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HomeMy WebLinkAboutAgenda - 08-27-2007-d3ORANGE COUNTY NON-PUBLIC HEARING AGENDA ITEM ABSTRACT Meeting Date: August 27, 2007 SUBJECT: Transfer of Development Rights (TDR) Update DEPARTMENT: Planning and Inspections Consultant Status Report Letter Administrative and Program Design Options Action Agenda Item No. D.3 PUBLIC HEARING: (Y/N) No INFORMATION CONTACT: Craig Benedict, Planning Director, 245 2592 Glenn Bowles, 245 2577 PURPOSE: To consider consultant's presentation of update of the TDR program and administrative design options and provide comments to staff and the consultant. BACKGROUND: The BOCC retained The Louis Berger Group and the University of North Carolina — Charlotte Urban Institute to complete Phase III of the TDR study. The Phase III studies are a continuation of the first two phases (background data collection and feasibility), which Berger and the Urban Institute completed in the fall of 2006. Staff has continued to work with The Louis Berger Group since their contract was amended in November 2006 to include Phase III work to define specific program and administrative design issues. The Environmental Resource Conservation Department and the County Attorney have been consulted on all aspects of these issues. The consultants made an informational presentation to the Planning Board on March 7, 2007. Members of the Planning Board, Affordable Housing Advisory Board, the Agricultural Preservation Board, the Historic Preservation Commission, the Commission for the Environment, the Economic Development Commission met with the consultant and Planning staff on April 23, 2007 to review the TDR program and administrative design options. FINANCIAL IMPACT: There is no financial impact associated with this item. Consultant costs were allocated in FY 2006-07. If implementation occurs within the upcoming fiscal year, Planning Department staff can handle the initialization of the program, as tentatively designed. RECOMMENDATION: The County TDR staff team recommends that the Board consider the consultant's suggestions regarding TDR program and administrative design* options of the County TDR program and provide the consultant and staff direction on the issues discussed. K THE Louis BERGER GROUP, INC. 1001 Wade Ave. Raleigh, North Carolina 27605 Tel (919) 866-4400 Fax (919) 755-3502 www.louisberger.com August 13, 2007 Craig Benedict, AICP, Director of Planning Glenn Bowles, AICP, Planner II Orange County Department of Planning and Zoning 306F Revere Road Hillsborough, NC 27278 Subject: Progress of Transfer of Development Rights Phase III (Implementation) Dear Messrs. Benedict / Bowles: The following is an assessment of the status, Joint Advisory Board (JAB) goals, and communication needs for the Transfer of Development Rights (TDR) Project Phase III, which is specifically oriented towards providing implementabon guidance of a specific program and administrative design of the TDR program. Status of Project To date, we have conducted one meeting of the Joint Advisory Board (April 23, 2007) to introduce the project, past work that has been completed in earlier phases, and the purpose of the Joint Advisory Board. Several meetings have been held with the Orange County Planning staff, and one meeting thus far with the County Attorney. We have or are in the process of conducting additional meetings with county private developers and comparable TDR programs outside of North Carolina that can provide insight into specific processes and program design issues identified by the project team. Draft documents have been completed for the secondary economic analyses; draft program design template; additional mapping / spatial analysis to refine both Sending and Receiving Area boundaries; draft administrative design workflow templates; a major project website update was completed in May; a list of questions submitted to the County Attorney; draft pros/cons document to illustrate major decision points; and draft conservation easement language. Additional work is being undertaken now to produce one or more display boards for the upcoming August 27th Board of Commissioners quarterly public hearing, and produce a draft baseline report to establish Sending Area credits for the Orange County Planning staff. To date, approximately 70% of the project budget has been expended. Joint Advisory Board Goals and Purpose The first JAB meeting was largely spent on reiterating work that has already been conducted and posted to the project website. During this meeting, it was apparent that the primary goal of the JAB — to help provide direction on the details of the program design and administrative options — was being subsumed by a larger discussion about the purpose of and need for TDR in Orange County. We would hope that the County would respond favorably towards past, relevant work products completed in Phases I and II of the project, and underscore the need for forward progress by the JAB to get comments on specific points of program and administrative design issues in subsequent meetings. IZ1911111MR, 1001 Wade Ave. Raleigh, North Carolina 27605 Tel (919) 866-4400 Fax (919) 755-3502 www.loulsberger.com Communication The project team (consultants plus Orange County Planning Department staff) have committed to having once-every-two-week telephone meetings, if necessary, to review progress and coordinate on upcoming work products. The consultant team (Louis Berger Group and UNC Charlotte Urban Institute) also conducts additional telephone coordination, as needed. The remaining coordination that is absolutely essential to completing this project by the end of calendar year 2007 is (A) a strong commitment by the County Attorney to address the remaining process issues and questions submitted recently, and to review draft products; and (B) as mentioned earlier, a renewed focus by the JAB members to commit to reviewing administrative and program design options so that final adjustments can be made to the TDR program description and process tools. I want to reiterate our appreciation to you and Orange County for taking on this challenging but very rewarding process; we remain highly committed to an excellent product and making sure that transfer of development rights becomes a reality in Orange County. Sincerely, The Louis Berger Group, Inc. J. Scott Lane, AICP, GISP Director of Planning Orange County TDR Implementation Planning 4 Administrative Design Options 0 = Recommended Course of Action 1. Pre-Certification of RCA C red es a pool" The baseline Properties of known_eligible certification report Should the Orange County staff may have to be done meet with potential RCA property when , eve ope,rs come in;the door`; all over again if a long period of time (e.g., owners and certify their e duce two years) passes properties as being eligible for credits prior to and unassociated on 'thedeyeIoprnent­' between the original with any development action ocess, by (pre) certification and instead of waiting until the TDR d6co uplih.g the-RCA, the actual credit transaction is initiated by a eligibilit.Yfrom the, � 1. '- , : '. transaction occurs development action? rest bf.the. .' '; May create a false transaction : process expectation of readiness on the part of the RCA property owners 2. Property Valuation Offers one way of ;6 Adds additional, Should a third-party property helping to ensure ::complexity: and valuation be done to determine some equity of expense to the TDR an objective value of the RCA credit market value process for both.: property and hence the number �: Sencling'dncl SGA of credits that the (conserved) rests . prop erty is worth, instead of allowing individual negotiations between Sending Area and Receiving Area landowner developer to set the TDR credit price.? 3. Incentives Through Process Initially, this was Omitting any part of,, Streamlining identified by .the. review process Should the County review developers as a would raise ,puestiOn' s':,_ process be shortened - probably way of raising.more aboutitsvalidify, - ncl:l': F.. . .1- .1 .1 _1 a through the deletion of the interest in .-may'..16e perceive, .. as::, ' d Neighborhood Informational participating in a 9ra.n ting evelopment- -for viable TDR projects, TDR scheme Interdst!'favors, .af the 'Meeting instead of the TDR project Streamlining expense of residents following the normal review becomes a more and business owners process? viable option IF TDR ...Shouldbe_ SGA design ..,:,considered after the standards are part :.ibRprogram has - be e hT of the required initiated lHrahsac.tion process activifyis low: 0 = Recommended Course of Action Orange County TDR Implementation Planning ❑ = Recommended Course of Action 1. Designate Sending and F ''•: t t `+ r t r Easyrto�comMON.cate ' � Generalizes some Receiving Areas by Using and understand at a properties that may Mapped Boundaries ,�glance�which °d not be suitable for participation with Should the County have a fproperfiie a,Yor others that are (not as map that shows boundaries much detail) for Sending Areas and �j`Areas can readily be May require Receiving Areas instead of � alignedvvth eXistm'g';, imposition of using criteria to judge 1; , . ,zoning or ofiher district additional eligibility eligibility? designations if criteria to identify more �appropFriate, , suitable properties _; Easier,fio d,etermrne � ,r� r alter to ac Re;ceiumg Areas to stim;ulate'ciemei'nd:, „Y 2. Allow Sending /Receiving Gives property owners = tCreatkes a Area Overlap maximum choice and �' "patchwork" flexibility as to whether conserved and rriore Should the TDR Program allow to conserve, develop " intensely', ev��loped overlap in Sending and at current zoning "properties 4'Yx }{ Receiving Areas instead of densities, or develop at i "Not�dll'arecs drer) > ,' having mutually exclusive higher densities -� dx suitedrto receivjP;Q Sending and Receiving higher density a Areas? w , s ;comphcbfied fMorbe corrimunicate, F F , Y ,: uncierstancld'an�i ' Y , 3. Criteria for Selecting or Avo1'. S, nfusion21s to ` Limits amount of land Qualifying Receiving Areas � y�hether,prior '` available for receiving d�� regulations or3` areas Should Orange County use agreementsYpreyenti'ng� Requires a more criteria (environmentally i FS cue eloping th4ese extensive public input sensitive, historic sites, already Fareas tgke`' rece`dence over process to develop conserved places, '� the TDR program °; ` �; acceptance of higher development zones) to �, "'guilds'acce ftance'for1 density areas other exclude, lower or increase ,y the,. " r�o rarnp when it' than those in allowable densities in p g, `q�reddy�,�; ` proposed aligns with ,'� prior programs Receiving Areas instead of r accepted programs setting a flat rate for t F y ) acceptable densities based ' 7 7 tl-irc I -M1 r s is s t on zoning? ❑ = Recommended Course of Action 4. Adopt Criteria for Selecting or Qualifying Sending Areas Should Orange County use criteria (historic areas / sites, high growth pressure locations, water supply watershed, wetlands, etc.) to modify the number of TDR credits attached to a Sending Area property instead of naming the entire unincorporated, non - Receiving Area part of the County as an eligible Sending Area? 5. Define a Minimum Acreage as a Pre - Condition for Eligibility as a Sending Area Should Orange County use minimum acreages of contiguous property to help determine eligible Sending Areas or accept no minimum area size? ❑ = Recommended Course of Action Orange County TDR Implementation Planning • Lose the sense of fairness that all are included if the entire county isn't eligible • Reduces the size of the "market" of potential easement sellers More complicated to explain and understand Could create some property owner frustration among those "in" the sending area boundary but not meeting the additional criteria 7 Orange County TDR Implementation Planning 6. Define Sending Area Credits a a. Fixed Formula Sense of fairness that all properties are treated m most; imp Should Orange County keep a fixed credit-to-acre formula the same (e.g., two credits per acre) to I I + Q r4;n r,=rN I-rnrMc %.-U �.A 'Zo lzo" & b. Formula that gives more credits to areas with more instead of applying more complex formulas that respect conservation merit (soils, habitat, historic sites) 6 Sense of unfairness �' the specific conditions of the t underlying property? that some properties aprioritizes, properties that receive preferential h; treatment[sn] 7. Define Receivina Area Credits as a Fixed Ratio to Acreage Should Orange County keep a fixed ratio (x credits = y additional housing units per acre) instead of bonuses based on development suitability criteria (e.g., zoning, soils) ? c. Formula that reduces credits allowed due to existinq structures on Sending Area property h, Misses the n opportunity to provide a participation incentive in the form of d extra credits Sense of fairness that all properties are treated the same Easier to explain and understand ❑ = Recommended Course of Action 7. Define Receivina Area Credits as a Fixed Ratio to Acreage Should Orange County keep a fixed ratio (x credits = y additional housing units per acre) instead of bonuses based on development suitability criteria (e.g., zoning, soils) ? c. Formula that reduces credits allowed due to existinq structures on Sending Area property h, Misses the n opportunity to provide a participation incentive in the form of d extra credits Sense of fairness that all properties are treated the same Easier to explain and understand ❑ = Recommended Course of Action Sense of fairness that all properties are treated the same Easier to explain and understand ❑ = Recommended Course of Action 8 Orange County TDR Implementation Planning 8. Apply Additional a. Building Design Guidelines �6 !"ffi`6'f:"1mpQc1 Decreases the value of Development Restrictions or Requirements in credits to developers, may Receiving Areas deVeiopfb-' deter developers from Should Orange County apply using credits additional site development guidelines such as design `zv guidelines or affordable housing requirements, instead dic of adhering to current development guidelines and policies for TDR projects? b. Affordable Housing Requirements 13 Encourages more IM -, f i", 1.7 affordable housing .401WIncuf"opposi istlh- options for medium- 16' 01,f�J and low-wage families t1h, 9. Allow Commercial 1 Existing codes' volume Development Credits fehIT' 1, restrictions difficult to calculate and translate Should Orange County relax er e, into a density bonus restrictions on parking, open Existing codes provide space, building height, little restriction on setbacks, or other dg�' commercial development requirements to encourage ,5WJ t b intensify vs. current market commercial development in anju demand Receiving Areas instead of rp,, y in Open space requirement only allowing residential-to- I is most obvious one to be residential TDR transactions? exchanged for sending area credits, but there's no gain to the County for trading open space neededtokeep commer cial development livable in urbanizing areas for open space needed to keep rural areas from being eveloped 0 = Recommended Course of Action 9 Orange County D]R Implementation Planning Should Orange County create a formula that equates TDR credits to monetary value of relaxed lifted restrictions' other restrictions requirements site or project to p I rojeCt[s15][s16] 11. Install Limits on the Density May be viewed as Allowable on a Receiving �n, hi". an arbitrary limit, and Area Property provides less flexibility for developers whose Should Orange County provide a project's desired density caps on a// Receiving Area properties instead of the limit allowing the market to dictate over Will require re-visiting periodically to ensure limits haven t been go eclipsed by market A limit would reduce the Sending amount of Area credits to be viron absorbed A limit does not allow the market to operate freely if there is a perceived or real density product 0 = Recommended Course of Action m Orange County TDR Implementation Planning Strategic Growth and Rural Conservation Program Design Specifications Under Orange County's Growth and Rural Conservation Program, owners of property in designated Growth Areas ( "GA "s) may be eligible for administratively - awarded density bonuses for development of their GA property (i.e., to allow development at a higher density than allowed as -by -right under their current zoning designation) when they purchase an approved conservation easement on an eligible property in a designated Conservation Area ( "CA "). This document describes how the program is designed. Administrative procedures for participating in the program are outlined in a separate document. 1. Designated Areas. Non - overlapping Growth Areas and Conservation Areas are designated by boundaries as drawn on an official (adopted) Strategic Growth and Rural Conservation Program Map, such that all tax parcels within the County's land regulatory jurisdiction are designated as either within a Growth Area or within a Conservation Area', as follows: a. The following constitute Growth Areas (except as noted below): i. Land within Economic Development Zoning Districts; ii. Land within the Rural Community Nodes as depicted in the County's Comprehensive Plan Land Use Element; iii. Land within the 10 -yr and 20 -yr Urbanizing Transition Areas in the Efland- Mebane area in the County's Comprehensive Plan Land Use Element; iv. Land within the County jurisdiction joint planning areas as depicted in the proposed Hillsborough Strategic Plan; v. Land within the Hillsborough Transition areas as depicted in the proposed Hillsborough Strategic Plan. b. Properties are excluded from Growth Areas and are designated as Conservation Areas if any of these criteria are met: ii. Property is on the National Historic Register, or is otherwise designated locally, or at the state or federal level as a historic site or as containing a historic structure; iii. Property contains environmentally sensitive features or areas: 2. Is in a Water Supply Watershed designated Critical Area; 3. Contains land that is within 150 feet of the main body (impounded or free - flowing) or perennial stream of any of the County's river systems; 4. Contains a wetland (as identified by the presence of hydric soils); 5. Contains a Natural Heritage Inventory site (as identified by the state's NHI maps); 6. Contains a Prime Rated Forest Habitat area (as identified by the County's Dept. of Environmental Resource Conservation maps); or, i Some tax parcels may be partially within and partially outside of the zoning and other planning boundaries used to designate Growth Areas, and as such, may have a portion of the tax parcel in a Growth Area and another portion in a Conservation Area. ❑ = Recommended Course of Action 2 Orange CoonfvTDR Implementation Planning c. All other land within County land regulatory jurisdiction that is not designated as Growth Area ix designated os Conservation Area. 2. G/\ Eligibility. Properties within O designated Growth Area are eligible to participate in theS<3RC Program only if they are not subject to a conservation easement, deed restriction or other enforceable agreement prohibiting development. 3. C/\Bigibi|itv.0bieotiveohtehodetenninewhetherop0peMywithiD{xdesigOotedConsemotion Area is eligible to participate in the 5GRC Pmg[ocO: o. Property must have unused development potential under current zoning and easements or deed restrictions, ifany; specifically, ot least one additional unit mf housing must be buildable under current zoning and subdivision regulations and deed restrictions (if any) on land not covered bvo conservation easement. b. Property must meet {z| least one of the following criteria: |s5O acres cxlarger iii. Contains o National Historic Register site or structure. iv. h adjacent too publicly-owned pod«desiQnuted primarily for natural habitat preservation or passive recreation, cvtouphvote|y-owned property under o permanent conservation easement; v. bina Water Supply Watershed designated Critical Area; vi. Contains land that b within l50 feet of the main body (impounded 0hree-flmwing\ or perennial stream of any of the County's river systems; vii Contains O wetland (as identified by the presence OfhYdhCsoi|s>; viii. Contains a Natural Heritage Inventory site (as identified by the state's NHI maps); ix. Contains o Prime Rated Forest Habitat area (as identified by the County's Dept. of Environmental Resource Conservation maps); x. Contains o Wildlife Corridor area (as identified bvthe County's Dept. of Environmental Resource Conservation mups); o. Owners of properties smaller than 5U acres may agree to bundle t heir acreage tomeet that criteria, provided that all properties in the bundle must have unused development potential os defined above. 4. C/\ Density Credits. Proposed conservation easements on eligible Conservation Area properties are allocated density credits as follows, for the acreage that is to be subject to a conservation oQreemont(ie.,exc|odiDgQOyhghtsOfvvoyo[u|reodydeve|opedoonaogeontheOUgib|e o. One credit per acre is awarded to all conservation easements on eligible properties; b. Plus additional credits per acre based on tax -assessed land value prior to placing of the conservation easement cxsfollows: Tax-assessed land value per acre2 Additional credits per acre 2 For properties in the use value progrom, this refers to assessed market value, not use value. O= Recommended Course ofAction 12 Orange County TDR /mplementation Planning c. Plus up to one additional credit per acre for proposed conservation easements that meet any one of the Chteho below, pro -rated boxed on the portion nfthe total easement acreage that meets the criteria, and criteria may be combined to earn more fractions of a credit per acre provided that no more than one additional credit per acre total may be awarded to the property overall: I. Participates in the state's use value tax assessment program (known as the foRn use program); ii. Contains a National Historic Register site or structure; �-.iii._ —is ino Water Supply Watershed designated Critical Area; �iv. —Contains land that is within l50 feet nf the main body (impounded orfreo' Oovvng\0rpen9nnio|streonoofonyoftheCountv'shverqmten0s; 4. V. Contains owe1|ond (as identified bythe presence ofhydh000||x); 4*i Contains o Natural Heritage Inventory site (as identified by the state's NH| nnc|pd; v4.-vii. Contains o Prime Rated Forest Habitat area (as identified bv the County's Dept. of Environmental Resource Conservation mopx\; ��iii.___Contoins o Wildlife Corridor area (as identified by the County's Dept. of Environmental Resource Conservation mups\; x-. i x._ —Contains steep slopes of25%orhigher. 5. Residential GA Density Bonuses. Proposed residential developments on eligible Growth Area properties may be granted density bonuses in exchange for purchase of a Conservation Area eligible property conservation easement as follows, subject to the density bonus limits and design requirements of the program: o. Conservation Area density credits are translated to Growth Area density bonuses at a l:l ratio. ie., for each one credit of density allocated to the proposed conservation easement, one additional housing unit may be built on the Growth Area property b. /\|temohvek/, owners of properties 25 acres o[ larger may enter into u Development Agreement with the County per G.3. l53A349.l-l3, under which the density credits allocated to the proposed conservation easement are considered by the County along With other performance conditions agreed toby the developer to determine the amount of density bonus mutually agreed toby the County and the developer. Other performance conditions may include, but are not limited to: i. Provision of affordable housing units; ii. Construction ofLEE[)-oertif)edhousingx. 3 As of date of this document no single-family detached residential subdivision design or home construction standards for LEED -certification have been officially adopted through USGBC. Multi-family, townhomeondoondoLEEO -cedificotionstondordshmvebeenednb|bhed. O= Recommended Course ofAction $30,000 and higher 1.5 c. Plus up to one additional credit per acre for proposed conservation easements that meet any one of the Chteho below, pro -rated boxed on the portion nfthe total easement acreage that meets the criteria, and criteria may be combined to earn more fractions of a credit per acre provided that no more than one additional credit per acre total may be awarded to the property overall: I. Participates in the state's use value tax assessment program (known as the foRn use program); ii. Contains a National Historic Register site or structure; �-.iii._ —is ino Water Supply Watershed designated Critical Area; �iv. —Contains land that is within l50 feet nf the main body (impounded orfreo' Oovvng\0rpen9nnio|streonoofonyoftheCountv'shverqmten0s; 4. V. Contains owe1|ond (as identified bythe presence ofhydh000||x); 4*i Contains o Natural Heritage Inventory site (as identified by the state's NH| nnc|pd; v4.-vii. Contains o Prime Rated Forest Habitat area (as identified bv the County's Dept. of Environmental Resource Conservation mopx\; ��iii.___Contoins o Wildlife Corridor area (as identified by the County's Dept. of Environmental Resource Conservation mups\; x-. i x._ —Contains steep slopes of25%orhigher. 5. Residential GA Density Bonuses. Proposed residential developments on eligible Growth Area properties may be granted density bonuses in exchange for purchase of a Conservation Area eligible property conservation easement as follows, subject to the density bonus limits and design requirements of the program: o. Conservation Area density credits are translated to Growth Area density bonuses at a l:l ratio. ie., for each one credit of density allocated to the proposed conservation easement, one additional housing unit may be built on the Growth Area property b. /\|temohvek/, owners of properties 25 acres o[ larger may enter into u Development Agreement with the County per G.3. l53A349.l-l3, under which the density credits allocated to the proposed conservation easement are considered by the County along With other performance conditions agreed toby the developer to determine the amount of density bonus mutually agreed toby the County and the developer. Other performance conditions may include, but are not limited to: i. Provision of affordable housing units; ii. Construction ofLEE[)-oertif)edhousingx. 3 As of date of this document no single-family detached residential subdivision design or home construction standards for LEED -certification have been officially adopted through USGBC. Multi-family, townhomeondoondoLEEO -cedificotionstondordshmvebeenednb|bhed. O= Recommended Course ofAction 13 Orange County TDR Implementation Planing 6. Commercial GA Density Bonuses. Proposed commercial ormixed-use developments on eligible Growth Area properties may be granted development intensity bonuses in exchange for purchase of a Conservation Area eligible property conservation easement as follows: o. Properties of 25 acres or larger may enter into a Development Agreement with the County per G.S. 153A 349.1-13, under which the density credits allocated to the proposed conservation easement are considered by the County along with other performance conditions agreed toby the developer to determine the amount of commercial or mixed- use development intensity bonus mutually agreed to by the County and the developer. b. Properties of less than 25 acres are not eligible at this time for commercial or mixed-use density bonuses through the program, but are expected to be added as the County gains o base of experience with residential and larger commercial or mixed use projects' participation. 7. Density bonus limits. The use ofGA Density Bonuses shall not elevate the total gross density ofthe property above l5dweU(ng units peracre for ��den�o|projects. ' 8. Design requirements. The County's design guidelines developed for the Efland-Mebane area will apply to all GA properties at the hnm| level of density or development intensity approved through the program, and are incorporated in this document by reference. |.e., o property zoned at two units per acre but granted a density bonus through the program that brings the total density to 8 units per acre will be required to meet the design guidelines for developments of 8 units per acre, not those for the underlying zoning of two units per acre. [I = Recommended Course of Action Orange County TDR Implementation Planning 14 The awarding of Growth Area Density Bonuses shall not elevate the. total gross density above 15 dwelling units per, 50 -acre, undeveloped parcel, R -1 zoning, no public road acreage. 50 dwelling units = permitted by right (at R -1 = 1 DU /ac.) 400 dwelling units = Developer's desired density (at 8 DU /ac.) ✓ 750 :dwelling units = Max density permitted with bonuses (15 DU /ac.) 50 ac. @ 1 dwelling unit per ac. = 50 DUs R:2 Conservation Area Credits Applied 480 CA Cs @ 1 dwelling unit per 3 CAPs = 240DUs Total density with Base plus CAPs = 290DUs To reach desired density of 400 DUs Still needed = 110 DUs Additional density bonuses can be earned if LEED standards (RAGB), and /or affordable housing (RAARC) are incorporated into the growth area's development design: R.3 LEED Standards Compliance (RAGB) Density Bonus (up to 15% of total dwelling units desired) 400 DUs x 15% = 60 DUs R.4 Affordable Housing (RAAHC) Density Bonus (1 for every 2;affordable units built) 100 DU affordable x 0.5 credits /affordable unit = 50 D Us Total possible Growth Area Density = R.1(50) + R.2 (240) + R.3 (60) + R.4 (50) = 400 DUs