September 8, 2017
Victor Planning & Zoning Commission
Victor City Hall
PO Box 122
Victor, Idaho 83455
RE: Fenn rezone proposal
Dear Victor Planning & Zoning Commission:
This letter serves as our official comment for the proposed rezone at the Garraux Property at 7634 N 500 W. As you know, the applicant, Mr. Jon Fenn, is proposing to rezone the property from NX & RS-7 to CX, IX, and RM-1.
Mr. Fenn was gracious enough to meet with our Board of Directors on August 24, 2017 to provide an overview of his rezone request/development concept, and to field our questions about the proposal. We would like to extend the utmost thanks to him for providing us with the opportunity to review the proposal in anticipation of the city’s public review process.
Our Board and Staff have carefully reviewed and discussed the proposal in the context of the City of Victor and Teton County Comprehensive Plans, as well as our 16-years of observing planning and development dynamics in Teton Valley. From this perspective, our organization has the following concerns:
- The proposed rezone would result in a vast swath of commercially-zoned land that is not adjacent to the downtown core. The City of Victor, in the course of de-annexation and downzoning, has implemented a clear, core-focused strategy toward infill development. We fear that a spot zone will undermine this strategy and shift Victor’s commercial locus northward, sapping development energy from the city’s core. According to a preliminary analysis from Teton County GIS, there appear to be at least 84 commercially-zoned parcels in the City of Victor that remain undeveloped. Before the city considers a substantial addition of new commercial, industrial, and multifamily lands, it may be worth considering current inventory and buildout capacity. We also note that the city conducted a community survey in 2015 prior to the adoption of its new zoning map, and respondents overwhelmingly favored walkable, compact commercial development in the city’s core. We believe that stated community preferences should be taken into account with discretionary approvals such as this proposed rezone. Furthermore, we believe the city’s core-focused strategy should be able to run its course before rezones are approved at the city’s fringes.
- The affordable housing benefits are not clear – especially when it comes to housing Teton Valley’s local workforce. We understand that the short-term rental units will be available for long-term lease outside of the peak summer season, but we must point out that summer is precisely when workforce housing is most needed according the 2014 Western Greater Yellowstone Housing Needs Assessment (HNA). Moreover, we emphasize that Teton Valley’s specific housing needs are represented in the HNA, and clearly, the greatest housing need is for year-round valley residents. Short-term rentals will likely be geared toward an itinerant workforce, and we fear that the envisioned development will serve as release valve for Jackson Hole rather than addressing local needs. We also note that development on the RM1-portion of the proposal will not be deed-restricted, and market sales prices will likely cause residential units to be unaffordable to most valley residents. In sum, we feel that the city should not grant special consideration to this rezone proposal based upon perceived housing benefits, because there is no guarantee this rezone will address the community’s increasing housing shortage.
- The proposed rezone may set a bad precedent. If the rezone is granted, other landowners will want the same deal – a rezone to accommodate a site-specific development plan that is inconsistent with the city’s long-term planning strategy. We understand the applicant has sought to purchase and assemble land in the city’s core, but has not been successful in this effort. Though we appreciate the difficulty in finding and developing suitable land (something Valley Advocates has experienced firsthand), the city’s 2015 public survey found that the community clearly favors concentrating commercial development in the core, and inhibiting it on the city’s fringe. For developers, infill development can a tough nut to crack, but we note that many small towns in the Rockies have stayed the course in promoting infill development and, as a result, attracted infill development that promotes a vibrant core.
- The development concept is vague and more information is needed to determine the appropriate physical design of the development. Once granted, the rezone will open the door for a 46-68 room hotel, over 100 short-term rental units, self-storage units, an undefined number of residential units, and undefined commercial uses north of the envisioned hotel site. The Planning & Zoning Commission should be cognizant of the fact that once a rezone is granted, the city will greatly diminish its control over the development concept; the vast array of uses or building types allowed by the city’s Land Development Code can be proposed by the applicant – or successor owners with different development ideas. In order for a large, precedent-changing development to be considered, the city should seek more clarity in the development plan and negotiate a comprehensive development agreement in order to address use, architecture, landscaping, site design, road/traffic improvements, infrastructure, phasing, and other project elements. If a re-zone is ultimately granted, the city should limit the uses and also bookend the entitlement with a reversion clause in the development agreement pursuant to Idaho Code § 67-6511A.
Recently, we’ve learned that the city has received a development plan for a 56-room hotel in the core of Victor. In addition, there are several housing and short-term rental developments also in the planning or construction stages. With all the current development underway that is occurring within the city’s existing planning and policy framework, we fear this rezone proposal could undermine the thoughtful, incremental growth the city has worked so diligently to promote. It appears that the city’s core-focused strategy is yielding positive results; staying the course may be the most prudent action at this time.
Finally, we understand the city will be updating its Comprehensive Plan next year. We believe this will be the perfect time to not only assess the city’s current strategy, but to incorporate the 2013 Code Studio Block Study, 2016 New Mobility West Workshop, and other substantial works that have been completed to date.
At this time, Valley Advocates cannot support this rezone proposal, however we support proactive solutions to the issues outlined above and others brought forth by the community. We have offered to help Mr. Fenn host a charrette to address specific site issues and have also offered our professional staff’s assistance to explore affordable housing solutions and draft a development agreement framework. He has declined at this time, but the offer still stands.
Thank you for the opportunity to comment, and if we can be of any assistance, please let us know.
Shawn W. Hill
Executive Director, Valley Advocates for Responsible Development