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5 n As a statement of the purpose of the LDR-2 zoning district, the City Attorney has advised 5�ti that it represents general guidance of intent and applicability of the zoning designation, 5� and that it is not an expression of requirements. 6-' 65 6�> 6' 6� 6`� 8� $.> 43 During the April 21, 2014 City Council review of this application, the Council identified two parts of the above purpose statement which were found to be in conflict with the proposal: the proposed lots were not "small" because they exceeded the LDR-1 minimum lot area standards, and the subject property is not in an area with "concentrations of two- family and townhouse dwellings". Additional comment from Planning Division staff about the compatibility or incompatibility of the LDR-2 district for the proposal is given below. a. When the existing Zoning Code was being drafted in 2010, Planning Division staff had proposed smaller minimum lot width and area requirements (i.e., 75 feet and 9,500 square feet, respectively) for the LDR-1 district. This proposal was ultimately rejected for the time being, in no small part because of the perception by members of the City Council and members of the public that reducing the lot width to 75 feet would allow for additional development to be squeezed into existing, stable neighborhoods. Without going into the full explanation here, the prospect of squeezing new homes into existing neighborhoods is very unlikely—almost to the point of being a practical impossibiliry, and it happens that the limiting factor acting as the main obstacle to fitting additional lots into established residential areas is the lot width. Knowingly or otherwise, people who had concerns that the establishment of smaller minimum lot sizes would increase the density of their neighborhoods were actually concerned about the proposed narrower lot width. In the 2010 discussion of reduced minimum lot sizes, "smaller" was, for all practical purposes, a shorthand reference to lot width less than the traditional 85 feet. Granted, the composition of the City Council is not the same today at it was in December 2010, but the City Council's observation that the presently-proposed 70- and 80-foot-wide lots are "not small" by virtue of their large area is the opposite of the policy position taken by the City Council less than four years ago in which residential lots less than 85 feet in width were characterized as small. b. The City Council's other concern about the LDR-2 district relates to the first half of this sentence in the district's Statement of Purpose: The district is established to 8�� recognize existing areas with concentrations of two family and iownhouse dwellings, 87 and for application to areas guided for redevelopment at densities up to 8 units per s� acre or with a greater diversity of housing types. If one focuses on the portion of the $;� sentence preceding the comma and understands the word "areas" to describe a very g�� small radius, rezoning a property to LDR-2 would indeed seem to run afoul of the g�� district's intended purpose without "concentrations of two-family and townhouse g�� dwellings" on the same block In fact, the Southwind townhome community is little g� more than 900 feet to the east of the subject property; whether Southwind represents a g� "concentration" in the "area" of the subject property is a question that can be debated, g� but the existence of Southwind (and even other, high-density developments further g�e- west) should not be ignored as part of the geographic and regulatory context of the 9�� subj ect property. 9 r> �� But the sentence introduced above continues beyond the comma, indicating that the LDR-2 district is also established "...for application to areas guided for PF14-002 Prelim RCA 051514.doc Page 3 of 8