Open Letter to PC/SB re: Draft Subdivision Regs

I'll be out-of-town for your hearing on the 20th, but wanted to pass along my thoughts, for what they're worth.

First, it's clear a great deal of work and care went into these proposed regs, for which the Planning Commission deserve our congratulations and our thanks.

I believe I understand the intent of Section 3.2, concerning determination of allowable density, and feel these efforts are well-conceived though ultimately quite limited. Similarly, the subsequent sections of Article 3, all identifying specific non-density concerns regarding existing natural, cultural, and infrastructure assets seems to me, again, well-conceived, but limited.

For example, Section 3.7(F), concerning "Traffic and Road Capacity," states that a proposed subdivision "shall not result in unreasonable traffic congestion or exceed the capacity of roads and intersections IN THE VICINITY OF THE SUBDIVISION." (My emphasis) Apart from the eminently disputable standard for "unreasonable traffic congestion," this aspect of the proposed regs leaves the community powerless to regulate the cumulative effect of traffic from further rural subdivisions on the center of town and the intermediate access roads.

The "density adjustments" provided under Table 3.2, appear to be an attempt to address some of these concerns by increasing minimum lots according to road access and travel distances to Tracy Hall. Again, these seem to me to be decent general minimum standards which are certainly better than what we currently have. Nevertheless, they do not specifically address the particular circumstances we find in Norwich where the center of town bears the brunt of traffic for five feeder roads along which most future subdivisions will occur.

Furthermore, while the road class adjustments are likely intended to remain flexible, I can foresee circumstances under which they might prove far less restrictive than we now imagine. For instance, as more houses are built on New Boston Road, I can imagine more distant stretches of road being upgraded , as we have seen along Beaver Meadow Road in the past ten years. Under Table 3.2, such upgrades create, in effect, a density multiplier for lots accessing that road, doubling, quadrupling, possibly even sextupling the density of all lots along the improved stretch.

For this reason, I would ask the Planning Commission and Selectboard to consider altering the Density Adjustment in Table 3.2 (B) from a series of staggered mile intervals, to a continuum formula in which the Density Adjustment is a strict function of travel distance. Thus, a lot which would qualify as being 5.4 miles from Tracy Hall would have a Density Adjustment multiplier of 5.4, rather than 2.5 under the current proposed formula. This change would simply mitigate the potential multiplier due to subsequent road upgrades according to distance traveled. While the proposed change would be more restrictive on attenuated development that the current proposed formula, it is consistent with the increased multiple as a function of distance traveled and it is less arbitrary in that there is an actual objective basis for the multiple which is consistently applied along the entire distance of any road. I hope you'll consider this change.

Returning, then, to my primary concern regarding cumulative automobile traffic incidental to further rural residential development, I would urge the Planning Commission and Selectboard to follow-up on these regs with a set of regs governing specific roads. These subsequent regs should draw more broadly upon the stated goals of the Town Plan and take note of specific characteristics unique to each road. I believe the cumulative automobile traffic incidental to rural residential development continues to degrade quality of life and safety for those within the village district. This increased traffic also discourages non-motorized transportation along the feeder roads, necessarily adding to the volume of motorized traffic. I would hope the subsequent regs might approach rural development in terms analogous to those used in watershed studies, addressing each major feeder road as a "trafficshed" and regulating further "upstream" development according to the way they affect quality of life and safety in areas "downstream." We cannot account for "downstream" traffic impacts and the congestion caused by attenuated residential development without directly addressing them. I don't think the density formulae provided in the proposed subdivision regs account for these impacts.

I don't suggest "trafficshed" regulation lightly. On the contrary, I think it's absolutely necessary if we are to implement many of the objectives and policies adopted in our Town Plan. Indeed, while I appreciate the time and effort put into the proposed subdivision regs, they simply highlight how much is left to do regarding implementing the numerous objectives articulated in the Town Plan. I think the proposed regs are an important first step in creating a minimum floor for further subdivision permitting, but would be deeply disappointed if it were to be the only step.