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HomeMy WebLinkAboutCity Council Committees - Land Use and Planning Board - 01/08/2018 Land Use and Planning Board Workshop Agenda KENT W A S H I N G T O N Board Members: Katherine Jones/ /Vice Chair; Shane Amodei; Frank Cornelius; Dale Hartman; Paul Hintz; Ali Shasti JANUARY 8, 2018 7 p.m. Item Description Action Speaker Time Pacie 1. Call to order Vice Chair Jones 1 min 2. Roll call Vice Chair Jones 1 min 3. Changes to the Agenda Vice Chair Jones 3 min 4. Urban Separators Preliminary NO Danielle Butsick 55 min 1 Alternatives 5. Adjournment Vice Chair Jones 1 min Unless otherwise noted, the Land Use and Planning Board meets at 7 p.m. on the second and fourth Mondays of each month in Kent City Hall, Council Chambers East, 220 Fourth Ave S, Kent, WA 98032. No public testimony is taken at LUPB workshops; however, the public is welcome to attend. For additional information, contact Pamela Mottram via email at pmottram()KentWA.gov or by phone at 253-856-5454. Documents pertaining to the Land Use and Planning Board may be accessed at the City's website: http://kentwa.igm2.com/citizens/Default.aspx?DepartmentID=1004. Any person requiring a disability accommodation should contact the City Clerk's Office at 253- 856-5725 in advance. For TDD relay service call Washington Telecommunications Relay Service at 1-800-833-6388. 1 ECONOMIC & COMMUNITY DEVELOPMENT Ben Wolters, Director 11�4 ,^000 0 W*0� Phone: 253-856-5454 KEN T Fax: 253-856-6454 W A 5 H I N G T O N 220 Fourth Avenue S. Kent, WA 98032-5895 December 22, 2017 TO: Vice Chair Jones and Members of the Land Use and Planning Board FROM: Danielle Butsick, Long-Range Planner/GIS Coordinator RE: Urban Separators Preliminary Alternatives For Meeting of January 8, 2018 MOTION: Information Only SUMMARY: The City received multiple requests from property owners during the 2014 and 2015 comprehensive plan amendment docket process to consider changes to zoning or allowed development density of Urban Separator parcels. City Council approved the addition of an Urban Separators analysis to the department's work plan starting in 2017. Staff completed an inventory and characterization report of existing Urban Separators parcels, and a consistency review to assess relevant policies; the next step in the scope of work is a list of preliminary alternatives to guide discussions with stakeholders and the public. Staff will present the preliminary alternatives at the January 8 presentation and will request feedback from the LUPB. BACKGROUND: Kent's comprehensive plan and King County Countywide Planning Policies designate certain areas in the city as Urban Separators. These areas are intended to create visual definition within and between urban areas, buffer rural or resource lands, preserve opportunities for recreation, and connect wildlife and critical area corridors. This designation effectively limits development on these parcels to one residential unit per acre, as all Urban Separators are zoned SR-1, the lowest density allowed under Kent's zoning code. In response to docket requests received in 2014-2015, City Council directed staff to broadly consider the Urban Separator land use designation, and evaluate where it may or may no longer be appropriate in Kent. Informed by the findings in the Inventory & Characterization report and Consistency Review report, staff has developed five preliminary policy or code amendment alternatives to serve as a platform for discussion with stakeholders and the public. These include 1) preserving the status quo, 2) adopting a long-term policy of retaining urban separators, 3) adopting a long-term policy for considering land use plan map amendments to urban separator lands, 4) modifying development standards for SR-1 zoning, and 5) adopting or encouraging enrollment in incentive-based programs to preserve urban separators. These alternatives are not exhaustive, nor are they mutually exclusive; they will inform the discussion with stakeholders and the public, which will result in a final set of alternatives to be considered by City Council. Staff will be available at the January 8 meeting to provide information about the alternatives and next steps, answer questions, and receive feedback from the LUPB. EXHIBITS: Preliminary alternatives; PowerPoint presentation BUDGET IMPACTS: None DB:pm S:\Permlt\PlankZONINGOTHER_CODEAMENDMENTS\2016kZCA-2016-2 Urban SeparatorskLUPB 01-08-2018\01-08-2018_LUPB_UrbanSeparators-memo-info-only.doc CC: Ben Wolters,Economic&Community Development Director Charlene Anderson,Long Range Planning Manager December 4, 2017 2 URBAN SEPARATORS PRELIMINARY ALTERNATIVES: Background In 2014-2015, the city received multiple docket requests to consider amendments to the land use plan map and zoning districts map to increase allowed development density in urban separator areas zoned SR-1. These requests revealed the need to revisit the urban separator land use designation and evaluate its continued relevance. Kent City Council directed staff to begin a program in 2017 to broadly consider the appropriateness of the urban separator designation in Kent. Urban separator is a land use plan map designation in Kent's comprehensive plan; the designation is also used in King County's Countywide Planning Policies (CPPs). Urban separators are meant to protect ecologically sensitive areas and to create open space corridors that provide visual, recreational, and wildlife benefits within and between urban areas. Some urban separator lands in Kent are designated only on the city's land use plan map; others are designated both in Kent's comprehensive plan and in the King County CPPs. Kent's comprehensive plan states that all urban separator lands will be zoned SR-1, Kent's lowest-density single family residential zoning district. The first steps in the project were to develop an Inventory & Characterization report documenting conditions in all of Kent's urban separator lands, and a Consistency Review describing relevant policies and how they apply to Kent's urban separators. This document represents the third phase of the project, in which a list of preliminary alternatives is developed to provide context and guide discussion during the stakeholder outreach phase. The following descriptions of potential alternatives are meant to establish a long-term comprehensive strategy for Kent's urban separator lands. Note these alternatives are not intended to be all-encompassing or comprehensive, nor are they intended to be mutually exclusive. The city may ultimately decide to implement portions of these alternatives, entirely new alternatives, or modifications/combinations thereof. These alternatives are simply meant to be thought-provoking; they should provide context and a 'jumping off point" for discussions with the public and stakeholders about urban separators. 1 December 4, 2017 3 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 1) Preserve the status quo. Make no amendments to the land use plan map, no amendments to the zoning districts map, and no amendments to i i Kent City Code. Staff would recommend denial of any land use plan map I i amendments or rezones in urban separators based on their failure to meet comprehensive plan amendment review standards in KCC 12.02.050 and their inconsistency with Countywide Planning Policies (CPPs) and the purpose i i of the urban separator designation. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Discussion: This alternative would preserve existing urban separators as designated in Kent's land use plan map and King County Countywide Planning Policies (CPPs); it would affirm the city's position on comprehensive plan policies to maintain SR-1 zoning in urban separator lands. Staff would recommend denial of land use plan map amendment or rezone requests in urban separator lands based on their inability to meet the comprehensive plan amendment review standards in KCC 12.02.050. This includes failure to demonstrate changing circumstances since the comprehensive plan's adoption that warrant plan amendments, or that the amendments will result in long-term benefits to the community as a whole. King County's 2014 Buildable Lands analysis and Kent's 2015 development capacity analysis demonstrate that Kent has sufficient vacant and redevelopable land to accommodate population growth targets through 2035. Therefore there is no demonstrated need to amend land use plan map designations for urban separator lands to allow higher-density zoning. As further reasoning for denial of the docket requests, these amendments would be inconsistent with adopted CPPs and Kent's comprehensive plan policies. The King County CPPs establish the subject areas for both of the 2014 and 2015 docket requests as urban separators, and Kent's comprehensive plan policies state that all urban separators should be zoned SR-1. Any amendments to the land use plan map designations or zoning of these areas would therefore be in conflict with policies in the CPPs and Kent's comprehensive plan. This alternative would be the fastest to implement, as it would require no amendments to comprehensive plan text, the land use plan map, or the zoning districts map, nor would it require amendments to the King County CPPs. 2 December 4, 2017 4 �— — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — —I 2) Adopt a clear long-term policy of retaining urban separator i properties under that land use plan map designation, which could be I i reconsidered when vacant and redevelopable land can no longer i accommodate projected growth or growth targets. Establish a new "reserve i zoning" overlay district that identifies certain urban separator lands to be i i considered for increased density in the future, if additional developable land i is needed. i f - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - J Discussion: This alternative would preserve existing urban separator lands, including those designated in the CPPs and those designated only on Kent's land use plan map. It would establish policies in Kent's comprehensive plan stating that urban separator lands should retain their land use plan map designation. Policy guidance would include a provision to strategically designate portions of urban separator lands under a "reserve zoning"overlay to be considered if at some point in the future Kent's vacant and redevelopable land cannot accommodate its projected growth targets. King County has used the model of"reserve"zoning, stating as its purpose: "...to phase growth and demand for urban services, and to reserve large tracts of land for possible future growth in portions of King County designated by the Comprehensive Plan for future urban growth while allowing reasonable interim uses of property..." "...this zone is appropriate in urban areas, rural towns or in rural city expansion areas designated by the Comprehensive Plan, when such areas do not have adequate public facilities and services or are not yet needed to accommodate planned growth, [or] do not yet have detailed land use plans for urban uses and densities..." Not all of Kent's urban separator lands would be included in the reserve zoning overlay district; they would be considered for reserve zoning based on criteria in the Inventory & Characterization and Consistency Review reports, including overall scores for consistency with urban separator policies. Those with lower relative scores that show the most potential for successful development in the future will be included in the reserve zoning overlay. Until these lands are needed to absorb additional growth, they would remain under the urban separator land use designation. Lands that score the lowest in the Inventory & Characterization Report in terms of overall consistency with urban separator policies nevertheless provide important benefits in one or more categories. Even the lowest-scoring urban separator lands still contain critical areas, connect wildlife corridors, or preserve low- density development to protect at-risk watershed subbasins. This alternative would maintain these benefits until the land is needed to accommodate new growth. This alternative would establish policies to revisit the reserve zoning only if it is determined through a GMA-compliant buildable lands analysis that Kent does not have sufficient vacant and redevelopable land to accommodate its 20-year growth targets. 3 December 4, 2017 5 i- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - , 3) Adopt a clear long-term policy for considering land use plan map amendments pertaining to urban separator lands. The policy will include i i criteria and circumstances under which redesignations may be acceptable. i Prior to finalizing any amendments to land use plan map designations for King County urban separator lands, they must first be proposed as i i amendments to the urban separator maps in the King County CPPs. The i i amendments to the CPPs must be finalized prior to Kent City Council's formal adoption of land use plan map amendments. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - i Discussion: This alternative would establish policy guidance to be included in the text of the comprehensive plan which clarifies whether and under what circumstances urban separator lands may be redesignated on the land use plan map. It would also present an opportunity for the subsequent rezoning of urban separator lands that meet the specified criteria and undergo amendments to their land use plan map designations. Criteria would be based on findings of the Inventory & Characterization and Consistency Review reports. Adoption of policies and criteria to amend both Kent-only and King County designated urban separators would require amendments to Kent's comprehensive plan as well as to the King County CPPs. In order to make the most efficient use of the CPP amendment process, Kent would likely identify urban separator lands that meet the criteria identified, regardless of whether a request for redesignation has been received. These areas could include the two 2014 and 2015 docket request locations, if they are determined to meet the established criteria. Urban separator lands that meet the criteria would undergo amendments to their land use plan map designations in Kent's comprehensive plan; prior to final adoption, any amendments to King County designated urban separator lands would have to be proposed as amendments to the King County CPPs. They must be approved by the King County Growth Management Policy Council (GMPC), and ratified by King County jurisdictions. This alternative would take the longest to implement, as adoption of amendments to the King County CPPs can be a very lengthy process. The amendments would first have to be presented to the Interjurisdictional Team (IJT), which provides staff support to the GMPC. If advanced to the GMPC, the amendments must be discussed in at least two GMPC meetings, which only occur a few times per year. Once approved by the GMPC, cities and towns in King County must ratify the amendments, and they have 90 days to do so. The whole process may take more than a year, and once complete the amendments would still have to be formally adopted by Kent's city council. It should be noted that if no King County designated urban separator lands are determined to meet the specified criteria, the amendment process could be substantially shorter. In this scenario there would be no need for amendments to the CPPs, limiting the amendment process to that required for making any other amendment to Kent's land use plan map and zoning districts map. While this could be achieved by simply establishing "Kent-only designation" as a criterion, staff would recommend against this approach and would recommend giving all urban separator lands in Kent equal consideration for redesignation. 4 December 4, 2017 6 r - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -I 4) Modify development standards for SR-1 to be more flexible and to more i easily facilitate development. For example, remove or modify the requirement i for "8-pack" clusters with 120-foot spacing, or consider additional flexibility in i housing types such as cottage housing, duplexes, triplexes, or townhouses. This i could be similar to condition (27) in 15.04.030 Residential Development i Standards Conditions, which allows 25% of new housing developments in SR- i 4.5, SR-6, and SR-8 zoning districts to be attached. i - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - J Discussion: This alternative would involve amendments to Kent's zoning code rather than amendments to Kent's land use plan map or the King County CPPs. Land use plan map designations and SR-1 zoning would remain in place for all urban separator lands; it would, however, offer some additional flexibility in development standards within SR-1 zoning districts without modifying the overall allowed density. Some developers in Kent have described certain components of the clustering requirement in SR-1 zones as cost-prohibitive. The "8-pack"cluster with mandatory 120-foot spacing is cited as frequently making the difference between a development being cost-effective or not. This requirement, coupled with the 50% open space set-aside for unconstrained land, can reduce the number of lots that can be achieved when property is subdivided for development, particularly in areas that are substantially constrained by critical areas. This can sometimes push the development below the threshold of profitability. Modification to this requirement, for example by reducing the spacing required or increasing the number of clustered lots from 8 to 10 or 12 could increase the likelihood that developers may be able to move forward with cluster developments. The 50% open space set aside could also be modified to require 50% of the entire parcel to be set aside as open space, rather than applying to the unconstrained area only. This would allow critical areas to be counted as open space on properties that are significantly constrained by critical areas while ensuring that at least half of the property is reserved for open space purposes. Code amendments that include provisions for a percentage of cottage housing or attached townhouses in cluster developments could also help to improve profitability and feasibility of development in urban separator lands. Cottage housing would allow lots smaller than the minimum 2,500 square feet, providing additional flexibility to fully accommodate the number of lots allowed by SR-1 zoning. It should be noted, however, that cottage housing, as codified in 2008 in Ord. 3895 Cottage Housing Demonstration Ordinance (since expired), establishes parking, storage, and community building requirements, along with design standards, which require additional space in addition to individual lots. Existing code includes a provision to allow 25% of new subdivision developments in higher- density single family zones to be attached single family housing such as townhomes, duplexes, or triplexes. Code amendments extending this provision to lower-density single family zoning districts, including SR-1, could also expand housing variety in urban separator lands without adding additional net density. Encouraging housing variety is an important land use goal in Kent's comprehensive plan. The addition of an ownership interest requirement for attached townhomes (as defined in KCC 15.02.525) could expand ownership opportunities for middle-income Kent residents. New homes in residential subdivisions in urban separator lands would be subject to residential design review; this would apply to both single family homes and duplex townhomes. For townhouse structures with three or more homes, multifamily design review would apply. This would help to ensure that any attached housing is consistent with residential character and compatible with adjacent properties; access to open space or trails would further enhance the value of such developments. 5 December 4, 2017 7 t — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — � 5) Adopt or encourage enrollment in incentive-based programs to preserve urban separators as private open space lands. This could include i programs like Transfer of Development Rights (TDR) similar to King County's i i "four to one" program, or use of King County's public benefit rating system i through which taxable value of property is adjusted according to public benefits provided by privately owned land. The purpose of adoption or i promotion of these programs would be to incentivize preservation of urban i separator lands and provide a reasonable financial return for property owners. L - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - J Discussion: This alternative would create new or promote existing incentive-based programs to go beyond zoning and regulation of urban separator lands. The purpose of the programs would be to promote the preservation of undeveloped land in urban separators while affording reasonable financial benefits to property owners. One type of program that could be used would be the Transfer of Development Rights (TDR) program. Urban separator lands would be identified as "sending sites', and other lands in Kent (or perhaps in an adjacent jurisdiction) would be strategically identified as "receiving sites': Property owners could transfer or sell development rights from urban separator lands to developers of receiving sites at a rate greater than 1 unit per acre. This could result in greater financial opportunity for property owners of urban separator lands, particularly for those whose land is substantially constrained by critical areas, making development challenging or even unfeasible. There are several challenges to implementing a TDR program in Kent. One of these would be the presence of market demand for development rights and the willingness of developers to purchase units from urban separator property owners. The program would necessarily be market-driven, and the incentives would only work if there were interested buyers. A second challenge would be that Kent's policies and zoning code are already supportive of density in locations that can support intensive development; it may be challenging to identify receiving sites that could reasonably absorb densities beyond those for which they are already zoned. Another incentive-based program would be King County's public benefit rating system (PBRS), which offers a reduction in taxable value for private property that preserves a public use or benefit including maintaining urban open space, providing an active trail linkage, or protecting significant wildlife or salmon habitat, among a long list of available categories. This program is already in place and available to property owners in Kent who wish to submit an application. No code or comprehensive plan amendments would be necessary for Kent residents to take advantage of the program. To promote more widespread use of the program in Kent, the city could adopt comprehensive plan policies to encourage property owners in urban separator lands to pursue enrollment in the PBRS as a way to preserve open space and other natural and beneficial functions of urban separator lands. An example of potential savings for a $275,000 property in Kent is shown below. PBRS Example: For this example, consider a home in Kent valued at $275,000. The home and improvements, which cannot be counted in the reduced assessed value for PBRS, are valued at$175,000. This leaves a total land value of$100,000. After subtracting the land taken up by the house, driveway, and landscaping, 75% of the property remains as qualifying urban open space. Urban open space earns five points in the PBRS, the minimum points required to receive program benefits, which according to the valuation schedule translates to a 50% reduction in assessed value for the qualifying land. To calculate the reduction in assessed value, the total land value of$100,000 would first be 6 December 4, 2017 multiplied by 75% to reflect the proportion of the property that qualifies for the program. This results in a total qualified assessed value of$75,000, which would then be adjusted by 50% (up to 90010 depending on the number of points earned). The reduction in assessed "current use" value would be $37,500. This number is then multiplied by the 2017 King County tax rate of 1.222495% to determine the total annual savings - $458.44. Total property value: $275,000 Points/percent reduced taxable value: 5 points = 50% Annual tax savings: $458.44 S:\Permit�Plan�ZONING_OTHER_CODE AMENDMENTS�2016�ZCA-2016-2 Urban Separators�LUPB 01-08-2018�Preliminary alternatives_v2.docx 7 9 URBAN F. P/^ " QTO RS Preliminary Alternatives Land Use and Planning Board — January 8, 2018 City of Kent— Economic and Community Development 10 Presentation Snapshot Urban Separators Overview Project Goals Nov. Meeting Follow-Up Preliminary Alternatives Next Steps January 8t", 2018— Urban Separators City of Kent— Economic and Community Development 11 The Role of Urban Separators Urban Separators are intended to: Create visual definition, "transitional space" within and between urban growth areas, or buffer rural areas Preserve open space for visual, recreational purposes Connect wildlife corridors, wetlands Protect critical areas Buffer resource lands (agriculture, forest) January 8t", 2018— Urban Separators City of Kent— Economic and Community Development 12 History Separatorsof Urban Countywide designation beginning in 1992 CPPs In response to GMA, 1990 Countywide effort to preserve "what makes King County special" City of Kent Ord . 3551 in 2001 Amendment to Comprehensive Plan Set standards for development (clustering, SR-1 ) Kent Adopted additional urban separators in 2004-2007 January 8t", 2018— Urban Separators City of Kent— Economic and Community Development 5 r7r • - - • 14 Dro'Ject Goals 1 ) Determine most desirable land use for Urban Separator lands 2) Develop a strategy consistent with: • CPPs • MCPPs • GMA • Kent Comprehensive Plan • Infrastructure, transportation, CIPs 3) Implement zoning code or comprehensive plan amendments as identified January 8t", 2018— Urban Separators City of Kent— Economic and Community Development Follow=Up : 15 Legal Mandate for Watershed Protection Endangered Species Act: Puget Sound Action Agenda and Salmon Restoration Plans (WRIA 9, WRIA 8) WRIA-specific salmon recovery plans approved by federal agencies ESA is legally enforceable - if we don't meet our goals, federal agencies can require us to do more State Statute — RCW 90.71 : Accountability for achieving Puget Sound Action Agenda State funding implications if a jurisdiction is found to be in non-compliance January 8tt', 2018— Urban Separators City of Kent— Economic and Community Development 16 Preliminary Alternatives Preserve the Status Quo. 2) Adopt long-term policy to retain urban separators. Adopt long-term policy for considering land use plan map amendments to urban separators. Modify development standards for SR-1 zoning district. Adopt or encourage enrollment in incentive-based programs to preserve urban separators. January 8t", 2018— Urban Separators City of Kent— Economic and Community Development 17 1 ) Preserve the Status Quo. No amendments to land use plan map, zoning districts map, or Kent City Code. Recommend denial of docket requests based on failure to meet comprehensive plan amendment review standards (KCC 12 .02 .050) and inconsistency with King County CPPs. January 8t", 2018— Urban Separators City of Kent— Economic and Community Development 2 Adopt longmtermpolicyto retain urban 18 separators. • Establish policies to retain all existing urban separators. Create new "reserve zoning" overlay district. Certain urban separator lands can be considered for increased density in the future, ONLY if buildable lands analysis shows insufficient capacity for growth targets Not all urban separators would be eligible - criteria for reserve zoning would be based on Inventory & Characterization and Consistency Review reports Urban separator lands would continue to protect at-risk watersheds, and connect critical areas and wildlife corridors January 8t", 2018— Urban Separators City of Kent— Economic and Community Development 3 Adopt longmtermpolicyfor considerin land g use plan map amendments to urban separators. Establish criteria under which redesignation of urban separator lands is acceptable Criteria based on findings of Inventory & Characterization report Amendments to King County urban separators would require amendments to CPPs prior to adoption Presented to IJT, approved by GMPC, and ratified by local jurisdictions • Docket requests may be approved if they meet the criteria January 8t", 2018— Urban Separators City of Kent— Economic and Community Development 4 Modify development standards for SR=1 20 zoning district. Amendments to development standards in zoning code, rather than to land use plan map or King County CPPs Intended to facilitate development and achieve planned densities (1 home per acre) Could include modification of cluster subdivision requirements; or allow cottage or attached housing Would apply to all SR-1 zones, citywide No site-specific map changes to docket request properties January 8t", 2018— Urban Separators City of Kent— Economic and Community Development Criti I Ar riti Ar a as 501 O n S ce riti Ar Re uire ent Developable 50% Open Space Developable in Developable Portion Portion Portion Minimum Lot Size Minimum Lot Size u January 8t", 2018— Urban Separators City of Kent— Economic and Community Development 22 5Adopt a enrollment in incentive) or encourage g based programs to preserve urban separators. Incentivize preservation as alternative to development, provide reasonable financial return for property owners Transfer of Development Rights (TDR) program — like King County 4: 1 Property owner sells rights to develop to developers in other areas • Public Benefit Rating System (PBRS) Reduction in property tax for "public benefits" provided January 8t", 2018— Urban Separators City of Kent— Economic and Community Development 23 Next Stepn 1 ) Inventory & Characterization Report 2) Consistency Review Report 3) Preliminary alternatives analysis — land use, zoning or code amendments 4) Consultation & Public Engagement — city leadership, other departments, King County, and the public 5) Regulatory Compliance & Implementation January 8t", 2018— Urban Separators City of Kent— Economic and Community Development x' we C.W �,_ .� .� - - - � _ ate' -_n- 'y-- Y^--_ .• ... �. .. - P y „>-�-1-••. .�i a�i �'�'Y.'}.y SLR �— f 7 [_ e''�..�aM rw•a�..� r -� v+��. ^tip '�_ .__ � .. ,. .. oa i��r r e fr, R i W i ram. i �r AMAOr ; - �� �. ) .� -- lam--. ��� �'� �•.' -- - .,. .._ ._ 44 January i i— Urban SeparatorsI Economic I Community Development