Letter: Community Council Opposition to Proposed Density Legislation

Please read the letter below.  It will be sent to all the Councilmembers and the Planning Commission

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Community Council Opposition to Proposed Density Legislation

Dear Councilmembers, and members of the Planning Commission,

We are writing on behalf of Invest in Neighborhood’s Neighborhood Councils Action Coalition, and as individuals who have researched, discussed, and engaged with this issue for many months.

The goal of the proposed legislation is to increase density which will increase affordable housing.  This is a laudable goal and we do not oppose the idea of creating affordable housing. 

However, we do not agree that this blanket approach to modifying the density restrictions within specific zoning codes is the correct approach. A blanket approach through a code change across the board would result in unintended consequences that would negatively impact the diversity of our neighborhoods. 

First, and significantly, this would remove the ability of neighborhoods to have their voices heard and to have any influence on the development in their neighborhood.  Second, and related, the proposed change does not recognize the distinctly different neighborhoods with different needs and different concerns in their communities.   Both of these problems would consequently limit the ability of communities to manage growth while maintaining what is unique to their neighborhood. 

In order to emphasize that this is not merely “NIMBYISM”, we have gathered concerns from different neighborhoods which demonstrate that specific needs and problems cannot be solved with a universal approach.  We have appended (lightly edited) representative examples from different communities across the City that provide very specific and valid concerns.

In addition to reviewing these, we also encourage the Planning Commission and City Council to listen to the recordings of the public meetings, reach out to the communities and hear their arguments before voting on this critical issue.

Again, we are NOT opposed to affordable housing and looking at ways to increase density in ways which can improve affordability, but we are opposed to a blanket approach. 

Finally, we feel that a legislative approach that works toward meeting these objectives can be crafted in collaboration with us which would lead to a stronger city and have long lasting positive effects on those who live here and will choose to live here.


Thank you for your consideration, 


{signatories here}


Specific Neighborhood Concerns addressing the impact of blanket change to code: 

Neighborhood: OTR
     “The various zoning variances requested by developers here are some of our only opportunities to register our objections to outsized and architecturally insensitive development proposals. As we understand the proposals they are nothing more than carte blanche concessions to developers who too often ignore the preferences and character of neighborhoods.

     Zoning variances give us a chance to demand affordable housing units in exchange for infrastructure and tax abatement subsidies. The current lame duck administration has made repeated concessions to corporate development interests that have left the City budget impoverished and have displaced 43% of the black population of OTR in the last 10 years. Further concessions such as the proposed density changes are egregious.”

Neighborhood: Paddock Hills
     I think the only concern for our neighborhood is that we do have a significant amount of multi-family housing that could be replaced with larger, taller buildings with less parking

West End
     Universally removing density limitations from residential multifamily districts will disproportionally harm people and communities of color. Removing density limitations in the West End, and other communities that are racially concentrated areas of poverty, will have the effect of exacerbating concentrated poverty and perpetuate segregation. The proposed zone changes specifically target the city’s most dense areas, including entire communities which are primarily poor and black. Removing density limitations in these historically disinvested areas will continue to steer low-income (aka affordable housing) developers to the very areas that are struggling with the residual effects of past (then legal) discriminatory housing patterns that related black people to poor black communities.

     As an aside, with this knowledge it should not come as a surprise to understand why these areas contain most of the regions affordable housing units. The city is fully aware that 94% of residents in low-income, aka affordable housing, are African American. When that housing, now being hyper-incentivized to only be built in poor, predominately black areas/communities, is sited in those communities, this has the effect of dictating where poor, predominately black people will live. It is shameful. No child’s zip code should determine her future.

Neighborhood: Evanston
     There is and has been locally and nationwide the concern of inequities in Neighborhoods populated with people of color and or limited income. To be honest, it seems no money no voice.  Unfortunately, we don’t seem to have enough leadership representation willing to discuss and work together to consider that concern. Limited concern about maintaining the historic layout and structures of communities already there when there is money to be made. There is a realization that each community has it’s needs.
    Funds seem to be and are limited to maintain existing structure and no concerned in working to revitalize what exists, which has a better quality of material. New means more money and tax abatements. There needs to be more discussion on this and other ongoing issues that really affect the total welfare of every community. We are really one big community, just different boundaries

Neighborhood: Hartwell

     Hartwell is a small neighborhood. Our neighborhood is already directly impacted by apartment housing, specifically the boarding houses. 

     Our area would not be able to handle higher density housing in a mostly residential area. Not only would it be completely out of place, we do not have the police presence to handle an influx of residents

Neighborhood: Kennedy Heights
     Kennedy Heights is experiencing a mind-blowing surge in housing prices. We are seeing homes being bought up, demolished, and new constructions going for three times the price of the home that had been there previously. A recent addition to the market is priced at a point that I can only assume is based on a buyer wanting its noticeable acreage, with the end goal of adding more housing. All this is occurring within the restraints of current zoning allowances. We are also facing a drastic shortage of affordable senior housing, and a growing senior population that is struggling to keep up with rising property taxes and physical maintenance of their properties.

     Kennedy Heights is in the middle of our neighborhood plan right now, and the overwhelming response we are hearing is that our priorities as a neighborhood is to preserve our diversity—this includes socioeconomic level and age. A universal removal of density requirements, while pitched to the public as increasing inventory and therefore affordability, does not offer the desired protections against profit-motivated developers who would continue to fill our neighborhood with luxury homes and luxury apartment complexes, thus continuing to change Kennedy Heights into a more homogeneous population.

Neighborhood: Oakley
     This impacts a significant portion of Oakley properties, and the impacted properties are in areas that contain most of our most affordable housing.

  • By including all RM zoned districts, this would allow developers to buy an existing 1/2/3 family unit/property, demo it, build up to 10/12 units *with off street parking* without needing any OCC approvals.
  • They also tout “affordable housing”, but this would have the opposite impact, as there is no way a developer is going to take on the expense to buy/demo/build/ and then offer the units at a price lower than current rent/mortgage is.
  • Additionally, by adding units in the same footprint, you will run off families as the new units would simply be too small.
  • Net impact – most of the more affordable housing, as documented in the recent Oakley Housing Inventory study, would likely be replaced by more expensive housing units.
  • The ordinance was done *without any community input*, which is concerning.  Thankfully, Liz is willing to have the town hall – mainly because the feedback has been overwhelmingly negative.
  • I have no real issue with the changes to the other zoning districts, just the RM.
  • My recommendation is to remove RM from the ordinance/proposal, and allow that to continue to be an item that each neighborhood has the ability to have input on, on an individual development basis.
  • I’ve been very clear, when I’ve voiced my opinion, that I’m speaking as an individual resident, and not on behalf of the OCC – because we’ve not discussed this as a group, nor have we voted to make a statement on the issue.
  • I’ll also add that, one reason the city put forth for doing this is really to make their job a little easier – they commented that most of the zoning requests that get submitted for land/size variances get approved, so why not just do away with the need to have a hearing.  Sorry, IMHO that is a weak rationale for taking control (what limited control/influence we do have) away from the neighborhoods.

Neighborhood: Linwood

     Future development based on increased density could, and most likely would, result in high priced rental units, for one or two occupants, not conducive to affordable housing for families which is what our City is lacking.  Our neighborhood, Linwood, already has a rental percentage of 45%+ even while having 700K+ new single family housing built in the last ten years driven by development (developers’) pressure.  Linwood has some zoning for manufacturing making its housing less concentrated around a neighborhood center where some density might be acceptable and desirable.  Any residential building with many units, accommodating only one or two occupants, built in a non-walkable environment can only increase unwanted traffic in a City where mass transit is not practically available.  There appears to be no actual universal planning by the City to create suitable profiles for each neighborhood; ours could use affordable SF housing, possibly attached, as a nod to density. 

Neighborhood: Clifton
     For Clifton: loss of historic homes and other historic structures that would be replaced with new builds that are made of cheap materials, out of scale for the neighborhood and inconsistent with the “Clifton aesthetic” that is part of its charm.

Neighborhood: Pendleton
1. The downtown core is already quite dense so it’s not clear what the impact of this specific overlay would be here. But it can have dramatic impacts on other neighborhoods. We should be supportive of our neighbors as our 52 neighborhoods make us “Cincinnati”.

  1. The concern from the downtown perspective, in my opinion, is two-fold based on things that have been largely unsaid. This zoning issue is, I believe, one part if a bigger effort that can be much more troubling.

     2.A For example, I understand that there will also be efforts to reduce parking minimums with more dense developments. Downtown already has parking challenges which, if made worse, will (i) cause fewer people to want to come downtown for business or pleasure and (I) will cause existing parking to increase (possibly by a lot!) their fees which will not only deter people from coming but merely line the pockets of those controlling the parking lots. And other neighborhoods may have similar or even more compelling problems. By way of example, OTR has been quite vocal about the struggle from lack of available parking even for their existing residents. Density should not be looked at without understanding “what’s next”.

     2.B. There may also be a background effort to ease setback requirements in the downtown core that will mean narrower and even more dangerous sidewalks for pedestrians (who already have to share with scooters and bikes). Other neighborhoods likely share these same concerns. Again, what’s the bigger picture?


Neighborhood: CUF

     Since September 5, 2002, I have been a Residential Home Owner living in the CUF (Clifton Heights-University Heights-Fairview) Neighborhood which is already the “most densely populated” neighborhood in the City of Cincinnati, primarily due to the large amount of older housing stock located in Clifton Heights, which is normally rented by UC Students and sometimes other Temporary Renters. The large amount of Transient and Temporary Residents co-existing among the Long-Term Home and Business Owners in the area poses a unique and often “very challenging” set of issues with vandalism, trash, littering, poorly maintained yards/exterior housing facades (one can only guess about the interiors), large unsupervised noisy parties, drug dealing in our local Parks and Streets, lack of enforced parking rules, too many cars without enough parking spaces, inability of the City to operate a Proper/Tax Payer Funded Street Sweeping Program, and young College Students walking around with targets on their backs as potential/actual robbery and assault victims. While some of these issues listed are mostly applicable to CUF and other nearby UC Campus neighborhoods, many more of the other issues listed will begin to “exponentially and negatively” impact other City Neighborhoods if “common sense” Zoning and Density Requirements are removed. The City of Cincinnati currently can’t (or won’t) stay on top of most of these Quality-of-Life and Infrastructure/Population Support Issues on a “consistent” basis as it is, let alone allowing Get-Rich-Quick Developers to build new Cheap, Shoddy, and possibly Toxic Multi-Housing Structures all over the City that probably won’t last a couple of decades (if that) without needing to be bulldozed and replaced.

     I also “highly concur with” every comment that I read pertaining to the Importance of Preservation of our Historic Buildings and the need to “prioritize” Community and Economic Incentives to properly rehab our existing building stock, much of which has sadly been allowed to deteriorate and rot over time by Irresponsible and Immoral Greedy Slumlords. Some of these properties exist where I live in the lower Fairview portion of CUF, around W. McMicken Avenue. Fortunately, we also have some of the opposite, beautiful historic older buildings (Single and Multi Family) that have been well maintained and cared for for over a Century by their Owners. Adding more density of people and buildings to a City that currently lacks in Adequately Safe Modern Street Lighting in ALL Neighborhoods, and is still scrambling to comply with Federally Mandated Sewer Pipe and Drainage Systems, and has an Inadequately Staffed Police/Safety Department needed to properly protect ALL of our Neighborhoods is Totally Asinine, Fiscally Irresponsible, and Structurally Unsustainable!!!

Neighborhood: Camp Washington
     Parking, traffic congestion, loss of neighborhood character

Neighborhood: Northside
     Very few negative issues beyond constraining the on-street parking supply.  My neighborhood (Northside) already has a strong mix of 1, 2, 3, and 4 family homes which has kept the area diverse and with multiple kinds of housing options for people.  Interestingly as the neighborhood became less dense over the years and more buildings were converted to single-family homes, the on-street parking issue became much worse.  This may be because people who live in single-family homes tend to have multiple personal vehicles, whereas people who live in denser housing tend to have fewer or no personal vehicles.  Very few Northside homes have driveways so on-street parking is key. As the neighborhood has become more attractive to higher earners and more single-family homes were built (as the current zoning only allows that) the on-street parking problem has actually gotten worse.  Northside now has fewer housing units than a decade ago, but far more cars.

Neighborhood: Hyde Park
     City Homes, on Wasson Road (across from Hyde Park Kroger) – the project is too dense for the site; there are multiple serious environmental and traffic concerns related to the development; it is not an optimal use for this property, which is adjacent to the Wasson Way Trail; the development will not be a good architectural fit in the community; there has been no progress on the  development since Ken French was granted City approval for the project, and the land is vacant, overgrown, and an eyesore to the neighboring properties. More than 2,000 Hyde Park residents signed a petition opposing the variances and other zoning relief that was granted for this project, and had City Council support to prevent the development, but the Mayor remanded the project to Planning Commission and they were able to approve the lot splits and variances without City Council approval.

A new development, by PLK, on property zoned CCA on Wasson Rd. between Michigan and Shaw does not require a zone change or any zoning relief.  The developer intentionally did not engage with the community in any way, nor did the City send notice about the development.  What is being proposed fits into the requirements for CCA – though they are being very fudgy about the commercial use requirement (that will be only 219 sq ft of office space that the developer will use as a leasing office for the property.) The proposed use (1 and 2 BR apartments) is too dense for the space and the adjacent neighborhood;  the 100+ new residents (and cars) it will bring in will present serious traffic and pedestrian safety issues. The height of the building (72 ft) and proximity to neighboring residences, and the balconies that will look down into those properties, will diminish property values as well as the neighbors’ enjoyment of their homes. Also, the architecture is completely out of character with the neighboring homes, and screening for the 2-story above-ground garage on which the apartments will be built appears to be marginal and ineffective.  This project is, on every level, a case study for bad community development.

Neighborhood: Pendleton
     Creation of new buildings that have too many people for the existing resources of the area (ex: too little parking, green space, room for trash cans), resulting in a worse quality of life for all existing residents/neighbors and thus changing the entire living context of the small neighborhood. Example: proposed Bennett Point project by CMHA.

     Historical district architectural characteristics (height etc) must be preserved. Affordable housing Act requires keeping dignity to all. Allowing many people to live within small confined apartments (after allowed with high density affordable housing) in old or new buildings without entertainment areas, hot rooms and noise environment with high density living, is illegal based on the federal law act above.

Neighborhood: Mt. Lookout
     We have RM areas nestled in the midst of SF zoning. Increasing density will directly affect those in SF areas – more traffic, more noise, more strain on infrastructure and local services. Our sewers are already over capacity. Adding more is not as feasible in neighborhoods as opposed to more commercial areas. Also, developers are already buying contiguous properties and then combining to build bigger multi-family developments. Eliminating density restrictions will encourage this practice and existing property owners will bear the brunt (it’s already happening now) as open space and views of trees and sky are replaced with walls of new buildings and parking lots. This irrevocably changes the character of the neighborhood and has a gross negative impact on the families that have already invested financially and emotionally here.

Neighborhood: College Hill

     Neighborhoods join the City in recognizing the need for more people and higher density to grow our City. We would rather see the City work with us to develop a comprehensive plan for making that happen than to expect great things from a piecemeal ordinance. Developers should not be the drivers for density. Bring a plan to us. Don’t just deal with each developer as it comes to the City seeking subsidies and tax breaks.


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