Concerns regarding the Proposed Revisions to the 2040 Comprehensive Plan
On Friday May 7th, the City Manager released a timeline detailing the next steps for the Charlotte Future 2040 Plan and the process for adoption. Also included, were memos from the three City Council committees, a summary of the committee discussions followed by staff recommendations and responses (a copy maybe found here).
Unfortunately, we still do not believe that the proposed 2040 Comprehensive Plan revision to the draft reflects the stated community goals of improving the racial and income segregation in our community. We acknowledge that the City Council had several community meetings to gather feedback, but it is not apparent that the proposed changes reflect the feedback. We still believe that the City Council should delay the approval until further revisions are considered. We do need a 2040 Comprehensive Plan, but we need a fully vetted strong Plan that reflects strong public debate of key issues. The initial Council meetings were a good start, but we need to have more dialogue before any documents are approved. This should include more examples of how the proposed policies will impact existing Neighborhoods.
· Review of the Proposed ‘Revisions’
o New timeline for approval
§ Does NOT INCLUDE any additional Public Hearings on the proposed changes.
o Separate the 2040 Plan into 3 different sections and only have the Council approve the policy portion
§ Vision and Policy (approx. 136 pages) – goal of approval at the June 21st Council Meeting.
§ Implementation Plan (approx. 50 pages)
§ Appendix (approx. 130 pages)
· We agree with this change, but we are concerned that there is not a stated process for the adoption of the Implementation Plan (where a lot of details reside) and the method/amount of public participation.
o Change the wording to allow duplexes and triplexes in all Place Types vs. the previously stated all Lots.
§ This does not change that the UDO can still only create single family zoning districts that will allow duplexes and triplexes in all lots. The wording does not alter the policy implications.
o Create new Commissions to resolve identified issues just postpones the resolution of the issues.
§ Anti-Displacement Commission to create new program recommendations in the future
§ Community Benefits Stakeholders’ Group to develop the policy framework that can be adopted that meets the needs of both the Neighborhoods and the development community.
· Hire a consulting firm to help define the agreed upon framework for implementation.
o Modify the wording to acknowledge that some of the aspirational goals (e.g. Mandatory Inclusionary Zoning) are not currently legal in NC. In addition, that these items require further future dialogue with entities outside the City organization
· Significant issues previously identified were not addressed in the planned revisions:
o Density ≠Affordability
§ A new duplex in Myers Park is not ‘Affordable’ to someone making 80% AMI.
o NO Stated policy of proactively utilizing the planned UDO (Uniform Development Ordinance) to mitigate the forced displacement in historically minority Neighborhoods adjacent to existing and planned Mass Transit Lines. The existing NC laws allow the city to limit the size of new homes in designated Neighborhoods (e.g. historically minority proximate to new public mass transit) to mitigate the amount of forced displacement. This would stop the demolition of 800-1,000 square foot homes that are replaced with 3,000+ square foot homes or 2,500 square foot duplexes (DUETS).
§ (Note: City leadership suggest that the only way that they can impact forced displacement risk is through their budget spending and creating a new temporary anti-displacement Commission. They fail to mention that the 2022 budget allocates $2 million less in funding for Affordable Housing related programs than the 2020 budget.)
o The Equitable Growth Framework does not accurately measure the risk of forced displacement in Neighborhoods. The current city definition does not acknowledge the impact of locating Mass Transit Lines (e.g. Blue, Gold, Silver Lines) on the likelihood of forced displacement occurring. It is not difficult to see the forced displacement in the Neighborhoods adjacent to the Blue Line. This is a critical ‘controllable risk factor’ for the City to acknowledge. This would acknowledge their accountability for their actions and not just blame ‘market forces’. If the policy was to purchase land in ‘at-risk’ Neighborhoods at the time of acquiring the land for the actual transit line than the forced displacement impact on the adjacent Neighborhoods would be greatly diminished.
o LACK OF MEASUREABLE GOALS: City leaders talk about the expectation of future revisions (5 years) based upon the effectiveness of the Plan. However, there are not stated targets for improvement of the historically racially segregated neighborhoods nor the amount of forced displacement that is currently occurring.