SHJH Comments on “Administrative Changes to the LDRs

SHJH submitted the following comments to our elected official on the proposed “administrative changes” to the Land Development Regulations:

We believe Paul D’Amours brought up valid points on Home Business/Home Occupancy at the recent joint meeting.  We hope you will not ignore his comments.


Our position on home business is that any home business must have the same impact or less impact on the neighborhood as a typical residence.  A small day care of 5 or less, is probably about the same as a large family.  A day care of more than 5 is a greater impact and should not be allowed regardless of state regulations.  Conventional Retail should not be allowed as it would generate too much traffic.  A small internet mail order business is probably OK.  A small metal shop or wood working shop that operates out of a garage with all employees on site is no different than a home hobbyist.  It should be allowed.  A large shop that has multiple deliveries by truck and multiple employees living off site should not be allowed.  A contractor who stocks supplies in his garage or shed and parks a single vehicle on-site should be allowed as long as it does not violate any parking regulations.  The CCRs in most subdivisions will have additional restrictions that will limit the type of commercial.  Processing of meat and game would generate more traffic and should not be allowed.  Someone who is doing catering from their house should be allowed as long as they meet all health regulations and the employees live on site.  Any business that uses 100% of the habitable space is not a home business, it is a business and belongs in a commercial zone. 


The Comp Plan envisions some home business.  Unfortunately despite its length the Plan does not provide a lot of guidance about what should be allowed. We believe commonsense should provide guidelines for what types of home business or home occupancy should be allowed.  Having sat through all the meetings where this was discussed by both the electeds and the Planning Commissions, I think that is what the Plan intends.  I hope you will clarify this before you proceed.


It is apparent to us that despite the best efforts of staff to produce the table of changes and the best efforts of groups like SHJH to review the table, it is not the most effective method of communicating the proposed changes to the public.  It appears that some changes may not have been included in the table or were not adequately explained. We do not believe the public or advocacy groups like SHJH should have to review the existing LDRs and the proposed LDRs line by line to find all the changes.  It is the responsibility of the planning department and the electeds to provide the proposed changes to the public in a manner that makes it easy to determine what is changing.   We believe the complexity of reviewing 3 documents concurrently  is why very few people have commented.  We propose that staff provide a single document that clearly shows what was deleted and what was added.  We believe working from three documents: the table of changes, the existing regulations and the proposed regulations is unwieldy and unacceptable.


Lastly, we believe that changing the administrative sections of the LDRs (especially home business and home occupancy) without having zoning maps to see how these changes will be applied is like trying to sell the public a pig in a poke.  The “administrative” changes should not be adopted until the zoning maps are done.