The Howard County General Plan is under way. According to the website, the General Plan is,

[A] long-range, visionary document that guides land use, growth, and development decisions. The County’s Department of Planning and Zoning is leading a community outreach effort to create a new General Plan, called HoCo By Design. County officials want to hear from every voice as we create one vision for the County's future.

In 2022, the county began releasing draft planning theme chapters. So far five chapters are available for public scrutiny. The fifth chapter is called “Supporting Economic Prosperity”, which presents the industrial, commercial and other business considerations to be taken in shaping the county’s future land-use decisions.

Unfortunately, the chapter does anything but. After reading through this chapter, I am left with a lot of unanswered questions.

1) Looking at the proposed timeline, the county does not intend to publish any chapters on our school system. Specifically, how will the next general plan address school overcrowding, how will it ensure that communities are not segregated by income and race, leading to high concentration of low-income students in some schools?

2) The chapter recommends amending the Adequate Public Facilities Ordinance (APFO), which is a residential development impact mitigation tool to address housing need to keep up with jobs-growth. This seems like another attempt to circumvent the mitigation requirements of APFO by adding an incompatible provision. How will the county ensure that the intended requirements of APFO remain unaffected by this new proposal?

3) The chapter estimates that an average of 3,000 new jobs per year were created over the past ten years. It extrapolates based on this figure that 59,000 new jobs will be created by 2040. This 59,000 jobs figure is used as a basis to project that 30,000 new housing units will be needed by 2040. In making this claim, the chapter assumes that ALL of the 3,000 new jobs per year resulted in a demand for housing, which is NOT true. By the same token, only a fraction of the 59,000 new jobs by 2040 will lead to housing demand.

4) During the public meeting to discuss this chapter, DPZ Director Amy Gowan asserted that residential development pays for itself and pointed to the Urban Analytics study as a basis for her assertion. The Urban Analytics study is riddled with flaws. Here is an analysis of the Urban Analytics report. Specifically, the Urban Analytics model was not benchmarked to demonstrate that it can produce known results. Before predicting the future, why was it not shown to predict the present by using development data for the past 20 years?

5) Looking at this chapter on economic prosperity, it ignores/neglects to mention the trends along Route 1 over the years where previously industrial zoned properties have been rezoned to so-called Mixed-Use zoning, thereby reducing the county’s commercial tax-base.

The chapter mentions so-called Corridor Activity Center (CAC)-zoned regions in Route 1 and states that:

The purpose of the CAC District, as stated in the Zoning Regulations, is to “...provide for the development of pedestrian-oriented, urban activity centers with a mix of uses which may include retail, service, office, and residential uses.”

The chapter then says, This intended purpose has not been realized.

As noted in the 2018 Land Development Regulations Assessment, many stakeholders indicated the 50% retail requirement was difficult to meet given retail market conditions along the Corridor. While the goals of this district remain desirable, the locations of these centers and incentives to create them must be revisited.

In 2021, the County Executive introduced CB8-2021, which further eliminated the commercial component of this zone type. First the county reduced the tax dollars potential of the land by rezoning from industrial to mixed-use (CAC), second, it completely eliminated the commercial component of the zone type for a property-owner thereby creating precedent for the remaining CACs.

The report notes that:

Many parcels along the Route 1 Corridor are zoned Corridor Activity Center (CAC).

The chapter proposes new zone types for Route 1 that is substantively unchanged from the current CAC zone type.

6) The chapter says one of the key approaches to enhancing Howard County’s economy includes “ensuring a healthy jobs-housing balance.” What does “healthy” mean in this context? How is it quantified?

7) The chapter acknowledges the future of “automation.” How is the county getting ready for automation? What kind of efforts are underway to address the impact on the service industry? How many of the service jobs will be impacted? How will overall income be affected? Relatedly over 80% of jobs that will exist in the 2030s have not been invented yet. So how does the 59,000 jobs by 2040 reconcile with this level of uncertainty in types of jobs. How does this economic prosperity plan account for them? What does “enhancing” access to employment training and education entail?

8) The chapter says that some people from the public engagement and planning process have remarked that “it is difficult to grow a diverse job base without affordable housing in places served by public transit.” What does “served” mean here? Is the mere existence of a bus stop qualify the area as being “served”? There is zero evidence that suggests that people have adequate access to public transportation to how is that measured?

9) The chapter says that “commercial land uses comprise 3%, or approximately 6.9 square miles, of land in the County.” Given that residential development in Howard County has not provided the needed revenue to cover its impacts on infrastructure and other public service needs, what does this 6.9 square miles translate into tax dollars? What is the optimal amount to cover the shortfall on taxes, to improve and maintain the level-of-service?

10) the chapter says that “industrial land, including. manufacturing, warehousing, and utilities represents 3% of the County, or approximately 7.12 square miles. How has the decline in industrial zoned land especially along Route 1 affected the tax-base?

11) The chapter says “the DCP also calls for new 6,244 residential housing units.” How many of these units are “affordable”?

The challenge in predicting the next 20 years given the different sources of uncertainties and unknowns is greatly appreciated. This challenge is exacerbated when untrue assumptions about the impact on revenue of residential development or critical components of the county’s economy - the schools - are ignored.