Please come to the Cobb County Board of Commissioners meeting, next Tuesday, Nov 12, at 9 AM, 2nd Floor BOC Room, 100 Cherokee Street, Marietta. We want to get the Commissioners to recommend a review of the CCRC (Continuing Care Retirement Community) zoning code, and the more people we have, the more likely this will happen. Make your voice heard! And if you cannot attend, sign the petition, and contact the Commissioners.
We received the news today that Isakson Living has re-filed their application to rezone the 53.7 acre parcel of land next to East Cobb Park from the current zoning of R-20 to CCRC. We don't have many details, so it is difficult to comment on specifics. We have heard that the new proposal has 840 units, which creates a density which is still too intense for this area of East Cobb.
We understood that Isakson Living would not file again until next year. Perhaps the growing opposition to the current CCRC zoning code (which Isakson Living helped to create in 2008) has prompted them to file again now, and be grandfathered in under the existing code, before any possible changes occur.
We have also seen comments that by opposing this proposal, we are somehow against retirement communities. Nothing could be further from the truth. We respect our elders, love our parents and grandparents, and many of us who oppose this proposal are seniors ourselves, or getting close. Done right, a retirement community enhances the larger surrounding community. We are opposed to the density and intensity of this proposal, not the fact that seniors would live there.
Cobb County zoning codes have a few different options for senior living. One is the non-supportive RSL (Residential Senior Living), which is basically a retirement community. The non-supportive RSL zoning code is one of the recommended codes for Low Density Residential areas like the proposed site of this CCRC. It limits building heights to two floors, and density to 5 units per acre (not including land which is wetlands or floodplain). Contrast that with CCRC, which intentionally has no upper cap on density - "a density loophole" as it was described by a speaker at the June 2008 hearing when this code was approved. Note that the first Isakson Living proposal was more than 20 units per acre, and the new proposal is still over 18 units per acre, not counting the 7.5 acres of floodplain on the site.
For those who do not know what a CCRC entails, the idea is that you move into an independent living unit, and later, if required, you can move to an assisted living (or nursing) unit.
The business model of a CCRC is that the independent living units subsidize the assisted living (nursing) units. It is kind of like a group insurance policy. This makes it imperative for a CCRC to have many occupied independent living units. We have heard that a CCRC needs a minimum of 400 to 500 units to be financially viable. Does that mean it should be built on Low Density Residential land, adjacent to existing subdivisions? Wouldn't Post Apartments make the same argument about needing to build tall and dense to be financially viable?
A CCRC is more suited for more dense areas of Cobb County, keeping similar types of developments together. During non-peak times, I can drive from my subdivision near the proposed site to the Windy Hill district in less than 10 minutes, and to the Cumberland Mall area in 20 minutes. How is driving a few miles a hardship on anyone? And certainly those areas are full of amenities for senior residents.
Here are the proposed changes to the CCRC zoning code:
1) A CCRC shall not be allowed in Low Density Residential (LDR) or Very Low Density Residential (VLDR) areas as shown on the future land use plan. It is already not allowed in Rural Residential (RR) areas.
2) For CCRCs in NAC, MDR, and P/I areas as shown on the future land use plan, the maximum building height shall be 35 feet above grade.
3) No floodplains, wetland areas or cemeteries may be used in calculating the overall density of the development.
4) The CCRC must be within five miles of an acute medical care center, by the roads customarily travelled by emergency response vehicles.
It is important to understand Cobb County's Future Land Use Plan, also referred to as the Comprehensive Plan. The idea was to define how land can be used, so that similar types of developments are built in the same areas. There are commercial land use categories, such as Community Activity Center and Neighborhood Activity Center, as well as residential categories such as Low Density Residential, Medium Density Residential and High Density Residential. There is also the Future Land Use Map, which shows the various areas of the county in different colors by their category.
The land for this proposed CCRC is Low Density Residential (LDR), as is the vast majority of the surrounding area, and most of unincorporated Cobb County. Low Density Residential is meant for developments up to 2.5 units per acre. The Future Land Use Plan specifically makes an exception for non-supportive Residential Senior Living (RSL) on LDR land to have a density of 5 units per acre, noting that seniors generally have less impact on an area. We agree with this, and think that non-supportive RSL is a well though-out zoning code that balances the needs of seniors with the needs of the surrounding community.
We are opposed to CCRCs on Low Density Residential land - it defeats the entire purpose of the Future Land Use Plan. The CCRC code is heavily weighted in favor of the developer, allowing for building heights of 4 stories (with the height of each story intentionally undefined), and unlimited density. This is disrespectful to the citizens of Cobb County who don't wish to live in an urban area.
Another thing to realize is that a developer can apply to rezone land from any zoning to any other zoning. However, unless the new zoning is one of the recommended zonings for the land's Future Land Use category, the zoning application is very unlikely to be approved. The CCRC code was intentionally written so a CCRC could be built in most areas of the county.
In some ways, CCRC is a combination of a non-supportive RSL and a supportive RSL (a nursing home). However, the supportive RSL zoning code in Cobb County is not a recommended zoning for Low Density Residential land - another well thought-out code, since a nursing home facility generally has high density, and is an intense usage of the land.
Also, the CCRC as proposed by Isakson Living has an independent living component with a density higher than that of most apartment complexes in Metro Atlanta. Again, the zoning codes used by apartment complexes in Cobb County (RM-8, RM-12, RM-16) are not recommended for Low Density Residential Land.
On Tuesday, Nov 12th, at 9 AM, the Cobb County Board of Commissioners will have their regular meeting at 2nd Floor BOC Room, 100 Cherokee Street, Marietta. We have heard that the CCRC zoning is on the agenda, but the official agenda is not yet available on the Cobb County website; we will post that as soon as it is available. We need people to attend, to turn up the heat on the Commissioners! We realize that 9 AM on a weekday is hard for most people, but please try. There is parking in nearby parking garages for $5 cash, so carpool if you can.
Understand that this is just to get the ball rolling. The Board of Commissioners will, we believe, ask the zoning department to review the CCRC zoning code with our specific changes in mind. The next steps, as we understand them, will likely involve forming a committee of citizens and developers to work through any changes, similar to the committee that created the zoning originally. Finally, there will be at least two public hearings before the Board of Commissioners takes a final vote on the changes.
But, we need to get started, and we need your help, so please try to make it on Tuesday!