Apr 11, 2008

GRTA Approves New DRI Procedures and Principles and Technical Guidelines

On April 9, 2008, the Board of the Georgia Regional Transportation Authority (GRTA) approved new Developments of Regional Impact (DRI) procedures and principles and technical guidelines. The effective date of the revised policies, procedures and technical guidelines is May 9, 2008.

GRTA regulates DRIs in the following 13 counties: Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding and Rockdale. DRIs are large scale land developments likely to have effects outside the local government jurisdiction in which they are located. Regional Development Centers (RDC) regulate DRIs in other jurisdictions and may have different rules.

The intent of the policy revisions is to clarify the goals of the program, to introduce a more predictable review outcome for DRI projects, and to establish an orderly and efficient process for DRI reviews. The expanded purpose of the DRI policy revisions is to ensure that proposed DRIs will contribute not only to improved regional mobility and air quality, but now also to land use practices.

The revised policies, procedures and technical guidelines include many changes to the DRI review process. Some of the key revisions are listed below:

Review Criteria: GRTA has established new review criteria by which DRI submittals are to be evaluated: general criteria applicable to all proposed DRIs; criteria for expedited reviews; and criteria for non-expedited reviews. The DRI submittal must include detailed statements of how the proposed DRI is meeting the purpose and intent of all applicable criteria. These criteria are spelled out in Article 3 of the new GRTA procedures and principles. The general criteria applicable to all DRIs concern accessibility, connectivity, access management, the promotion of regional policies and plans, and local standards which support regional policies. The criteria for expedited review are applicable in 5 situations: limited trip generation, mixed uses, urban with 3 mile area of influence, alternative modes of transportation, and livable centers initiatives. The revisions open the door for more DRI projects to go through an expedited review. The criteria for non-expedited reviews relate to traditional notions of promoting improved regional mobility, air quality and land use practices, as well as a focus on vehicle miles of travel, transportation and traffic analysis, and relationship to existing development and infrastructure.

User Guide, Site Plan Guidelines, and Checklist: GRTA has also developed a DRI User Guide which better defines each criterion and provides detailed information concerning what GRTA is seeking from DRI plans of development. Likewise, GRTA has developed an appendix to its technical guidelines which sets forth DRI site plan guidelines. This appendix lists the specific information that an applicant must include on the site plan submittal as part of a DRI review package. Additionally, GRTA has developed a lengthy checklist which must be completed and provided with all DRI review package submittals. The checklist incorporates a land use and planning focus not previously addressed in the DRI review process. This document is a combined joint checklist between GRTA and the Atlanta Regional Commission (ARC). GRTA will use the checklist as a guide to the DRI review and to identify potential conditions, while ARC will use the checklist to score proposed projects. The Georgia Department of Community Affairs is currently undergoing a review of its own DRI rules, and is expected to adopt revisions in January 2009 which would give ARC more discretion and flexibility in reviewing DRI projects.

Transportation Studies: The revised DRI policies and procedures provide that all traffic analyses be prepared at a level of service (LOS) D, which is established as the common standard throughout the region, unless required otherwise. Additionally, the revisions allow an applicant to submit more than one recommendation for improvement on a roadway segment or intersection, but the applicant is required to indicate the recommendation that brings the segment or intersection up to the required LOS standard. The applicant must also identify the preferred alternative. Area of impact studies are eliminated unless the applicant is seeking an area of impact expedited review. There are various other transportation study changes in the newly adopted technical guidelines which the applicant should review.

Timelines: There are various timeline changes throughout the DRI review process under the newly approved policies and procedures. Some of the timelines are shortened, while others are lengthened. In sum, the overall time frame to complete the review of a DRI project remains about the same, although the revised policies and procedures do offer additional opportunities for expedited reviews. The applicant should carefully review the revised time periods so that important deadlines are not missed.

Revisions to Notice of Decision: The newly adopted DRI policies and procedures include a new section dealing with revisions to issued Notices of Decision (NOD). This section creates a clear and formal process for revising NODs. Significantly, the request for revision must come from the permitting local government. This new section identifies the following 7 minimum request submittal requirements: revision request letter identifying the challenged condition; new site plan identifying change and revised traffic analysis; purpose of revision request, such as hardship; any mitigation proposed; suggested wording for replacement condition; information pertaining to policies, rules or guidelines of the local government; and copy of the original NOD and any subsequent revisions.

Summary: Under the old DRI review process, the emphasis was primarily with the transportation analysis. Under the new DRI review process, there is now an increased land use and planning emphasis. It is anticipated that the developer’s team of consultants — traffic engineers, land planners, zoning and land use attorneys, etc. — will need to coordinate much earlier in the process.

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