDF] from bc.edu

Overlay Zoning, Performance Standards, and Environmental Protection After Nollan

RJ Blackwell - BC Envtl. Aff. L. Rev., 1988 - HeinOnline

... Agency may scientifically develop maximum pollutant discharge levels for an industry that may
be subsequently adopted by a local community in its zoning ordinance. 14 Primitive standards
are more general than precision standards, and include standards based on nuisance ...

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Wayne Township: Zoning for Whom?: In Brief Reply

CM Haar - Harvard Law Review, 1954 - JSTOR

... It is highly pertinent that a recent report to the President includes descriptions of many state and
local zoning ordinances, all of which are based on space occupancy standards which vary with
the number of occupants." Further, most model codes, such as that of the American ...

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Zoning for parking as policy process: A historical review

E Ferguson - Transport Reviews, 2004 - Taylor & Francis

... practice. Today they generally advocate more specific parking standards based
on broader national experience. Zoning for parking nonetheless appears to be a
more flexible strategy today than it was 50 years ago. Parking ...

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