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I RPC COMMENT Petition 4590. This is a proposed unsewered plat of 58 lots of • residential and 4 lots of commercial development located outside the • Deerfield urban service area in an agricultural preservation area. The rationale for this development is to develop another highway access between Deerfield and Highways 12 & 18. Current uses include a farm house and farm buildings on both sides of the highway. The agricultural policy requires that land should not be rezoned for non-farm residential development at an overall density of greater than one dwelling unit per 35 acres. (The proposed plat is for 62 lots on 117.5 acres, while • current policy would allow for 3 lots.) "Any land considered for rezoning shall meet the following • criteria. It should be: Land where there has not been a history of economically viable farming activities." Comment: Most of the soils on this farm are classified as prime agricultural: soils by USDA definition. There is currently corn, tobacco and other crops growing on this farm. Economic viability can be argued on many farms. "Land which is too small to be economically used for agricultural purposes..." Comment: This policy is aimed at the individual non-farm lot, but this proposal is to develop an entire 112 acre farm. "Land located such that there would be no possible conflict with the surrounding agricultural uses." Comment: This proposal is injecting a major suburban development in an agricultural area. The other possible conflict is the effect on agricultural land values for surrounding farms. The relevant commercial policy states: "Only commercial uses clearly related to or compatible with agricultural production should be permitted to rezone in designated agricultural preservation areas." Comment: The four lots of proposed C-1 does not appear to be consistent with that policy. Prior to action on the zoning, there must be consideration of an amendment to the Town Plan and County Farmland Preservation Plan. One of the tests of such amendments is the adopted Standards for Review of Town Plans where Section II, B.7. says: "The plan should note how it is related to any other local or regional plans. The adopted Regional Open Space, Transportation, Water Quality or Land Use Plans as well as other local master plans should be considered in local plan preparation. If plans differ, the reasons should be explained." The Village of Deerfield Plan has policies which affect this area, since the plat is in the extraterritorial area of the village. That plan states on page 45: "In'cooDerati6n with the Town of Deerfield, the Village should support efforts to preserve farmland, but prohibiting residential subdivision within the extraterritorial area." Clearly this proposal directly contradicts that Village policy. • • The adopted regional plan is the Regional Development Guide. The relevant agricultural policies are: 3. To direct urban development to urban service areas and not to productive farm lands, except where such lands are adjacent to an existing urban community and are or may be served by urban services. Generally, urban development should always be discouraged on good productive agricultural land, and directed to the urban service areas. Not only is this policy environmentally sound, but it reduces the pressure to take farmland permanently out of production by allowing development at higher densities. However, where productive agricultural land lies within or adjacent to an urban service area, in the path of future community growth, it is T---- / not practical nor realistic to expect the land to (,4590 PC COMMENT remain permanently in agriculture. •