CVermont1@aol.com
June 27, 2001
Dear Gina:
The Central Vermont Regional Planning Commission's Growth Center Committee has reviewed the "Agency of Natural Resources Infrastructure Funding Programs and Growth Center White Paper (Draft 9)". We support the concept of targeting growth centers for public infrastructure funding as a strategy for promoting smart growth and applaud your efforts in this regard. However, we do have some concerns about the use of the current draft in the implementation of this goal. These concerns are outlined below.
* The Policy contains some apparent contradictions:
1. On page one it states, "...the majority of the growth resulting from these facilities will only occur in growth centers" - Which is it, "majority" or "only"?
2. On page 9 it is stated that "Growth Centers are not: Highway-oriented, commercial and industrial zones located on the edge and outside of traditional growth centers and characterized by separate uses...". This directly contradicts previous narrative (pages 3 and 4) wherein its stated that "existing and proposed industrial parks" and "commercial strip developments or other forms of scattered development" outside of traditional centers are both acceptable types of growth centers. Neither do these areas display the 9 identifiable traits it is suggested that "all growth centers" have (page 4).
If the intent of including the above places is to provide more flexibility in funding decisions, we believe it makes more sense to identify them as "other types of developments eligible for funding" rather than to try to try to force them into a definition they clearly do not fit.
* The Policy does not present a process for decision making. Who will be deciding what areas are growth centers? By what process? Using what objective criteria? These are significant unresolved issues. In some similar situations (town plan approval, and transportation improvements planning, for instance) the State either defers to, or relies heavily upon the findings of the regional planning commissions, reasoning that our ability to view local initiatives in the broader context is beneficial. Our Growth Center Committee would argue that the same principle should apply here. In fact, CVRPC has had a growth center evaluation process in place for seven years (See attached) . This process and its results are sanctioned by our Regional Plan. Any State initiative to designate growth centers should recognize this, or any other, compatible effort in conformance with Section 4305 of Chapter 117.
* Growth center characteristics 1 and 2 (page 4) suggest that fundable growth centers must allow for densities which can not be accommodated without waste water infrastructure. Understandably, municipalities will not rezone until the infrastructure exists. This is a classic "chicken and egg" situation that should be clarified before the policy is implemented.
Thank you for providing us with the opportunity to comment upon the draft. Please let me know if you would like to discuss any of these issues in more detail.
Sincerely,
Chris Walsh
On behalf of CVRPC's Growth Center Committee
CVermont1@aol.com