04 Brodie Oaks Redevelopment Site Specific SOS Amendment; District 5.pdf — original pdf

Backup

ITEM FOR ENVIRONMENTAL COMMISSION AGENDA November 2, 2022 Brodie Oaks Redevelopment PUD C814-2021-0099 Armbrust & Brown (David Armbrust) 4107 S Capital of Texas Highway COMMITTEE MEETING DATE: NAME & NUMBER OF PROJECT: NAME OF APPLICANT OR ORGANIZATION: LOCATION: COUNCIL DISTRICT: 5 ENVIRONMENTAL REVIEW STAFF: Leslie Lilly, Environmental Program Coordinator, (512)535- 8914, Leslie.lilly@austintexas.gov WATERSHED: Barton Creek Watershed/Barton Springs Zone REQUEST: PUD zoning for the property STAFF RECOMMENDATION: STAFF CONDITION: Staff recommended with conditions A. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8, Subchapter A, Article 13 (Save Our Springs Initiative) at the time of permit application except as modified below. a. Section A of 25-8-514 (Pollution Prevention Required) shall be modified to allow a maximum impervious cover for the site of 56% net site area. B. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8 Section A (Water Quality) at the time of permit application except as modified by the PUD ordinance. a. ECM 1.6.7.5 (D) shall be modified to allow captured runoff for beneficial reuse b. 25-8-341 shall be modified to allow cut not to exceed a maximum of fourteen (14) feet. c. 25-8-342 shall be modified to allow fill not to exceed a maximum of fourteen (14) feet. d. 25-8-281 shall be modified to allow encroachment into CEFs as indicated on Exhibit F. C. Additionally, development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with the following requirements a. Reduction in impervious cover from 84% NSA to 56% NSA b. Bring the site into compliance with SOS water quality treatment requirements c. Clustering impervious cover and disturbance 75’-250’ away from Barton Creek Greenbelt d. Restoring 2 acres of the tract to native vegetation e. Provide 100% GSI for water quality controls. f. Provide rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area. g. Provide superior tree protections. h. Comply with Austin Green Building 3-star rating i. Exceed landscaping requirements. j. Provide superior open space and parkland dedication.  COMMITTEE MEETING DATE: NAME & NUMBER OF PROJECT: NAME OF APPLICANT OR ORGANIZATION: LOCATION: ENVIRONMENTAL REVIEW STAFF: WATERSHED: REQUEST: COUNCIL DISTRICT: 5 STAFF RECOMMENDATION: STAFF CONDITION: ITEM FOR ENVIRONMENTAL COMMISSION AGENDA November 2, 2022 Brodie Oaks Redevelopment Site Specific SOS Amendment C814-2021-0099 Armbrust & Brown (David Armbrust) 4107 S Capital of Texas Highway Leslie Lilly, Environmental Program Coordinator, (512)535- 8914, Leslie.lilly@austintexas.gov Barton Creek Watershed/Barton Springs Zone In response to Council Resolution 20221011-076, consider a site- specific amendment to City Code Chapter 25-8, Subchapter A, Article 13 (Save Our Springs Initiative), as minimally required to allow for limits to impervious cover as proposed in application C814-2021-0099 for the Brodie Oaks PUD development. The proposed site-specific amendment should be included as part of the discussion and consideration of the Brodie Oaks PUD development. Staff recommended with conditions A. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8, Subchapter A, Article 13 (Save Our Springs Initiative) at the time of permit application except as modified below. a. Section A of 25-8-514 (Pollution Prevention Required) shall be modified to allow a maximum impervious cover for the site of 56% net site area.  B. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8 Section A (Water Quality) at the time of permit application except as modified by the PUD ordinance. a. ECM 1.6.7.5 (D) shall be modified to allow captured runoff for beneficial reuse b. 25-8-341 shall be modified to allow cut not to exceed a maximum of fourteen (14) feet. c. 25-8-342 shall be modified to allow fill not to exceed a maximum of fourteen (14) feet. d. 25-8-281 shall be modified to allow encroachment into CEFs as indicated on Exhibit F. C. Additionally, development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with the following requirements a. Reduction in impervious cover from 84% NSA to 56% NSA b. Bring the site into compliance with SOS water quality treatment requirements c. Clustering impervious cover and disturbance 75’-250’ away from Barton Creek Greenbelt d. Restoring 2 acres of the tract to native vegetation e. Provide 100% GSI for water quality controls. f. Provide rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area. g. Provide superior tree protections. h. Comply with Austin Green Building 3-star rating i. Exceed landscaping requirements. j. Provide superior open space and parkland dedication. Brodie Oaks Redevelopment PUD 4107 S Capital of Texas Highway C814- 2021- 0099 Leslie Lilly Environmental Program Coordinator Watershed Protection C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T Site Background • Proposed new PUD • Part of original 128-acre Barton Creek Plaza Development • Current site - 37.6 acres • Full Purpose Jurisdiction • Activity Center for Redevelopment in Sensitive Environmental Areas in Imagine Austin Vision Plan • Council District 5 C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 3 C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 5 Environmental Features • Barton Springs Watershed • Barton Springs Zone • Edward Aquifer Recharge and Contributing Zone • 84% Impervious Cover • Brodie Oaks Seep/Spring CEFs • Airman’s Cave • Non-compliant with SOS water quality requirements C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T Land Use Plan C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 8 Proposed Environmental Code Modifications • • • • 25-8-341 (Cut Requirements) shall be modified to allow cut not to exceed a maximum of fourteen (14) feet as indicated on Exhibit G. 25-8-342 (Fill Requirements) shall be modified to allow fill not to exceed a maximum of fourteen (14) feet as indicated on Exhibit G. 25-8-281 (Critical Environmental Features) shall be modified to allow encroachment into CEFs as indicated on Exhibit F. SOS Ordinance Section A of 25-8-514 (Pollution Prevention Required) shall be modified to allow a maximum impervious cover for the site of 56% net site area. C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 10 E x h i b it G : G r a d i ng P l a n C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 11 Exhibit F: Environment 1. Modify CEF setback for S-1/S-2 Impact to Airman’s Cave CEF 2. setback is limited of up to 80’ with conditions 3. Protective fencing for CEFs C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 12 C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 13 E x h i b it F : Wa t e r Q u a l i t y 1. Brodie PUD with comply with SOS with subgrade ponds for retention/reirrigation system and rainwater harvesting with beneficial reuse Infiltration testing 2. 3. Trenching > 5’ will be inspected by geologist C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 14 Proposed Environmental Superiority • Clustering impervious cover 75-250’ away from Barton Creek Greenbelt • Restoring 2 acres of the tract to native vegetation • Provide 100% Green Stormwater Infrastructure for water quality controls that meet SOS non- degradation pollutant removal. • Provides rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area. • Provides superior tree protections. • Exceed landscaping requirements. • Provide superior open space and parkland dedication • Complies with Austin Green Building 3-star rating C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T Additional Environmental Elements • Reducing impervious cover from 84% NAS to 56% NSA (36% decrease) • Rainwater will be used to offset potable water demands for irrigation and cooling tower makeup water (in accordance with 25-8-151 (Innovative Management Practices) • Remove retaining walls from greenbelt edge and restore more natural grade • LEED Neighborhood Development certification • U.S. Green Building Council SITES certification C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T Exhibit F: Open Space C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 17 AEGB 3 Star R ating 2022 Requirements • Bicycle parking and supporting facilities • Electric vehicle charging • Energy performance • Dual plumbing to reduce potable demand C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 18 Recommendation S t a f f r e c o m m e n d s a p p r o v a l o f t h e P U D w i t h t h e f o l l o w i n g c o n d i t i o n s • Reduce impervious cover from 84% NSA to 56% NSA • Cluster impervious cover 75-250’ away from Barton Creek • Restore 2 acres of the tract to native vegetation • Provide 100% Green Stormwater Infrastructure for water quality controls that meet SOS non-degradation pollutant removal. • Provide rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area. • Provide superior tree protections. • Exceed landscaping requirements. • Complies with Austin Green Building 3-star rating • Provide superior open space and parkland dedication • LEED Neighborhood Development certification • U.S. Green Building Council SITES certification C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T Brodie Oaks Redevelopment SOS Site-Specific Amendment 4107 S Capital of Texas Highway C814- 2021- 0099 Leslie Lilly Environmental Program Coordinator Watershed Protection C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T What is an SOS Site-Specific Amendment • • • • • • • 1 9 9 2 S a v e O u r S p r i n g s o r d i n a n c e a d o p t e d b y c i t i z e n i n i t i a t i v e P e r 2 5 - 8 - 5 1 5 , v a r i a n c e s t o S O S a r e n o t a l l o w e d , p r o h i b i t i n g m o d i f i c a t i o n b y P U D o r d i n a n c e 2 5- 8 - 2 6 R e d e v e l o p m e n t E x c e p t i o n i n t h e B S Z d e e m e d n o t a p p r o p r i a t e O n l y a p p l i e s t o t h e B r o d i e O a k s R e d e v e l o p m e n t P U D p r o j e c t S u p e r m a j o r i t y o f C o u n c i l m u s t a p p r o v e a m e n d m e n t s t o S O S C o u n c i l R e s o l u t i o n 2 0 2 2 1 0 1 1- 0 7 6 o n O c t o b e r 1 3 , 2 0 2 2 : “ T h e C i t y M a n a g e r i s d i r e c t e d t o i n i t i a t e s i t e s p e c i f i c v a r i a n c e s … . . C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T Other SOS Site-Specific Amendments 10111 Dobbin Drive Garza Ranch Ordinance No. 20130926-051 C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T SOS Requirements 2 5- 8 - 5 1 4 P o l l u t i o n P r e v e n t i o n R e q u i r e d • I m p e r v i o u s c o v e r i n t h e E d w a r d s A q u i f e r R e c h a r g e Z o n e i s 1 5 % N S A , 2 0 % N S A i n t h e C o n t r i b u t i n g Z o n e • W a t e r Q u a l i t y C o n t r o l s r e q u i r e d f o r r u n o f f f r o m a l l i m p e r v i o u s c o v e r t o m e e t u n d e v e l o p e d c o n d i t i o n s . C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T Brodie Oaks SOS Site-Specific Amendment S e c t i o n A o f 2 5 - 8 - 5 1 4 ( P o l l u t i o n P r e v e n t i o n R e q u i r e d ) s h a l l b e m o d i f i e d t o a l l o w a m a x i m u m i m p e r v i o u s c o v e r f o r t h e s i t e o f 5 6 % n e t s i t e a r e a . B r o d i e P U D O r d i n a n c e 2 5- 8 - 3 4 1 s h a l l b e m o d i f i e d t o a l l o w c u t n o t t o e x c e e d a m a x i m u m o f f o u r t e e n ( 1 4 ) f e e t a s i n d i c a t e d o n E x h i b i t G . 2 5- 8 - 3 4 2 s h a l l b e m o d i f i e d t o a l l o w f i l l n o t t o e x c e e d a m a x i m u m o f f o u r t e e n ( 1 4 ) f e e t a s i n d i c a t e d o n E x h i b i t G . 2 5- 8 - 2 8 1 s h a l l b e m o d i f i e d t o a l l o w e n c r o a c h m e n t i n t o C E F s a s i n d i c a t e d o n E x h i b i t F. • • • • C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T Land Use Plan C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 26 E x h i b it F : Wa t e r Q u a l i t y 1. Brodie PUD with comply with SOS with subgrade ponds for retention/reirrigation system and rainwater harvesting with beneficial reuse Infiltration testing 2. 3. Trenching > 5’ will be inspected by geologist C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 27 Recommendation S t a f f r e c o m m e n d s a p p r o v a l o f t h e S O S a m e n d m e n t w i t h t h e f o l l o w i n g c o n d i t i o n s • Reduce impervious cover from 84% NSA to 56% NSA • Cluster impervious cover 75-250’ away from Barton Creek • Restore 2 acres of the tract to native vegetation • Provide 100% Green Stormwater Infrastructure for water quality controls that meet SOS non-degradation pollutant removal. • Provide rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area. • Provide superior tree protections. • Exceed landscaping requirements. • Complies with Austin Green Building 3-star rating • Provide superior open space and parkland dedication • LEED Neighborhood Development certification • U.S. Green Building Council SITES certification C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T Questions? C o n t a c t I n f o r m a t i o n : L e s l i e L i l l y l e s l i e. l i l l y @ a u s t i n t e x a s . g o v C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 30  November 2, 2022 TO: Austin Environmental Commission Via Hand-delivery and email FROM: Bill Bunch, Executive Director, SOS Alliance RE: Brodie Oaks PUD needs changes to meet required “superior” standards, to comply with Austin’s Imagine Austin Comprehensive Plan, and to meet Water Forward and Climate Equity Plan goals Dear Chair Ramberg and Commissioners: Save Our Springs Alliance representatives have actively engaged with Applicant representatives off and on for over a year on this project. The goal has always been to reach agreement on all issues so that Brodie Oaks would be a model project that would set a very high standard for redevelopment in the Barton Springs watershed and for the larger Austin community. While we can agree on some key elements, and very much appreciate the Applicant’s efforts to engage with neighborhood and environmental representatives and provide answers to our questions, the project as currently proposed does not meet required “superior” standards on environmental issues and does not fully meet Imagine Austin, Austin Climate Equity, and Austin Water Forward environmental and planning standards. For context, the current development holds approximately 360,000 square feet. The proposed development would, according to the Applicant, total about 3.2 million square feet. Thus the proposal is not simply a significant increase in overall density but would rather be roughly a 900 percent increase in density. While some substantial density increase is readily supported, the scale and type of development proposed both push the project into “inferior” status and in direct conflict with multiple environmental standards and planning goals. SOS does support a narrowly tailored SOS ordinance site specific amendment for the Brodie Oaks PUD. This amendment would accept the Applicant’s proposed reduction in impervious cover from 84% gross site area to approximately 56% net site area and the Applicants commitment that SOS “pollution prevention” requirements would be met with SOS level water quality controls. 1 Our consulting expert, Dr. Lauren Ross, Ph.D., P.E., has reviewed the details of the Applicant’s water quality controls. Dr. Ross generally agrees with the Staff that if implemented as described the water quality controls would provide the necessary treatment and capture volumes to meet the “pollution prevention” standards. In doing so, pollutant loading from the site would be greatly reduced, along with the impervious cover, as compared to the current development. The environmental shortfalls to “superiority” are, however, significant. We ask that the Environmental Commission vote to find that the proposed PUD is not environmentally superior and should be denied unless the following changes shortfalls are corrected: 1. Need for offsite mitigation land to reduce overall impervious cover to below 15% net site area and to mitigate for offsite pollution and environmental impacts. The Brodie Oaks tract rests within the Barton Springs recharge zone and thus is otherwise subject to a 15% net site area limit. We recognize that under the SOS redevelopment exception ordinance, the council has discretion to approve a much higher level of onsite impervious cover when considering the specific circumstances of a project. That SOS exception ordinance contemplates and in some cases requires the acquisition of land or conservation easements offsite so that the overall impervious cover (taking the two tracts together) meets SOS impervious cover standards. Absent this offsite mitigation requirement, the proposed PUD cannot be viewed as “superior” to either the SOS ordinance or the SOS redevelopment exception ordinance requirements. The SOS redevelopment ordinance provides in relevant part at Section 25-8-26: “(G) City Council shall consider the following factors in determining whether to approve a proposed redevelopment: (1) benefits of the redevelopment to the community; (2) whether the proposed mitigation or manner of development offsets the potential environmental impact of the redevelopment; (3) the effects of offsite infrastructure requirements of the redevelopment; and (4) compatibility with the City's comprehensive plan. (H) Redevelopment of property under this section requires the purchase or restriction of mitigation land if the site has a sedimentation/filtration pond. . . . (1) The combined gross site area impervious cover of the mitigation land and the portion of the redevelopment site treated by sedimentation/filtration ponds may not exceed 20 percent.” As noted below, several of these factors are implicated by the proposed redevelopment project. Offsite impacts will be substantial given that the project is heavy on office, retail, and hotel that will drive secondary development further out into the Barton Springs watershed, in direct conflict with Imagine Austin goals. As proposed there would be developed 1.2 million sq. feet of office, 140,000 sq. ft. of retail, and a 200 room hotel – all of which will create a demand for yet more housing over the Barton Springs Edwards Aquifer watershed. 2. Need to reduce height to meet Climate Equity Plan and “carbon neutral” goals Skyscrapers are not climate-friendly, primarily because of the “embodied” energy required to manufacture the concrete and steel required to support very tall buildings. There is now solid research showing that cities that develop with mid-rise and low-rise projects that are dense enough to support public transit and walkability and limit land consumption have greatly reduced greenhouse gas emissions when compared to skyscraper development. This short piece from October 2021 in Resilience provides an excellent summary on the issue. We do not have an exact height limit to recommend at this time but keeping the height low enough, in the 5 to 10 story range, that use of energy intensive steel and concrete construction can be minimized or avoided altogether, while being consistent with Imagine the Imagine Austin Comprehensive plan should be recommended. This would allow substantial increase in density and likely could accommodate all of the proposed residential development if the 1.2 million square feet of office and hotel were scaled back. Converting the internal streets from auto traffic to pedestrian malls would also allow more of the onsite impervious cover to be dedicated to buildings rather than car habitat. 3. Need to remove skyscrapers or other otherwise reduce density to meet Austin Water Forward “net zero water” goals. The skyscrapers in the plan not only push the site away from being “carbon neutral” but also result in the project failing to meet “net zero water” goals. These buildings and the extra density they accommodate translate into having too little available onsite water to meet summer cooling tower, landscaping, and other project water demands. By reducing the scale of the development, the project would be able to flush toilets and meet other onsite water demands that cannot be met as proposed. 4. Need to remove skyscrapers to be consistent with the Imagine Austin Comprehensive Plan’s call for an “activity center in a sensitive environmental area.” SOS respectfully disagrees with Staff’s stated conclusion that the proposed development is consistent with the Imagine Austin Comprehensive Plan. The “activity center in an environmentally sensitive area” designation calls for lower density, low- to mid-rise redevelopment that supports public transit without inviting major density centers into the Barton Springs watershed. As proposed, the project would be more on the order of a “satellite downtown,” especially when the large commercial tracts across Lamar and adjacent to the Brodie Oaks tract move toward redevelopment. The attached list of Imagine Austin and neighborhood plan references prepared by long-time Zilker neighborhood/South Lamar development expert Lorraine Atherton make clear that the proposal, in its current form, is not consistent with the Imagine Austin Comprehensive Plan and should be scaled back to be consistent. It is certainly not “superior” to the comprehensive plan requirements. 5. Parks need more attention and should be “public” and mostly kept natural and not converted to outdoor commercial areas controlled by the developer. 6. Please request that the matter be returned to the Environmental Commission when there is an actual draft zoning ordinance to be reviewed. We have learned from the Statesman PUD that having boards and commissions “review” a complex “zoning” ordinance that addresses far more than zoning when that ordinance does not actually exist leads to all kinds of problems – problems that are hidden from view or simply go unnoticed when they are not written down on paper. To address this problem, please include in your recommendation that the Environmental Commission be allowed to again review and make recommendations when there is an actual draft ordinance to review. Currently the staff back-up says there are 43 code modifications requested. Several of these have not been addressed here, and some of these are very important. For example, the proposal appears to mostly gut Hill Country Roadway Ordinance protections that are important not just for scenic beauty but also for air quality, urban heat island, and carbon capture. These issues deserve some attention, at least to the point of what is being lost from what would otherwise be required. Regretfully, we have not figured this one out yet. It only recently registered with us that the proposal would greatly reduce setbacks from a spring on the site. We also do not yet understand this issue but of course are concerned and don’t see how reducing setbacks from the spring can be environmentally superior. As to Airman’s Cave, we do believe that, given the unique geology of the site and the configuration of the cave, that the cave should be adequately protected. Thank you for your service to the community and for your consideration. Sincerely, Bill Bunch Enclosure Cc: David Armbrust, Pat Oles, Milo Burdette, Applicants Melissa Hawthorne, Barton Hills Neighborhood Assn. Lorraine Atherton, Zilker Neighborhood Assn. Hon. Ann Kitchen, Councilmember, District 5 Here's a run-down of the passages relevant to the proposed Brodie Oaks PUD from Imagine Austin [with Lorraine’s comments in square brackets]. The references to building height are found on page 105. Here goes: Pages 100-103, Figures 4.2 (Bicycle and Pedestrian Networks), 4.3 (Transit Networks), 4.4 (Roadway Networks), and 4.5 (Growth Concept Map): On all maps, the dots indicating the activity center at Ben White and Lamar are positioned to the east, between Lamar and Manchaca, not on top of Barton Creek. Page 104, Growth Concept Map Definitions, Activity Centers and Corridors Centers that are already established by existing small-area plans . . . are drawn to reflect those plans. Centers without small-area plans are simply shown with a circle, indicating scale and general location. Specifying boundaries for these centers may occur through small-area plans" [In this case, the center's boundaries should now reflect the South Austin Combined neighborhood plan. The South Austin Combined NP captures perfectly the definition of an activity center in the third paragraph on page 104. The Brodie Oaks proposal, on the other hand, has no library, no college campus, no high school, no hospital, no playing fields, no housing choices other than high-rise multifamily, and no transit center. It has one bus stop, and the Brodie PUD proposal pushes it south to the equivalent of a highway on-ramp, isolating it from any possible pedestrian traffic.] Page 105, description of Regional Centers "The central regional center encompassing Downtown . . . is the most urban. It includes low- to high-rise residential and office buildings." [Regional Center is the only category that includes high-rise buildings. The intersection of Ben White and South Lamar is NOT a regional center in Imagine Austin. Also see page 124 below.] Page 105, description of Town Centers "The buildings found in a town center will range in size from one- to three-story houses, duplexes, townhouses, and row houses, to low- to midrise apartments, mixed use buildings, and office buildings. These centers will also be important hubs in the transit system." [Town Center is the only category that fits the "Activity center for redevelopment in sensitive environmental areas" designation for the intersection of Ben White and South Lamar. The South Austin Combined NP fits the Town Center description perfectly, with lots of variety embedded in a grid of South Austin bus routes with established routes to the north and east.] Page 106, Activity Centers for Redevelopment in Sensitive Environmental Areas “Five centers are located over the recharge or contributing zones of the Barton Springs Zone of the Edwards Aquifer or within water-supply watersheds. These centers are located on already developed areas and, in some instances, provide opportunities to address long-standing water quality issues and provide walkable areas in and near existing neighborhoods.” [Note that it says "existing neighborhoods," not "new."] “State-of-the-art development practices will be required of any redevelopment to improve stormwater retention and the water quality flowing into the aquifer or other drinking water sources. These centers should also be carefully evaluated to fit within their infrastructural and environmental context." [In this case, the size of the proposed project overwhelms the fire, power, water, and street infrastructure that can be provided within the environmental context. Attempts to provide that increased level of services to the Brodie site will necessarily divert resources away from the redevelopment of the Westgate and South Austin Hospital areas, which are already under way.] "The Growth Concept Map not only guides where Austin may accommodate new residents and jobs but also reflects the community intent to direct growth away from environmentally sensitive areas including, but not limited to, the recharge and contributing zones of the Barton Springs segment of the Edwards Aquifer, and to protect the character of neighborhoods by directing growth to areas identified by small area plans." [In this case, growth should be directed to the approved South Austin Combined neighborhood plan, which is well-positioned as an education, medical, and transportation hub, and able to absorb a large population in the redevelopment of large and small shopping centers.] "Protect Austin's natural resources and environmental systems by limiting land use and transportation development in sensitive environmental areas." "transit stops are identified as ‘proposed.’ As more detailed planning occurs, these may move. When this happens, the associated activity center should move as well." [In this case, the Westgate transit center has moved to Ben White at Victory, which means the associated activity center should be the South Austin Combined neighborhood plan area. Given the state highway department’s policies controlling the Lamar right of way south of Panther, it Page 107: Also, Page 108: will not be possible to change traffic patterns or make any substantial pedestrian or transit connections to the Brodie Center in the foreseeable future.] Page 118, Best Practices: “One of the most critical pieces of the code is the concept of ‘successional zoning.’ This allows rezoning only to the next most intense zone if the property abuts a more intense zone. This promotes a controlled evolution of the built environment and minimizes opportunities for developers to acquire a property and request a rezoning to a dramatically different intensity or use.” [In other words, rezoning of Brodie Oaks should not exceed the zoning across the street, which is GR with a VMU overlay.] Page 124, Figure 4.6, Combined Future Land Use Map: There is one, and only one, parcel designated as a bright blue "Activity Center." It is the Westgate Shopping Center, on the southeast corner of the Ben White-Lamar intersection.