PRACTICE INCLUSIVE ZONING - LU 20-0015
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ZONING PRACTICE MAY 2020 AMERICAN PLANNING ASSOCIATION ISSUE NUMBER 5 PRACTICE INCLUSIVE ZONING 5 LU 20-0015 EXHIBIT F-1/PAGE 1 OF 8
Modern Family: Zoning and the Non-Nuclear Living Arrangement By Brian J. Connolly and David A. Brewster The list of residential land uses contained resulted in increased demand for group liv- two opposite-sex married partners and their in the typical zoning code is fairly formulaic. ing arrangements. non-adult, unmarried children, pervaded Household living arrangements permitted While aimed at establishing stable the American zeitgeist. The nuclear family by a code generally include single-family neighborhoods, historical definitions of has been extensively studied, critiqued, dwellings, two-family or duplex dwellings, “family” contained in zoning codes have and debated over the past 50 years. As and multifamily dwellings. From there, the regularly excluded a wide variety of groups, David Brooks of the New York Times recently code often goes on to allow a few other and the forms of housing prescribed by commented, “[w]hen we have debates types of residential uses: live/work units, more traditional zoning codes fail to accom- about how to strengthen the family, we are assisted living facilities, nursing homes, modate many of these groups. Examples of thinking of the two-parent nuclear family, perhaps a variety of group living arrange- these include unmarried couples, same-sex with one or two kids, probably living in ments, boarding houses, shelters, and couples, religious organizations that live some detached family home on some subur- sometimes, student housing. Single-room in communities, group homes for people ban street” (Brooks). occupancy motels, short-term rentals, and with disabilities, post-incarceration halfway Increasingly, however, the nuclear fam- accessory dwelling units may also be per- houses, foster families, and others. All of ily is a foreign concept to most American mitted, in limited circumstances. For the these forms of housing are necessary in our households. In 2017, the U.S. Census Bureau household living uses, the term “dwelling” modern society. estimated that less than half of households is generally defined with respect to a living As the amorphous concepts of “fam- were headed by a married couple, and less space and, frequently, cooking, bathing, ily” and “household” evolve and become than 30 percent of households had children and sleeping facilities. increasingly difficult to define, the law of the householder at home. Nearly 30 The lines between several of the zon- still prescribes meaning to these terms in percent of households were single people ing classifications described above can be various forms. For example, the Internal living alone. Other households included blurry. In many cases, they turn upon the Revenue Service allows us to file taxes everything from grandparent-headed people who live in these various forms of individually or as a family while evolving to households—an estimated 7.2 million grand- housing, rather than the physical charac- incorporate same-sex marriages. The U.S. parents were raising their grandchildren in teristics of the housing types themselves. Census collects information on households 2017—to single-parent households, which Indeed, many zoning codes define the term and families, and these classifications have comprised 17.3 percent of all households. “family”—as used in the terms single-family broadened as well. Yet, while certain legal Of the U.S. population living in a household, or multifamily dwelling—as a group of people frameworks have adapted to the changing 6.2 percent, or nearly 20 million people, related by blood, marriage, or adoption, or face of American families and households, were unrelated to the householder by blood, up to a certain number who are unrelated. local zoning laws, in many respects, have not. marriage, or adoption. These classifications of residential land The balance of this article examines the This is a significant change from the uses, and the definitions of “dwelling” and changing face of modern American families, middle of the 20th century. According to “family” that accompany them, have proven and the increasing demand and need for the Pew Research Center, in 1960, roughly durable. But modern social and cultural housing types that recognize nontraditional 87 percent of children in the United States changes are testing their permanency. The or “non-nuclear” families and households. It lived in a two-parent household. A 2015 Pew U.S. population has moved markedly away also evaluates existing law as it pertains to study revealed that, in 2014, roughly 64 per- from the household unit comprised of a mar- regulation of household structure and offers cent of children under the age of 18 lived in ried couple and their children. Unaffordable suggestions for how zoning might be tweaked a household with two parents. In turn, just housing has pushed families to live with to respond to many of the changing norms of over one-fourth of children in the United extended family members, groups of unre- American family and household life. States live in one-parent households, lated roommates to cohabitate, and home compared to nine percent in 1960. The seekers to find smaller, more efficient forms NUCLEAR NO MORE U.S. Census Bureau’s Current Population of housing. At the same time, contempo- In the years following World War II, the con- Survey recently estimated that nearly 35 rary treatment methods for disabilities has cept of the “nuclear” family, composed of percent of children now live in “nonfamily” ZONINGPRACTICE 5.20 AMERICAN PLANNING ASSOCIATION | page 2 LU 20-0015 EXHIBIT F-1/PAGE 2 OF 8
households, which are defined as those that the Centers for Disease Control esti- “[b]y 2050, one-fifth of the total U.S. popu- households not headed by a parent. mated in 2018 that one in four Americans has lation will be elderly” with the number of These developments also comple- a disability that limits a major life activity individuals age 85 or older growing the fastest ment changing gender roles within families. (and two in five Americans over 65 fall in that (CBO). As such, the need for long-term group In the period between 1950 and 1965, category), we can assume that there is sig- assisted living arrangements will likely gradu- when the nuclear family was in its heyday, nificant unmet demand for group living. ally increase as baby boomers age. Brooks writes that “most women were rel- Tiny homes, adult dormitories, and egated to the home” and “[d]emeaning and CHANGING FAMILIES, CHANGING HOMES group living facilities are a small snapshot disempowering treatment of women was As the concept of the nuclear family fades, of the diverse and unique living arrange- rampant” (Brooks). By 1993, roughly one- so too does the traditional living style ments growing in both popularity and need third of households in the United States were associated with that construct—the single- throughout the country. Demand for nontra- headed by women (Dandekar). A 2019 Center family home. Increasingly, Americans are ditional housing types, like the evolution for American Progress study found that a opting, whether by choice or by reason of and growth of the nontraditional American national average of 41 percent of house- circumstance, for alternatives to the single- family, is ever increasing. holds in the United States are headed by family home. For starters, the average size However, embracing and promoting “breadwinning” mothers, those who earn the of new single-family home builds is decreas- new forms of housing is not merely a trendy highest income in the family (Glynn). ing. Data from the National Association pandering to millennials. Emily Badger An analysis of changing gender roles is of Home Builders reveals that the median wrote in the New York Times in a 2019 col- incomplete without discussion of the evolv- square footage of a new single-family home umn with respect to the campaign platforms ing institution of marriage. In 1949, roughly decreased for the third straight year in 2018. of various 2020 Democratic presidential 78.8 percent of American households con- This shift toward smaller single-family hous- hopefuls, “[a] reckoning with single-family tained married couples, while in 2017, less ing is likely a reaction to high demand from zoning is necessary, they say, amid mount- than half of households contained married younger buyers attempting to purchase entry- ing crises over housing affordability, racial couples. Contributing to this decline are level housing. inequality and climate change” (Badger). steadily increasing divorce rates since 1990, New and innovative ways of meeting Driven by increasing home prices and gener- the fact that couples are choosing to marry entry-level housing demand, outside the tra- ally stagnant incomes, America’s affordable later in life, and an increasing number of ditional single-family model, are continuing to housing crisis has been characterized as people who choose not to marry at all. Yet, grow. A National Association of Home Build- a “ticking time bomb” waiting to blow. A while marriage rates continue to decline, ers study conducted in 2018, for example, shortage of affordable housing options the Census Bureau reports that cohabitation revealed that more than half of Americans in cities across the country has resulted among nonmarried partners between the (and 63 percent of millennial Americans) in higher home prices, reductions in gov- ages of 25 and 34 has steadily increased, and would consider living in a tiny home of less ernment subsidies for housing, and the the number of one-person households has than 600 square feet. As Ilana E. Strauss concentration of home ownership among also increased “fivefold since 1960.” Pew also reports, companies and communities are older, whiter, and wealthier Americans. reports that older Americans are among the also experimenting with cohousing, or living More significantly, a Joint Center for highest demographic of one-person house- arrangements where “individuals or families Housing Studies (JCHS) of Harvard University holds. In the United States, 27 percent of generally have their own houses, bedrooms, report observes that the affordable housing adults ages 60 and older live alone, compared or apartments but share things like kitchens shortage has created an upturn in homeless- with 16 percent of adults in 130 countries and and community spaces” (Strauss). ness, increased threats of displacement due territories recently studied. Still, while the cohousing model may to natural disasters, and disproportionally As households continue to evolve, so be a new prospect to many Americans, burdened low-income and minority house- has the U.S. population in group quarters, states continue to rely heavily on group liv- holds. As its outlook, the study noted that, which include everything from correctional ing arrangements for the elderly, medically “[o]n the supply side, however, conditions facilities to nursing homes, student housing, dependent, and children without alternative at the lower end of the market will remain and group homes for people with disabili- housing options. According to a 2015 Pew challenging as millions of low-income house- ties. In 2017, the Census Bureau estimated report, Colorado, Rhode Island, West Virginia, holds compete for an already insufficient that more than eight million Americans live and Wyoming have the greatest percentage of number of affordable rental units” (JCHS). in group quarters arrangements. Of these, foster children living in group homes. Roughly Simply, the status quo will not suffice to 2.2 million were incarcerated, and 2.7 million 35 percent of children in Colorado’s foster provide housing for millions of Americans. were living in on-campus student housing. care system, for example, live in congregate Promoting new housing solutions to combat That leaves more than three million Ameri- group care living facilities. What is more, the rising socioeconomic and climate threats cans who lived in nursing homes or other U.S. Congressional Budget Office (CBO) noted must begin, at a local government level, with types of group living arrangements. Given in a 2013 report, a “reckoning” with single-family zoning. ZONINGPRACTICE 5.20 LU 20-0015 EXHIBIT F-1/PAGE 3 OF 8 AMERICAN PLANNING ASSOCIATION | page 3
Future Atlas, Flickr The prevalence of single-family zoning in the United States is challenged by major demographic and social changes. What’s more, as we write this article, Euclid v. Ambler units against higher-density forms of hous- the U.S. economy appears to be headed The Court was not shy in using its first oppor- ing. It was also clear from the face of the for a slowdown, triggered by the COVID-19 tunity to consider the constitutionality of ordinance that it supported nuclear fami- pandemic that has swept the world. As zoning to gratuitously weigh in on the merits lies. The ordinance used the term “family” potentially millions of Americans face job of development patterns predominated by pervasively, but defined it as follows: “[a] losses and pay decreases, the need for single-family detached dwellings. In 1922, ‘family’ is any number of individuals living affordable housing options will become the Village of Euclid, Ohio, a Cleveland and cooking together on the premises as a only greater. suburb characterized by largely low-density single housekeeping unit.” The term “single residential land-use patterns, adopted a zon- housekeeping unit” was undefined in the JUDICIAL TREATMENT OF ‘FAMILY’ ZONING ing regulation that classified lands according Euclid ordinance, suggesting that groups With these changes in American household to uses. The use districts established in the of unrelated people might be permitted to structure and demand for a variety of hous- zoning ordinance included a “U-1” district occupy single-family dwellings if they shared ing types in mind, we now turn to how the that allowed only single-family dwellings common household responsibilities. law addresses these issues. A careful read- and a “U-2” district that expanded its use The ordinance was challenged by a ing of cases from the U.S. Supreme Court allowances to two-family homes. Higher- business that was dissatisfied with its classi- and lower courts suggests that, since its intensity districts, which constituted a small fication under the ordinance. The case made early days, one of the paramount goals proportion of the village’s land area, allowed its way to the U.S. Supreme Court. In Village and outcomes of zoning has been the pro- multifamily apartments as well as commer- of Euclid v. Ambler Realty Co., 272 U.S. 365 tection and reinforcement of patterns of cial and industrial uses. (1926), the Court ruled zoning a constitu- housing for traditional, nuclear families. Euclid’s zoning ordinance was clearly tional exercise of the police power. And those goals have largely been met intended to protect low-density neighbor- In so doing, however, the Court with judicial endorsement. hoods characterized by detached dwelling emphasized the importance of protecting ZONINGPRACTICE 5.20 AMERICAN PLANNING ASSOCIATION | page 4 LU 20-0015 EXHIBIT F-1/PAGE 4 OF 8
single-family homeowners from noxious or disability discrimination—is devoid of be extended to group living arrangements. effects of higher-density residential and any suggestion of racial or cultural diversity Returning to its historical preference for nonresidential uses. The Court’s char- (the Court invalidated racially restrictive low-density, single-family development, acterization of single-family detached municipal regulation just one year after the the Court observed that “boarding houses, development patterns and family life paint a New York City zoning ordinance was adopted fraternity houses, and the like present urban picture of idyllic suburbia, characterized by in the case of Buchanan v. Warley, 245 U.S. problems. More people occupy a given public safety, healthy environs, and growing 60 (1917)), same-sex couples, accommoda- space; more cars rather continuously pass families. In particular, the Court observed tion for low-income families, or housing for by; more cars are parked; noise travels with that the segregation of single-family, two- people with disabilities. crowds.” The Court followed its indictment of family, and other land uses would “increase nontraditional living arrangements with one the safety and security of home life, greatly Village of Belle Terre v. Boraas of its most memorable paragraphs regarding tend to prevent street accidents, especially The Court’s next occasion to visit the con- land-use regulation. As in Euclid, the Court to children, by reducing the traffic and stitutionality of single-family zoning came accepted the invitation to hail the benefits of resulting confusion in residential sections, nearly 50 years later in the case of Village suburban residential development as follows: decrease noise and other conditions which of Belle Terre v. Boraas, 416 U.S. 1 (1974). produce or intensify nervous disorders, pre- That case, which arose from circumstances A quiet place where yards are wide, people serve a more favorable environment in which in another small suburban community, few, and motor vehicles restricted are to rear children, etc.” addressed the constitutionality of a more legitimate guidelines in a land-use project The Court then saved its most pointed restrictive definition of the term “family.” A addressed to family needs. . . . The police observations for the distinctions between one-square mile community with just 220 power is not confined to elimination of apartments and more low-density forms homes, the Village of Belle Terre is located filth, stench, and unhealthy places. It is of residential uses. The Court refers to the near the State University of New York at ample to lay out zones where family values, apartment house as a “mere parasite” that Stony Brook. An attractive place for prospec- youth values, and the blessings of quiet “monopolizes the rays of the sun” and whose tive landlords to rent to student tenants, the seclusion and clean air make the area a automobile traffic is “depriving children of the village adopted a zoning ordinance defined sanctuary for people. privilege of quiet and open spaces for play.” family as “one or more persons related by The Court’s rhetoric in Euclid was blood, adoption, or marriage, living and The result of Belle Terre was that emblematic of a widespread cultural accep- cooking together as a single housekeeping many local governments—in college towns, tance of the benefits of low-density living in unit, exclusive of household servants. A suburbs and even large cities—eventually the early part of the 20th century. Following number of persons but not exceeding two adopted zoning provisions defining the term a period of largely unregulated industrializa- (2) living and cooking together as a single “family” with respect to the relatedness tion in U.S. cities that resulted in unsanitary, housekeeping unit though not related of individuals residing in a housing unit, crowded conditions, New York City adopted by blood, adoption, or marriage shall be thereby ensuring that residential neighbor- the nation’s first zoning ordinance 10 years deemed to constitute a family.” hoods could only be occupied by nuclear before Euclid. Other jurisdictions quickly Thus, to reside in a single-family dwell- families. Like Euclid, Belle Terre’s endorse- followed. In the same year the Court decided ing in Belle Terre, it was not sufficient to ment of suburban forms of development and Euclid, the U.S. Department of Commerce simply constitute a single housekeeping family values appeared not to consider the promulgated the Standard State Zoning unit. Familial relatedness was obligatory. impacts of predominantly single-family resi- Enabling Act, which recited the lessening A group of unrelated tenants and their dential development patterns on non-white of congestion, reduction of fire risk, promo- landlord challenged the law. The group families, lower-income buyers and renters, tion of public health, assuring adequate asserted that it violated several rights inher- groups of unrelated people, or people with light and air, and reducing concentrations ent in the Due Process Clause of the Fifth disabilities. In the 60 years from the adop- of population as the core purposes of zon- Amendment, including rights of associa- tion of the first zoning ordinance to Belle ing. The Court’s unvarnished description of tion and privacy. Included in the Belle Terre Terre, the zoning power had morphed from a suburban idyll where children frolic free challenge was a suggestion that the law one that regulated building form to full- from the nuisances of higher-density urban was aimed at producing a homogeneous scale regulation of the people that resided areas was characteristic of common views community. The Supreme Court eventually in those building forms. of urban development. At the same time, disagreed with these assertions. however, its discussion of the merits of Although the Court had recently The Limits of Belle Terre detached dwellings—undertaken at a time expanded privacy rights in the cases of While a review of Belle Terre might lead an when the Court was composed of nine white Griswold v. Connecticut and Roe v. Wade, in observer to guess that there was little to no men and long before it invalidated racially which it famously approved of contraception constitutional limit to the regulation of liv- restrictive covenants, school segregation, and abortion, the right to privacy would not ing arrangements, the Court’s decision in ZONINGPRACTICE 5.20 LU 20-0015 EXHIBIT F-1/PAGE 5 OF 8 AMERICAN PLANNING ASSOCIATION | page 5
that case was in many ways a legal apex for Santa Barbara v. Adamson, 27 Cal. 3d 123 grants to track and implement land-use poli- exclusionary zoning. In the intervening years (1980), that familial relatedness require- cies to encourage the production of housing. since Belle Terre, it has been limited in sev- ments in a local zoning code violated These policies include everything from allow- eral respects. the state constitutional right to privacy. ing higher-density development by right to Just three years after it decided Belle Michigan and New York also followed suit, allowing manufactured housing, single-room Terre, in Moore v. City of East Cleveland, 431 adopting similar rationale to these decisions. occupancy uses, mixed-use development, U.S. 494 (1977), the Supreme Court rejected The Fair Housing Act and its amend- and limiting dimensional and procedural the use of zoning to restrict intrafamily living ments, 42 U.S.C. § 3601 et seq., also limit restrictions on new housing. arrangements. There, East Cleveland, Ohio, Belle Terre. In 1988, Congress amended the another Cleveland suburb, sought not only Fair Housing Act to specifically incorporate MODERN APPROACHES FOR to prohibit unrelated persons from residing familial status and handicap as classes pro- THE MODERN FAMILY together, but actually went so far as to define tected under the law. The addition of these Federal constitutional law continues, at its the term “family” as a nuclear family, con- two protected classes reaffirmed Congress’s core, to allow local governments to establish sisting only of a husband or wife and either commitment to prohibiting discrimination, zoning policies allowing only single-family their unmarried children or their parents. particularly against single parents with development patterns and to restrict that The practical effect of the city’s regulation, children and people with physical or cogni- form of housing to related family members. which had a legislative and procedural his- tive disabilities, including those in recovery However, the population and housing trends tory evidencing unscrupulous racial motive, from addiction. described above, and the legal limitations on was to exclude groups of extended family In particular, the Fair Housing Act’s Belle Terre, demand a thoughtful response members living together. A grandmother and protections for people with disabilities often from local zoning officials. her two grandchildren who resided together conflict with local definitions of “family” Opportunities abound for zoning successfully challenged the regulation, that restrict unrelated people from living authorities to embrace inclusionary prac- which the Supreme Court decided on right together. In City of Edmonds v. Oxford House, tices. Zoning codes that permit a wide to privacy grounds. Inc., 514 U.S. 725 (1995), the Supreme Court variety of housing types are an important Several states have also limited the confirmed that familial occupancy restric- first step. In 2019, Minneapolis became the reach of Belle Terre on constitutional or tions did not comport with the Fair Housing first major U.S. city to abolish single-family statutory grounds. The first to do so was Act’s allowance for maximum occupancy zoning, allowing triplexes to be constructed New Jersey in the case of State v. Baker, restrictions based on safety considerations. in most neighborhoods that previously 405 A.2d 368 (N.J. 1979). There, the court Several other cases have found that restric- only allowed detached housing. Other cit- determined that Plainfield Township could tive family definitions may not be used to ies have provided for additional accessory not, under the state constitution, prohibit exclude people with disabilities from living dwelling units, by-right multifamily zoning, two families from living together as a single in group settings. and a variety of “missing middle” forms housekeeping unit. The court’s holding was Similarly, as states have adopted state- of housing. These forms of housing might based upon the idea that a local govern- law versions of the Fair Housing Act, many include “slot homes,” where row houses are ment restriction aimed at creating stable of them have placed limitations on family oriented perpendicular to street frontages, residential communities was not necessar- zoning. Many state-law equivalents of the or garden courts or row houses. These types ily furthered by a prohibition on unrelated Fair Housing Act add protected classes over of housing allow for increased density in persons residing together. The New Jersey and above those identified in the federal residential areas that, if designed appro- Supreme Court wrote: “The fatal flaw in law, including, for example, marital status, priately, can blend well with surrounding attempting to maintain a stable residential sexual orientation, age, and others. These single-family development. neighborhood through the use of criteria statutes may require local governments to In considering the variety of housing based upon biological or legal relationships vary familial-relatedness limitations if they types that might be permitted in a juris- is that such classifications operate to pro- interfere with protected classes’ ability to diction, zoning officials may also need to hibit a plethora of uses which pose no threat buy or rent housing. reconsider classifications of residential to the accomplishment of the end sought Present demand for affordable housing uses. For example, where a code defines a to be achieved. . . . The ordinance distin- may be encouraging further federal action to “boarding house” as a residential structure guishes between acceptable and prohibited limit local governments’ exclusionary zoning where rooms are rented out for permanent uses on grounds which may, in many cases, actions. As of this writing, Congress is con- occupancy but generally restricts boarding have no rational relationship to the problem sidering a law called the Yes In My Backyard houses throughout the municipality, it may sought to be ameliorated.” Act, H.R. 4351, which passed in the House of prohibit new, “pod”-style multifamily devel- Shortly after the New Jersey court invali- Representatives on March 2, 2020. That law opment wherein units share common areas dated “family” definitions, the California would require local governments that receive and cooking facilities but contain separate Supreme Court also concluded in City of federal housing and urban development bedrooms and bathrooms. ZONINGPRACTICE 5.20 AMERICAN PLANNING ASSOCIATION | page 6 LU 20-0015 EXHIBIT F-1/PAGE 6 OF 8
Similarly, zoning officials might to adopt and enforce building and fire codes ABOUT THE AUTHORS also reevaluate definitions of “dwelling” con- that limit that number of persons who may tained in codes, and the dimensional limits occupy a dwelling to avoid fire or public Brian J. Connolly is a shareholder and placed on housing units, to accommodate health risks. director in the Land Use, Litigation, and Real more creative forms of housing. Where a code Similarly, zoning officials must con- Estate practice groups at Otten Johnson prohibits small housing units or properties, sider their obligations under state and Robinson Neff + Ragonetti, PC in Denver. tiny homes or other affordable forms of hous- federal fair housing laws. A local govern- He has received national recognition for his ing may be excluded from the community. ment utilizing a definition of “family” that work on First Amendment issues associated At the same time, local governments would otherwise restrict groups of people with local government regulation, including should consider whether definitions of with disabilities or others protected by fair signs and outdoor advertising, and his work “family” based on blood, marriage, or housing acts must be prepared to grant on fair housing matters in local planning and adoption serve the jurisdiction’s planning reasonable accommodations where neces- zoning, particularly in the area of housing for goals. To the extent a municipality seeks sary to maintain compliance with the law. people with disabilities. to regulate land use for the purposes In general, local governments should adopt enshrined in the Standard State Zoning zoning procedures for granting reasonable David A. Brewster is an associate in the Enabling Act—lessening congestion, reduc- accommodations if their codes restrict Litigation and Real Estate practice groups ing risks of natural disasters, protecting groups of unrelated people from living at Otten Johnson Robinson Neff + Ragonetti. for public health and safety, and oth- together. Zoning officials should also con- His litigation practice focuses on complex ers—restricting dwelling units to groups of sider avoiding unnecessary restrictions on real estate, land-use, and property rights related people is unlikely to directly accom- these living arrangements, including further disputes, and his transactional practice plish these goals. A large family of related land-use planning goals such as avoiding includes assisting clients with the individuals is just as likely to produce congestion or nuisances. acquisition and disposition of real property. congestion or overcrowding as an unrelated group of the same number of people. CONCLUSION Local governments that wish to avoid We are in an unprecedented time of hous- the problems created by restrictive “family” ing unaffordability and expanding notions Cover: iStock.com/mrPliskin definitions might consider applying a defi- of what constitutes a household or family. nition of “single housekeeping unit” that While the law has been somewhat slow to VOL. 37, NO. 5 focuses on the sharing of household chores evolve, our local governments must consider or cooking and eating together. And of how their zoning policies accommodate a The American Planning Association provides leadership in the development of vital course, local governments should continue wide variety of living arrangements. communities for all by advocating excellence in planning, promoting education and resident empowerment, and providing our members with the tools sand support necessary to ethically meet the challenges of growth and change. REFERENCES Badger, Emily. 2019. Cities Across Glynn, Sarah Jane. 2019. “Breadwinning Zoning Practice (ISSN 1548–0135) is a monthly publication of the American Planning America Question Single Family Zoning. Mothers Continue To Be the U.S. Norm.” Association. Joel Albizo, fasae, cae, Chief New York Times. June 18. Available at Center for American Progress. Available Executive Officer; Petra Hurtado, phd, Research https://nyti.ms/3b5AdQd. at: https://ampr.gs/2XzVm14. Director; Joseph DeAngelis, aicp, and David Morley, aicp, Editors. Brooks, David. 2020. The Nuclear Family JCHS. 2019. The State Of The Nation’s Subscriptions are available for $95 (U.S.) and $120 (foreign). Missing and damaged print Was a Mistake. The Atlantic. March. Housing 2019. Available at https://bit. issues: Contact APA Customer Service (312- Available at: https://bit.ly/2XxneCV. ly/2xhsmkb. 431-9100 or subscriptions@planning.org) within 90 days of the publication date. CBO. 2013. Rising Demand for Long-Term Strauss, Ilana E. 2016. “The Hot New ©2020 by the American Planning Association, which has offices at 205 N. Michigan Ave., Services and Supports for Elderly People. Millennial Housing Trend Is a Repeat Suite 1200, Chicago, IL 60601–5927, and 1030 Available at https://bit.ly/2JZqejt. of the Middle Ages.” The Atlantic. 15th St., NW, Suite 750 West, Washington, DC September 26. Available at https://bit. 20005–1503; planning.org. Dandekar, Hemalata C. 1993. Shelter, ly/3asunap. All rights reserved. No part of this publication Women and Development: First and Third may be reproduced or utilized in any form or by any means without permission in writing World Perspectives. Ann Arbor, Mich.: WG from APA. Wahr Publishing Co. Printed on recycled paper, including 50-70% recycled fiber and 10% postconsumer waste. ZONINGPRACTICE 5.20 LU 20-0015 EXHIBIT F-1/PAGE 7 OF 8 AMERICAN PLANNING ASSOCIATION | page 7
LU 20-0015 Creating Great Communities for All ZONING PRACTICE AMERICAN PLANNING ASSOCIATION 205 N. Michigan Ave. Suite 1200 Chicago, IL 60601–5927 NUCLEAR FAMILIES? EXHIBIT F-1/PAGE 8 OF 8 MAKE SPACE FOR NON- DOES YOUR ZONING CODE
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