Letter Of Review From Benzonia Township Regarding Joyfield Township Master Plan

STAFF REPORT

LAKES TO LAND (BLAINE, CRYSTAL LAKE, GILMORE, AND JOYFIELD TOWNSHIPS) MASTER PLAN.

Date:​​February 10, 2014

To:​​Benzie County Planning Commission

​​L2L Planning Commission

From:​​Jason Barnard, Acting Chair, West Benzie Joint Planning Commission (WBJPC)

RE: ​Review by the West Benzie Joint Planning Commission (WBJPC) of the Lakes to Land Master Plan covering the adjacent communities of Blaine, Crystal Lake, Gilmore, and Joyfield Townships

On February 10, 2014, at a Special Meeting, the WBJPC voted unanimously to forward the following analysis of the L2L Plans for Blaine, Gilmore, Joyfield, and Crystal Lake Townships to the County Planning Commission and L2L Planning Commission(s).

Determining whether a Proposed Plan Is ‘Inconsistent’”4 reads:

“The following standard ... would have required ‘consistency’ ... with adopted plans...:

‘(d) The proposed plan shall be consistent. A proposed plan is consistent if both of the following apply:

(i) The goals, policies, and program of implementation for each element of the plan would further, or at least not interfere with, the goals, policy, and program of implementation of other elements of the same plan.  

There appears to be little conflict with the goals, policies, and implementation for the most part with the overall Lakes to Land Master Plan and the County Master Plan, also adopted by reference by the WBJPC.  However,the Plan for the adjacent townships relies heavily on no new growth of commercial or industrial uses or areas or in land/natural resource based development within their Plan Area and that surrounding areas will absorb that development.  Benzonia Township has a developing urban services district but the size is limited by inadequate soils for on-site sewage and septage treatment as are futures sites for municipal large scale public treatment facilities.  Both theVillages of Benzonia and Beulah have public water and only Beulah having public sewage treatment, which is limited to serving existing areas within the Villages.  Both Villages are providing and maintaining these systems to smallcommunities and have limited ability to finance expansion. A no growth policy in surrounding townships will impactBenzonia Township and these Villages which may not be able to provide adequate areas for such new developmentand new job growth.

(ii) The goals, policy, and program of implementation of the plan and each element thereof would further, or at least not interfere with, the goals, policy, and program of implementation of a plan of the reviewing entity adopted under this act or under an enabling act in effect at the time of adoption of the reviewing entity's plan. Circumstances that violate the requirements of this subparagraph include, but are not limited to, all of the following:

(A) If the jurisdictional area of the reviewing planning commission and the jurisdictional area of the proposing planning commission are contiguous, land use intensity, land use density, or capital facilities in the jurisdictional area of the proposing planning commission and near the common border are incompatible with or would conflict with land use intensity, land use density, or capital facilities in the jurisdictional area of the reviewing planning commission and near the common border.

Comments in this regard are similar in that land uses densities and  intensity remain similar today, however future development may be directed to Benzonia Township prematurely and negatively impacting public infrastructure.  The assumption that other communities out of L2L Planning Jurisdiction will be able to absorb addition growthmeant for these communities yet redirected elsewhere into Benzonia Township will negatively impact the WBJPC planning area.  In addition, the reliance on agriculture to provide living wage jobs will not be feasible over the long-term unless some local manufacturing is allowed.  This may be an “inconsistency” that will negatively impact Benzonia Township.

(B) If the reviewing entity is the planning commission of a local unit or a regional planning commission, the proposed plan would create 1 or more specific, verifiable threats to the health or safety of individuals within the local unit or region.

Though there may be no direct effect on health or safety of individuals within Benzonia Township, there would be a long-term impact to public infrastructure requiring additional investment above current rates to meet the higher rate of growth. Such an impact would cause premature increases in tax rates to maintain and build new public infrastructures such as roads, publice water and sewer systems, etc.

(C) If the reviewing entity is the planning commission of a local unit or a regional planning commission, cumulative effects of the proposed plan or element are likely to reduce the existing or planned quality of life in the proposed local unit or region in reasonably identifiable and verifiable ways.’

Same as previously stated.

If one provides too little area for commercial development, the impacts to adjacent communities are:

1. Not enough opportunity for small business

2.  Higher rents

3.  Unmet market demand

4.  Market leakage

5.  Fewer jobs paying living wages

Consequently, if planning and zoning is forced to prematurely provide or absorb commercial development, the consequences are:

1.  increased development regulations or Leap froggedStrip,

2.  Overvalued commercial properties,

3.  Less attractive commercial development, and

4.  Unprofitable businesses

If the L2L Master Plan does not provide enough nonresidential land uses or a place for them, then that could be perceived as an inconsistency with the existing Benzonia Township Master Plan.