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AGENDA
ASPEN PLANNING & ZONING COMMISSION
November 16, 2021
4:30 PM, WebEx Virtual Meeting (See agenda packet for
instructions to join the meeting)
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II.ROLL CALL
III.COMMENTS
IV.MINUTES
None
V.DECLARATION OF CONFLICT OF INTEREST
VI.PUBLIC HEARINGS
VI.A.Land Use Code Amendment
Resolution - P&Z Recommendation
Single-Family and Duplex Affordable Housing Mitigation
P&Z Recommendation_Staff memo.pdf
Exhibit A - Redline Edits.pdf
EXHIBIT B Clean Draft.pdf
EXHIBIT C - Review Criteria.docx
Draft Resolution_11.16.21.docx
VII.OTHER BUSINESS
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VIII.ADJOURN
Typical Proceeding Format for All Public Hearings
1)Conflicts of Interest (handled at beginning of agenda)
2) Provide proof of legal notice (affidavit of notice for PH)
3) Staff presentation
4) Board questions and clarifications of staff
5) Applicant presentation
6) Board questions and clarifications of applicant
7) Public comments
8)Board questions and clarifications relating to public comments
9) Close public comment portion of bearing
10) Staff rebuttal/clarification of evidence presented by applicant and public comment
11) Applicant rebuttal/clarification
End of fact finding.
Deliberation by the commission commences.
No further interaction between commission and staff, applicant or public
12) Chairperson identified the issues to be discussed among commissioners.
13) Discussion between commissioners*
14) Motion*
*Make sure the discussion and motion includes what criteria are met or not met.
Revised January 8, 2021
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MEMORANDUM
TO: City of Aspen Planning and Zoning Commission
FROM: Ben Anderson, Principal Long-Range Planner
THROUGH: Amy Simon, Planning Director
MEMO DATE: November 11, 2021
MEETING DATE: November 16, 2021
RE: P&Z Recommendation related to Proposed Land Use Code
Changes - Calculation of Single-Family and Duplex Residential
Affordable Housing Mitigation
REQUEST OF THE PLANNING AND ZONING COMMISSION:
At a Work Session on July 12, 2021, City Council unanimously directed staff to develop
amendments to the Land Use Code (LUC) that would have the effect of increasing
required affordable housing mitigation for single-family and duplex residential
development. Specifically, the changes would eliminate the credit for existing floor area
and use a gross, rather than net Floor Area calculation when assessing affordable
housing mitigation requirements on these types of development (and redevelopment).
On November 9, 2021, City Council in a 5-0 vote approved a Policy Resolution that
formally begins the Amendment process.
Staff has drafted a Resolution for P&Z’s consideration. This Resolution, as drafted, would
provide formal recommendation to City Council in support of proposed code changes.
P&Z may: 1) approve the Resolution as drafted, 2) deny the Resolution, 3) approve the
Resolution with conditions or amendments, or 4) take no action.
First and Second Readings of an Ordinance approving these amendments would come
before Council on November 23rd and December 14th.
Staff recommends P&Z approve the Resolution – providing P&Z support for the
proposed changes to the Land Use Code.
SUMMARY AND BACKGROUND: As part of an ongoing effort to better coordinate the
Land Use Code in support of Council’s Affordable Housing Goals and in relationship to
discussions with Council about the effectiveness of Aspen’s Growth Management Quota
System in responding to the current development context, staff has continued to study
and analyze a range of related topics. Staff has held several Work Sessions with Council
over the last 18 months toward better understanding the issues and in thinking about
possible improvements. As part of this work, Council passed a series of targeted code
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Staff Memo, P&Z Recommendation
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amendments in May of 2021 – including an update to the Affordable Housing Mitigation
Fee-In-Lieu.
The relationship of Growth Management to Affordable Housing Mitigation has long been
a part of Aspen’s system of housing the employees generated by different development
types. The specific mechanisms within the LUC that have defined this relationship over
time have been changed and adjusted numerous times to respond to shifting dynamics
in Aspen’s development context. It has become apparent through analysis of our Growth
Management Allotment system and issued building permits, that residential development
and redevelopment is now the dominant contributor to both the real impacts and
perceived pressures that growth creates.
Overtime, technical changes to the LUC have had the effect of reducing the mitigation
requirements for single-family and residential development and redevelopment in a way
that has not been applied to commercial, lodge and multi-family residential. In the current
context, while the construction and other employee generation impacts of single-family
and duplex residences has intensified, the mitigation requirements have not kept pace.
The current mitigation requirements for single-family and duplex development are based
on a 2015 study by research consultants, RRC. While staff remains confident in the
fundamentals of this study – the application and intersection of the findings of this study
with other calculation methodologies (particularly Floor Area) has had the effect of
significantly reducing required mitigation.
The proposed code changes would do two things in response:
1. Remove the credit for existing Floor Area from the calculation of Affordable
Housing Mitigation in redevelopment scenarios when demolition occurs.
2. Use a gross Floor Area calculation, rather than a net calculation, in determining
mitigation requirements. The gross Floor Area calculation would include all sub-
grade areas, garages, and circulation features for the purposes of AH mitigation
only. This new methodology would not affect the calculation of allowable floor area
in meeting Zone District dimensional requirements, and residential development
rights would be unchanged.
STAFF DISCUSSION:
Single-Family and Duplex Development Affordable Housing Mitigation
Two different AH mitigation calculations apply when the Land Use Code refers to
Residential Development. First, and not part of these proposed amendments applies
when a subdivision with multiple lots is created, a change of use takes place, or a new
multi-family project is developed. These types of projects require the assignment of
Growth Management Allotments and require that 30% of the project’s Floor Area (and 60
or 70% of the project’s units) be some balance of deed restricted affordable housing. This
requirement could also be called inclusionary zoning in the broader planning world’s
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Staff Memo, P&Z Recommendation
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terminology. These projects require a Planning and Zoning review in the final
determination of the mitigation requirements.
The second calculation is typically assessed during the building permit review process.
Today, this calculation is much more common than the scenario described above. These
projects take place on existing residential lots – either as new construction or the
redevelopment of an existing home or homes. Different from the above scenario, the
mitigation here has been understood as a much more direct impact fee, rather than a
form of inclusionary zoning – calculating employee generation on a per square foot basis.
No development Growth Management Allotments are required. When a new home is
built or square footage is added to an existing home, a 2015 Employee Generation Study
established the following mitigation requirements:
.16 FTE per 1,000 square feet of Floor Area up to 4,500 sf.
.36 FTE per 1,000 square feet of Floor Area over > 4,500 sf.
Per the study, these figures were derived from an estimate of the full-time employees
generated during the construction and life span of the property. For example, a new
home, on a previously vacant lot, with a Floor Area of 5,500 square feet as measured per
the LUC would have the following mitigation requirements: 4,500 / 1000 = 4.5 x .16 = .72 FTE
1000 / 1000 = 1 x .36 = .36 FTE
.72 + .36 = 1.08 FTE
Existing Floor Area Credit
In redevelopment scenarios, the current code allows for the Floor Area of the existing
home to be credited against the Floor Area for the new home. Additionally, in situations
where a significant remodel that triggers demolition is contemplated, only new, additional
floor area is calculated. In both cases, the exemption of the existing floor area is credited,
regardless of whether mitigation was ever assessed on the property and regardless of
whether the existing Floor Area is renovated or scraped and replaced.
AH mitigation for new residential development became a requirement in the mid-1980s.
Depending on the circumstance and the code requirements in effect at the time of the
project, on-site units, off-site units, fee-in-lieu, and accessory dwelling units have all been
used in meeting mitigation requirements. Because of the change in code requirements
over time and the variability of development history on residential properties, simply
providing the credit was previously argued as a fair and straightforward response to this
issue.
The credit for existing residential floor area, like the previously eliminated credits for
existing commercial and lodge development, seems to have its origins in thinking about
growth management that came to define the system – that new development is what
drives growth. Long-standing, existing development should be exempt, and a new
development that mitigates – has provided mitigation forever. Today – it is redevelopment
of properties that is driving the growth that the community is experiencing. The whole
concept of a credit is undermined by the real impacts to employee generation that
redevelopment scenarios are creating.
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Staff Memo, P&Z Recommendation
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Since 2015, approximately 325,000 square feet of existing floor area has been
credited in redevelopment and major renovation scenarios 1. If not credited, the
square footage would conservatively translate into 52 FTEs (or approximately $19.5M of
mitigation value based on Cat. 2 FIL). It is also important to note that a similar credit for
existing Floor Area for commercial redevelopment was eliminated from the LUC in a 2017
Amendment and the credit for existing Lodge units was recently eliminated by Ordinance
No. 13, Series of 2021.
Sub-Grade (Basement) and other Exemptions from gross Floor Area
Under current code Sub-Grade areas (and other areas, like garages and circulation
elements) are effectively exempt from the contribution to both Allowable Floor Area and
Affordable Housing Mitigation. In essence, a calculation is made based on the percentage
of exposed wall area and applied to the gross floor area. As a consequence, unless a
project purposely exposes a large percentage of the basement to the surface for light
wells or other features, or the property is on a slope that naturally exposes the basement,
the vast majority of the gross floor area of basements is exempt.
In the 2015 Employee Generation Study, sub-grade and other exempt areas were
discussed as having impacts – but it was determined these areas should remain exempt
in consistency with the calculations for Allowable Floor Area in limiting the mass and scale
of a house.
Figure 1: Comparison of a redevelopment project’s mitigation requirements – with and without the
credit for existing floor area. The existing credit reduced the required mitigation by .32 FTE.
1 Calculated though analysis of a spreadsheet that documents impact fees used in zoning review of
issued building permits
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Staff Memo, P&Z Recommendation
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Figure 2: Comparison showing the impacts to AH mitigation created by the Sub-Grade Exemption.
In this example, the exemption reduces the mitigation requirements by .78 FTE.
Figure 3: The effect of eliminating both the credit for existing Floor Area and sub-grade
exemption.
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Staff Memo, P&Z Recommendation
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Staff does not have a calculation to summarize the total amount of sub-grade area that
has been exempted from mitigation over time, but the combination of real estate values
on a square foot basis and the exemption of basements from Allowable Floor Area
calculations has given significant incentive to maximize the size of these spaces. At this
time, staff is proposing to include this area in AH mitigation requirements but is not
proposing to limit these areas in relationship to calculation for Allowable Floor Area.
Analysis
Staff recognizes the scale of impact that these two changes would have on the current
mitigation requirements for single-family and duplex development and re-development.
In evaluating these potential impacts, staff analyzed six recent redevelopment projects
(See Table 1 on page 7). Of the six, only one (Project 3) is an outlier due to the size of
the sub-grade area and the fact that it is technically two, detached dwellings. The others
are representative of typical, single-family projects.
What would these changes accomplish?
Staff believes the changes pursued by these amendments would be an effective response
to Council and community concerns about affordable housing requirements for residential
development and may generate the following outcomes:
1. A more fully responsive mechanism to mitigate for the development activity that is most
shaping Aspen’s current “growth” context. This includes the continuing trend of increased
demand and valuation of single-family and duplex homes, the scale and pace of scrape
and replace redevelopment, and the growing role of Short-Term Rentals across our
residential zone districts.
2. Assess a mitigation requirement for development that is clearly generating new
demand for employees.
3. Create a more equitable mitigation requirement across different types of development
– Commercial, Lodge, Residential.
4. Create additional demand within the Affordable Housing Credits program by increasing
mitigation requirements which may be met through the purchase of credits from the
market. This may result in the development of more AH units by the private sector.
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Staff Memo, P&Z Recommendation
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Table 1: Examples of recent, actual single-family development projects depicting the mitigation
requirements under current code and the impacts of eliminating the credit for existing floor area
and subgrade exemption.
The table shows that each project is different in how these changes would impact the
eventual mitigation requirement. Some project financial proformas would be impacted
more significantly than others based on the size of the new home’s subgrade area or the
size of the existing home (and credit for Floor Area) in relationship to the size of the new
home.
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Staff Memo, P&Z Recommendation
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Figure 4. In spite of the significant increase that these changes would make to residential mitigation,
the mitigation per square foot would remain well below that of mitigation required for a similarly
sized commercial area. Note. The Commercial example calculates as if it were entirely ground floor
Net Leasable area.
Changes to the Land Use Code Required to Implement These Changes
While these proposed changes are impactful, they do not require significant changes to
the text of the Land Use Code. Four sections of the Code would need to be amended.
1) 26.104.100. Definitions. Floor Area. Staff proposes a minor change to the
definition of Floor Area. This is not a definition that is utilized frequently under the
current code regime. In essence the change would clarify a gross Floor Area
calculation that would apply to all enclosed areas on a property.
2) 26.470.090. Administrative applications. (Growth Management). This is the
section (26.470.090.A) that would require the most modification as it describes the
employee generation and mitigation requirements for single-family and duplex
development. The change would identify the use of gross Floor Area in calculating
mitigation requirements and would identify three scenarios for how to calculate
employee generation:
• New construction on an established, vacant lot
• Redevelopment or renovation that does not trigger “Demolition”
• Redevelopment or renovation that triggers “Demolition”
Also, the gross floor area methodology was extended to multi-family expansion
scenarios in 26.470.090.B to retain consistency.
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Staff Memo, P&Z Recommendation
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3) 26.470.140. Reconstruction limitations. (Growth Management). This section
provides description of the limitations on reconstruction rights following demolition
of all types of development. Clarification to the application of this section to single-
family and duplex development is needed if the change is made to 26.470.090.
4) 26.575.020.D. Measuring Floor Area. No changes are proposed to the text other
than underlining “floor area ratio” and “allowable floor area” to emphasize what this
section is describing – and providing a note to direct attention to 26.470.090 for
the calculation of employee generation and mitigation for single-family and duplex
development.
The red line edits and clean drafts of the code changes are included as Exhibits A
and B.
Public Outreach
Typically, when ComDev is proposing an amendment to the LUC, we have a public
outreach plan in place to gather input and comment in shaping the amendment. On this
set of topics however, staff does not believe that traditional public outreach will move the
needle in support of these proposals. In staff’s view, removing these long-standing
reductions in the required mitigation for residential projects will be unpopular within the
development community – and particularly for those that are contemplating
redevelopment projects. On the other hand, like many other requirements of the of the
LUC that translate into the development of affordable housing – those that may benefit
from an additional housing unit being built or those that may generally support additional
affordable housing may not be fully engaged in technical aspects of the LUC. Additionally,
the context surrounding COVID has made comprehensive outreach efforts challenging.
Staff has posted the process for these potential amendments in two recent editions of the
Community Development Newsletter and will continue to do so through Second Reading.
Additionally, staff, will conduct direct outreach to members of the development and design
community explaining the proposed changes ahead of Second Reading. Any feedback
received from this outreach will be summarized for Council consideration.
In thinking about these proposed changes and the nature of public outreach, it should be
noted that all required residential mitigation can be deferred if the owner is a full-time,
locally working resident under APCHA Guidelines.
2015 Aspen Residential Employment Generation Study
Employment generation studies are essential to the foundation of Aspen’s GMQS system
in that they establish the measurable impacts of development. These studies set the
clear nexus between a square foot of construction and long-term operations and
maintenance and the demand for employees that are being created by the new
development.
The RRC (consultant) study from 2015 is built on the assumption that it is measuring the
new impacts of residential development for two specific activities – construction and future
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Staff Memo, P&Z Recommendation
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maintenance and operations. The current report is applicable to new development on an
established vacant lot and redevelopment scenarios. The report also briefly references
the inclusion of sub-grade area. On both topics, the report (Credit and Exemption) is
responding to these reductions in mitigation as established elements in Aspen’s LUC –
rather than factors that are driving the impacts of employee generation. RRC has
provided recent (November 2021) evaluation of the 2015 employee generation study as
it relates to these specific code changes and per that evaluation, staff does not believe
that the proposed amendments would undermine the basis of the original study.
Staff raises this topic because of the importance of our mitigation requirements matching
the generation studies behind them. If Council were to implement the elimination of the
existing floor area credit and utilize gross Floor Area, staff recommends an update to the
generation study in 2022 to reflect the new stipulations in the LUC and more fully
understand the impact of redevelopment scenarios. This study could additionally be
expanded to incorporate analysis of short-term rentals (STRs) and their relationship to
residential uses and redevelopment in evaluating employee generation impacts. As the
use of residential properties has changed over time with an increasing STR presence and
other novel ownership models emerge (example, Pacaso), the occupancy of these units
and the services required by STRs have likely changed the employee generation of our
residential uses.
CONCLUSION AND NEXT STEPS:
The proposed Amendments under consideration in this Resolution would, in staff’s view,
be a positive step in further recognizing the impacts of single-family and duplex
development and redevelopment on employee generation and the demand for affordable
housing. While impactful, the code amendments necessary to achieve this change are
minimal in scope and complexity and do not alter underlying development rights.
P&Z’s recommendation would be included with the next steps of the amendment process
during City Council’s review:
November 23rd – First Reading of Ordinance with Council
December 14th – Second Reading of Ordinance with Council
RECOMMENDATIONS: Staff recommends the Planning and Zoning Commission
approve Resolution XX, providing support for the proposed changes to the Land Use
Code.
EXHIBITS:
A – Red line edits of the proposed code changes
B – Clean drafts of the proposed code changes
C – Review Criteria for a Land Use Code Amendment
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26.104.100. Definitions
Floor area. The sum total of the gross horizontal areas of each story of the building measured from the
exterior walls of the building. (See, Supplementary Regulations — Section 26.575.020, Calculations and
measurements).
EXHIBIT A - Red line edits
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26.470.090 Administrative applications.
The following types of development shall be approved, approved with conditions or denied by the
Community Development Director, pursuant to Section 26.470.060, Procedures for Review, and the criteria
described below. Except as noted, all administrative growth management approvals shall not be deducted
from the annual development allotments. All approvals apply cumulatively.
A. Single-Family and Duplex Residential Development or Expansion. The following types of
free-market residential development shall require the provision of affordable housing in one of the methods
described below:
1) The development of a single-family, two detached residential units, or a duplex dwelling on a
lot in one of the following conditions:
a. A lot created by a lot split, pursuant to Subsection 26.480.060.A.
b. A lot created by a historic lot split, pursuant to Subsection 26.480.060.B, when the subject lot
does not itself contain a historic resource.
c. A lot that was subdivided or was a legally described parcel prior to November 14, 1977, that
complies with the provisions of Subsection 26.480.020, Subdivision: applicability,
prohibitions, and lot merger.
2) The net increase of Floor Area of an existing single-family, two detached residential units on a
single lot, or a duplex dwelling, during redevelopment and renovation scenarios when the
definition of Demolition is not met, regardless of when the lot was subdivided or legally
described. and regardless of whether demolition occurs. This type of development shall not
require a growth management allocation and shall not be deducted from the respective annual
development allotments.
3) Redevelopment or renovation of an existing single-family, two detached residential units on a
single lot, or a duplex dwelling, when the definition of Demolition is met. This type of
development shall not require a growth management allocation and shall not be deducted from
the respective annual development allotments.
2)
3)4) Affordable housing mitigation requirements for the types of free-market residential
development described above shall be as follows. The applicant shall have four options:
a. Recording a resident-occupancy (RO), or lower, deed restriction on the single-family dwelling
unit or one of the residences if a duplex or two detached residences are developed on the
property. An existing deed restricted unit does not need to re-record a deed restriction.
b. Providing a deed restricted one-bedroom or larger affordable housing unit within the Aspen
Infill Area pursuant to the Aspen/Pitkin County Housing Authority Guidelines (which may
require certain improvements) in a size equal to or larger than 30% of the Floor Area increase
to the Free-Market unit. The mitigation unit must be deed-restricted as a "for sale" Category 2
(or lower) housing unit and transferred to a qualified purchaser according to the provisions of
the Aspen/Pitkin County Housing Authority Guidelines.
c. Providing a fee-in-lieu payment or extinguishing a Certificate of Affordable Housing Credit in
a full-time-equivalent (FTE) amount based on the following schedule:
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Floor Area per dwelling unit Employment Generation Rate
First 4,500 square feet (Floor Area) .16 employees per 1,000 square feet
of Floor Area.
Above 4,500 square feet (Floor Area) .36 employees per 1,000 square feet
of Floor Area.
Notes:
- The calculation of the Employment Generation shall be assessed per
dwelling unit. Duplex dwelling units do not combine their floor area for
one calculation.
- An Accessory Dwelling Unit or Carriage House, as defined by and
meeting the requirements of this Title, shall be calculated as floor area of
the primary dwelling.
- When redevelopment of a property adds floor area, the difference between
the generation rates of the existing floor area and the proposed floor area
shall be the basis for determining the number of employees generated. No
refunds shall be provided if Floor Area is reduced.
- When demolition is proposed, the redevelopment shall be credited the
floor area from the demolished residential dwelling unit. Credit from a
demolished dwelling unit cannot be allocated to development on a
different lot.
- The above generation rates are based on a study of employment generation
of Aspen residences, from both initial construction and ongoing operation,
performed by RRC Associates of Boulder, Colorado, dated March 4,
2015.
- The calculation of Floor Area for the purposes of determining employee
generation and required mitigation shall be based on the definition of
“Floor Area” in 26.104.100, Definitions: “The sum total of the gross
horizonal areas of the building measured from the exterior walls of the
building.” This calculation is inclusive of all enclosed levels of the
buildings on the property – including, basements, crawl spaces, attics
with walkable floors, garages, and vertical circulation. This calculation
shall not include storage areas of less than 32 square feet, or minimally
sized wildlife-resistant trash and recycling enclosures.
- See Figure 2, in 26.575.020.D, for a depiction of “Measuring to Face of
Framing” in calculating Floor Area from exterior wall.
- For new construction on a vacant lot, all Floor Area shall be included in
the calculation of employee generation and required mitigation.
- For redevelopment or renovation of an existing single-family or duplex
that does not meet the requirements of Demolition (26.104.100), only
new, additional Floor Area shall be calculated towards employee
generation and required mitigation.
- For redevelopment or renovation of an existing single-family or duplex
that meets the definition of Demolition (26.104.100), all Floor Area
(existing and new) shall be calculated toward employee generation and
required mitigation.
- Demolition that occurs as a result of an act of nature or through any
manner not purposefully accomplished by the owner, shall be evaluated
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by Community Development staff, and a credit for existing Floor Area
may be issued toward the reconstruction of the home.
- The calculation of the Employment Generation shall be assessed per
dwelling unit. Duplex dwelling units do not combine their floor area for
one calculation.
- An Accessory Dwelling Unit or Carriage House, as defined by and
meeting the requirements of this Title, shall be calculated as floor area of
the primary dwelling.
- The above generation rates are based on a study of employment
generation of Aspen residences, from both initial construction and
ongoing operation, performed by RRC Associates of Boulder, Colorado,
dated March 4, 2015.
- All required mitigation using Certificates of Affordable Housing Credits
or fee-in-lieu for single-family and duplex development shall be provided
at Category 2.
Affordable housing mitigation must be provided at a Category 2 (or lower) rate. Certificates
must be extinguished pursuant to the procedures of Chapter 26.540, Certificates of
Affordable Housing Credit. Fee-in-lieu rates shall be those stated in Section 26.470.100 –
Calculations; Employee Generation and Mitigation, in effect on the date of application
acceptance. Providing a fee-in-lieu payment in excess of .10 FTE shall require City Council
approval, pursuant to Section 26.470.110.C.
Example 1: A new home of 3,400 square feet of Floor Area on a vacant lot created by a
historic lot split. The applicant must provide affordable housing mitigation for .54 FTEs.
3,400 / 1,000 x .16 = .54
In this example the applicant may provide a Certificate of Affordable Housing Credit or
request City Council accept a fee-in-lieu payment.
Example 2: An existing home of 4,5400 square feet of Floor Area is expanded by 250 square
feet of Floor Area. The renovation does not meet the definition of Demolition. The applicant
must provide affordable housing mitigation for .097 FTEs., the difference in employee
generation of the two house sizes.
(4,500 / 1,000 x .16) + (150 / 1,000 x .36) – (4,400 / 1,000 x .16) = .07
(250/1000 x.36 = .09 FTE
**Note: the mitigation for the additional Floor Area is calculated at .36 FTE /1000sf
as the home now crosses the 4,500 square feet threshold identified above.
In this example the applicant may provide a Certificate of Affordable Housing Credit or a
fee-in-lieu payment.
Example 3: An existing home is redeveloped in a fashion that meets the definition of
Demolition. The redeveloped home has a Floor Area of 5,700 sf.
(4,500/1000 x .16) + (1,200/1000 x .36) = 1.15 FTE
In this example the applicant may provide a Certificate of Affordable Housing Credit or
request City Council accept a fee-in-lieu payment.
In this example the applicant may provide a Certificate of Affordable Housing Credit or a
fee-in-lieu payment.
d.c. For property owners qualified as a full-time local working resident, an affordable housing
mitigation deferral agreement may be accepted by the City of Aspen subject to the Aspen/Pitkin
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County Housing Authority Guidelines. This allows deferral of the mitigation requirement until
such time as the property is no longer owned by a full-time local working resident. Staff of the
City of Aspen Community Development Department and Staff of the Aspen/Pitkin County
Housing Authority can assist with the procedures and limitations of this option.
B. Multi-Family Residential Expansion. The following types of free-market residential
development shall require the provision of affordable housing in one of the methods described below:
1) The net increase of Floor Area of an existing free-market multi-family unit or structure,
regardless of when the lot was subdivided or legally described and provided demolition does not
occur. (When demolition occurs, see Section 26.470.100.E, Demolition or redevelopment of
multi-family housing.) This type of development shall not require a growth management
allocation and shall not be deducted from the respective annual development allotments
established pursuant to Section 26.470.040.
2) Affordable housing mitigation requirements for the type of free-market residential development
described above shall be as follows. The applicant shall have four options:
a. Recording a resident-occupancy (RO), or lower, deed restriction on the dwelling unit(s)
being expanded. An existing deed restricted unit does not need to re-record a deed
restriction.
b. Providing a deed restricted one-bedroom or larger affordable housing unit within the Aspen
Infill Area pursuant to the Aspen/Pitkin County Housing Authority Guidelines (which may
require certain improvements) in a size equal to or larger than 30% of the Floor Area increase
to the Free-Market unit(s). The mitigation unit(s) must be deed-restricted as a "for sale"
Category 2 (or lower) housing unit and transferred to a qualified purchaser according to the
provisions of the Aspen/Pitkin County Housing Authority Guidelines.
c. Providing a fee-in-lieu payment or extinguishing a Certificate of Affordable Housing Credit
in a full-time-equivalent (FTE) amount based on the following schedule:
Floor Area per dwelling unit Employment Generation Rate
square feet of expansion (Floor Area) .18 employees per 1,000 square feet of
Floor Area
Notes:
- The calculation of Floor Area for the purposes of determining employee generation and
required mitigation shall be based on the definition of “Floor Area” in 26.104.100,
Definitions: “The sum total of the gross horizonal areas of the building measured from
the exterior walls of the building.” This calculation is inclusive of all enclosed levels of
the building on the property – including, basements, crawl spaces, attics with walkable
floors, garages, and vertical circulation.
- The calculation of the Employment Generation shall be assessed per dwelling unit.
Multiple dwelling units do not combine their floor area for one calculation.
- When a unit adds floor area, the difference between the generation rates of the existing
floor area and the proposed floor area shall be the basis for determining the number of
employees generated. No refunds shall be provided if Floor Area is reduced.
- When demolition is proposed, please see Section 26.470.100.E – Demolition or
Redevelopment of Multi-Family Housing. Projects
Formatted: Font: 12 pt
17
- The above generation rates are based on a study of employment generation of Aspen
residences, from both initial construction and ongoing operation, performed by RRC
Associates of Boulder, Colorado, dated March 4, 2015.
Affordable housing mitigation must be provided at a Category 2 (or lower) rate. Certificates
must be extinguished pursuant to the procedures of Chapter 26.540, Certificates of
Affordable Housing Credit. Fee-in-lieu rates shall be those stated in Section 26.470.050 –
Calculations; Employee Generation and Mitigation, in effect on the date of application
acceptance. Providing a fee-in-lieu payment in excess of .10 FTE shall require City Council
approval, pursuant to Section 26.470.110.C.
Example 1: A multi-family unit of 1,400 square feet of Floor Area is expanded by 400
square feet of Floor Area. The applicant must provide affordable housing mitigation for .09
FTEs.
500 / 1,000 x .18 = .09
In this example the applicant may provide a Certificate of Affordable Housing Credit or a
fee-in-lieu payment.
Example 2: A multi-family unit of 1,400 square feet of Floor Area is expanded by 2,600
square feet of Floor Area. The applicant must provide affordable housing mitigation for .47
FTEs, the difference in employee generation of the two unit sizes.
2,600 / 1,000 x .18 = .47
In this example the applicant may provide a Certificate of Affordable Housing Credit or
request City Council accept a fee-in-lieu payment.
d. For property owners qualified as a full-time local working resident, an affordable housing
mitigation deferral agreement may be accepted by the City of Aspen subject to the
Aspen/Pitkin County Housing Authority Guidelines. This allows deferral of the mitigation
requirement until such time as the property is no longer owned by a full-time local working
resident. Staff of the City of Aspen Community Development Department and Staff of the
Aspen/Pitkin County Housing Authority can assist with the procedures and limitations of
this option.
26.470.140. Reconstruction limitations.
In reconstruction scenarios, growth management allotments and any other reconstruction rights that this
Code establishes, may continue, subject to the following limitations.
A. An applicant may propose to demolish and then delay the reconstruction of existing development for a
period not to exceed one (1) year. To comply with this limitation and maintain the reconstruction right
credit, an applicant must submit a complete building permit application for reconstruction on or before the
one-year anniversary of the issuance date of the demolition permit. The City Council may extend this
deadline upon demonstration of good cause. This time limitation shall not apply to the reconstruction of
single-family and duplex development. The continuation of growth management allotments in a
reconstruction scenario for single family and duplex development are not subject to this time limitation.
A.B. Single-family and Duplex development receive no credit for Floor Area in redevelopment scenarios
that meet the definition of Demolition – per 26.470.090.A.3. The exception to this is when a single-family
or duplex is demolished by an act of nature or through any manner not purposefully accomplished by the
owner.
Formatted: Font: Not Bold
Formatted: Font: Not Bold
Formatted: Indent: Left: 0", First line: 0"
Formatted: No bullets or numbering
18
B.C. Applicants shall verify existing conditions prior to demolition with the City Zoning Officer in order
to document any reconstruction rights. An applicant's failure to accurately document existing conditions
prior to demolition and verify reconstruction rights with the City Zoning Officer may result in a loss of
some or all of the reconstruction rights.
C.D. Reconstructed buildings shall comply with applicable requirements of the Land Use Code, including
but not limited to Chapter 26.312, Nonconformities, and Chapter 26.710, Zone Districts.
D.E. Reconstruction rights shall be limited to reconstruction on the same parcel or on an adjacent parcel
under the same ownership.
E.F. Residential redevelopment credits may be converted to lodge redevelopment credits by right. The
conversion rate shall be three (3) lodge units per each one (1) residential unit. This is a one-way conversion,
and lodge credits may not be converted to residential credits.
19
D. Measuring Floor Area. In measuring floor areas for floor area ratio and allowable floor area, the
following applies:
1. General. Floor area shall be attributed to the lot or parcel upon which it is developed. In measuring
a building for the purposes of calculating floor area ratio and allowable floor area, there shall be
included all areas within the surrounding exterior walls of the building. When measuring from the
exterior walls, the measurement shall be taken from the exterior face of framing, exterior face of
structural block, exterior face of straw bale, or similar exterior surface of the nominal structure
excluding sheathing, vapor barrier, weatherproofing membrane, exterior-mounted insulation
systems, and excluding all exterior veneer and surface treatments such as stone, stucco, bricks,
shingles, clapboards or other similar exterior veneer treatments. (Also, see setbacks.)
Framing
Exterior Face
of Framing Property
Line
Window
Window Sill
Wood Veneer
Stone Veneer
Floor Area Measured to Face of Framing Setback measured to
edge of veneer
20
26.575.020. , Calculations and Measurements
D. Measuring Floor Area. In measuring floor areas for floor area ratio and allowable floor area, the
following applies:
1. General. Floor area shall be attributed to the lot or parcel upon which it is developed. In measuring
a building for the purposes of calculating floor area ratio and allowable floor area, there shall be
included all areas within the surrounding exterior walls of the building. When measuring from the
exterior walls, the measurement shall be taken from the exterior face of framing, exterior face of
structural block, exterior face of straw bale, or similar exterior surface of the nominal structure
excluding sheathing, vapor barrier, weatherproofing membrane, exterior-mounted insulation
systems, and excluding all exterior veneer and surface treatments such as stone, stucco, bricks,
shingles, clapboards or other similar exterior veneer treatments. (Also, see setbacks.)
Note: In measuring Floor Area for the purposes of calculating employee generation and affordable
housing mitigation for single-family and duplex development, please refer to 26.470.090.
Formatted: Font: Bold
Formatted: Underline
Formatted: Underline
Formatted: Font: (Default) Times New Roman, 12 pt
21
26.104.100. Definitions
Floor area. The sum total of the gross horizontal areas of the building measured from the exterior walls of
the building. (See, Supplementary Regulations — Section 26.575.020, Calculations and measurements).
Exhibit B - Clean Draft, Proposed
Code Changes
22
26.470.090 Administrative applications.
The following types of development shall be approved, approved with conditions or denied by the
Community Development Director, pursuant to Section 26.470.060, Procedures for Review, and the criteria
described below. Except as noted, all administrative growth management approvals shall not be deducted
from the annual development allotments. All approvals apply cumulatively.
A. Single-Family and Duplex Residential Development or Expansion. The following types of
free-market residential development shall require the provision of affordable housing in one of the methods
described below:
1) The development of a single-family, two detached residential units, or a duplex dwelling on a
lot in one of the following conditions:
a. A lot created by a lot split, pursuant to Subsection 26.480.060.A.
b. A lot created by a historic lot split, pursuant to Subsection 26.480.060.B, when the subject lot
does not itself contain a historic resource.
c. A lot that was subdivided or was a legally described parcel prior to November 14, 1977, that
complies with the provisions of Subsection 26.480.020, Subdivision: applicability,
prohibitions, and lot merger.
2) The net increase of Floor Area of an existing single-family, two detached residential units on a
single lot, or a duplex dwelling, during redevelopment and renovation scenarios when the
definition of Demolition is not met, regardless of when the lot was subdivided or legally
described. This type of development shall not require a growth management allocation and shall
not be deducted from the respective annual development allotments.
3) Redevelopment or renovation of an existing single-family, two detached residential units on a
single lot, or a duplex dwelling, when the definition of Demolition is met. This type of
development shall not require a growth management allocation and shall not be deducted from
the respective annual development allotments.
4) Affordable housing mitigation requirements for the types of free-market residential development
described above shall be as follows. The applicant shall have four options:
a. Recording a resident-occupancy (RO), or lower, deed restriction on the single-family dwelling
unit or one of the residences if a duplex or two detached residences are developed on the
property. An existing deed restricted unit does not need to re-record a deed restriction.
b. Providing a deed restricted one-bedroom or larger affordable housing unit within the Aspen
Infill Area pursuant to the Aspen/Pitkin County Housing Authority Guidelines (which may
require certain improvements) in a size equal to or larger than 30% of the Floor Area increase
to the Free-Market unit. The mitigation unit must be deed-restricted as a "for sale" Category 2
(or lower) housing unit and transferred to a qualified purchaser according to the provisions of
the Aspen/Pitkin County Housing Authority Guidelines.
c. Providing a fee-in-lieu payment or extinguishing a Certificate of Affordable Housing Credit
in a full-time-equivalent (FTE) amount based on the following schedule:
23
Floor Area per dwelling unit Employment Generation Rate
First 4,500 square feet (Floor Area) .16 employees per 1,000 square feet
of Floor Area.
Above 4,500 square feet (Floor Area) .36 employees per 1,000 square feet
of Floor Area.
Notes:
- The calculation of Floor Area for the purposes of determining employee
generation and required mitigation shall be based on the definition of
“Floor Area” in 26.104.100, Definitions: “The sum total of the gross
horizonal areas of the building measured from the exterior walls of the
building.” This calculation is inclusive of all enclosed levels of the
buildings on the property – including, basements, crawl spaces, attics
with walkable floors, garages, and vertical circulation. This calculation
shall not include storage areas of less than 32 square feet, or minimally
sized wildlife-resistant trash and recycling enclosures.
- See Figure 2, in 26.575.020.D, for a depiction of “Measuring to Face of
Framing” in calculating Floor Area from exterior wall.
- For new construction on a vacant lot, all Floor Area shall be included in
the calculation of employee generation and required mitigation.
- For redevelopment or renovation of an existing single-family or duplex
that does not meet the requirements of Demolition (26.104.100), only
new, additional Floor Area shall be calculated towards employee
generation and required mitigation.
- For redevelopment or renovation of an existing single-family or duplex
that meets the definition of Demolition (26.104.100), all Floor Area
(existing and new) shall be calculated toward employee generation and
required mitigation.
- Demolition that occurs as a result of an act of nature or through any
manner not purposefully accomplished by the owner, shall be evaluated
by Community Development staff, and a credit for existing Floor Area
may be issued toward the reconstruction of the home.
- The calculation of the Employment Generation shall be assessed per
dwelling unit. Duplex dwelling units do not combine their floor area for
one calculation.
- An Accessory Dwelling Unit or Carriage House, as defined by and
meeting the requirements of this Title, shall be calculated as floor area of
the primary dwelling.
- The above generation rates are based on a study of employment
generation of Aspen residences, from both initial construction and
ongoing operation, performed by RRC Associates of Boulder, Colorado,
dated March 4, 2015.
- All required mitigation using Certificates of Affordable Housing Credits
or fee-in-lieu for single-family and duplex development shall be provided
at Category 2.
Affordable housing mitigation must be provided at a Category 2 (or lower) rate. Certificates
must be extinguished pursuant to the procedures of Chapter 26.540, Certificates of
Affordable Housing Credit. Fee-in-lieu rates shall be those stated in Section 26.470.100 –
Calculations; Employee Generation and Mitigation, in effect on the date of application
acceptance. Providing a fee-in-lieu payment in excess of .10 FTE shall require City Council
approval, pursuant to Section 26.470.110.C.
24
Example 1: A new home of 3,400 square feet of Floor Area on a vacant lot created by a
historic lot split. The applicant must provide affordable housing mitigation for .54 FTEs.
3,400 / 1,000 x .16 = .54
In this example the applicant may provide a Certificate of Affordable Housing Credit or
request City Council accept a fee-in-lieu payment.
Example 2: An existing home of 4,500 square feet of Floor Area is expanded by 250 square
feet of Floor Area. The renovation does not meet the definition of Demolition. The applicant
must provide affordable housing mitigation for .09 FTEs.
250/1000 x.36 = .09
**Note: the mitigation for the additional Floor Area is calculated at .36 FTE /1000sf
as the home now crosses the 4,500 square feet threshold identified above.
In this example the applicant may provide a Certificate of Affordable Housing Credit or a
fee-in-lieu payment.
Example 3: An existing home is redeveloped in a fashion that meets the definition of
Demolition. The redeveloped home has a Floor Area of 5,700 sf. The applicant must provide
affordable housing for 1.15 FTEs.
(4,500/1000 x .16) + (1,200/1000 x .36) = 1.15 FTE
In this example the applicant may provide a Certificate of Affordable Housing Credit or
request City Council accept a fee-in-lieu payment.
d. For property owners qualified as a full-time local working resident, an affordable housing
mitigation deferral agreement may be accepted by the City of Aspen subject to the Aspen/Pitkin
County Housing Authority Guidelines. This allows deferral of the mitigation requirement until
such time as the property is no longer owned by a full-time local working resident. Staff of the
City of Aspen Community Development Department and Staff of the Aspen/Pitkin County
Housing Authority can assist with the procedures and limitations of this option.
B. Multi-Family Residential Expansion. The following types of free-market residential
development shall require the provision of affordable housing in one of the methods described below:
1) The net increase of Floor Area of an existing free-market multi-family unit or structure,
regardless of when the lot was subdivided or legally described and provided demolition does not
occur. (When demolition occurs, see Section 26.470.100.E, Demolition or redevelopment of
multi-family housing.) This type of development shall not require a growth management
allocation and shall not be deducted from the respective annual development allotments
established pursuant to Section 26.470.040.
2) Affordable housing mitigation requirements for the type of free-market residential development
described above shall be as follows. The applicant shall have four options:
a. Recording a resident-occupancy (RO), or lower, deed restriction on the dwelling unit(s)
being expanded. An existing deed restricted unit does not need to re-record a deed
restriction.
b. Providing a deed restricted one-bedroom or larger affordable housing unit within the Aspen
Infill Area pursuant to the Aspen/Pitkin County Housing Authority Guidelines (which may
require certain improvements) in a size equal to or larger than 30% of the Floor Area increase
to the Free-Market unit(s). The mitigation unit(s) must be deed-restricted as a "for sale"
Category 2 (or lower) housing unit and transferred to a qualified purchaser according to the
provisions of the Aspen/Pitkin County Housing Authority Guidelines.
25
c. Providing a fee-in-lieu payment or extinguishing a Certificate of Affordable Housing Credit
in a full-time-equivalent (FTE) amount based on the following schedule:
Floor Area per dwelling unit Employment Generation Rate
square feet of expansion (Floor Area) .18 employees per 1,000 square feet of
Floor Area
Notes:
- The calculation of Floor Area for the purposes of determining employee generation and
required mitigation shall be based on the definition of “Floor Area” in 26.104.100,
Definitions: “The sum total of the gross horizonal areas of the building measured from
the exterior walls of the building.” This calculation is inclusive of all enclosed levels of
the building on the property – including, basements, crawl spaces, attics with walkable
floors, garages, and vertical circulation.
- The calculation of the Employment Generation shall be assessed per dwelling unit.
Multiple dwelling units do not combine their floor area for one calculation.
- When a unit adds floor area, the difference between the generation rates of the existing
floor area and the proposed floor area shall be the basis for determining the number of
employees generated. No refunds shall be provided if Floor Area is reduced.
- When demolition is proposed, please see Section 26.470.100.D – Demolition or
Redevelopment of Multi-Family Housing. Projects
- The above generation rates are based on a study of employment generation of Aspen
residences, from both initial construction and ongoing operation, performed by RRC
Associates of Boulder, Colorado, dated March 4, 2015.
Affordable housing mitigation must be provided at a Category 2 (or lower) rate. Certificates
must be extinguished pursuant to the procedures of Chapter 26.540, Certificates of
Affordable Housing Credit. Fee-in-lieu rates shall be those stated in Section 26.470.050 –
Calculations; Employee Generation and Mitigation, in effect on the date of application
acceptance. Providing a fee-in-lieu payment in excess of .10 FTE shall require City Council
approval, pursuant to Section 26.470.110.C.
Example 1: A multi-family unit of 1,400 square feet of Floor Area is expanded by 400
square feet of Floor Area. The applicant must provide affordable housing mitigation for .09
FTEs.
500 / 1,000 x .18 = .09
In this example the applicant may provide a Certificate of Affordable Housing Credit or a
fee-in-lieu payment.
Example 2: A multi-family unit of 1,400 square feet of Floor Area is expanded by 2,600
square feet of Floor Area. The applicant must provide affordable housing mitigation for .47
FTEs, the difference in employee generation of the two unit sizes.
2,600 / 1,000 x .18 = .47
In this example the applicant may provide a Certificate of Affordable Housing Credit or
request City Council accept a fee-in-lieu payment.
d. For property owners qualified as a full-time local working resident, an affordable housing
mitigation deferral agreement may be accepted by the City of Aspen subject to the
Aspen/Pitkin County Housing Authority Guidelines. This allows deferral of the mitigation
26
requirement until such time as the property is no longer owned by a full-time local working
resident. Staff of the City of Aspen Community Development Department and Staff of the
Aspen/Pitkin County Housing Authority can assist with the procedures and limitations of
this option.
26.470.140. Reconstruction limitations.
In reconstruction scenarios, growth management allotments and any other reconstruction rights that this
Code establishes, may continue, subject to the following limitations.
A. An applicant may propose to demolish and then delay the reconstruction of existing development for a
period not to exceed one (1) year. To comply with this limitation and maintain the reconstruction right, an
applicant must submit a complete building permit application for reconstruction on or before the one-year
anniversary of the issuance date of the demolition permit. The City Council may extend this deadline upon
demonstration of good cause. The continuation of growth management allotments in a reconstruction
scenario for single-family and duplex development are not subject to this time limitation.
B. Single-family and duplex development receive no credit for existing Floor Area for the purposes of
determining affordable housing mitigation in redevelopment scenarios that meet the definition of
Demolition – per 26.470.090.A.3. The exception to this is when a single-family or duplex is demolished
by an act of nature or through any manner not purposefully accomplished by the owner.
C. Applicants shall verify existing conditions prior to demolition with the City Zoning Officer in order to
document any reconstruction rights. An applicant's failure to accurately document existing conditions prior
to demolition and verify reconstruction rights with the City Zoning Officer may result in a loss of some or
all of the reconstruction rights.
D. Reconstructed buildings shall comply with applicable requirements of the Land Use Code, including
but not limited to Chapter 26.312, Nonconformities, and Chapter 26.710, Zone Districts.
E. Reconstruction rights shall be limited to reconstruction on the same parcel or on an adjacent parcel
under the same ownership.
F. Residential redevelopment credits may be converted to lodge redevelopment credits by right. The
conversion rate shall be three (3) lodge units per each one (1) residential unit. This is a one-way conversion,
and lodge credits may not be converted to residential credits.
27
26.575.020. Calculations and Measurements
D. Measuring Floor Area. In measuring floor areas for floor area ratio and allowable floor area, the
following applies:
1. General. Floor area shall be attributed to the lot or parcel upon which it is developed. In measuring
a building for the purposes of calculating floor area ratio and allowable floor area, there shall be
included all areas within the surrounding exterior walls of the building. When measuring from the
exterior walls, the measurement shall be taken from the exterior face of framing, exterior face of
structural block, exterior face of straw bale, or similar exterior surface of the nominal structure
excluding sheathing, vapor barrier, weatherproofing membrane, exterior-mounted insulation
systems, and excluding all exterior veneer and surface treatments such as stone, stucco, bricks,
shingles, clapboards or other similar exterior veneer treatments. (Also, see setbacks.)
Note: In measuring Floor Area for the purposes of calculating employee generation and affordable
housing mitigation for single-family and duplex development, please refer to 26.470.090.
28
EXHIBIT C – REVIEW CRITERIA
26.310.050 Amendments to the Land Use Code Standards of review - Adoption.
In reviewing an application to amend the text of this Title, per Section 26.310.020(B)(3), Step Three –
Public Hearing before City Council, the City Council shall consider:
A.Whether the proposed amendment is in conflict with any applicable portions of this Title.
Staff Response: The term “floor area” is used in many different contexts and with different application as
one moves through the Land Use Code. For many years “Floor Area” has been a single calculation that is
used for “floor area ratio” (FAR), “allowable floor area” and affordable housing mitigation requirements.
This calculation is a “net” floor area that includes exemptions for basements, garages, vertical circulation,
etc. and has the effect of significantly reducing the calculated size of a house – from the “gross” calculation
of floor area. To implement the policy change of utilizing a gross calculation for affordable housing
mitigation, changes needed to be made across three chapters of the code to bring consistency to the topic.
Staff finds this criterion to be met.
B.Whether the proposed amendment achieves the policy, community goal, or objective cited as
reasons for the code amendment or achieves other public policy objectives.
Staff Response:The purpose statement of Chapter 26.470 – Growth Management Quota System (GMQS)
is as follows: The purposes of this Chapter are to: (a) implement the goals and policies for the City and
the Aspen Area Community Plan; (b) ensure that new growth occurs in an orderly and efficient manner in
the City; (c) ensure sufficient public facilities are present to accommodate new growth and development;
(d) ensure that new growth and development is designed and constructed to maintain the character and
ambiance of the City; (e) ensure the presence of an adequate supply of affordable housing, businesses and
events that serve the local, permanent community and the area's tourist base; (f) ensure that growth does
not overextend the community's ability to provide support services, including employee housing, traffic
control and parking; and (g) ensure that the resulting employees generated and impacts created by
development and redevelopment are mitigated by said development and redevelopment.
Staff finds that the proposed code changes are a direct response to (a), (e), (f), and (g) stated above. Staff
finds this criterion to be met.
C.Whether the proposed amendment is compatible with the community character of the City and is in
harmony with the public interest and the purpose and intent of this Title.
Staff Response: Per previous discussion with City Council, changes of the type being proposed are
consistent with the Aspen Area Community Plan and with the intent and purpose of the Growth Management
Quota System. The proposed changes are necessary to reflect the nature of the current development context
in the City of Aspen, where single-family and duplex redevelopment are driving growth impacts and are
currently under mitigating for their impacts to employee generation. Staff finds this criterion to be met.
29
30
Planning and Zoning Commission
Res. XX No., Series of 2021
Page 1 of 9
RESOLUTION NO. XX
(SERIES OF 2021)
A RESOLUTION OF THE ASPEN PLANNING AND ZONING COMMISSION
RECOMMENDING APPROVAL BY CITY COUNCIL OF PROPOSED AMENDMENTS
TO THE LAND USE CODE IN CHAPTERS 26.104, GENERAL PROVISIONS; 26.470,
GROWTH MANNAGEMENT QUOTA SYSTEM; AND 26.575, MISCELLANEOUS
SUPPLEMENTAL REGULATIONS.
WHEREAS,the Community Development Department has held multiple work sessions
with City Council on the topic of coordination of the Land Use Code and Council’s affordable
housing goals; and,
WHEREAS,at a work session on July 12, 2021, City Council provided direction to
Community Development staff to develop Land Use Code amendments related to affordable
housing mitigation requirements for single-family and duplex development; and,
WHEREAS,on November 9, 2021, City Council passed Policy Resolution #106, Series
of 2021, approving initiation of code amendments; and,
WHEREAS Community Development staff are proposing specific amendments to the
Land Use Code; and,
WHEREAS,at a duly noticed public hearing on November 16, 2021, the Planning and
Zoning Commission considered the proposed code amendment, reviewed staff’s memo, and
received public comment at the hearing, and by a X-X (X-X) vote approves Resolution No. XX,
Series of 2021, recommending Council consideration and approval of the proposed amendments.
NOW, THEREFORE BE IT RESOLVED BY THE PLANNING AND ZONING
COMMISSION OF THE CITY OF ASPEN, COLORADO THAT:
Section 1:
Planning and Zoning Commission recommends Land Use Code Amendments to:
a. Section 26.104.100 that amends the definition of Floor Area.
b. Section 26.470.090 that amends the employee generation and mitigation calculation for
single-family and duplex residential development, and expansion of multifamily
developement.
c. Section 26.470.140 that amends Reconstruction Limitations to be consistent with the
changes made to 26.470.090.
d. Section 26.575.020.D to bring clarity in measuring Floor Area for “floor area ratio” and
“allowable floor area” as differentiated from measuring Floor Area for the calculation of
employee generation and mitigation for single-family and duple development.
The proposed language for the Amendments to Land Use Code are attached as Exhibit A.
31
Planning and Zoning Commission
Res. XX No., Series of 2021
Page 2 of 9
Section 2:
This Resolution shall not affect any existing litigation and shall not operate as an abatement of any
action or proceeding now pending under or by virtue of the ordinances repealed or amended as
herein provided, and the same shall be conducted and concluded under such prior ordinances.
Section 3:
If any section, subsection, sentence, clause, phrase, or portion of this Resolution is for any reason
held invalid or unconstitutional in a court of competent jurisdiction, such portion shall be deemed
a separate, distinct, and independent provision and shall not affect the validity of the remaining
portions thereof.
FINALLY,adopted, passed, and approved this 16th day of November 2021.
Approved as to form: Approved as to content:
________________________________________________________________
Katherine Johnson, Assistant City Attorney Spencer McKnight, Chair
Attest:
_______________________________
Cindy Klob, Records Manager
EXHIBIT A: Draft of Proposed Code Language
32
Planning and Zoning Commission
Res. XX No., Series of 2021
Page 3 of 9
EXHIBIT A: Proposed Code Language
26.104.100. Definitions
Floor area. The sum total of the gross horizontal areas of the building measured from the exterior
walls of the building. (See, Supplementary Regulations — Section 26.575.020, Calculations and
measurements).
26.470.090 Administrative applications.
The following types of development shall be approved, approved with conditions or denied by
the Community Development Director, pursuant to Section 26.470.060, Procedures for Review,
and the criteria described below. Except as noted, all administrative growth management
approvals shall not be deducted from the annual development allotments. All approvals apply
cumulatively.
A. Single-Family and Duplex Residential Development or Expansion. The following types of
free-market residential development shall require the provision of affordable housing in one of
the methods described below:
1) The development of a single-family, two detached residential units, or a duplex
dwelling on a lot in one of the following conditions:
a. A lot created by a lot split, pursuant to Subsection 26.480.060.A.
b. A lot created by a historic lot split, pursuant to Subsection 26.480.060.B, when the
subject lot does not itself contain a historic resource.
c. A lot that was subdivided or was a legally described parcel prior to November 14,
1977, that complies with the provisions of Subsection 26.480.020, Subdivision:
applicability, prohibitions, and lot merger.
2) The net increase of Floor Area of an existing single-family, two detached residential
units on a single lot, or a duplex dwelling, during redevelopment and renovation
scenarios when the definition of Demolition is not met, regardless of when the lot was
subdivided or legally described. This type of development shall not require a growth
management allocation and shall not be deducted from the respective annual
development allotments.
3) Redevelopment or renovation of an existing single-family, two detached residential
units on a single lot, or a duplex dwelling, when the definition of Demolition is met.
This type of development shall not require a growth management allocation and shall
not be deducted from the respective annual development allotments.
4) Affordable housing mitigation requirements for the types of free-market residential
development described above shall be as follows. The applicant shall have four
options:
33
Planning and Zoning Commission
Res. XX No., Series of 2021
Page 4 of 9
a. Recording a resident-occupancy (RO), or lower, deed restriction on the single-family
dwelling unit or one of the residences if a duplex or two detached residences are
developed on the property. An existing deed restricted unit does not need to re-record
a deed restriction.
b. Providing a deed restricted one-bedroom or larger affordable housing unit within the
Aspen Infill Area pursuant to the Aspen/Pitkin County Housing Authority Guidelines
(which may require certain improvements) in a size equal to or larger than 30% of the
Floor Area increase to the Free-Market unit. The mitigation unit must be deed-
restricted as a "for sale" Category 2 (or lower) housing unit and transferred to a
qualified purchaser according to the provisions of the Aspen/Pitkin County Housing
Authority Guidelines.
c. Providing a fee-in-lieu payment or extinguishing a Certificate of Affordable Housing
Credit in a full-time-equivalent (FTE) amount based on the following schedule:
Floor Area per dwelling unit Employment Generation Rate
First 4,500 square feet (Floor Area).16 employees per 1,000 square feet
of Floor Area.
Above 4,500 square feet (Floor
Area)
.36 employees per 1,000 square feet
of Floor Area.
Notes:
-The calculation of Floor Area for the purposes of determining
employee generation and required mitigation shall be based on the
definition of “Floor Area” in 26.104.100, Definitions: “The sum
total of the gross horizonal areas of the building measured from
the exterior walls of the building.”This calculation is inclusive of
all enclosed levels of the buildings on the property – including,
basements, crawl spaces, attics with walkable floors, garages, and
vertical circulation. This calculation shall not include storage
areas of less than 32 square feet, or minimally sized wildlife-
resistant trash and recycling enclosures.
-See Figure 2, in 26.575.020.D, for a depiction of “Measuring to
Face of Framing” in calculating Floor Area from exterior wall.
-For new construction on a vacant lot, all Floor Area shall be
included in the calculation of employee generation and required
mitigation.
-For redevelopment or renovation of an existing single-family or
duplex that does not meet the requirements of Demolition
(26.104.100), only new, additional Floor Area shall be calculated
towards employee generation and required mitigation.
-For redevelopment or renovation of an existing single-family or
duplex that meets the definition of Demolition (26.104.100), all
Floor Area (existing and new) shall be calculated toward employee
generation and required mitigation.
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Planning and Zoning Commission
Res. XX No., Series of 2021
Page 5 of 9
-Demolition that occurs as a result of an act of nature or through any
manner not purposefully accomplished by the owner, shall be evaluated
by Community Development staff, and a credit for existing Floor Area
may be issued toward the reconstruction of the home.
-The calculation of the Employment Generation shall be assessed per
dwelling unit. Duplex dwelling units do not combine their floor area for
one calculation.
-An Accessory Dwelling Unit or Carriage House, as defined by and
meeting the requirements of this Title, shall be calculated as floor area of
the primary dwelling.
-The above generation rates are based on a study of employment
generation of Aspen residences, from both initial construction and
ongoing operation, performed by RRC Associates of Boulder,
Colorado, dated March 4, 2015.
-All required mitigation using Certificates of Affordable Housing Credits
or fee-in-lieu for single-family and duplex development shall be provided
at Category 2.
Affordable housing mitigation must be provided at a Category 2 (or lower) rate.
Certificates must be extinguished pursuant to the procedures of Chapter 26.540,
Certificates of Affordable Housing Credit. Fee-in-lieu rates shall be those stated
in Section 26.470.100 – Calculations; Employee Generation and Mitigation, in
effect on the date of application acceptance. Providing a fee-in-lieu payment in
excess of .10 FTE shall require City Council approval, pursuant to Section
26.470.110.C.
Example 1: A new home of 3,400 square feet of Floor Area on a vacant lot
created by a historic lot split. The applicant must provide affordable housing
mitigation for .54 FTEs.
3,400 / 1,000 x .16 = .54
In this example the applicant may provide a Certificate of Affordable Housing
Credit or request City Council accept a fee-in-lieu payment.
Example 2: An existing home of 4,500 square feet of Floor Area is expanded by
250 square feet of Floor Area. The renovation does not meet the definition of
Demolition. The applicant must provide affordable housing mitigation for .09
FTEs.
250/1000 x.36 = .09
**Note: the mitigation for the additional Floor Area is calculated at .36
FTE /1000sf as the home now crosses the 4,500 square feet threshold identified
above.
In this example the applicant may provide a Certificate of Affordable Housing
Credit or a fee-in-lieu payment.
Example 3: An existing home is redeveloped in a fashion that meets the definition
of Demolition. The redeveloped home has a Floor Area of 5,700 sf. The applicant
must provide affordable housing for 1.15 FTEs.
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Planning and Zoning Commission
Res. XX No., Series of 2021
Page 6 of 9
(4,500/1000 x .16) + (1,200/1000 x .36) = 1.15 FTE
In this example the applicant may provide a Certificate of Affordable Housing
Credit or request City Council accept a fee-in-lieu payment.
d. For property owners qualified as a full-time local working resident, an affordable
housing mitigation deferral agreement may be accepted by the City of Aspen subject
to the Aspen/Pitkin County Housing Authority Guidelines. This allows deferral of the
mitigation requirement until such time as the property is no longer owned by a full-
time local working resident. Staff of the City of Aspen Community Development
Department and Staff of the Aspen/Pitkin County Housing Authority can assist with
the procedures and limitations of this option.
B. Multi-Family Residential Expansion. The following types of free-market residential
development shall require the provision of affordable housing in one of the methods described
below:
1) The net increase of Floor Area of an existing free-market multi-family unit or structure,
regardless of when the lot was subdivided or legally described and provided demolition
does not occur. (When demolition occurs, see Section 26.470.100.E, Demolition or
redevelopment of multi-family housing.) This type of development shall not require
a growth management allocation and shall not be deducted from the respective annual
development allotments established pursuant to Section 26.470.040.
2) Affordable housing mitigation requirements for the type of free-market residential
development described above shall be as follows. The applicant shall have four
options:
a. Recording a resident-occupancy (RO), or lower, deed restriction on the dwelling
unit(s) being expanded. An existing deed restricted unit does not need to re-record
a deed restriction.
b. Providing a deed restricted one-bedroom or larger affordable housing unit within
the Aspen Infill Area pursuant to the Aspen/Pitkin County Housing Authority
Guidelines (which may require certain improvements) in a size equal to or larger
than 30% of the Floor Area increase to the Free-Market unit(s). The mitigation
unit(s) must be deed-restricted as a "for sale" Category 2 (or lower) housing unit
and transferred to a qualified purchaser according to the provisions of the
Aspen/Pitkin County Housing Authority Guidelines.
c. Providing a fee-in-lieu payment or extinguishing a Certificate of Affordable
Housing Credit in a full-time-equivalent (FTE) amount based on the following
schedule:
Floor Area per dwelling unit Employment Generation Rate
square feet of expansion (Floor Area).18 employees per 1,000 square feet
of Floor Area
Notes:
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Planning and Zoning Commission
Res. XX No., Series of 2021
Page 7 of 9
-The calculation of Floor Area for the purposes of determining employee generation and
required mitigation shall be based on the definition of “Floor Area” in 26.104.100,
Definitions: “The sum total of the gross horizonal areas of the building measured from
the exterior walls of the building.”This calculation is inclusive of all enclosed levels of
the building on the property – including, basements, crawl spaces, attics with walkable
floors, garages, and vertical circulation.
-The calculation of the Employment Generation shall be assessed per dwelling unit.
Multiple dwelling units do not combine their floor area for one calculation.
-When a unit adds floor area, the difference between the generation rates of the existing
floor area and the proposed floor area shall be the basis for determining the number of
employees generated. No refunds shall be provided if Floor Area is reduced.
-When demolition is proposed, please see Section 26.470.100.D – Demolition or
Redevelopment of Multi-Family Housing Projects.
-The above generation rates are based on a study of employment generation of Aspen
residences, from both initial construction and ongoing operation, performed by RRC
Associates of Boulder, Colorado, dated March 4, 2015.
Affordable housing mitigation must be provided at a Category 2 (or lower) rate.
Certificates must be extinguished pursuant to the procedures of Chapter 26.540,
Certificates of Affordable Housing Credit. Fee-in-lieu rates shall be those stated
in Section 26.470.050 – Calculations; Employee Generation and Mitigation, in
effect on the date of application acceptance. Providing a fee-in-lieu payment in
excess of .10 FTE shall require City Council approval, pursuant to Section
26.470.110.C.
Example 1: A multi-family unit of 1,400 square feet of Floor Area is expanded
by 400 square feet of Floor Area. The applicant must provide affordable housing
mitigation for .09 FTEs.
500 / 1,000 x .18 = .09
In this example the applicant may provide a Certificate of Affordable Housing
Credit or a fee-in-lieu payment.
Example 2: A multi-family unit of 1,400 square feet of Floor Area is expanded
by 2,600 square feet of Floor Area. The applicant must provide affordable
housing mitigation for .47 FTEs, the difference in employee generation of the two
unit sizes.
2,600 / 1,000 x .18 = .47
In this example the applicant may provide a Certificate of Affordable Housing
Credit or request City Council accept a fee-in-lieu payment.
d. For property owners qualified as a full-time local working resident, an affordable
housing mitigation deferral agreement may be accepted by the City of Aspen
subject to the Aspen/Pitkin County Housing Authority Guidelines. This allows
deferral of the mitigation requirement until such time as the property is no longer
owned by a full-time local working resident. Staff of the City of Aspen Community
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Planning and Zoning Commission
Res. XX No., Series of 2021
Page 8 of 9
Development Department and Staff of the Aspen/Pitkin County Housing Authority
can assist with the procedures and limitations of this option.
26.470.140.Reconstruction limitations.
In reconstruction scenarios, growth management allotments and any other reconstruction rights
that this Code establishes, may continue, subject to the following limitations.
A.An applicant may propose to demolish and then delay the reconstruction of existing
development for a period not to exceed one (1) year. To comply with this limitation and maintain
the reconstruction right, an applicant must submit a complete building permit application for
reconstruction on or before the one-year anniversary of the issuance date of the demolition permit.
The City Council may extend this deadline upon demonstration of good cause. The continuation
of growth management allotments in a reconstruction scenario for single-family and duplex
development are not subject to this time limitation.
B.Single-family and duplex development receive no credit for existing Floor Area for the
purposes of determining affordable housing mitigation in redevelopment scenarios that meet the
definition of Demolition – per 26.470.090.A.3. The exception to this is when a single-family or
duplex is demolished by an act of nature or through any manner not purposefully accomplished by
the owner.
C.Applicants shall verify existing conditions prior to demolition with the City Zoning Officer in
order to document any reconstruction rights. An applicant's failure to accurately document
existing conditions prior to demolition and verify reconstruction rights with the City Zoning
Officer may result in a loss of some or all of the reconstruction rights.
D.Reconstructed buildings shall comply with applicable requirements of the Land Use Code,
including but not limited to Chapter 26.312, Nonconformities, and Chapter 26.710, Zone Districts.
E.Reconstruction rights shall be limited to reconstruction on the same parcel or on an adjacent
parcel under the same ownership.
F.Residential redevelopment credits may be converted to lodge redevelopment credits by right.
The conversion rate shall be three (3) lodge units per each one (1) residential unit. This is a one-
way conversion, and lodge credits may not be converted to residential credits.
26.575.020. Calculations and Measurements
D. Measuring Floor Area. In measuring floor areas for floor area ratio and allowable floor
area, the following applies:
1. General. Floor area shall be attributed to the lot or parcel upon which it is developed. In
measuring a building for the purposes of calculating floor area ratio and allowable floor
area, there shall be included all areas within the surrounding exterior walls of the building.
When measuring from the exterior walls, the measurement shall be taken from the exterior
face of framing, exterior face of structural block, exterior face of straw bale, or similar
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Planning and Zoning Commission
Res. XX No., Series of 2021
Page 9 of 9
exterior surface of the nominal structure excluding sheathing, vapor barrier,
weatherproofing membrane, exterior-mounted insulation systems, and excluding all
exterior veneer and surface treatments such as stone, stucco, bricks, shingles, clapboards
or other similar exterior veneer treatments. (Also, see setbacks.)
Note: In measuring Floor Area for the purposes of calculating employee generation and
affordable housing mitigation for single-family and duplex development, please refer to
26.470.090.
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