As part of our ongoing engagement around the state to offer a housing abundance perspective to the Act 181 mapping project currently underway, Let's Build Homes today sent a letter to the Chittenden County Regional Planning Commission outlining our feedback on the initial maps.

While CCRPC was the first to get their draft maps to public review, we'll be closely monitoring the map making processes in all eleven RPCs over the coming year to ensure there is an eye towards enabling housing growth in every community across Vermont.

Read the full letter below.

CCRPC Staff,

Thank you for your ongoing work to implement the requirements of Act 181 through the development of Chittenden County’s draft Future Land Use maps. We know this is a complex and high-stakes effort, and we appreciate the thoughtful and transparent approach you’ve taken so far. On behalf of Let's Build Homes, I am writing to offer feedback informed by our internal review and a recent working session with board members and regional land use experts.

Our Role and Vision

Let's Build Homes is an organization dedicated to advancing land use and housing policy that meets the scale of Vermont’s acute housing shortage. We believe the Act 181 mapping process represents a generational opportunity to reshape Vermont’s growth framework in a way that supports abundant, well-located, climate-smart housing.

As Vermont’s population dynamics shift and the need for new homes becomes increasingly urgent, it is essential that our land use maps reflect not only where housing has been, but where it needs to go.

Ensuring Adequate Room for Housing Growth

As Chittenden County strives to meet ambitious housing targets and address the acute shortage of homes, it is critical that the new maps set out generous, logical, and future-oriented areas for growth.

In general, it is our sense that your preliminary maps do this. In particular, we were pleased to see that all of the developable areas of Burlington would be eligible for a 1a exemption, as would large sections of Winooski, South Burlington, Essex, Essex Junction, and Williston. We generally support these maps and appreciate how you have worked to give municipalities significant opportunity for Tier 1a/1b lands.

With the maps for some of the smaller, more rural towns, we do have some concern that the exemption areas are quite limited. We see three main conceptual opportunities to strengthen the framework for new housing that we hope you will consider as the maps are being finalized:

1. Final Future Land Use Map should attempt to include in Tier 1a/1b areas comparable in land area to the Interim Act 250 Housing Exemption Maps.

   The Interim Act 250 Housing Exemption Maps provide a broad, inclusive set of boundaries for housing growth, particularly through the use of buffer zones around core areas. The sizable buffer zones around existing designated areas are conceptually critical because those areas were generally created for purposes other than the Act 181 purpose of stimulating new housing creation. There are early indications that the exemption policy is succeeding at changing the troubling trajectory of Vermont housing creation.

   The new maps at the end of the multi-year process should not take us backward to a more restrictive permitting environment, nor should they be narrowly tailored to include only areas that are already developed. LBH believes that the overarching goal of this process should be for each community to have at least as much area eligible for Act 250 exemption once the final maps are drawn as there is today. While we have not been able to complete a comprehensive comparison of current and proposed future maps, it is clear from the Hinesburg Draft Future Land Use map that this has not been achieved in every community.

   We urge the CCRPC to compare the amount of land area in the proposed Draft Future Land Use Maps with the land area in the Interim Act 250 Housing Exemption maps (we understand that this analysis has been done by the Northwest RPC) and in communities where the Draft Maps show a smaller Tier 1a/1b area than what is currently exempted explore opportunities for adding further acreage to Tier 1a/1b for that area. If you feel you do not have the legislative authority to add this acreage we would welcome the opportunity to work with you to explore how this could be fixed.

2. Consider expanded use of “Transition” designation

   In many rural towns, the Draft Future Land Use maps includes Tier 1a/1b-eligible designations that are quite limited, often restricted to small village cores surrounded by large areas that you have primarily designated as “Rural General”. This condition is clear on the Jericho, Hinesburg, St. George and possibly other Draft Future Land Use maps. On these maps the use of the “Transition” designation is very limited.

   LBH understands and is sympathetic to the policy decisions that limit the ability of the RPC to designate broader exemption areas because there is not currently local regulation, infrastructure, or administrative capacity in these areas. However, it strikes us that it is (or should be) within the RPCs authority to designate areas that are good candidates for future growth as “Transition” areas as to signal potential future expansion of Tier 1a/1b to municipalities, land owners, and other stakeholders. Greater use of this classification in this manner would allow rural communities to identify and set aside space for moderate, well- sited growth outside of already built-out centers, supporting incremental housing expansion in line with each town’s vision and capacity. While this is not how the "Transition" designation is currently described, perhaps this could be amended.

   In summary, LBH urges CCRPC to consider much greater use of the “Transition” designation in areas that are contiguous to the proposed Tier 1a/1b areas, particularly in the more parts of Chittenden County.

3. Transportation Corridors for Growth Designation

   We appreciate the innovation the RPC made on the Interim Act 250 Housing Exemption Maps by including key transportation corridors. We believe such focus on transportation corridors often represents wise land use and transportation policy. Well-served corridors represent logical places for additional high-density housing, providing access to jobs, services, and transit. Aligning growth designations with these corridors can help maximize the impact of public infrastructure, reduce vehicle miles traveled, and facilitate the kinds of connected communities we will need in the years ahead.

   While our interpretation of the Draft Future Land Use Maps is that the great majority of these transportation corridors are currently mapped with exemption- eligible designations, this does not appear to be universally the case.

   If you have not done so already, we urge the CCRPC to compare the transit corridors on the temporary exemption map to the Draft Future Land Use maps and consider designating all such areas as either Tier 1a/1b or Transition (per rationale above).

4. Incorporate Other Current Mapping Data Into the Future Land Use Maps

   In recent years the University of Vermont has invested in important new data efforts that should impact the way that we plan for future growth. Specifically, we recommend considering:

   • Existing and Planned Future Water and Sewer Infrastructure Mapping – A recent collaborative project carried out by UVM students and faculty, and regional planning partners, found that in the two communities they analyzed (Montpelier and Brattleboro) 15-20% of existing sewer infrastructure, shown in the VERSO Wastewater Infrastructure Map, was not included in the temporary exemption areas. UVM has mapped much of the state’s existing water and sewer infrastructure. It is critical that we leverage this existing public investment by ensuring, at a minimum, that existing and planned water and sewer infrastructure is in Tier 1a/1b-eligible areas on the final Future Land Use Map. Identifying these areas may reveal other land that should be designated Tier 1a/1b-eligible areas or Transition.
   • Flood Area Mapping – UVM is producing innovative flood layer maps to better project the types of flooding that Vermont has seen in recent years. The UVM Livability Map should be considered by the RPC, and where this analysis significantly impacts and reduces areas that would otherwise be Tier 1a/1b-eligible, the RPC should identify comparable nearby land outside of the flood zone to add to exemption-eligible lands. By proactively doing such mapping the RPC can identify a path to a future where flooding impacts are reduced and create the land use regulations that make that possible.

Let's Build Homes will continue to engage with this process both in Chittenden County and across the state in the months ahead. We appreciate the chance to offer our feedback and look forward to continued collaboration.

Sincerely,

Miro Weinberger

Executive Chair, Let’s Build Homes