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The Garden Cities movement, developed by English social reformer Ebenezer Howard, is said to have served as the ideological roots of planning and ultimately of zoning.40 Howard developed his proposals to improve the lives of London inhabitants, advocating for a resettling of some of London's inhabitants into small, new towns in the countryside where they could avoid the harsh, crowded conditions of the large city. These new cities were characterized by an effusion of single family houses, surrounded by gardens. Howard's idea had several unique aspects. First, it called for a strict segregation of uses and a permanent belt of open land which would limit the growth of the new city.41 It dispensed with private ownership and called for municipal ownership of the entire tract, which would then be distributed via leaseholds to inhabitants.42 It further called for limits on population, the development of industries able to support the population, and made provision for the founding of new communities as original garden cities became fully inhabited.43 A number affluent, influential, and socially conscious Americans helped to bring Howard's ideas to the attention of American city planners. Many of these the planners adopted some of Howard's ideas in their efforts to design the new city of the twentieth century.44 One result was the creation of the City Beautiful movement, premised on the notion that civic 40 See generally Ebenezer Howard, Garden Cities of Tomorrow (F.J. Osborn ed., MI.T. Press 1965; originally published in 1902 as Garden Cities of Tomorrow; first published in 1898 as Tomorrow: A Peaceful Path to Real Reform). 41 Lewis Mumford, Introduction: The Garden City Idea and Modern Planning, in Howard, supra note 40, at 29, 34. 4z Id at 3 5 43 Id �` Peterson, supra note 14, at 232. 14