Dear Louisville Planning Commission,

The Louisville residents in the historic Little Italy neighborhood, as well as local community members, are pro-development, but have the following major concerns about the Coal Creek development as it is currently described in the PUD. We urge the planning commission not to approve the Preliminary Plat until the planning department and developer have met with Little Italy residents and considered a few major revisions to preserve existing neighborhood character. Three major items that need amendment before approval of the Preliminary Plat are summarized here and described in detail below:

1. Remove motorway connections to Front St. and the Little Italy alley behind Harper St. These roads are not designed for increased traffic and parking, especially since Louisville Middle School students are expected to walk to school (no bus) within these blocks. These connections should be revised to multi-use pathways with emergency vehicle access only. 
2. Reduce the number of townhomes on A Road and B Drive by 4 in order to maintain the existing alley, along with existing Little Italy property access, including unplatted lands. As designed the development could trigger Adverse Possession and delay the development. Moreover, this would safely ensure surface drainage of flood waters to Outlot D, which are currently routed through the existing alley.
3. Increase green space, tree coverage and definitively ensure sufficient drainage within and surrounding Coal Creek village with designs up to a 100-yr flood level. 

First, and most importantly, Little Italy is strongly opposed to a connected motorway along Front St. between the Coal Creek development and Little Italy neighborhood. We propose that the road be designed only for emergency vehicle access but restricted to bikes and pedestrians at all other times, either through the use of pylons or a gate. Without this important safety measure, motorists will cut through the Little Italy neighborhood, reducing safety and increasing traffic substantially in a small, historic area that was not designed to accommodate throughway traffic. As currently planned, the Coal Creek development has three entrance and exit locations onto South Boulder Road and Highway 42. There is no need for additional auto traffic through the Little Italy neighborhood. With 188 dwellings planned this would completely alter the character and safety of the historic neighborhood, and impact school drop-off at Louisville Middle School. A previous development on Weldona Way in Louisville created an unsafe accessway and the City had to retroactively close this connection. Little Italy asks that this connection be removed in an amendment before approval is granted, not retroactively once it has become a problem as in the Weldona Way development.

Second, the development provides a connection to the existing alley, which triggers all the concerns described above connecting the development to Front St. Little Italy asks that there be no connection to the existing alley, which is used by many residents to access their properties, particularly alley-facing garages. The plan appears to cut into (or completely cut off) access to the existing alley (which is 20' wide) at the west end near C Avenue. Narrowing the alley is also not an appropriate or necessary development choice and will adversely impact current Louisville residents in Little Italy. If the developer removes only 4 units of the planned 188 on A Road and B Avenue they can proceed with the development without triggering Adverse Possession by impacting existing Little Italy access to their properties along the alley, which has been maintained in its current configuration since at least 1952.

Third, the plan does not appear to provide enough green infrastructure, and the storm line management is lacking. This is especially important given that the current lot has a small wetland region in the northeast that serves as critical habitat and a migration pathway for birds of prey, and that the entire lot is a major drainage point for the city. As designed, the amount of impermeable surface will increase flood risks to the historic Little Italy neighborhood and nearby major streets of South Boulder Road and especially Highway 42. The developer needs to design the plans to include best management practices for green storm-water infrastructure, including space for stormwater capture to prevent flooding (outlot D is not sufficient given the drainage directions noted on page 17/32 on the PUD). On the current PUD, the existing dirt alley is set up to channel water into outlot D, with drainage directions showing water is directed towards Little Italy and its alleyway along the entire adjoining region. A dirt alley will not be able to route the amount of water without major damage that the City will be responsible for regularly managing, especially as flood risks increase in a changing climate. Little Italy residents would bear the brunt of this poor design.

Besides water and flood management risks, the elevation drawings have no trees on the alley-loaded dwellings, negatively impacting the current residents. Alley loaded units need to be given the same attention as other units by providing trees between the Little Italy neighborhood and new development. The section of the Coal Creek development facing the historic Little Italy neighborhood lists no trees (Block 2 and Block 3), or only 1 tree/300sf (Block 1) as compared to 1 tree per 20 linear foot on Blocks facing South Boulder Road, Highway 42, and- internal to the development- Cannon Circle. While there are trees on the drawing, the requirements listed in the boxes do not include trees. Little Italy would like a commitment from the developer to plant relatively mature trees as is drawn on the landscaping plan, but not listed in the Block requirements on that same page. These greenway adjustments will help to address other resident concerns about a potential heat island and/or the right of quiet enjoyment within the Little Italy neighborhood.

In addition to these three major concerns, the Little Italy neighborhood will be permanently altered by this development. The developer should provide improvement to the existing alleyway, burying of utility lines to connect with the development’s proposed updated service, improvement to sewer lines in Little Italy (only 10" diameter on Harper Street and with increase of flood waters from development this will become untenable), and general improvements to the neighborhood, including access to improved utility services coming to the Coal Creek development. Lastly, has there been an analysis of the potential impact of underground mines on construction/development safety?

The City of Louisville, its government and people, are making a lot of changes to accommodate this development including Rezoning and Special Review Use. The above requests are not much to ask, are even supportive of the development, yet bring community care to an otherwise dangerous and unsafe situation for Little Italy, DELO residents and Louisville Middle school families and staff. 

Section 17.08.374 of the Louisville municipal code states: "“The planned unit development includes usable, functional open space for the mutual benefit of the entire tract; and is designated to provide variety and diversity through the variance of normal zoning and subdivision standards so that maximum long range benefits can be gained, and the unique features of the development or site preserved and enhanced while still being in harmony with the surrounding neighborhood.” In order to meet this requirement, the developer and planning department must work with Little Italy residents to address their major concerns. If the preliminary plat is approved the city planner has advised that changes involving Front St. and/or the alley used by residents (our highest and foremost concern) will be almost impossible to amend. The charge for a Special Review Use Analysis states: "External and negative impacts on adjacent properties are controlled for and reduced." Existing Louisville residents have not had a voice until now, and more time is needed for their voices to be heard.

Please do not approve this preliminary plat until the planning department and developer negotiate solutions to existing resident concerns. Thank you, and we look forward to finding common ground from one historic residential area to a new (if approved) residential area.

Sincerely,

Residents of Little Italy and Supportive Community Members