Essential 

Smart Growth 

Fixes 

for 

Urban and 

Suburban 

Zoning Codes

EPA 231-k-09-003

November 2009
ACKNOWLEDGEMENTS

Principal author:

Kevin Nelson, AICP, US EPA

Contributing authors:

Amy Doll, ICF International

Will Schroeer, ICF International

Jim Charlier, Charlier Associates

Victor Dover, Dover, Kohl & Partners

Margaret Flippen, Dover, Kohl & Partners

Chris Duerksen, Clarion Associates

Lee Einsweiler, Code Studio

Doug Farr, Farr Associates

Leslie Oberholtzer, Farr Associates

Rick Williams, Van Meter Williams Pollack

Contributors and reviewers from US EPA:

John Frece 

Abby Hall 

Lynn Richards 

Megan Susman 

Document Layout:

Colin Scarff, Code Studio

Additional Participants: January 2008 and October 2008 Workshops:

US EPA:

Geoff Anderson 

Kevin Nelson

Ilana Preuss 

Lynn Richards

Tim Torma

Center for Planning Excellence (host of January 2008 workshop)

Elizabeth “Boo” Thomas

Camille Manning-Broome

Cover Image: Van Meter Williams Pollack
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 1

Contents

0 | Introduction 2

1 | Allow or Require Mixed-Use Zones 4

2 | Use Urban Dimensions in Urban Places 7

3 | Rein In and Reform the Use of Planned Unit Developments 10

4 | Fix Parking Requirements 14

5 | Increase Density and Intensity in Centers 18

6 | Modernize Street Standards 22

7 | Enact Standards to Foster Walkable Places 27

8 | Designate and Support Preferred Growth Areas and Development Sites 31

9 | Use Green Infrastructure to Manage Stormwater 34

10 | Adopt Smart Annexation Policies 38

11 | Encourage Appropriate Development Densities on The Edge 42
2 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Introduction

Across the country, state and local governments are searching 

for ways to create vibrant communities that attract jobs, foster 

economic development, and are attractive places for people to 

live, work, and play. Increasingly, these governments are seeking more cost-effective strategies to install or maintain infrastructure, protect natural resources and the environment, and 

reduce greenhouse gas emissions. What many are discovering 

is that their own land development codes and ordinances are 

often getting in the way of achieving these goals.

Fortunately, there is interest in tackling these challenges. As 

the nation’s demographics change, markets shift, and interest 

in climate change, energy efficiency, public health, and natural 

resource protection expands, Americans have a real opportunity to create more environmentally sustainable communities.

To address these issues, many local governments want to 

modify or replace their codes and ordinances so that future development and redevelopment will focus on creating complete 

neighborhoods—places where residents can walk to jobs and 

services, where choices exist for housing and transportation, 

where open space is preserved, and where climate change 

mitigation goals can be realized. Many local governments, 

however, lack the resources or expertise to make the specific 

regulatory changes that will create more sustainable communities. And for many, model codes or ordinances can be too 

general for practical use or are often designed to be adopted 

wholesale, which many communities are unprepared to do. 

To respond to this need, the U.S. Environmental Protection 

Agency’s (EPA) Development, Community, and Environment 

Division (DCED), also known as the Smart Growth Program, 

has put together this document to help those communities 

that may not wish to revise or replace their entire system of 

codes and ordinances, but nevertheless are looking for “essential fixes” that will help them get the smarter, more environmentally responsible, and sustainable communities they want.

Smart growth creates lively 

walkable places that bring 

businesses to the street.

Introduction

Farr Associates
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 3

To find the changes that can be most helpful, DCED convened 

a panel1 of national smart growth code experts to identify 

what topics in local zoning codes are essential to creating the 

building blocks of smart growth. This document presents the 

initial work of that panel. It is an evolving document, one that 

will be regularly revised, added to, and updated. It is intended 

to spark a larger conversation about the tools and information local governments need to revise their land development 

regulations. 

The purpose of this document is to identify the most common 

code and ordinance barriers communities face and to suggest 

actions communities could take to improve their land development regulations. Given the effort and political will that is necessary to make any changes to local regulations, the suggested 

code provisions are separated into three categories: 

 Modest Adjustments: Code suggestions in this category 

assume the local government will keep the existing 

regulations and is looking for relatively modest revisions 

that will help it remove barriers to building smart growth 

developments or create a regulatory framework where all 

development types are on equal footing. Examples include 

changing code language from minimum setbacks or parking requirements to maximums. 

 Major Modifications: Code suggestions in this category 

assume the local government is looking to change the 

structure of the existing code. Suggestions include creating incentives for smart growth development or creating 

overlay zones and mixed-use districts. 

 Wholesale Changes: Code suggestions in this category assume the local government wants to create a new regulatory framework, such as creating a form-based code or 

requiring sidewalks and alleys. 

1 The panel met in January and October 2008. See the Acknowledgements for a list of participants.

Every community is distinct, with different landscapes, natural 

resources, demographics, history, and political culture. Some 

communities have found that an incremental approach to code 

changes works best, while others have found success in wholesale change. This document strives to provide a starting point 

for all communities by recognizing their wide variability. 

The document includes eleven Essential Fixes to the most 

common barriers local governments face when they want 

to implement smart growth approaches. Each Essential Fix 

describes the problem and how to respond, expected benefits, 

and implementation steps. Other resources include practice 

pointers and examples. 

This tool does not include model language, nor is it intended 

to provide model codes or ordinances. The information here, 

however, can help communities evaluate their existing codes 

and ordinances and apply the information to achieve smart 

growth objectives. This document focuses primarily on barriers in suburban and urban communities. Similar issues 

regarding rural development will be addressed in a subsequent 

document that is under development. The intent is to continually revise, update, and expand the information provided here. 

Please send comments, feedback, or suggestions to the EPA 

project manager, Kevin Nelson, AICP, at nelson.kevin@epa.

gov or 202-566-2835. 
4 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Allow or Require Mixed-Use

Zones

Introduction

A common problem with the conventional Euclidean zoning used by many communities is its focus on separating 

potentially incompatible land uses. This separation has made 

our development patterns inefficient, forcing residents to 

drive longer distances to get to their jobs, schools, shops, and 

services, which increases traffic congestion, air pollution, and 

greenhouse gas emissions. The underlying health and safety 

problems that zoning was designed to address 80 years ago—

separating homes from factories, stock yards, and other “nox1

Rockville Town Square in Maryland contains a vibrant mixture of offices, residences, retail and gathering space for people to enjoy.

ious” uses—are still important, but in our current economy, 

many commercial uses and workplaces can be integrated with 

homes without “noxious” effects. The health and safety goals 

of separating uses must now be placed in context with a range 

of other problems that are created by not allowing uses where 

they will be most efficient. Such separation can frustrate efforts to promote alternative modes of transportation and create 

lively urban places. 

Allow or Require Mixed-Use Zones

US Environmental Protection Agency 
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 5

Response to the Problem

The response to this problem is to encourage or require more 

mixed-use zones. Mixed-use zones will look different in various contexts, from downtowns to transit-oriented development 

(TOD) to commercial corridors to the neighborhood corner 

store. Communities should be mindful of these variations 

so that there is not a “one size fits all” solution for how land 

uses are mixed to accommodate market conditions and design 

expectations. Requiring vertically mixed-use buildings, such as 

a building with ground-floor retail and offices or residences in 

the upper floors, along older, pedestrian-oriented corridors can 

reinvigorate a sleepy street. Alternatively, simply permitting a 

variety of uses within one zoning district allows a horizontal 

mix of uses that can break up the monotony of single uses, 

such as strip centers or single-family housing. This horizontal mix can make a street more interesting and bring stores, 

services, and workplaces closer to residents.

Expected Benefits

 Reduction in vehicle miles traveled, resulting in lower 

greenhouse gas emissions, lower commuting costs, and 

decreased road congestion.

 More balanced transportation systems that support walking, bicycling, and public transit, as well as driving.

 Livelier urban spaces with public gathering places and a 

variety of shops, restaurants, and entertainment.

 Complete neighborhoods where residents can live, work, 

and play.

 Diversity of housing for people of all incomes and at all 

stages of life.

 More vibrant commercial areas that provide retail and 

services for patrons.

 More compact development that helps preserve open 

space in outlying areas by reducing the need and demand 

for low-density, sprawling development.

 Efficient use of services and infrastructure, resulting in 

cost savings for the public.

Mixed land use can integrate 

offices, retail and residences so that 

vehicular trips can be minimized. 

Steps to Implementation

1. Modest Adjustments

 Define mixed-use areas/activity centers in land use plans 

(on a neighborhood, community, and/or regional scale), 

and designate preferred locations for them.

 Permit residences in the upper floors of buildings in appropriate existing commercially zoned districts.

2. Major Modifications

 Remove obstacles to mixed-use development by creating 

zoning districts that allow mixed-use development by right 

(i.e., without the need for a rezoning or special discretionary approval process).

 Develop a variety of mixed-use districts, including vertical 

mixed uses and horizontal mixed uses, as needed. The 

context of uses (e.g., main street, neighborhood setting) is 

important for determining the type of mixed-use district.

 Designate mixed-use districts on the official zoning map.

3. Wholesale Changes

 Synchronize zoning codes and area plans to coordinate 

the location and development of mixed-use districts. 

Farr Associates
6 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Practice Pointers

 Consider mandatory mixed-use development in preferred 

locations (e.g., near transit stops) to ensure that these 

prime locations are not used for low-density, single-use 

development.

 Adopt compatibility standards to ensure adequate transitions to adjacent, lower-density uses. Consider architectural, design, open space, operational, and other categories 

of transitional standards.

 Tailor development standards (such as parking, open 

space, and landscaping regulations) for mixed-use developments so as not to create unintended hurdles for this 

preferred development form. For example, typical parking requirements often do not reflect the reduced need 

for parking typical of most mixed-use developments. The 

additional land that such excessive standards require for 

parking can spread out growth so that lively, compact 

developments are hard to achieve.

 Use market studies to ensure an appropriate amount of 

commercially and residentially zoned land. Avoid requiring more vertically mixed uses than the market can 

support. Horizontal mixed-use districts can allow the 

market to determine the appropriate mix of uses. Establish standards for the development of each use within the 

area to ensure contiguous retail areas. In these locations, 

establish triggers such as achieving market benchmarks 

for renewed planning efforts as the area begins to change.

 Level the playing field for mixed-use developments. For 

example, make sure that single-use commercial strip 

developments are held to the same high design and other 

standards required of mixed-use developments.

 Create incentives for mixed-use development, such as a 

wider array of permitted uses in mixed-use districts (as 

opposed to single-use districts), increased densities, and 

accelerated application processing.

Examples and References 

 International City/County Management Association and 

Smart Growth Network. Getting to Smart Growth: 100 Policies for Implementation. 2002. EPA 231-R-05-001. http://

www.epa.gov/smartgrowth/getting_to_sg2.htm. 

 Ewing, R., Bartholomew, K., Walters, J., Chen, D. Growing 

Cooler: The Evidence on Urban Development and Climate 

Change. Urban Land Institute. 2008. p. 25.

 Lewis, L. “Celebration Traffic Study Reaffirms Benefits 

of Mixed-Use Development.” Transportline. HDR. 2004. 

http://www.hdrinc.com/Assets/documents/Publications/

Transportline/September2004/CelebrationTrafficStudy.

pdf. 

 Coupland, A. Reclaiming the City: Mixed Use Development. 

Routledge. November 1996. p. 35.

 Williams, K. and Seggerman, K. Model Regulations and 

Plan Amendments For Multimodal Transportation Districts. 

Florida Department of Transportation. April 2004. pp. 

7-14. http://www.dot.state.fl.us/planning/systems/sm/los/

pdfs/MMTDregs.pdf. 

 Oregon Transportation and Growth Management Program. Commercial and Mixed-Use Development Code Handbook. October 2001. pp. 33-38. http://egov.oregon.gov/

LCD/docs/publications/commmixedusecode.pdf.

 Morris, M., ed. “Sec. 4.1: Model Mixed-Use Zoning District 

Ordinance.” Model Smart Land Development Regulations. 

Interim PAS Report. American Planning Association. 

March 2006. pp. 3-5. http://www.planning.org/research/

smartgrowth/pdf/section41.pdf.

 Duany Plater-Zyberk & Company. SmartCode, Version 9.2. 

February 2009. http://www.smartcodecentral.com/smartfilesv9_2.html.

 City of Colorado Springs, Colorado. Mixed Use Development Design Manual. March 2004. pp. 56-64. http://permits.springsgov.com/units/planning/Currentproj/CompPlan/MixedUseDev/IV-%20E.pdf.

Allow or Require Mixed-Use Zones
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 7

Use Urban Dimensions in 2 Urban Places

Introduction

Conventional zoning codes are typically replete with various 

dimensional standards that govern a range of topics, including minimum lot sizes and widths, floor area ratios, setbacks, 

and building heights. These standards are generally geared 

to produce low-intensity, low-rise residential and commercial 

development. Even codes for more mature urban areas often 

reflect this lower-density orientation. While this development 

pattern may be appropriate in some areas and under some 

circumstances (e.g., around environmentally sensitive areas), these standards often have unintentionally stifled more 

compact development in many cities and towns, preventing 

the development of attractive, lively, and cost-efficient places. 

Recalibrating dimensional standards can help accommodate 

and promote a more compact development pattern and create 

attractive urban environments. Changes in dimensional standards can also improve connectivity enhanced site planning 

and design. (See Essential Fixes Nos. 4 and 6 for street- and 

parking-related dimensional standards.)

This street in the Georgetown neighborhood of Washington, DC exhibits a mature development of a city street.

Van Meter Williams Pollack
8 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Response to the Problem

Cities across the country have been built based on the availability of land and proximity to jobs and amenities. Dimensional standards were established to accommodate these 

conditions. As communities and prosperity yielded larger lots 

and more spread-out development, communities began to 

reassess their function and design. A compact, walkable neighborhood is achieved through design and direction from codes 

and ordinances. A principal way of creating this type of place 

is through modifications to the dimensional standards—that 

is, the size of lots, setback requirements, height restrictions, 

and the like. 

Form-based codes are a typical response for communities that 

are looking to increase options for compact form and walkable neighborhoods. Components of form-based codes include 

regulating plans, building form standards (building siting 

and height), and optional architectural elements. In essence, 

the form of the building is more important than the use that 

occupies it. 

Expected Benefits

 More compact development patterns that help preserve 

open space in outlying areas.

 Higher density development that supports transit and 

mixed-use activity centers.

 A more attractive public realm that is designed to balance 

pedestrians and bicyclists with the car.

 Cost-efficient provision of infrastructure and services.

Steps to Implementation

1. Modest Adjustments

 Tailor dimensional standards in the development code to 

promote more compact development. Consider changing 

minimum standards to maximums.

– For residential development, relevant changes could 

include lot width and area changes, smaller yards, 

increased lot or building coverage for smaller lots, increased height, and increased density. 

– For commercial or mixed-use development, relevant 

changes could include increased height, smaller yards 

and open space, increased lot or building coverage, and 

increased floor area ratios (FAR). 

 Replace FAR with form standards such as height and 

maximum setbacks. Consider limiting building footprints 

in neighborhood commercial areas.

 Modify codes for commercial districts to allow residential 

development, especially over first-floor retail. 

 Eliminate landscape buffers in the commercial area; there 

is no need to buffer like uses, such as two office buildings 

or a restaurant and a store, from each other.

2. Major Modifications

 Create incentives to provide multiple housing types in 

existing districts through dimensional standards (e.g., enable small lots and limited buffer yards between homes).

 Establish or reduce block lengths or perimeters to produce 

better connections and increase walkability.

Use urban Dimensions in Urban Places

US Environmental Protection Agency 

Pedestrians traverse through a neighborhood park to reach homes and businesses that are built to the street line, creating appropriate 

dimensions for common open space amidst small lots.
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 9

 Adopt context-based or neighborhood-based dimensional 

standards that replicate existing, appealing, compact 

neighborhood patterns (e.g., narrow street width, sidewalks wide enough for safe and comfortable walking).

 Revise the codes for existing districts to encourage neighborhood redevelopment by applying new dimensional 

standards such as smaller lot requirements.

 Create districts for new compact building and development types that are not currently found in your community or neighborhood. (See the discussion of mixed use in 

Essential Fix No. 1.)

3. Wholesale Changes

 Coordinate new form-based dimensional standards, such 

as the siting of buildings, with zoning map changes to 

reflect the nature of form-based development versus usespecific zones.

 Plan a subarea of the community, then develop or calibrate and adopt a form-based code to create an option for 

additional compact, walkable neighborhoods. 

Practice Pointers

 Where significant change in dimensional standards is proposed, create a computer model, preferably in 3-D (using 

ArcGIS or a similar program), of the existing standards in 

comparison to the proposed standards.

 Consider design and operational compatibility standards 

to ensure that new compact development is compatible 

with surrounding lower-density residential neighborhoods.

 Revise subdivision specifications and standards (e.g., 

narrower streets, reduced minimum driveway width) to 

encourage denser, more compact development.

 Relate dimensional standards to the transportation system 

(e.g., modify setbacks based on right of way instead of the 

street width).

 Replace standards that allow a variety of forms, such as 

FAR, with ones that provide a consistent benchmark, such 

as height requirements.

 Include other agencies, such as the public works or fire 

departments, early in discussions regarding efforts to 

revise dimensional standards.

 Analyze stormwater management requirements of denser 

developments, and consider green infrastructure approaches. (See Essential Fix No. 9.) 

Examples and References

 Oregon Transportation and Growth Management Program. Commercial and Mixed-Use Development Code Handbook. October 2001. pp. 40-43. http://egov.oregon.gov/

LCD/docs/publications/commmixedusecode.pdf.

 Freidman, S.B. and American Planning Association. Planning and Urban Design Standards. John Wiley and Sons. 

April 2006. pp. 664-666.

 City of Franklin, Tennessee. “Chapter 5: Dimensional 

Standards.” City of Franklin Zoning Ordinance. http://

www.franklintn.gov/planning/Side-by-Side%20Comparison%20Workshops/Chapter%205/Side-by-side%20Comparision%20Ch%205-%20Part%20One.pdf. Accessed 

August 12, 2009.

 City of Durham, North Carolina. Durham City-County Unified Development Ordinance. http://www.durhamnc.gov/

udo. Accessed August 12, 2009.

 City of Colorado Springs, Colorado. Mixed Use Development Design Manual. pp. 56-64. March 2004. http://permits.springsgov.com/units/planning/Currentproj/CompPlan/MixedUseDev/IV-%20E.pdf.

 U.S. Green Building Council. LEED for Neighborhood 

Development (LEED-ND). http://www.usgbc.org/leed/nd. 

Accessed May 15, 2009.

 Parolek, D. et al. Form-Based Codes: A Guide for Planners, 

Urban Designers, Municipalities and Developers. John Wiley 

and Sons, Inc.: New Jersey. 2008. pp. 12-17.
10 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Rein In and Reform the Use of 3 Planned Unit Developments

Introduction

The inflexibility of Euclidean single-use zone districts, inappropriate development and dimensional standards, and 

Byzantine approval processes have given rise to the use of 

negotiated developments in many communities. These negotiated developments usually take the form of planned unit developments (PUDs), planned developments, or master-planned 

communities. This discussion will use PUD as the collective 

term. PUDs allowed communities to overcome some of the 

strictures of Euclidean zoning and provided a vehicle for local 

government to negotiate community benefits such as additional open space, recreational facilities, better design, and 

contributions to infrastructure. PUDs, which spread rapidly 

after the concept was introduced in the 1960s, are attractive 

because they are often simpler and quicker than seeking multiple amendments and variances to an outdated zoning code.

Originally, PUDs were conceived of and used to allow flexibility in design standards to take advantage of site characteristics 

or to address community goals (e.g., clustering development 

to provide open space or protect sensitive natural areas). PUDs 

were meant to achieve higher quality developments and meet 

community goals better than the standard subdivision and 

New Town in St. Charles, Missouri features is a planned unit development that encapsulates a variety of smart growth and new 

urbanism features including compact development, mix of land uses and design guidelines to create a distinctive place.

Rein in and Reform the use of planned unit developments

Whitaker Builders, Inc. 
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 11

zoning regulations would allow. Sea Ranch in Northern California was a model of PUD, using attractive design to better 

integrate with the natural environment. Many of the initial 

Traditional Neighborhood Developments (TNDs) were approved through a PUD process.

Today, however, relatively standard subdivisions are being 

approved using PUDs as an alternative to rewriting zoning 

and subdivision regulations for time and cost considerations. 

PUDs allow communities to impose conditions as part of the 

approval, which cities use to ensure they receive the appropriate infrastructure, off-site improvements, and fees to offset 

development impacts. The initial objective of distinctive or 

attractive design, however, often is lost as part of the PUD 

process.

The PUD approach has now proliferated to the point that 

most projects of any size or significance are approved that way. 

Some observers estimate that upwards of 40 percent2 of all 

residential units in the United States each year are approved 

through a PUD process, not conventional zoning. The result is 

that many growing cities are not the products of their land use 

plans and zoning codes, but rather the result of individually 

negotiated agreements. Indeed, in a growing number of communities, all major developments are being reviewed through 

the PUD process.3

As this trend proliferates, communities have increasingly 

recognized the downside of relying too heavily on PUDs and 

negotiated developments, including:

 There is significant uncertainty for developers, who have 

no standards to guide the development approval process, 

and for neighbors of proposed PUDs, who find that they 

cannot rely on existing zoning or land use plans and that 

the city planning staff controls much of the planning 

process. 

 Project reviews can become longer, less efficient, and 

politically charged and can drag out for years. 

2 Duerksen, C. “Rural Smart Growth Zoning Code Tools.” American 

Planning Association National Conference, April 28, 2009.

3 Ibid.

 Major planning decisions are made with less public input 

into defining the community objectives prior to a development proposal.

 Environmental and design standards are often minimized 

in the process.

 Often this process creates an administrative nightmare 

for staff that have to deal with multiple mini-zoning codes 

created for each PUD, each of which differs on development standards and other requirements. 

 The planning process becomes a project-by-project process rather than a comprehensive development review, 

and more of a political process than an evaluation of planning regulations and community goals.

Response to the Problem

To respond to these problems, communities are reducing the 

use of PUDs by updating their zoning districts and standards 

to accommodate preferred development patterns and types. 

They are also limiting the use of PUDs to larger projects that 

can provide compensating community benefits without waiving key design and environmental standards.

Communities are attempting to get out in front of PUD proposals by creating PUD zoning regulations or design guidelines. These are generally developed as part of a community 

design process so that the city can define its goals for a site or 

area prior to specific development proposals. Principles, regulations, and design guidelines are then used in conjunction 

with PUD zoning to provide clearer direction while allowing 

the desired design flexibility.
12 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Expected Benefits

 Increased certainty and predictability in the development 

review process while still allowing appropriate design flexibility.

 Setting the basic goals and fundamental standards for 

an area’s development prior to a specific development 

proposal: 

– Creates an efficient design and review process and 

requires less staff time to administer the development 

over time.

– Adheres to community growth visions and goals as established in comprehensive plans and gives the development sector clear direction on the quality, character, and 

fundamental elements the community wishes to see in 

any proposal. 

– Prevents important design and environmental standards 

from being waived or weakened in the PUD process.

Steps to Implementation

1. Modest Adjustments

 Reform the PUD process to ensure that the parcel is 

designed appropriately given topography, adjacent uses, 

and additional impacts in the PUD-designated areas, and 

reduce the use of PUDs on small sites (under 2 acres).

 Remove or substantially reduce the need to use PUDs by 

fixing dimensional standards, particularly on small parcels. (See Essential Fix No. 2.)

 Create standards for PUD (e.g., apply Traditional Neighborhood Design policies, standards, and design guidelines 

as base PUD regulations prior to receiving development 

proposals). 

 If PUDs are allowed, rein them in by establishing a minimum size for PUD projects, identifying specific allowable 

locations, and prohibiting waivers or other weakening of 

important environmental and design standards.

2. Major Modifications

 Prohibit PUDs as an alternative to following comprehensive plans and zoning codes. This may require communities to run public input processes to provide the detailed 

goals, objectives, and design elements for individual 

development proposals for larger sites. The community 

may also decide to rewrite its zoning regulations.

3. Wholesale Changes

 Create distinctive area and sector plans that give clear 

guidance to staff and the development community as to 

the vision and intended built-out of development. Complement these plans with accompanying zoning. 

This drawing of the 

Belmar neighborhood 

shows how the 

development fits 

within the context of 

neighboring uses.

Rein in and Reform the use of planned unit developments

Van Meter Williams Pollack
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 13

 Prior to accepting a development proposal for an area, 

communities should undergo a public master planning 

process to set goals and objectives; map land use and 

zoning; and set standards, regulations, and development 

quality through guidelines for the entire planning area. 

 Implement an overlay district that allows the development of a site or area if specific standards are adopted. An 

example could be an overlay of the SmartCode or another 

set of development regulations onto an area designated in 

the comprehensive plan for future development. 

Practice Pointers

 Consider establishing a list of compensating community 

benefits (such as a park, sidewalks, or trails) that the community expects in return for flexibility in uses, density, 

and other factors. This will reassure the community that 

they will get benefits from development and provide some 

certainty for developers regarding negotiated benefits.

Examples and References

 Newby, B. “Planned Unit Development: Planning Implementation Tools.” Center for Land Use Education. November 2005. ftp://ftp.wi.gov/DOA/public/comprehensiveplans/ImplementationToolkit/Documents/PUD.pdf.

 New York State Legislative Commission on Rural Resources. A Guide to Planned Unit Development. State of New 

York. Fall 2005. pp. 4-8. http://www.dos.state.ny.us/lgss/

pdfs/PUD1.pdf. 

 Benton County, Oregon. “Chapter 100: Planned Unit 

Development in Corvallis Urban Fringe.” Benton County 

Development Code. April 1999. http://www.co.benton.

or.us/cd/planning/documents/dc-ch_100.pdf. Accessed 

August 12, 2009.

 City of Westminster, Colorado. Design Guidelines for Traditional Mixed Use Neighborhood Developments. April 2006. 

pp. 12-18. http://www.ci.westminster.co.us/files/tmund.

pdf. 

 City of Mountain View, California. “Precise Plans.” http://

www.mountainview.gov/city_hall/community_development/planning/plans_regulations_and_guidelines/precise_plans.asp. Accessed August 12, 2009.

 St. Lucie County, Florida. “Chapter 7: Recreation and 

Open Space Element.” Land Development Code. May 

2009. http://www.municode.com/resources/gateway.

asp?pid=14641&sid=9. Accessed August 12, 2009.

 Larimer County, Colorado. “Proceedings of the Board of 

County Commissioners, February 8, 1999.” http://www.

co.larimer.co.us/bcc/1999/BC990208.HTM. Accessed 

July 10, 2009. 
14 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Introduction

The parking standards found in many conventional zoning codes can be a significant barrier to 

lively, mixed-use developments and activity centers, especially in existing downtowns. Parking 

standards commonly in use in the United States 

often call for too much off-street parking and 

require all or too much of it to be provided on 

the development site. Also, many zoning codes 

do not allow consideration of alternative parking 

arrangements, such as shared parking or credit 

for on-street parking that can reduce the need 

for on-site spaces and help create a more attractive streetscape. Such regulations fail to recognize the difference between parking demand in 

various contexts. 

In many communities, the effect of conventional 

parking requirements is to make redevelopment 

of smaller parcels in older, mature areas infeasible and to 

make dense, compact, mixed-use development nearly impossible because of the code requirement for large expanses of 

surface parking or expensive structured parking. Large areas 

of surface parking in commercial areas discourage walking 

and actually increase parking demand by forcing people to 

drive between destinations. Frequently, zoning codes or development regulations allow (or even require) surface parking 

to be placed between buildings and the street, and they often 

allow parking structures to be built as stand-alone uses—both 

of which are deadly to vibrant, pedestrian-oriented places.

4 Fix Parking Requirements

Response to the Problem

Municipal governments across the country have been working to create more effective parking management systems for 

at least a couple of decades. The best parking management 

systems have these characteristics in common:

 They recognize that too much parking can be a serious 

issue, but so can not enough parking. Regulating parking 

supply became common in the first place because of the 

issues caused when developers provided inadequate parking and parking spilled over into nearby neighborhoods. 

What is generally needed is “the right amount” of parking, 

which can vary widely by place and by time. Good parking 

systems are carefully balanced to be specific to their settings and are adaptable to changes over time.

Codes and regulations should enable adjacent uses to share parking as 

evidences by the demand or overlap in this chart.

FIX Parking requirements

Van Meter Williams Pollack
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 15

 They recognize that parking policy must be well integrated 

with overall transportation policy and land use policy. 

Transit services, good bicycle facilities, and a great walking 

environment can reduce parking demand significantly. 

Mixed-use development coupled with good walking 

environments can reduce parking demand even further. 

However, these transportation options must be in place 

before reducing parking requirements. For example, it 

makes little sense to reduce parking supply so that people 

will ride the bus if transit service levels are too low to attract ridership.

 They take into account that parking is inherently expensive. Surface parking consumes valuable land, removing 

it from productive use. Structured parking incurs capital 

costs that can exceed $20,000 per space,4 thereby subtracting capital funds from development. Successful parking management systems reconcile the cost of providing 

parking with local taxation and fees, with the fine schedule 

for parking violations, and with the fees charged for use of 

parking.

Successful municipal parking management systems generally 

incorporate some combination of the following strategies and 

measures: 

 Lower Parking Supply Minimums – The minimum 

parking requirements in many local codes are based on 

demand studies conducted in spread-out suburban places. 

These studies reflect parking demand in settings where 

shoppers and workers do not or cannot walk or use transit. In mixed-use settings with good pedestrian environments, such regulations overestimate parking demand 

and have a self-fulfilling effect by making mixed-use devel4 U.S. EPA. Parking Spaces / Community Places: Finding the Balance 

Through Smart Growth Solutions. February 2006. EPA 231-K-06-001. p. 9. 

opment and redevelopment physically impossible.

 Off-Site Parking – In mixed-use environments, parking 

should be treated as a utility, not an on-site private activity. 

Requiring each landowner in a downtown to provide private parking on his or her parcel is akin to requiring each 

landowner to drill his or her own water well. Modern parking ordinances allow parking minimums to be met off 

site, although they may require that the parking location 

be within a maximum 600- to 1,000-foot distance from 

the development. These could be private joint parking facilities or public facilities owned by a parking district. The 

developer is still responsible for the cost of parking, either 

directly through capital fees or indirectly through property taxes. In some settings, it is feasible to “unbundle” 

parking from residential projects, allowing parking to be 

provided on the open market.

 Fee-In-Lieu System – In places where the city is providing 

public parking facilities or where a parking district has 

been created, provisions can be written that allow a developer to pay a set fee in lieu (FIL) of providing parking supply directly. The money from FIL payments is then used to 

expand public parking supply. It is important that any FIL 

fee schedule be realistic about actual costs of parking. 

 Shared Parking Credits – Spread-out parking requirements assume that each business has its own separate 

parking supply and that it must be large enough to accommodate the peak hour of the peak day of the year. That 

assumption results in excessive parking. Different parking 

uses peak at different times of day—office parking in the 

middle of the day, retail in late afternoon and on weekParking can be 

accommodated 

through a variety of 

means including mixed 

use parking structures.

Van Meter Williams Pollack
16 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

ends, restaurants in the evening. Shared parking provisions allow developers to reduce parking supply requirements when different uses can share the same parking 

spaces.

 Parking Enforcement – A pervasive cause of perceived 

parking shortages is the misuse of premium parking by 

employees. The closest, most convenient parking spaces—storefront, on-street parking in particular—should 

be protected for use by customers. Yet in many places, 

these spaces are occupied by employees’ cars. Even where 

time restrictions have been established, they are often 

poorly enforced or the fines are too low to deter routine 

abuse. This situation can be corrected by ensuring there 

is adequate employee parking nearby and by adequately 

staffing enforcement.

 Public Transit – Many communities have reduced parking 

demand in mixed-use areas by improving transit service, 

especially for commuters. This approach is especially attractive because it reduces parking demand while improving mobility and access. Transit provides environmental 

benefits as well, including reduced air pollution and 

greenhouse gas emissions.

 On-Street Parking – The most valuable parking in most 

commercial and mixed-use places is parking on the street 

in front of businesses. Yet many cities are careless about 

keeping on-street parking or do not do enough to ensure 

the maximum number of spaces per block. Shifting from 

parallel to diagonal parking can increase parking supply 

by up to 30 percent per block face.

Expected Benefits

 Lower cost of redevelopment and infill projects, helping 

them compete with outlying projects.

 Lively, active, economically strong mixed-use districts that 

are regional destinations.

 Increased tax base and tax revenues.

 Increased transit patronage that supports increased levels 

of transit service.

 More pedestrian-friendly environments.

Steps to Implementation

(Note: some of these measures are in support of code changes, 

but are not in themselves addressed through the zoning or 

land development code.)

1. Modest Adjustments 

 Create a parking overlay district in the parking code for a 

downtown or other mixed-use area. Reduce minimum offstreet parking supply requirements in the overlay district 

based on recalculated demand resulting from alternative transportation options, the mix of land uses, and a 

“park once” strategy that encourages parking in one place 

and walking to multiple destinations. Calculate a shared 

parking allowance based on the specific land uses in the 

overlay district.

 Develop residential parking permit provisions to help 

protect neighborhoods affected by overflow parking resulting from increased parking enforcement. Design the 

system to be applied in neighborhoods (not automatically 

citywide) based on criteria, such as the actual amount of 

on-street parking demand. Carefully manage and enforce 

the residential parking permit system to avoid abuse, such 

as sale of permits. Consider returning a portion of receipts 

from parking permit fees to the neighborhood in the 

form of street repairs and improvements. Consider selling “commuter permits” for residential streets in parking 

permit districts near mixed-use centers, with all or some 

of the revenue returned to the neighborhood in the form 

of capital repairs and improvements.

 Work with the public works department to increase the 

amount of on-street parking in a downtown or other 

mixed-use center. Convert parallel to diagonal parking where feasible. Evaluate parking stall specifications 

(length and width) and reduce them if possible to increase 

parking supply.

 Establish (in the code) authorization for parking advisory 

committees for specific areas where parking issues are 

controversial. Provide for the appointment of a cross section of stakeholders, including businesses and residents. 

Charter the committee to advise on parking studies and 

on potential changes to parking ordinances.

2. Major Modifications 

 Undertake a comprehensive revision of the parking ordinance. Some specific revisions might include: 

– Revise the tables of parking supply minimums, reducing them wherever possible to reflect context, transportation options, and land use mix. 

– Develop a system of shared parking credits, either as a 

set percentage in connection with form-based codes or 

based on the land use mix in connection with zoning. 

FIX Parking requirements
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 17

– Create parking overlay districts for downtowns and 

mixed-use centers, and write provisions for future additional overlay districts. 

– Unbundle parking from residential development in 

districts with higher densities and a mix of uses. 

– Allow off-site parking in dense retail districts and set 

limits for its distance from development sites. 

– Develop provisions to govern joint parking (i.e., parking 

allowed through contracts or leases with other businesses or landowners) to ensure that parking supply 

commitments made in connection with development 

approval are honored and maintained over time. 

– Allow some credit for on-street parking supply in retail 

districts. Allow for substitution of a form-based code in 

certain zone districts to simplify and eliminate the need 

for more detailed parking regulations.

 Overhaul the parking enforcement system. Improve enforcement of parking time limits by acquiring hand-held 

computers for issuing tickets (replacing a system of chalking tires). Revise the parking overtime ordinance to provide escalating fines for scofflaws (repeat offenders) and 

set fines at levels that deter abuse. Increase enforcement 

levels so that probability of being ticketed for overtime 

parking approaches certainty. Evaluate parking supply in 

and around parking overlay districts and identify parking 

supply to be available for commuter parking use. Develop 

a Residential Parking Permit (RPP) system to help protect 

neighborhoods impacted by overflow parking resulting 

from increased parking enforcement.

3. Wholesale Changes 

 Work with the local or regional transit agency to develop 

a commuter transit pass that is bundled with a parking 

permit in parking districts and paid for with proceeds 

from the district’s revenues, including tax revenues. Use 

this “universal pass” to increase transit patronage while 

managing commuter parking demand.

 Institute paid parking for public parking supply in parking 

districts. Start with off-street, publicly owned parking. 

Pay kiosks for on-street parking can reduce streetscape 

impacts such as visual clutter from individual parking 

meters, are more efficient, and are more convenient for 

customers.

Practice Pointers

 Implement design standards for parking structures.

 Tailor parking standards for infill areas as opposed to 

greenfield sites (e.g., fewer, smaller spaces in infill).

 Provide priority parking for hybrid or alternative-fuel 

vehicles to encourage use of these vehicles.

 Consider requiring a portion of the parking lot to be constructed of pervious materials.

Examples and References

 Shoup, D. The High Cost of Free Parking. Planners Press, 

American Planning Association. 2005. Chapter 20. 

 Metropolitan Transportation Commission. Developing 

Parking Policies to Support Smart Growth in Local Jurisdictions: Best Practices. April 2007. pp. 14-18. http://www.mtc.

ca.gov/planning/smart_growth/parking_study/April07/

bestpractice_042307.pdf.

 U.S. EPA. Parking Spaces / Community Places: Finding the 

Balance Through Smart Growth Solutions. February 2006. 

EPA 231-K-06-001. http://www.epa.gov/smartgrowth/

parking.htm.

 Maryland Governor’s Office of Smart Growth. Driving 

Urban Environments: Smart Growth Parking Best Practices. 

March 2006. pp. 5-6. http://www.smartgrowth.state.

md.us/pdf/Final%20Parking%20Paper.pdf. 

 Litman, T. Parking Management: Strategies, Evaluation, and 

Planning. Victoria Transport Policy Institute. November 

2008. p. 15. http://www.vtpi.org/park_man.pdf. 

 Fitzgerald & Halliday, Inc. Northwest Connecticut Parking Study - Phase II: Model Zoning Regulations for Parking 

for Northwestern Connecticut. Northwestern Connecticut 

Council of Governments and Litchfield Hills Council of 

Elected Officials. September 2003. http://www.fhiplan.

com/PDF/NW%20Parking%20Study/NW%20Connecticut%20Parking%20Study%20Phase%202.pdf.

 Forinash, C. et al. “Smart Growth Alternatives to Minimum Parking Requirements.” Proceedings from the 2nd 

Urban Street Symposium. July 28-30, 2003. http://www.

urbanstreet.info/. 

 Victoria Transport Policy Institute. “Parking Maximums.” 

TDM Encyclopedia. http://www.vtpi.org/tdm/tdm28.

htm#_Toc128220478. Accessed April 12, 2009.
18 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

5 Increase Density and

Intensity in Centers

Introduction

Density is probably the most discussed and least understood concept in urban planning. Residents and elected officials routinely 

see the amount of development (e.g., the number of dwelling units, the square footage of commercial space) allowed on a site as 

one of the most important consideration in local planning. “Too much” density is often seen as the cause of traffic congestion, 

ugly buildings, loss of green space, crime, and many other ills. However, increasing the average density of infill, redevelopment, 

and greenfield projects is crucial to improving the quality of life in the community. Higher density is important to protecting 

open space and supporting transportation options like transit, walking, and biking. Furthermore, EPA research5 shows that 

higher densities may better protect water quality—especially at the lot and watershed levels. 

5 U.S. EPA. Protecting Water Resources Through Higher-Density Development. 2006. EPA 231-R-06-001.

As a development center, the Ballston neighborhood of Arlington, Virginia has been designated to accommodate additional growth.

Increase density and intensity in Centers 

US Environmental Protection Agency 
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 19

Much of what people dislike about density is in reality the 

result of development patterns that help to increase congestion on arterials, single-use areas that emphasize driving to 

get to destinations, and dense developments that are poorly 

designed. And, unfortunately, many people associate density 

with poorly managed rental or affordable housing developments. Fear of lower property values is often an underlying 

concern of residents when discussing higher density developments.

Density itself does not determine the quality of development. 

Many high-density areas, in fact, are the most desirable areas 

in a region, such as Dupont Circle in Washington, D.C., and 

the Chicago suburb of Oak Park, Illinois. These areas are 

attractive because the density is well designed, with appealing streetscapes, mixture of uses, site planning, and building 

design. Despite the multiple benefits that can be derived from 

projects with higher densities, gaining political approval for 

higher density projects is often difficult and controversial.

Desire for privacy, feeling crowded, fear of crime, parking, and 

compatibility with the character of the community are often 

the issues that residents cite as concerns with more dense 

developments. Identifying techniques and requirements to ensure that higher density projects are compatible with existing 

neighborhoods will help respond to these concerns. 

Response to the Problem

The concept of density requires ample discussion and education to allay misconceptions and correct misunderstandings 

about its purpose and benefits. Increased density creates 

the customer base needed for transit, retail, and amenities 

residents want. Residents of less dense communities may ask, 

“Why can’t we have the amenities that that community has?” 

Often, the answer is that the other community is denser. The 

benefits and resources discussed in this section provide the 

foundation for a complete community, one that needs increased density to thrive. 

Communities need to address density in a comprehensive 

manner rather than project by project. There are a number 

of strategies and tools that communities may use to decide 

which parts of their community should be densest. Through 

the comprehensive or general plan process, the community 

should target areas that have the character and infrastructure 

to support higher density development. Communities should 

ensure that higher density developments go into mixed-use 

areas that will allow walking and biking to shops and services, 

which reduces driving and can minimize parking requirements. Lastly, communities should focus much of their higher 

density where it can be served conveniently by bus or rail transit, which will also reduce the need to drive and provide other 

environmental benefits. 

These policies can be implemented through new mixed-use or 

transit-oriented development (TOD) districts, changes in zoning designations, or modifying zoning to allow greater density 

in existing districts. Other strategies include creating new 

compatibility standards and design guidelines to improve transitions between higher density development and low-density 

neighborhoods.

Expected Benefits

 Less pressure to expand development to outlying areas, 

thus protecting agricultural lands, natural open space, 

bodies of water, or sensitive habitat.

 Buildings and developments that use less energy, less 

land, and typically less materials. Because of the more efficient buildings and the transportation options that reduce 

the need to drive, residents generate fewer greenhouse 

gases per capita.

 More diverse communities with more opportunities for affordable housing, particularly in areas that have high land 

values and scarce development sites. 

 More effective transit service. In lower density neighborhoods, seven to eight units per acre is the minimum 

density necessary to support transit service.6 

 Support for local shops and services that rely on customers who can walk or bike from surrounding neighborhoods. 

6 Dittmar, H. and Ohland, G. The New Transit Town. 2003.
20 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Steps to Implementation

1. Modest Adjustments

 Set minimum (as opposed to maximum) densities in 

general or comprehensive plans and zoning districts. This 

tool helps creates neighborhoods that are close-knit and 

vibrant and helps achieve benchmarks for citywide housing policies and goals.

 Designate locations for higher density development centers in comprehensive plans. 

 Create activity center districts with higher densities, 

increased heights and FAR, and reduced parking requirements. This can be done by creating specific zones, modifying existing zones, or creating a new overlay district that 

allows selective modification of existing zoning regulations in an already zoned area without changing all of the 

zoning of a parcel.

2. Major Modifications

 Tailor development standards (e.g., height limits and FAR, 

parking requirements, and open space and landscaping regulations) to accommodate denser developments. 

Urban-style projects should not be evaluated based on lowdensity development standards. 

 Rezone areas designated as activity centers based on comprehensive plans to increase density, as opposed to using 

case-by-case rezoning. 

3. Wholesale Changes

 Use a redevelopment agency to purchase difficult-toobtain or critical parcels. This is particularly effective with 

areas such as corridors, which often have smaller parcels 

that require aggregation to allow higher density development.

 Establish minimum densities or intensities in community 

or regional mixed-use centers and transit-oriented developments.

 Use height, placement, coverage and perviousness requirements, rather than FAR, to regulate structured parking. For example, do not count structured parking toward 

FAR if it is screened from view with retail, residential or 

office structures, or is constructed above the ground floor 

of a structure.

 Parking can be a costly component of development. Parking may be reduced as part of a TOD or a mixed-use, highdensity district. Parking may also be “unbundled” from 

the residential units, which allows residents to choose not 

to purchase parking. (See Essential Fix No. 4.) 

The Back Bay in Boston, Massachusetts serves as a center for commerce, housing and other activities. The intensity of resources here 

minimizes pressure to develop elsewhere because of available infrastructure and services.

Increase density and intensity in Centers 

US Environmental Protection Agency 
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 21

 Set parking maximums rather than minimums to discourage too much parking supply for a development. This will 

allow higher density development, as parking often limits 

a project’s overall density.

Practice Pointers

 Density is context sensitive; different levels of density will 

be appropriate in different places.

 Adopt site and building design standards for higher density projects to ensure high-quality, attractive development.

 Consider offering density bonuses and flexible zoning 

standards to encourage construction of affordable housing. Many jurisdictions have developed density bonuses, 

as well as allowable concessions or variances for specific 

regulations, as an incentive for affordable, senior, or disabled housing. 

 Designating a buildable envelope rather than specifying 

density allows flexibility in the number of units, which 

creates greater density while controlling variables such as 

height and setbacks.

 Adopt transition/compatibility standards (e.g., building 

setbacks, open space, landscaping) to ensure that higher 

density projects in activity centers are compatible with surrounding neighborhoods. 

Examples and References

 U.S. EPA. Protecting Water Resources with Higher-Density 

Development. January 2006. EPA 231-R-06-001. pp. 44-51. 

http://www.epa.gov/smartgrowth/water_density.htm.

 State of Georgia. “Minimum Density Zoning.” Georgia 

Quality Growth Toolkit. http://www.dca.state.ga.us/intra_nonpub/Toolkit/Guides/MinDensZning.pdf. Accessed 

June 30, 2009.

 Edelman, M. “Increasing Development Density to Reduce 

Urban Sprawl.” Iowa State University Extension Service. 

1998. http://www.extension.iastate.edu/newsrel/1998/

dec98/dec9810.html.

 Coupland, A. Reclaiming the City: Mixed Use Development. 

Routledge. November 1996. p. 35.

 Williams, K. and Seggerman, K. Model Regulations and 

Plan Amendments For Multimodal Transportation Districts. 

Florida Department of Transportation. April 2004. http://

www.dot.state.fl.us/planning/systems/sm/los/pdfs/MMTDregs.pdf.

 Oregon Transportation and Growth Management Program. Commercial and Mixed-Use Development Code Handbook. October 2001. pp. 40-43. http://egov.oregon.gov/

LCD/docs/publications/commmixedusecode.pdf.

 City of Colorado Springs, Colorado. Mixed Use Development Design Manual. March 2004. pp. 56-64 http://permits.springsgov.com/units/planning/Currentproj/CompPlan/MixedUseDev/IV-%20E.pdf.

 Institute for Urban and Regional Development. “Relations 

between Affordable Housing Development and Property 

Values.” Working Paper 599. University of California, 

Berkeley. May 1993. http://www.hcd.ca.gov/hpd/prop_value.pdf. Accessed August 27, 2009.

 California Housing Law Project. “SB 1818 – Density Bonus.” Fact sheet. 2004. http://www.housingadvocates.org/

facts/1818.pdf. 

 Shoup, D. The High Cost of Free Parking. Planners Press, 

American Planning Association. 2005. Chapter 20. 
22 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Introduction

For several decades, municipal decisions about the size and 

design of streets have been based primarily on traffic capacity 

considerations. This narrow focus overlooks the fundamental 

role that streets play in shaping neighborhoods and communities. Streets are an important use of land. The design of streets 

influences the character, value, and use of abutting properties, 

as well as the health and vitality of surrounding neighborhoods. Street design also determines whether the area will 

be walkable, whether certain types of retail will be viable, and 

whether the urban landscape will be attractive and comfortable 

or stark and utilitarian. These impacts, in turn, affect land values (and associated tax receipts) and overall economic strength 

and resiliency. The character of streets can discourage or 

encourage redevelopment, hasten or reverse urban flight, and 

add or subtract value from abutting property. These are obviously important policy considerations for any municipality. 

Street design also affects environmental factors, including the 

volume of stormwater runoff, the water quality of that runoff, 

and the magnitude of the urban heat island effect. Street trees 

are particularly important: they remove carbon dioxide and 

certain pollutants from the air; they intercept and absorb rain 

before it reaches the street; they shade the landscape, reducing 

ambient air temperatures in warm months; they add aesthetic 

value to neighborhoods; and they slow traffic, improving public safety.

Cities and towns have tended to make planning and design 

decisions about streets one project at a time and based on a 

limited perspective of specific sections of specific streets. This 

narrow perspective ignores the fact that transportation systems 

6 Modernize Street Standards

are comprised of networks of facilities. The macro-scale characteristics of networks are more important than the micro-scale 

design of specific street sections in determining how well a 

local transportation system functions (including how much 

capacity the system has). 

This conventional project-by-project perspective has resulted 

in poorly connected networks of oversized streets, rather than 

well-connected networks of smaller streets. The resulting 

connectivity problems have been exacerbated by the national 

trend, beginning in the 1920s, of letting developers make 

network layout and connectivity decisions for streets built as 

part of their subdivisions and commercial sites. The inevitable 

outcomes have been poor connectivity, inconvenient circulation, and over-crowded arterials. These outcomes, in turn, have 

been detrimental to emergency service response, access to 

existing businesses, and neighborhood walkability.

The issues around street design and network connectivity have 

been further compounded by oversimplified and unsupported 

theories about traffic safety. In recent years, transportation 

engineering analysis has shown that street width; the size, 

proximity, and orientation of buildings and street trees; the 

configuration of intersections; and the presence of on-street 

parking all have significant effects on the speed and attentiveness of drivers. Designed properly, these elements can reduce 

both accident frequency and accident severity.

Clearly, there is a need for communities to update their approach to planning, designing, and building streets and street 

networks. 

Modernize street Standards
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 23

Response to the Problem

Generally, cities have addressed street design issues through 

subdivision regulations rather than zoning ordinances, although that varies depending on the local regulatory structure. 

Form-based codes can provide a foundation for street design 

and, to a lesser extent, for connectivity, but additional design 

details and procedural requirements will be needed. The 

primary techniques that cities and towns are implementing to 

improve street design include:

 Complete Streets – Streets should be designed to serve 

all modes of travel equally well—pedestrians, bicycles, personal vehicles, and transit.

 Narrow Local Streets – Local streets (streets that primarily 

provide access to abutting properties, as opposed to streets 

that primarily serve pass-through traffic) should be no 

wider than absolutely necessary.

 Context-Sensitive Thoroughfares – Arterial and collector thoroughfares should be designed to fit the character 

of abutting lands and surrounding neighborhoods and 

should not be overly wide or designed to encourage inappropriate vehicular speeds.

 Pedestrian-Oriented Environments – Streets should be 

walkable—safe, attractive, and convenient for pedestrians, 

including people walking for utilitarian purposes as well 

as people strolling and exercising.

 Universal Design – Pedestrian facilities should be designed to be convenient and safe for a wide variety of 

people, including persons with disabilities, elderly people 

and children, people pushing strollers, and strong, fit 

pedestrians walking quickly.

 Green Streets – Streets can be designed with features that 

manage stormwater and protect water quality by reducing the volume of water that flows directly to streams and 

rivers; using a street tree canopy to intercept rain, provide 

shade to help cool the street, and improve air quality; and 

serving as a visible element of a system of green infrastructure that is incorporated into the community. 

 On-Street Parking – On-street parking is not only a convenient way to add value to properties in mixed-use districts. 

It can also be a design strategy to make streets safer and 

more appealing for pedestrians.

This view of University Boulevard in Palo Alto, California includes amenities for cars and bikes.

Van Meter Williams Pollack
24 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Many communities, along with state departments of transportation, are addressing network connectivity issues by changing 

their land development codes and subdivision regulations to 

require minimum connectivity in new development and in 

redevelopment. To be effective, these standards must address 

both external connectivity (how well connected a development 

is with the larger street network) and internal connectivity 

(how well the land uses in the development are connected with 

each other). The most commonly used connectivity regulations 

establish standards for:

 Maximum block length and circumference or block area;

 Minimum intersections per linear mile of roadway or per 

square mile of area; and

 Connectivity Index (the number of street links divided by 

the number of intersections).

Expected Benefits

 Improved safety for drivers, pedestrians, and bicyclists.

 Reduced environmental footprint, including less stormwater runoff, less of a heat island effect, and less land 

consumed.

 More walking and biking with attendant health benefits.

 Value added to abutting properties and surrounding 

neighborhoods.

 Increased tax base and tax revenues.

 A more attractive city or town with more economic vitality 

and resiliency.

 A more flexible, adaptive network to help avoid congestion.

 Improved emergency response and emergency evacuation 

capability.

 Reduced street maintenance costs.

 Allowing people to drive less with no reduction in mobility.

Steps to Implementation

1. Modest Adjustments

 Revise the local street design standards to add a “road 

diet” cross section for appropriate streets that currently 

have four general purpose lanes with no on-street parking, 

no bike lanes, inadequate pedestrian space, or any combination of these deficiencies. Set criteria for conversion to 

three lanes (two general purpose lanes and a two-way left 

turn lane) with either bike lanes or on-street parking and 

improved pedestrian amenities.

 Update the local street design standards to include universal design criteria for pedestrian curb ramps, crosswalks, 

This street section show the typical array of uses for a right of way including pedestrians 

and automobiles.

Modernize street Standards

Van Meter Williams Pollack
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 25

and curb extensions. Create overlay design criteria for Safe 

Routes to School programs, transit corridors, downtowns, 

and other priority pedestrian areas.

 Update design standards governing provision of street 

trees to increase the city’s street canopy as new streets are 

built and as existing streets undergo major renovation. 

Clearly and permanently resolve issues of cost responsibility for maintenance of street trees. Ensure that standards 

are realistic for the local climate, specifying appropriate 

tree species and appropriate designs to contain tree root 

structures.

 Adopt a policy governing provision of bike lanes on arterials and collectors as streets are built and as existing streets 

undergo major renovation. Set standards for deciding 

which streets will have on-street lanes, taking into account 

spacing of facilities, speed of traffic, availability of right of 

way, and other practical matters. This policy will be most 

effective if it is based on a local bicycle system plan that 

sets system objectives, defines facility types, and sets connectivity standards.

 Begin developing and testing stormwater management 

designs such as rain gardens, bio-swales, and other techniques in preparation for development of green streets 

standards and policies.

2. Major Modifications

 Because streets are integral to community form and 

character, the best way to set the stage for improvements 

in street design and street network connectivity is to 

embed street design principles in the comprehensive plan 

or community master plan. In states and regions with 

growth management or environmental requirements 

governing preparation of local plans, this will be a necessary step prior to the measures described below. In most 

places, the planning foundation should take the form of a 

multimodal transportation master plan or a multimodal 

transportation element in the comprehensive plan.

 Revise the street classification system to create a “multimodal corridor” designation. This can also be handled 

as an overlay requirement without changing the underlying functional classification system. Use the multimodal 

corridor designation to apply complete streets principles 

(design for all modes) in specific corridors. A network of 

multimodal corridors based on local transit routes and on 

a bicycle system plan can guide both development review 

and prioritization of projects in a capital improvements 

program. This should be an interim step toward implementation of complete streets requirements communitywide.

 Revise street design standards to add “narrow local 

streets” categories. Create design templates for residential 

and commercial streets that are narrower than currently 

allowed.

 Set minimum internal connectivity standards for new 

subdivisions based on maximum block length, block size, 

intersections per square mile, or a Connectivity Index.

 Create a policy or update existing requirements to prevent 

any street abandonment or closure that would reduce the 

connectivity of the street network. 

3. Wholesale Changes

 The need for a planning foundation applies to measures 

in this section as well. All of the measures described below should be based on an adopted multimodal transportation master plan or multimodal transportation element 

in the comprehensive plan.

 Overhaul the street design standards with the objective 

of reducing the future environmental footprint of streets. 

Incorporate complete streets provisions and green streets 

principles. Adopt narrower lanes, narrower rights of way, 

and reduced-lane cross sections. 

 Reintroduce public alleys into the local transportation 

system. Create standards allowing and guiding provision 

of alleys in subdivisions and requiring them in large commercial projects. Add alley templates to the local street 

design standards.

 Set minimum internal and external connectivity standards 

to be applied to all new subdivisions and large commercial 

projects and to guide local public works decision-making 

relative to the capital improvements program.

 Update the code to significantly increase the amount of 

on-street parking in commercial and mixed-use districts 

and on residential streets.
26 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Practice Pointers

 Involve emergency service providers and the public works 

and other departments early in comprehensive planning 

and before code revisions are drafted. Narrower lanes and 

reduced-lane cross sections can be controversial, and city 

councils may be unwilling to override a fire chief’s concerns about these issues. In many cases, coordination and 

cooperation between local departments have overcome 

such obstacles.

 In many states, at least some degree of state guidance applies to local street design standards. And in virtually any 

municipality, some important streets will be under state 

jurisdiction (e.g., state routes). For these reasons, early 

and continuing coordination with the state department 

of transportation is critical to the success of most of the 

measures outlined above.

 Look for opportunities for cost savings and other benefits associated with narrower street standards, including 

reduced stormwater volume, reduced snow removal and 

other maintenance costs, and other savings.

Examples and References

 Handy, S., Paterson, R., and Butler, K. Planning for Street 

Connectivity: Getting from Here to There. Planning Advisory 

Service Report Number 515. American Planning Association. May 2003. pp. 12-15. http://www.planning.org/apastore/search/default.aspx?p=2426

 Institute of Transportation Engineers. Context Sensitive 

Solutions in Designing Major Urban Thoroughfares for Walkable Communities: An ITE Proposed Recommended Practice. 

May 2005. http://www.ite.org/emodules/scriptcontent/orders/ProductDetail.cfm?pc=RP-036. (Note: this document 

is being updated and is expected to be issued as a final 

recommended practice in late 2009.)

 Larimer County, Colorado. Larimer County Urban Area 

Street Standards. April 2007. http://www.larimer.org/engineering/gmardstds/UrbanSt.htm. Accessed June 25, 

2009.

 City of Charlotte, North Carolina. Urban Street 

Design Guidelines. October 2007. http://www.

charmeck.org/Departments/Transportation/

Urban+Street+Design+Guidelines.htm. Accessed June 25, 

2009.

 Williams, K. and Seggerman, K. Model Regulations and 

Plan Amendments For Multimodal Transportation Districts. 

Florida Department of Transportation. April 2004. http://

www.dot.state.fl.us/planning/systems/sm/los/pdfs/MMTDregs.pdf. 

 National Complete Streets Coalition. http://www.completestreets.org.

 City of Roanoke, Virginia. Street Design Guidelines. July 

2007. http://www.roanokeva.gov/85256A8D0062AF37/C

urrentBaseLink/7C223BF47CE37256852575F2006CEDF

8/$File/STREET_DESIGN_GUIDELINES.pdf. Accessed 

June 14, 2009.

 Duany Plater-Zyberk & Company. SmartCode, Version 9.2. 

February 2009. http://www.smartcodecentral.com/smartfilesv9_2.html.

 American Association of State Highway and Transportation Officials. Guidelines for Geometric Design of Very 

Low-Volume Local Roads (ADT ≤ 400). 1st Edition. June 

2001. https://bookstore.transportation.org/imageview.

aspx?id=450&DB=3. 

 Neighborhood Streets Project Stakeholders. Neighborhood 

Street Design Guidelines: An Oregon Guide for Reducing 

Street Widths. Oregon Transportation and Growth Management Program. November 2000. http://www.oregon.gov/

LCD/docs/publications/neighstreet.pdf. 

 Mozer, D. “Planning: Bicycle and Pedestrian Friendly 

Land Use Codes.” International Bicycle Fund. April 2007. 

http://www.ibike.org/engineering/landuse.htm. Accessed 

September 13, 2009.

 Metro Regional Government (Portland, Oregon). Green 

Streets: Innovative Solutions for Stormwater and Stream 

Crossings. June 2002. http://www.oregonmetro.gov/index.

cfm/go/by.web/id=26335.

 City of Boulder, Colorado. “Multimodal Corridors.” 

April 2006. http://www.bouldercolorado.gov/index.

php?option=com_content&task=view&id=355&Itemid=162

4. Accessed June 12, 2009.

Modernize street Standards
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 27

Enact Standards to Foster 7 Walkable Places

Introduction

In smart growth communities, people are able to walk comfortably and safely to work, school, parks, stores, and other 

destinations. Current codes in many communities, however, 

result in places that prevent or discourage walking by imposing low-density design (see Essential Fix No. 2), including 

overly wide streets and landscapes designed for cars instead 

of people (see Essential Fix No. 6). In such places, the pedestrian realm is treated as an afterthought—the space left over 

between the edge of the street and the buildings and parking lots. One significant challenge to developing a walkable 

community is the lack of design standards or performance 

measures for walkability, like those that guide other kinds of 

transportation planning and design. Thus many communities 

are not in a position to guide private development and public 

works investments to build good pedestrian accommodation 

into development and redevelopment, and they do not have 

programs or provisions to repair older, pedestrian-hostile 

areas. The magnitude of this need has been highlighted in 

recent years both by the number of pedestrian injuries and 

fatalities and by the health effects that less physical activity—

which is often a direct result of urban design—have had on 

the U.S. population. 

Response to the Problem

The two primary elements to be addressed through codes are 

design standards for facilities, including public works facilities built by and for the city (e.g., streets and sidewalks), and 

requirements for private development and redevelopment 

projects. Communities usually regulate facility design through 

design standards adopted as ordinances or as administrative 

rules. In addition to guiding the planning and design decisions for municipal facilities, these design requirements may 

Pearl Street in Boulder, Colorado shows the street view of how wide 

sidewalks can contribute to a pleasant walkable experience.

Van Meter Williams Pollack
28 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

be applied to private projects in 

part through the zoning approval 

process and in part through subdivision regulations. In some communities, form-based codes are 

used not only to guide the design 

of streets and sidewalks, but also 

to create a connection between all 

elements of the built environment. 

Communities may also use level 

of service7 standards to ensure that 

development and redevelopment 

projects meet minimum criteria 

for walkability. Finally, communities may adopt Safe Routes to 

School program planning and 

design criteria and may designate 

pedestrian districts or zones in 

special areas (e.g., in downtowns, 

around schools, near colleges and 

universities).

Expected Benefits

 Safer communities with fewer pedestrian injuries and 

deaths from vehicle collisions.

 Healthier people because of more opportunities to walk or 

bike.

 More economically viable places, stabilized property 

values, and reduced retail leakage (where potential patrons 

go elsewhere, perhaps due to a lack of safe walking conditions).

 Increased transit ridership because of better pedestrian 

access to transit.

 Reduced parking demand in commercial areas due to 

“park once” strategy.

 Reduced driving as short trips are made by walking rather 

than driving.

 Reduced per capita emissions of criteria air pollutants8 

and greenhouse gases resulting from reduced driving.

7 Level of service is a measure of effectiveness by which traffic engineers determine the quality of service of elements of transportation.

8 Criteria pollutants are monoxide, lead, nitrogen dioxide, ozone, particulate matter, and sulfur dioxide and are regulated by EPA under the Clean 

Air Act.

Steps to Implementation

1. Modest Adjustments

 Develop or revise street and street crossing design standards to improve pedestrian safety, convenience, and comfort, both as a part of routine public works projects and as 

a part of ongoing development and redevelopment.

 Adopt standards to incorporate trees and other shade 

structures into the pedestrian realm, especially in mixeduse districts, addressing maintenance and irrigation as 

well as landowner responsibilities.

 Prepare and implement a Safe Routes to School program, 

taking advantage of federal funding and a national database of successful examples.

2. Major Modifications

 Designate one or more pedestrian districts (keep the 

initial number small) where the community will focus its 

efforts to make walking safer and more pleasant. Develop 

The fountain and plaza located at the entrance of a bookstore act as a central gathering and 

meeting space in Bethasda Row.

Enact Standards to Foster walkable Places

Code Studio
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 29

a zoning overlay district to make targeted changes to the 

underlying zoning categories to reallocate street cross sections, regulate building setbacks, and so forth. Prioritize 

capital improvement funding to pedestrian facility needs 

in the zoning overlay district. Build upon success by designating additional pedestrian districts once the program 

has solid achievements to show in the initial district(s).

 Establish pedestrian level of service and connectivity 

requirements for all development and redevelopment 

projects of more than two acres. Include minimum pedestrian connectivity within developments and with adjacent 

developments.

 Adopt pedestrian environment standards for mixed-use 

districts to improve pedestrian safety, comfort, and convenience, including requirements for on-street parking, 

build-to lines, minimum façade transparency, building entrance spacing, canopies, and similar pedestrian-friendly 

elements.

3. Wholesale Changes

 Prepare and adopt a pedestrian circulation element in the 

comprehensive plan or in a separate transportation master 

plan. Develop a prioritized multi-year pedestrian capital 

improvements plan to implement the circulation element.

 Require major developments to include pedestrian circulation plans as part of application or site plan submittals. Set 

and apply minimum connectivity standards and level of 

service criteria.

 Revise subdivision and zoning development standards to 

require sidewalks on both sides of streets in all developments.

 Require walkways in parking lots larger than 1 acre or 200 

feet wide, linking perimeter sidewalks to primary building 

entrances.

Practice Pointers

 Communities often adopt plans calling for the entire community to be “pedestrian friendly.” This often turns out to 

be more a slogan than a policy. Virtually any community 

in the United States today has vast areas of landscape with 

poor pedestrian accommodation, and fixing these areas 

will take many years of investment and careful regulation. 

Communities should implement regulations that prevent 

new development of areas with inadequate pedestrian 

accommodation and adopt standards that prevent construction of any new streets with inadequate provisions 

for pedestrians. Public investment to retrofit and improve 

sidewalks, crosswalks, grade separations, and other facilities should go initially to school zones and routes, downtowns and other mixed-use districts, transit corridors, 

and other areas where a significant pedestrian presence is 

expected or desired.

 Involve a wide range of stakeholders and city departments 

(e.g., fire, police, public works) throughout any pedestrian 

circulation planning process. 

 One of the most important characteristics of public 

streets affecting pedestrian environments is the speed of 

vehicular traffic. Speeds above 30 mph make sidewalks 

less pleasant and street crossings more dangerous and 

difficult.

 The most critical link in any pedestrian network is the 

availability of safe, appropriately spaced street crossings, 

especially crossings of arterial streets. Communities need 

good policies for location, frequency, and design of street 

crossings, and they must invest in safe, well-designed 

crossings if they want to develop functional, active pedestrian districts.

 On-street parking is an important pedestrian feature that 

protects walkers by separating sidewalks from moving 

traffic. On-street parking also makes it easier for people to 

walk to their destinations.

 Cities must stay current with universal design requirements that ensure sidewalks, trails, crosswalks, parking 

lots, building entrances, and other features of the built 

environment are fully accessible to people with physical 

disabilities and other physical challenges. The national 

Americans with Disabilities Act outlines specific regulatory requirements, which are expanded and updated 

frequently.
30 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Examples and References

 Florida Department of Transportation. Multimodal Transportation Districts and Areawide Quality of Service Handbook. November 2003. p. 26. http://www.dot.state.fl.us/

planning/systems/sm/los/pdfs/MMTDQOS.pdf. 

 National Complete Streets Coalition. http://www.completestreets.org. 

 Dixon, L. “Bicycle and Pedestrian Level-of-Service Performance Measures and Standards for Congestion Management Systems.” Transportation Research Record 1538. 1996.

http://www.enhancements.org/download/trb/1538-001.

PDF.

 Landis, B. et al. Modeling the Roadside Walking Environment, A Pedestrian Level of Service. Transportation Research 

Board Paper No. 01-0511. 2001. http://www.dot.state.fl.us/

planning/systems/sm/los/pdfs/pedlos.pdf. 

 U.S. Green Building Council. LEED for Neighborhood Development Rating System Credit for Walkable 

Streets (Neighborhood Pattern and Design, Credit 7, 

in pilot version). http://www.usgbc.org/DisplayPage.

aspx?CMSPageID=148. Accessed June 20, 2009.

 Duany Plater-Zyberk & Company. SmartCode, Version 9.2. 

February 2009. http://www.smartcodecentral.com/smartfilesv9_2.html.

 Ewing, R. Pedestrian and Transit-Friendly Design: A Primer 

for Smart Growth. International City/County Management 

Association and Smart Growth Network. 1999. http://

www.epa.gov/smartgrowth/pdf/ptfd_primer.pdf.

 Federal Highway Administration. Designing Sidewalks and 

Trails for Access: Part I of II: Review of Existing Guidelines 

and Practices. 1999. http://www.fhwa.dot.gov/environment/sidewalks/index.htm. 

 Federal Highway Administration. Designing Sidewalks and 

Trails for Access: Part II of II: Best Practices Design Guide. 

2001. http://www.fhwa.dot.gov/environment/sidewalk2/

index.htm. 

 City of Redmond, Washington. “Pedestrian Program 

Plan.” Transportation Master Plan. November 2005. http://

www.redmond.gov/connectingredmond/policiesplans/

tmpprojectdocs.asp.

 National Center for Safe Routes to School. http://www.

saferoutesinfo.org.

 City of Seatac, Washington. Pedestrian Overlay District. 

Seatac Zoning Code. November 2002. http://mrsc.org/mc/

seatac/stac1528.html. Accessed May 5, 2009.

 Cleveland Neighborhood Development Coalition. Pedestrian Retail Overlay (PRO) District. http://www.cndc2.org/

prod.html. Accessed May 5, 2009. 

 Leaf, W.A. and Preusser, D.F. “Literature Review on Vehicle Travel Speeds and Pedestrian Injuries.” U.S. Department of Transportation. DOT HS 809 021. October 1999. 

http://www.nhtsa.dot.gov/people/injury/research/pub/

hs809012.html. 

 Federal Highway Administration “Safe Routes to School: 

Program Legislation – SAFETEA-LU, Sec. 1404.” http://

safety.fhwa.dot.gov/saferoutes/overview/legislation.

cfm#sec1404. Accessed May 5, 2009.

Enact Standards to Foster walkable Places
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 31

8

Introduction

For many decades, most municipalities have handled land 

development and growth reactively. Zoning changes have been 

initiated primarily by landowners and developers. Developers 

have often selected development locations that did not follow 

city comprehensive plans. Subdivision and property assembly 

have been undertaken by landowners and developers with specific development projects in mind. There is often a financial 

incentive for developers to develop peripheral sites rather than 

redeveloping infill sites. However, communities can better 

control the development they get by focusing their resources 

to catalyze redevelopment in desired areas. 

Planning land uses and development intensities in preferred 

growth areas and development sites generates several benefits. It encourages and facilitates redevelopment and infill, 

supports transit, and guides new development to appropriate 

areas with ready access to existing infrastructure. Local governments need to play a more active role in selecting areas where 

new growth makes the most sense. They need to reinforce 

those choices by revising their development codes and capital 

improvement plans to make these areas more attractive to the 

development community than other, less appropriate areas. 

This more focused approach to development can benefit both 

individual landowners and the entire community. 

A palm tree-lined pedestrian plaza leads to the entrance of 

the largest apartment buildings at the center of Mizner Park 

in Florida. Higher densities in this existing development 

enable greenfields to be preserved.

Designate and Support

Preferred Growth Areas

and Development Sites Code Studio
32 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Response to the Problem

Municipalities need to be proactive 

about determining where and to what 

extent they will grow. This planning 

can provide government officials 

with the justification to say “no” to 

development proposals that are not 

in the community’s best interests and 

are inconsistent with the community 

plan. Even in communities that cannot 

keep up with infrastructure needs, many 

local governments believe there is benefit in 

encouraging more development. But to be effective on behalf of current residents and thoughtful about the needs of future residents, cities 

need to designate where growth will occur, then rezone, 

change codes, and alter utility and infrastructure provisions to 

accommodate that growth.

To focus development where it makes the most sense, a 

community needs a detailed plan. This plan should include 

comprehensive subdivision regulations and street mapping, 

zoning, and design guidelines, as well as an infrastructure 

plan and a financing or implementation plan. Developing the 

plan should include a comprehensive stakeholder and public 

engagement process. The designation of growth areas should 

be supported by studies and data, such as a fiscal impact analysis or a cost of infrastructure study. 

Expected Benefits

 Greater predictability for infill proposals that meet the 

new development standards, and certainty of location and 

development potential for landowners, developers, and 

citizens.

 More efficient development review processes. Complete 

policies on land use and development regulations will 

help streamline the review process and garner stronger 

support from the planning commission and/or city council.

 Cost-effective provision of infrastructure. Focusing on and 

prioritizing infill development will use existing infrastructure efficiently. 

 Preservation of open space and natural resources. Focusing on infill development reduces pressure to expand on a 

community’s periphery or to develop in areas with sensitive habitat or open space.

Steps to Implementation

(Note: Steps may be applied differently in infill versus greenfield locations.)

1. Modest Adjustments

 Identify and map preferred growth areas in a comprehensive plan. The plan should include goals and objectives for 

the various areas. 

 Establish utility and transportation capacity plans.

 Change the minimum lot size, requiring smaller parcels 

to be aggregated or developed in conjunction with larger 

parcels in a coordinated manner. 

 Designate agriculture interim/holding zones in lieu of 

low-density zoning in areas where the local government 

would rather not see imminent development.

This rendering of Santa Clara, California illustrates how 

the city has designated preferred growth areas to keep 

distinctive places intact.

Designate and Support Preferred Growth Areas and Development Sites

Van Meter Williams Pollack
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 33

 Create district or area plans to guide development.

 Vary fees for development based on location, as infill sites 

usually have lower infrastructure costs than peripheral or 

greenfield development. 

2. Major Modifications

 Enact an adequate public facility ordinance (APFO). An 

APFO helps ensure that infrastructure for schools, road, 

sewers, and fire protection exists to accommodate new 

development.

 Establish a policy that sets criteria for annexation, including the provision of utilities, infrastructure financing, and 

minimum development thresholds. The policy should also 

include requirements for developing an annexation plan 

for the area. (See Essential Fix No. 10 for more on annexation issues.)

 Establish urban service areas or boundaries as part of the 

overall master facilities plan to help phase development in 

coordination with infrastructure.

3. Wholesale Changes

 Establish urban service areas or growth boundaries, and 

support them by zoning areas outside the boundaries for 

agriculture and other very low-density uses.

 As part of detailed area plans, rezone designated growth 

areas (e.g., around transit stops or regional activity centers) to allow denser development.

Practice Pointers

 Coordinate local government capital investment plans to 

support development in designated growth areas and to 

discourage it in other areas.

 Adopt a comprehensive plan land use map that depicts 

preferred development areas and clearly describes the mix 

of uses, community design principles, and key features 

desired for each area.

 Coordinate with other local governments in the region to 

adopt supportive plans and designated growth areas. It is 

extremely important to coordinate what will happen in the 

areas between cities so that these community separators 

can be maintained over time.

 It is also critical to strategically manage the phasing of 

growth areas. Each town or city needs to find the appropriate strategy for holding growth areas in check until they 

are prepared for the types of development that the community envisions. 

 Communities need to find ways to prioritize development 

so that key projects can be implemented earlier as catalysts. Often, lower intensity or less complex developments 

will be attempted first, which sometimes robs critical or 

desired projects of their market opportunity and thus 

pushes them off for many years. This is particularly true 

of retail, which requires residential support and typically 

will be drawn to automobile-oriented sites before the infill 

sites the community may desire.

Examples and References

 Porter, D. “Chapter 3: Managing Community Expansion: 

Where to Grow.” Managing Growth in America’s Communities. Island Press. November 2007. 

 Nolon, J.R. “Chapter 2: Local Land Use Controls That 

Achieve Smart Growth.” Well Grounded: Using Local Land 

Use Authority to Achieve Smart Growth. Environmental Law 

Institute. July 2001. 

 Lancaster County, Pennsylvania. “Designated Rural Area 

Concept.” Lancaster County Comprehensive Plan. June 

2005. http://www.co.lancaster.pa.us/planning/lib/planning/long_range/growth_management/rural_area_concept_summary.pdf. 

 City of Austin, Texas. Smart Growth Initiative. http://

www.ci.austin.tx.us/smartgrowth. Accessed June 10, 2009.

 City of Austin, Texas. Smart Growth Criteria Matrix. February 2001. http://www.epa.gov/smartgrowth/scorecards/

austin_matrix.pdf. 

 State of Maryland. Smart Growth Priority Funding Areas 

Act of 1997. http://www.mdp.state.md.us/fundingact.htm. 

Accessed April 22, 2009.

 City of Boulder, Colorado. Boulder’s Open Space & Mountain Parks: A History. http://www.bouldercolorado.gov/

index.php?option=com_content&task=view&id=1167&Item

id=71. Accessed May 12, 2009.
34 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Introduction

Many communities across the United States face the challenge 

of balancing water quality protection with accommodating new 

growth and development. Conventional development practices 

cover large areas with impervious surfaces such as roads, 

driveways, and buildings. Once such development occurs, 

rainwater cannot infiltrate into the ground. Instead, it runs off 

9 Use Green Infrastructure to

Manage Stormwater

the land at much higher levels than would naturally occur. The 

collective force of this runoff scours streams, erodes stream 

banks, and carries large quantities of sediment and other pollutants into waterbodies each time it rains. Most municipal 

stormwater regulations require stormwater management only 

at the site scale, using pipes, curbs, gutters, and basins. This 

approach has functioned well to mitigate local flooding but 

has resulted in degraded waterways and poor water quality at 

the watershed scale. A conventional approach to managing 

stormwater at the site scale fails to address the impacts of land 

use on water quality, particularly: 

 Loss of natural land and disruption of water systems;

 Increased impervious surface area; and

 Increased stormwater runoff volumes.

Many local ordinances besides stormwater regulations pose 

barriers to better stormwater management and watershed protection. Communities must also look beyond the site scale and 

consider the impacts of where and how development occurs 

across neighborhoods and watersheds. 

This picture illustrates site level green infrastructure practices 

such as landscaped swales to capture runoff.

Use Green Infrastructure to Manage Stormwater

US Environmental Protection Agency 
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 35

Response to the Problem

Communities are recognizing that the water quality impacts 

of development need to be managed at a variety of scales, 

including the municipal, neighborhood, and site levels. Green 

infrastructure uses natural and built systems at all three scales 

to protect water quality. 

At the regional or watershed scale, green infrastructure is the 

interconnected network of preserved or restored natural lands 

and waters that provide essential environmental functions. At 

the community or neighborhood scale, green infrastructure 

incorporates planning and design approaches such as compact, mixed-use development; parking reductions; and street 

trees and other vegetation that reduce impervious surfaces and 

make communities more attractive. At the site scale, green 

infrastructure mimics natural systems by holding stormwater 

in rain gardens or swales to allow it to absorb into the ground 

(infiltration), using trees and other vegetation to convert it to 

water vapor (evapotranspiration), and using rain barrels or 

cisterns to capture stormwater for reuse. 

Changing codes to support green infrastructure at all three 

scales protects water quality while creating many other environmental, community, and economic benefits. Local governments can incorporate green infrastructure by adopting plans, 

removing barriers, enacting regulations, and creating incentives for green infrastructure on both public lands and private 

property. Certain local policies, such as landscaping and parking requirements or street design criteria, can complement 

strong stormwater standards and make it easier for developers 

to simultaneously meet multiple requirements. 

Communities can incorporate green infrastructure provisions 

into codes, policies, and standard practices through a few essential steps. First, the stormwater management plan review 

would take place early in the development review process to 

ensure that green infrastructure practices are thoughtfully 

incorporated into plans. Next, zoning codes and building 

codes need to result in the same goals and objectives for green 

infrastructure implementation. For instance, policies such as 

harvesting rainwater for irrigation can be an effective green infrastructure strategy when permissible with building codes. To 

make sure that green infrastructure policies are meeting water 

quality and other goals, communities will need to monitor and 

track implementation and maintenance. 

Expected Benefits

 Reduced stormwater volume and velocity and fewer 

stormwater overflow events.

 Less polluted stormwater runoff.

 Lower cost for stormwater management facilities.

 Urban heat island mitigation and reduced energy demand.

 Potential recreational and aesthetic amenities.

 Traffic calming.

 More distinctive communities.

 Increased land values. 

Steps to Implementation

1. Modest Adjustments

 Add stormwater management requirements and water 

quality elements to comprehensive plans to recognize and 

allow green infrastructure stormwater management alternatives in zoning and subdivision regulations.

 Complete the EPA Water Quality Scorecard. The tool gives 

local governments an idea of the range of green infrastructure policies and which might be right for a specific 

community. 

 Offer zoning upgrades, expedited permitting, reduced 

stormwater requirements, and other incentives for 

development proposals that include green infrastructure 

practices. 
36 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

 Encourage site-planning meetings early in the approval 

process to review the green infrastructure components 

of development proposals along with other site planning 

topics.

 Develop incentives for homeowners to install rain barrels, 

rain gardens, green roofs, and other green infrastructure.

2. Major Modifications

 Develop a performance standard that requires a system of 

stormwater management where stormwater infiltrates in 

ground, is either reused on site and/or evapotranspires, 

and avoids single-use facilities. Require developers to 

meet stormwater requirements using green infrastructure 

practices where appropriate.

 Update the community’s stormwater design manual with 

locally appropriate examples and guidelines for designing, 

installing, and maintaining green infrastructure.

 Review and change, where necessary, building and zoning 

codes or other local regulations to ensure that green infrastructure is legal (e.g., remove restrictions on downspout 

disconnection and stormwater reuse). 

 Take into account rainwater harvesting and reuse when 

setting the stormwater management requirements for a 

development.

 Develop or revise stormwater utility bills to include a fee 

based on impervious services to address combined sewer 

overflows and offer a fee discount based on the use of 

green infrastructure techniques. 

 Conduct inspections of sites and develop mechanisms to 

enforce stormwater management plans and maintenance 

agreements. 

3. Wholesale Changes

 Give fiscal credit to developers toward stormwater management requirements for preservation of trees and open 

space, which help to decrease impervious surfaces and 

allow for stormwater infiltration.

This mall, Pompano Fashion Square in Pompano Beach, Florida, is a good example of a parking lot that could be repurposed for green 

infrastructure.

Use Green Infrastructure to Manage Stormwater

US Environmental Protection Agency 
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 37

 Amend stormwater management regulations and development codes to allow off-site stormwater management, 

especially for infill and redevelopment areas.

 Require green infrastructure bonds or other revenue 

generation in zoning or subdivision ordinances to ensure 

proper operation and maintenance of green infrastructure 

stormwater management facilities.

Practice Pointers

 Engage local governments in regional stormwater management strategies and coordinate future land use and development decisions for large-scale water quality benefits.

 Ensure that all local government departments/agencies 

coordinate with one another so that green infrastructure 

meets multiple community objectives (e.g., allow rain 

gardens to meet landscaping requirements).

 Enact riparian buffer regulations to protect water resources from nonpoint source pollution, stabilize banks, and 

provide aquatic and wildlife habitat.

 Consider separate stormwater management requirements 

for densely developed activity centers and infill sites as opposed to greenfield development. Recognize that impervious cover limits, open space requirements, and on-site 

detention requirements may be appropriate for large 

greenfield developments but not for more urban sites. 

Provide flexibility to allow off-site and regional stormwater 

management facilities, and give credit for alternative approaches like pervious pavement and green roofs.

 Work with key staff from local agencies such as transportation, planning, and public works to integrate green 

infrastructure into all codes and ordinances.

Examples and References

 U.S. EPA. Water Quality Scorecard. August 2009. http://

www.epa.gov/npdes/pubs/gi_municipal_scorecard.pdf.

 U.S. EPA. Green Infrastructure Municipal Handbook. (series 

of publications) http://cfpub.epa.gov/npdes/greeninfrastructure/munichandbook.cfm. 

 U.S. EPA. Stormwater Management Handbook: Implementing Green Infrastructure in Northern Kentucky Communities. 

May 2009. http://www.epa.gov/smartgrowth/sgia_communities.htm#ky. 

 U.S. EPA. Protecting Water Quality with Smart Growth 

Strategies and Natural Stormwater Management in Sussex 

County, Delaware. January 2009. http://www.epa.gov/

smartgrowth/noaa_epa_techasst.htm#6. 

 U.S. EPA. “Source Water Protection.” http://www.epa.gov/

nps/ordinance/sourcewater.htm. Accessed July 22, 2009.

 U.S. EPA. “Stormwater Pollution Prevention Plans for 

Construction Activities.” http://cfpub.epa.gov/npdes/

stormwater/swppp.cfm. Accessed July 22, 2009.

 U.S. EPA. Protecting Water Resources with Higher-Density 

Development. January 2006. EPA 231-R-06-001. pp. 23-29. 

http://www.epa.gov/smartgrowth/water_density.htm.

 Center for Neighborhood Technology. “Green Values 

Stormwater Toolbox.” http://greenvalues.cnt.org. Accessed 

June 20, 2009.

 City of Portland, Oregon. “General Requirements and 

Policies.” Stormwater Management Manual. http://www.

portlandonline.com/bes/index.cfm?c=35122&a=55769. Accessed June 22, 2009.

 Santa Clara Valley (California) Urban Runoff Pollution 

Prevention Program. Operations and Maintenance of Treatment BMPs. http://www.scvurppp-w2k.com/om_workproduct_links.htm. Accessed June 20, 2009.

 U.S. EPA. “Environmental Management Systems.” http://

www.epa.gov/ems. Accessed June 22, 2009.

 U.S. EPA. Reducing Stormwater Costs through Low Impact 

Development (LID) Strategies and Practices. December 

2007. EPA 841-F-07-006. http://www.epa.gov/owow/nps/

lid/costs07.

 City of New York. “Water.” PlaNYC. http://www.nyc.gov/

html/planyc2030/html/plan/water.shtml. Accessed May 

19, 2009.
38 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Introduction

Communities often have the most influence over development 

on their edges when land is annexed into a municipality. It 

is then that the greatest opportunity exists to determine how 

this land will help the community advance its overall planning goals and to ensure that the public costs of providing 

infrastructure and services for the annexed area are balanced 

with potential tax and other revenues from the annexed lands 

(including any exactions or other requirements). 

In most states, municipalities face enormous pressure to annex lands. One of the most important forces driving annexation is communities’ desire to increase their tax base, thereby 

increasing revenues into municipal coffers. Further, in growth 

areas in many states, municipalities fear that if they do not annex aggressively, their neighbors may, hemming them in and 

limiting their ability to grow. Finally, in many growth areas, 

municipalities may believe the only way to ensure that growth 

in the surrounding region occurs responsibly and according to 

a plan is to annex areas to gain control over planning, development, and design decision-making before development occurs.

Ad hoc annexation is a major cause and enabler of exurban 

development and sprawl. Ironically, in many cases, the tax 

burden from annexed areas may exceed the increase in tax 

revenues, especially over the long term.

Response to the Problem

The principal policies that successful communities use to 

handle annexations include:

 Revising local codes to anticipate annexations in the comprehensive planning process and to ensure that annexations are consistent with adopted comprehensive plans;

10 Adopt Smart

Annexation Policies

 Developing intergovernmental processes and agreements—between counties and municipalities, and 

between neighboring municipalities—to guide and govern 

planning for physical expansion and annexation; and

 Establishing criteria for the review process leading up to 

potential annexations, including criteria for fiscal impact 

analyses.

Because many of the forces driving ad hoc annexation stem 

from local competition for tax base, communities and regions may also need to work together to rationalize their local 

taxation systems, including consideration of revenue sharing 

among jurisdictions.

Expected Benefits

 Well-planned, contiguous municipal expansion that benefits the community, supports community character and 

quality of life, and promotes compact development.

 Creation of communities that are “tax positive”—places 

that have a logical and fiscally sound annexation of land 

where services and infrastructure are adequate. 

 Focus on intergovernmental collaboration instead of competition for territorial expansion leading to over-extension 

of municipal boundaries and the resulting scattered, 

leapfrog development.

 Creation of logical, well-planned communities, instead 

of ad hoc formation of small incorporated municipalities 

intended primarily to prevent tax increases associated with 

annexation.

 Orderly, planned community expansion that accommodates population growth and provides the tax base required to meet the community’s objectives. 

Adopt Smart Annexation Policies
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 39

This urban growth boundary shows a stark contrast between the developed and undeveloped areas of this community.

Steps to Implementation

1. Modest Adjustments 

 Establish a code requirement that future annexations be 

consistent with the community comprehensive plan (or 

local equivalent), along with a requirement that the comprehensive plan map and describe future potential areas 

of annexation. These could be developed using a sphere of 

influence/urban transition area approach, like that used 

in California’s Local Agency Formation Commission, or 

tiered planning areas like those used by the city of Boulder 

and Boulder County, Colorado.

 Require future potential annexation areas mapped in 

the comprehensive plan to include a preliminary identification of anticipated zoning, as well as a preliminary 

description of how municipal services and infrastructure 

(e.g., water, sanitary sewer, stormwater, transportation, 

police, and fire) would be funded in annexed areas. This 

should be based on community service standards and an 

assessment of existing conditions and capacities in the 

mapped areas.

 Require the mapping of potential future annexation 

areas in the comprehensive plan to identify and evaluate 

any prime agricultural lands, important wildlife habitat, 

areas of special ecological value or concern, and any lands 

contaminated by past industrial or agricultural activities or 

hazardous materials spills.

 Establish a code requirement that the transportation 

element of the community comprehensive plan (or local 

equivalent) identify a future collector and arterial street 

network for any potential annexation areas mapped in the 

plan. Require extensions of the existing municipal street 

network to be mapped to meet minimum internal connectivity standards in any annexed areas, as well as minimum 

external connectivity with existing and future neighborhoods.

2. Major Modifications

 Adopt fiscal impact analysis requirements for proposed 

annexations, including criteria for the forecast ratio of 

revenues to costs. Include provisions for additional fees to 

rectify imbalances. 

Van Meter Williams Pollack
40 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

 Establish a minimum contiguity requirement for any 

proposed annexation area. For example, at least 25 percent 

of the circumference of any proposed annexation must be 

coterminous with the existing incorporated area, subject 

to exceptions for bodies of water. An adjunct provision or 

variation would be to specifically prohibit “flagpole” annexations.9

 Develop and adopt joint infrastructure standards (e.g., water, sanitary sewer, stormwater, streets) for a municipality 

and its surrounding county, or by multiple municipalities 

and/or counties, to be applied to proposed development in 

areas that may eventually be annexed into a municipality. 

This ensures that any development in future annexation 

areas that occurs prior to annexation is compatible with 

the annexing community. It also ensures that facilities are 

designed consistently with standards of the municipalities. This coordination discourages landowners or developers from “shopping” one government against another to 

obtain the combination of services and fees—which could 

turn out to be a bad deal for the municipality. 

3. Wholesale Changes 

(Note: some measures below are in support of code changes, 

but are not in themselves addressed through the zoning or 

land development code.)

 Develop an intergovernmental agreement between one or 

more municipalities and one or more counties providing 

for development and adoption of a multi-jurisdiction comprehensive plan. Include provisions for identifying areas 

of potential annexation and provisions for zoning, infrastructure, lands of special concern, and street extensions, 

similar to the four measures described under Modest 

Adjustments.

 Develop an intergovernmental agreement between one or 

more municipalities and one or more counties to guide 

the annexation process in specific areas, which would be 

mapped in the agreement. Include provisions addressing 

infrastructure standards, funding for extension of infrastructure and services, and the approval processes of the 

affected jurisdictions.

 Develop a regional compact or intergovernmental agreement for revenue sharing to reduce or eliminate the pressure to annex land for municipal budget growth.

9 Flagpole annexations are connected to a municipality through a 

narrow strip of land.

The Urban Development Boundary in Miami-Dade County, 

Florida, illustrates the division between land intended for 

development and area meant to be preserved. 

Practice Pointers

 Annexation law and policy are among the most controversial aspects of growth management. Many states are 

changing the laws governing the authority of municipalities to annex land, establishing or revising criteria for 

annexations, requiring additional review and approval by 

adjacent counties and municipalities, and providing for 

oversight by third parties or agencies. The first step for 

any municipality is to make sure that its ordinances are 

consistent with state law.

 Issues related to estimating costs of extending infrastructure and municipal services into potential annexation 

areas are difficult to resolve if there are no agreed-upon 

standards for the timing, placement, and design of faciliAdopt Smart Annexation Policies

US Environmental Protection Agency 
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 41

ties and services. An important step in addressing annexation policy issues is to work—ideally in cooperation with 

other area governments—on design and service standards 

to estimate the cost of providing facilities and services.

 One of the potential benefits of good annexation policy, 

especially with multiple jurisdictions involved, is avoiding 

the leapfrogging of suburban subdivisions and commercial projects outside municipal areas. 

Examples and References

 California Association of Local Agency Formation Commission. http://www.calafco.org.

 Local Agency Formation Commission of Monterey County, California. “Sphere of Influence Policies and Criteria.” 

October 2006. http://000sweb.co.monterey.ca.us/lafco/

policy.htm. 

 Denver Regional Council of Governments. “Mile High 

Compact.” August 2000. http://www.drcog.org/index.

cfm?page=MileHighCompact. Accessed May 13, 2009.

 City of Austin, Texas. Smart Growth Initiative. http://

www.ci.austin.tx.us/smartgrowth. Accessed May 31, 2009.

 City of Austin, Texas. Smart Growth Criteria Matrix. February 2001. http://www.epa.gov/smartgrowth/scorecards/

austin_matrix.pdf.

 Boulder County, Colorado. “Intergovernmental Agreements.” http://www.bouldercounty.org/lu/igas/index.htm. 

Accessed June 12, 2009. 

 Larimer County, Colorado. Rural Land Use Center. http://

www.co.larimer.co.us/rluc. Accessed June 20, 2009.

 Larimer County, Colorado. Larimer County Urban Area 

Street Standards. April 2007. http://www.co.larimer.co.us/

engineering/GMARdStds/GMARdStds.htm.

 Hinze, S. and Baker, K. Minnesota’s Fiscal Disparities 

Programs. Minnesota House of Representatives Research 

Department. January 2005. http://www.house.leg.state.

mn.us/hrd/pubs/fiscaldis.pdf.
42 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

Introduction

On the periphery of urban areas, suburbs, and small towns, 

communities’ development patterns are often not dense 

enough to support mixed land uses or transit or to create other 

efficiencies associated with denser development patterns, such 

as cost-efficient infrastructure. At the same time, these areas 

are often too dense for rural areas to maintain a truly rural 

character. Rural development patterns typically:

 Are supported by limited infrastructure (relying, for instance, on gravel roads and septic systems);

 Cost less to support because they use fewer government 

services; and 

 Preserve large tracts of open space and agricultural lands. 

This issue is most relevant to exurban development—areas 

outside the jurisdictional boundaries of cities and towns. The 

density is approximately 2 to 4 housing units per gross acre at 

the more suburban end of the spectrum, and one unit per 20 

to 40 acres at the rural end. Many suburban, small town, and 

county zoning codes and subdivision ordinances allow only 

these densities. Densities can vary based on regional differences. For instance, Western states will have a different threshold 

than those in the Southeast. 

This low-density development pattern has been one of the fastest growing sectors of the housing market, fueled by a variety 

of factors, including people moving to rural communities for 

the quality of life, an expanding second-home market for less 

expensive vacation homes in small towns, and rural communities’ desire to grow. Developers have also found such rural areas to be the “path of least resistance.” They are generally able 

to quickly obtain approvals through a county or rural town’s 

less complicated entitlement procedure. 

11

Encourage Appropriate

Development Densities on

The Edge

Land use laws, particularly in the Western states, give extensive rights to large landowners, ranchers, and farmers to develop their properties in the future, typically at lower densities. 

In these places, low-density residential zoning is the de facto 

zoning that has been overlaid onto many large tracts of land. 

This means that many areas that are perceived to be rural are, 

in fact, zoned for residential development that does not fit a 

rural context. 

The desire to remain rural or maintain a small-town character 

is a common theme in these communities. Lower densities are 

often encouraged in the belief that they will help preserve an 

area’s rural character. These densities, however, most frequently translate into low-density, cookie-cutter subdivisions, with 

streets and homes that are more typical of suburban, rather 

than rural, communities. The most difficult densities are those 

in the 1⁄2-acre to 5-acre range. The difficulties with these densities include:

 Expensive infrastructure to both provide and maintain to 

serve a minimal number of units;

 Reliance on septic systems, which have a limited capacity 

over time;

 A land use pattern that is difficult or impossible to intensify later, as it typically includes individual property owners, 

making land hard to assemble; and 

 Farmland that becomes fragmented by these large-lot 

homes, which means little possibility of carrying on true 

agriculture or maintaining farm animals in these areas.

These densities are neither rural nor town-like in their character. Once developed, they are difficult to change and become 

more difficult to maintain over time.

ENCOURAGE APPROPRIATE DEVELOPMENT DENSITIES ON THE EDGE
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 43

This type of growth also becomes a jurisdictional, city-versuscounty issue. Much of this development pattern is occurring 

within county jurisdictions at or near city limits because large 

agricultural properties are being developed under county 

development procedures. The counties often have minimal 

regulations and limited resources to plan for, review, or process these types of developments. This has made it difficult 

to control the implementation of policies and restrictions as 

well as standards for these developments. Developers often are 

better equipped than county planning and engineering staff 

to deal with the various complex issues that arise from these 

developments.

Response to the Problem

Density that cannot support necessary services is not sustainable on any level—fiscally, environmentally, socially, and for 

public health. In most places, zoning at one unit per 2 gross 

acres typically cannot support necessary services. When zoning at this density, communities usually are focused more on 

the perceived market demand and/or potential tax revenue 

than on what it will take in infrastructure and other resources 

to support such a pattern. When communities look at the 

potential impacts and decipher where they can make improvements through increased densities as well as other zoning 

changes, they can make their neighborhoods fiscally sound 

and environmentally sustainable.

Finding a solution takes a balance of strategies, combining 

those that eliminate the types of densities so persistent where 

urban and rural communities meet with those that direct unsustainable development patterns away from these areas. 

When communities grow, their comprehensive plans should 

cover only areas that form a natural edge to the community 

and that will not be expanded beyond or leapfrogged in the 

future. An example may be an area bordering a creek or other 

natural open space, which provides a natural barrier to expansion and clearly defines an edge to the community. Another 

strategy is to continue the town’s street pattern to use the 

infrastructure to its fullest capacity and then end in an agricultural zone at the community’s edge. This will better integrate 

large lots into the community by using them to transition to 

agricultural uses at the town’s periphery. 

These remedies only address the properties at a community’s 

edge. The most problematic developments are those that 

employ unsustainable densities outside these areas as ranches, 

orchards, and farms are developed. These sites are typically in 

counties’ jurisdictions. Counties and towns, therefore, need 

to coordinate their planning efforts to minimize the ad hoc 

development of rural areas and integrate their comprehensive 

plans to include expansion areas and areas that will be maintained for agriculture or open space. Towns and counties will 

This aerial from suburban Dallas shows how the “Devil’s Density” is built out on the edge of the town at residential density that is not 

efficient with more compact development patterns.

US Environmental Protection Agency 
44 | Essential Smart Growth Fixes for Urban and Suburban Zoning Codes - November 2009

need to tackle this issue together in a comprehensive manner 

to address planning, engineering, property ownership, and 

development issues. 

Expected Benefits

 Lower infrastructure costs for local and state governments 

and service providers. 

 Preservation of large, contiguous blocks of open space and 

agricultural lands. This is most critical for protecting habitat corridors and maintaining viable agricultural activities 

and related businesses. 

 Support for downtowns and traditional neighborhood 

developments, with greater connectivity with the immediate town or city.

 Consistent and connected patterns of development instead 

of leapfrog growth, which disregards planned boundaries.

 Minimizing the areas that are hamstrung by limited redevelopment potential due to ownership patterns and the 

lack of opportunities for land assembly.

Steps to Implementation

(Note: Several implementation steps from Essential Fix No. 

8 that support preferred growth areas also apply to this fix, 

including agricultural interim holding zones, area-specific 

impact fees, adequate public facilities ordinances, annexation 

policies, and urban services areas and boundaries.) 

1. Modest Adjustments

 Adopt comprehensive plans that encourage sustainable 

development patterns in peripheral and exurban areas by 

redesignating density allocations. 

 Amend zoning ordinances to repeal zone districts that allow unsustainable densities at the community’s edge. 

 Develop design regulations that require connectivity and 

integration with adjacent neighborhoods and create transitions to adjacent agricultural or undeveloped areas.

2. Major Modifications

 Establish benchmarks for intended densities in comprehensive plans in rural areas (e.g., one unit per 80 acres in 

some Western states).

 Require minimum densities in areas targeted for growth.

 Require cluster/conservation subdivisions at the community’s edge to transition to rural areas. These subdivisions 

are for edge conditions only, with denser zoning on one 

side and rural areas on the other. 

 Require comprehensive fiscal impact and mitigation analysis for proposed rural developments. Require mitigation 

measures so that rural developments pay their own way.

 Use the SmartCode to categorize and implement the zoning regulations by classifying an appropriate transect for 

these urban-rural interface areas and adapting the regulations for the community.

This New Jersey farmland is 

punctuated by a low density 

residential development 

creating a conflict between 

providing services to these 

homes and preserving 

agricultural uses.

US Environmental Protection Agency 

ENCOURAGE APPROPRIATE DEVELOPMENT DENSITIES ON THE EDGE
November 2009 - Essential Smart Growth Fixes for Urban and Suburban Zoning Codes | 45

3. Wholesale Changes

 Preserve agricultural viability by zoning for large agriculture-only districts.

 Require mandatory annexation as a condition of development approvals in town impact areas (consider a “no 

objection” clause that is approved by the property owner 

when annexation is feasible and desired by the town. This 

clause will make the annexation process predictable and 

fair). 

 Encourage joint town and county policies that set criteria 

such as location or size controls to coordinate the development of land instead of insular land use resulting from 

PUDs. (See Essential Fix No. 3.) 

Practice Pointers

 Depending on the state, land patterns, and types of agriculture, the appropriate acreage for agriculturally zoned 

parcels will vary.

 Consider how rules related to lot splits or family subdivision rights chart the course for inappropriate densities. 

Family subdivisions are often used to get around minimum lot size regulations.

 In the past, communities have zoned for economic 

development and property ownership interests, relying 

on unsustainable development patterns. Often, smaller 

towns see fees associated with low-density development, 

along with construction jobs and retail sales, as economic 

development. Unfortunately, the cost of maintaining the 

public infrastructure frequently exceeds the value brought 

with the short-term economic development.

 Do not allow cluster/conservation subdivisions in areas 

where true rural development patterns are preferred. Clustered subdivisions disrupt agricultural operations.

 In certain circumstances, land trusts have purchased 

conservation easements from farmers and ranchers that 

prohibit development. Selling the easement gives landowners some financial benefit without having to develop 

their land. This strategy allows landowners to maintain 

their farms. 

 Transfer of Development Rights (TDR) programs may be 

considered; however, these programs are complex and will 

be feasible only in specific situations.

Examples and References

 Duerksen, C. and Snyder, C. Nature-Friendly Communities. 

Island Press. May 2005. pp. 40-50.

 Burchell, R. et al. Costs of Sprawl—2000. Transit Cooperative Research Program Report 74. Transportation Research 

Board. June 2002. pp. 26-31.

 Freedgood, J. et al. Cost of Community Services Studies: 

Making the Case for Conservation. American Farmland 

Trust. August 2002. pp. 55-60. http://www.farmlandinfo.

org/farmland_search/index.cfm?articleID=28415&functio

n=article_view. 

 Livingston, A. et al. The Costs of Sprawl: Fiscal, Environmental, and Quality of Life Impacts of Low-Density Development 

in the Denver Region. Environment Colorado. March 2003. 

pp. 24-29. http://www.environmentcolorado.org/envcogrowth.asp?id2=9356. 

 Tischler, P. Analyzing the Fiscal Impacts of Development. 

Management Information Service Report No. 20. March 

1988. pp. 54-56.

 American Farmland Trust. Saving American Farmland: 

What Works. May 1997. pp. 43-47. http://www.farmlandinfo.org/farmland_preservation_literature/index.

cfm?function=article_view&articleID=29384. 

 Bowers, D. “Achieving Sensible Agricultural Zoning 

to Protect PDR Investment.” Presented at “Protecting 

Farmland at the Fringe.” September 2001. http://www.

farmlandinfo.org/documents/29520/Achieving_Sensible_

Agricultural_Zoning_full_presentation.pdf. 

 County of Marin, California. “Agricultural Element – Executive Summary.” Marin Countywide Plan. http://www.

co.marin.ca.us/depts/cd/main/comdev/advance/cwp/

ag.cfm. Accessed August 11, 2009.

 County of Marin, California. 2007 Marin Countywide Plan. 

2007. http://www.co.marin.ca.us/depts/CD/main/fm/

TOC.cfm. Accessed August 11, 2009.