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  How and Why to Read Your City's Comprehensive Plan

  Feb 19, 2022

  This article explains how to read your city's Comprehensive Plan quickly and efficiently. 

  BUT WHY SHOULD I???

   “Why on earth should I read a Comprehensive Plan?”  you may ask.  It's a fair question.   Comprehensive Plans are long, complicated, and its hard to see how they relate to unbridled growth in the region.  But to fix a problem, you need to understand the problem.   And the 2040 Plans for Kootenai cities—developed during COVID lockdowns and a housing panic—are definitely a problem.   

  Comprehensive Plans are used to guide changes to land use zoning.   Developers who would like to increase density or change usage before building on their land must request a zone change from the city and when they do this the Comp Plan guides the rezoning process.  The option of rezoning for higher density development is worth millions to land-owners, and anyone who wants to know what the “stakeholders” have in store for their neighborhood, must read and understand their city’s Plan.  

  Developers understand Comprehensive Plans and know how to use them to get approval for their projects. But residents who oppose densification usually do not understand the provisions in the Plan that are most harmful, or how they could be resisted.  They may also not realize that citizens have the right to request a modification of their city's Plan at any time.   We'll talk more about amending Comp Plans later. For now, let's focus on the parts of greatest interest.  

  THE IMPORTANCE OF FLUMS TO LAND-OWNERS

  Every Comp Plan has a Future Land Use Map.   This map indicates regions of the city that are likely to be annexed or upzoned in the coming years.   Of course, when a parcel of land is upzoned its owner makes windfall profits.   And although the city has the legal right to determine land use, it cannot profit from zoning changes. Only private land-owners gain directly from rezoning, and  upzoning parcels immediately before they are developed is a well-established method of minimizing taxes, constraining buildable land, and controlling all aspects of development.     

  Decisions to upzone are supposedly objective, based on what is best for the city, but of course, what is “best for the city” is usually decided in consultation with “stakeholders”.    In order to assure that the city's goals can be said to reflect the concerns of its residents,  planners rely on carefully worded surveys of public opinion and use “smart growth” talking points to obscure unpopular plans for densification.  But in spite of these pretenses, it is obvious that in the latest round of Comp Plans, city officials submitted entirely to developer interests and ignored resident priorities. 

  Before getting indignant, however, it is important to understand that developers and city planning departments have operated in this manner for many years.   In earlier eras, when homes were built by independent builders instead of corporations, cities expanded by building roads and sewers, and selling "city lots" to cover costs.   Now that investors hold most of the land surrounding cities, much urban planning has been handed over to corporations;  hence the rise of HOAs, cul-de-sacs, walled-off subdivions, and "planned developments".  An example of the problems that arise when cities cede important decisions to private developers is the  absolute wreck of a traffic grid in West CDA. 

  This unhealthy collusion between city planners and "stakeholders" was less noticable when priority was given to single family homes.  Now that they are going all-in for densification and multi-family rentals, the baneful consequences of developer-dominated city planning are alarmingly apparent.  

  WHERE TO FIND YOUR COMPREHENSIVE PLAN

  Comprehensive plans are usually available on city websites.   We’ve listed links to the comp plans for four of the cities in Kootenai County below, along with the key sections for close study.  

  CITY                                                                       FUTURE LAND MAP                        POLICY GUIDELINES

  Hayden 2040 Comp Plan                                  Appendix B ii, pg. 18                       ppg. 6-18

  Rathdrum Comp Plan                                        Future Land Use Map                    ppg. 20-21,28-30

  Post Falls Comp Plan                                         Chapter 2, ppg. 1-9                        Appix B, ppg. 7-14.

  New CDA Comp Plan                                          Part IV, 44, 45-61                            ppg. 38,  Appx, ppg. 91-101

  Each city's plan is unique, but all use similar terms and have similar components. We have indicated where the Future Land Use Map, Zoning Types, and Policy Guidelines, in each of the plans listed above can be found.   These are the main areas of interest , and it is these sections that you should focus on and attempt to understand.   

  Much of the rest of the Plan covers topics that state law requires all Comp Plans to include:  Population projections, Demographics, Schools, Economic Development, Housing, Property Rights, Natural Areas, Public Services, Parks, Sewers, Transportation, etc.  There are also pages dedicated to the history and particular attractions of each city.   The pages covering these topics are often informative and give the impression that the Plan is concerned with preserving each city's unique charm.  It isn't.  Most of this information is filler.  It can be SKIPPED.   

  HOW TO READ A COMPREHENSIVE PLAN

  Although many different topics are discussed in Comp Plans,  LAND USE and ZONING are where the MONEY is.   Much of the rest of the plan is a smoke screen.   The essential matter to keep in mind is this:  Providing guidelines to justify upzoning parcels for the benefit of influential property owners is the main purpose of the Comp Plan.  Once you have this clearly in mind, you will be able to grasp the importance of the most significant sections.  These are the three critical components of a Comp Plan: 

  1. Future Land Use Map—We have already discussed the importance of the FLUM.   In the past, Flums  were fairly simple, and indicated commecial, single family, and multi-family areas as distinct zoning types.  Recently, however, the movement to densify  neighborhoods and mix commercial and residential areas, has complicated zone maps, and some areas of the map may allow a variety of densities or usages. 
  2. Land Use Types—These general categories tell what type of development can be done in each zone.  The precise zoning type specifications, including parcel minimums, set backs, height restrictions,  etc., such as are not defined in the Comp Plan., and each city uses different terms to describe allowable zoning types.  Examples of land use types would be Mixed Use, Industrial, Commercial, Single Family (various densities,R-1,R-5,R-8, etc.), Multi-family, Mixed Residential, etc. 
  3. Goals and Objectives—Each Comp Plan  includes a set of policy objectives related to land use, which are crucial to the process of rezoning.   They are often couched in vague terms that have very specific meanings to planners and developers.  

  The FLUM and Land use types are visual and relatively easy to understand, but it is important to correlate what is shown on the map with the range of possible densities for given uses.    It is noteable that over time there has been a progression towards broader zoning categories that give developers "more flexibility" regarding both density and usage.   Developers always want more "flexibility" and "flexibility" almost always means higher densities.  

  The Mixed Use zoning catagory, which combines commercial property with high density apartments, is the HOLY GRAIL of "flexible" zoning categories, and is by far the most dangerous for dystopian, corporate, mega-development.  Mixed Use is the BIG BOX approach to community development,  and it wrecks every neighborhood in which it becomes dominant.   If you want to save your city, focus on reigning in Mixed Use. 

  The importance of the "Goals and Objectives" portion of the Comp Plan can be harder to understand.   There may be any number of goals or policies, and less than half deal directly with zoning.  Those that relate to zoning are usually couched in “smart growth” terminology and emphasize "housing options" and "choices".  The importance of these goals is that they lay out the rational for upzoning in terms of general benefits to the public by presenting densification as a positive social good.  

  COMPREHENSIVE PLAN TERMS AND PHRASES

  The following terms and phrases are often used in Comp Plans, but they have very specific meanings related to upzoning.  It is important to undertand the way in which they are used, so that citizens recognize the agenda of the planners and developers, even when it is couched in harmless sounding words.   

  • "Housing"—Almost always refers to rental units instead of owners occupied homes.   Providing "housing" and increasing the "housing supply" mean building more apartments.
  • "Affordable", "Fair", "Workforce", "Low-income" Housing—Government subsidized rentals.   The solution to the "housing crisis" is always more subsidizes paid directly to corporate owners of over-prices apartments. 
  • "Balance of Housing Types", "Missing Middle Housing"—Densification, multi-family up-zoning, rentals.
  • Housing "Options", "Opportunities", "Choices"—Multi-family dwellings in single family neighborhoods.   
  • "Compact Neighborhoods", "Mixed Residential"—Densification, multi-family up-zoning, rentals.
  • "Mixed Use", "Walkable communities"—Large scale corporate apartment complexes with retail on main floor, built on arterials or property formerly zoned as commercial.
  • "Preserve Historic Neighborhoods"—Mow down and rebuild anything not deemed "historic". 
  • "Transportation options"—Apply for federal government grants to upgrade public transit and build bike lanes.
  • "Multi-modal Transportation options"—Still no idea what this means, but it sounds threatening. 

  The main thing to understand about all these terms is that they all favor densification, and in almost all cases this means rentals, not single family homes.   In other words, the crisis of rising home prices is what is used to justify densification, but densification primarily increasing the supply of rentals, which does nothing to lower the price of homes.    In fact, quite the opposite is true.  Densification tends to increase, not lower home prices. 

  CHANGING, REPEALING COMPREHENSIVE PLANS

  The good news is that Idaho Code (67-6509), which governs the adoption, amendment, and repeal of Comprehensive Plans, provides that (d) "Any person may petition the [Planning and Zoning] commission . . . for a plan amendment at any time."  The bad news is that it may be difficult to get your P&Z Committees to approve of amendments.  But if you don't know what the critical components of your plan are you won't have the knowledge you need to be effective.     

  For those citizens who want to preserve their city, electing a City Council that represents the citizens instead of the "stakeholders" is an essential first step, but even when this is done, problems remain.  City planners tend to be loyal to their "customers" (i.e. the developers), and P&Z Commisions are often composed of those in the building and real estate industries.   Getting amendments made to The Plan that will actually slow out-of-control growth is a daunting task, and we beleve it may be more effective to work for FULL REPEAL than for amendments.   

  The fundamental problem with Comprehensive Plans is that they are part of a larger, utterly corrupt system of tax-breaks, corporate partnerships, government subsidies, and crony-capitalism, that favors land trusts and concentrates control of urban development into the hands of well-connected "insiders".    Comp Plans are part of a system by which land can be held undeveloped for decades and taxed a rate far below its real worth, until city officials wave their magic wand and make the land enormously valuable.  City planners defer to landowners in many matters, and are bound to support the "property rights" of unaccountable and sometimes anonymous corporations, while laws at the city, state, and federal level are all weighted in their favor.

  Eventually, the whole rotten system of property tax breaks, zoning manipulation, and government subsidies needs to be gutted, with the aim of opening up some of the land locked up in land trusts to citizens and small scale developers.  This may take years and must be done at the federal level, but it's the only way to return rationality to land prices and usage.  In the mean time, the best local residents can do is to gum up the works, resist over-development, and slow down the destruction of our cities.  To do this, you will need to understand Comprehensive Plans, and how their provisions can be turned to serve the interests of existing residents instead of investors and oligarchs.  

   

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