CVermont1@aol.com
Dear Gina,
I was surprised to learn (very late) that ANR was looking for input on its Growth Center White Paper by July 1. Having recently met with my committee and just received feedback, I offer the following comments on behalf of the Central Vermont Chamber of Commerce:
We applaud ANR & ACCD for rekindling efforts to give preference
to designated growth centers. This is an absolutely critical incentive
for many towns and good policy for the state regardless.
We commend and generally support the background, arguments, definitions
and characteristics of growth centers in Draft 9 of May 21, 2001.
(If there has been a more recent draft, we cannot comment as we
have not seen it, but I'm sure you can apply our input anyway.)
We believe more emphasis should be placed on the Agency's recognition
that "the term "growth center" does not require
growth to occur there." While we support "preference",
we are very concerned that any agency might go too far. Some are
concerned that the Agency is proposing that virtually all loans
and grants be for growth centers - an unrealistic and dangerous
position. Threats to public health and the environment should
continue to take strong preference over the socio-political desire
for concentrating new growth. Also, the majority of growth in
the foreseeable future will be outside growth centers. We can
stem the tide, but trying to "stop" growth outside growth
centers will produce only frustration and resentment. This would
hurt rather than help the cause.
We generally agree with the first three subcategories of growth
centers, however, we feel existing and proposed industrial parks
need to be identified as "critical economic areas" or
the like. They need to be at the top of the priority list, but
they cannot be termed "growth centers" without distorting
the desired definition beyond recognition.
We do take strong exception to growth center Characteristic
#1 (lot size, etc) in that emerging growth centers cannot realistically
comply. Most historic communities do not meet today's minimum
standards for lot sizes, storm water controls, and numerous other
ANR criteria. By ANR and Environement Board edict, most areas
without infrastructure in place prior to initial development have
been built over the past three decades using far more land consumption
than "historic patterns." No "magic wand"
from ANR can rewind the clock in these already-built areas.
We take equally strong exception to Characteristic # 6 (absorbing
growth over succeeding 20-year period). This flatly contradicts
the Agency's assertion that "growth center does not require
growth to occur there." In fact, most existing "growth
centers" will struggle to merely maintain their current residential
and commercial base. Many will need assistance to do so. In the
face of changing age demographics and household sizes, only a
few growth centers will be able to maintain their current percentages
of area population and employment in the next few decades.
A goal of reducing sprawl and concentrating more future growth
in growth centers than has been the case in the past 30 years
may be achievable. "Stopping" sprawl and/or limiting
future growth to growth centers is impossible. Attempting to do
so is destructive, not constructive. (Apologies for the redundancy.)
THE PROCESS FOR EVALUATING / DESIGNATING GROWTH CENTERS
is the most critical element of all, and discussion on this topic
is woefully absent from the Agency of Natural Resources Infrastructure
Funding Programs and Growth Center White Paper.
ANR cannot assume the role of "designator of growth centers.
There is a Consolidated Plan definition of "growth centers",
and ACCD cannot assume this role either. No state agency can or
should.
Multiple "growth center" designations will cause
confusion and frustration that undermine the basic concept instead
of building public support.
In various ways, local and regional planning organizations
have been addressing "growth centers" for more than
a decade. They must be the focus of any serious effort to revitalize
the concept and broaden support.
In order for "growth centers" to succeed, their designation
must parallel the process for "approved town plans";
i.e., towns must present their best efforts to regional planning
commissions who work within broad state guidelines to evaluate
and "approve" or "reject" the growth centers
proposed.
Only through such a process can the differences between a Chittenden
County "growth center" and an Orleans County "growth
center" be sensibly reconciled and credibly recognized.
Regions must be asked to develop criteria for evaluating "growth
centers" in their regions, and state-recognized "growth
centers" should be only those "approved" or certified
by the RPC.
Regions must also be asked to develop separate, specific criteria (in conjunction with RDC's) for
Regions should also be asked to review, comment and recommend
approval or non-approval of projects outside growth centers that
seek loans or funding. They are in the best position to determine
the general fit - or lack thereof - with the regional plan and/or
surrounding municipal plans.
To conduct evaluations or approvals of growth centers in any other way would be counter-productive and would likely violate the requirement that ANR's Agency Plan and policies be compatible with Regional Plans.
We appreciate the opportunity to provide this input. We wish you well in this important endeavor, and offer our time and participation in any on-going dialogue relative to refinement and implementation.
Sincerely,
Central VT Chamber
CVermont1@aol.com