MORE PROPOSED GROWTH IS COMING TO THE LULA AREA
WHICH WILL HAVE A LONG TERM EFFECTS ON OUR COMMUNITY
IT’S YOUR CITY. GET INVOLVED .
Growth is coming to our city and north Hall. The community needs to be diligent in understanding the opportunities these issues of growth bring to our area, positively and negatively. There is a new proposed project coming to North Hall County and specifically the Lula area, which will have a significant impact on the community. The application is coming from CBD Investments, LLC to rezone a 303 +/- tract of land located Cornelia Hwy (SR365), Lula Rd (SR52), and Athens Street from Agricultural/ Residential to Planned Commercial Development /Planned Industrial, which is just outside the City of Lula’s jurisdiction.
With this potential for Industrial development, this proposal will significantly impact the traffic for our city, Hall County and Banks County. Couple this with the Inland Port Development being constructed on HWY 365 will bring significant auto and truck traffic to the area. The impact of this additional industrial traffic is likely to cause extreme difficulties for the residents of Lula. The city strongly recommends that the community become familiar with the proposed development and let your views be heard at Hall County as they consider approval or denial.
Hall County’s Planning Commission Met 5:15 on Monday, Oct 3rd, 2022, after hearing the significant objections raised by the City of Lula and constituents of Lula made a recommendation to the Board of Commissioners for approval with conditions. Hall County staff recommendations were not available at the meeting of the Hall County Planning Commission.
The Board of Commissioners will hold a public hearing for the final determination of the request at the meeting scheduled for 6:00 p.m. on Thursday, October 27, 2022, at the same location. Moved to Nov 9th 6 PM
The following link below will be available on the day of the meeting.
https://www.hallcounty.org/1097/Online-Meetings.
Please read the city’s detailed report below
City of Lula
August 2022
DRI Comments for
Project Narrative for Inland 365 Business Park
The comments submitted by the City of Lula are an effort to address specific issues related to this proposal with the hope and intent that if this proposed development were to go forward that the public’s interest is assured to the best of the ability of data and supporting information. Whereas the City of Lula, North Hall, Banks and Habersham County obviously have the opportunity to benefit regarding economic development with expansion of proposed projects such as this, the public interest is first and foremost and how the communities are impacted positively and negatively must be accurately stated. Lula’s comments are an attempt to address areas of omission, and or lack of clarity in our review, our hope is that these areas can be addressed in a timely manner collectively with all affected governments playing a responsible role in the final outcome with this development and future economic developments. The city comments found throughout the documents can be found in BOLD type below.
LOCATION -Old Cornelia Hwy (SR 365), Lula Rd (SR 52) & Athens St., Lula, GA 30554
ACREAGE-302.39 acres+/-
APPLICANT- CBD Investments, LLC
Summary
The accompanying application seeks zoning district change from AR-IV to PID for 302.39 acres+/- of undeveloped property located on Old Cornelia Highway (SR 365), Lula Road (SR 52) and Athens Street in east Hall County. The intent is to develop a mixed use business park that will serve industrial, light commercial, highway business and office-institutional uses. This narrative will propose a unified set of standards for the project. Where can these “Unified set of Standards be found/ listed in this document? It appears the specifics are vague and can be altered by the developer and or the end user- (see Conceptual Master Plan That states, “ Modifications to the locations and arrangement of buildings, roads, and other improvements that do not conflict with specific standards and requirements of these conditions may be made by the Developer or End User.”
This Proposal conflicts with current and future land use plans as adopted by the City of Lula with regards to supporting transportation needs infrastructure and surrounding existing and future land use.
Site Description
The site has approximately 3200 LF of frontage along Old Cornelia Highway (SR 365), 3400 LF along Lula Road (SR 52), and 3900 LF along Athens Street. A portion of the site along SR 365 and SR 52 is located within the Gateway Corridor Overlay District The site is comprised of multiple tax parcels and is rectangular in shape. The southeastern boundary of the site is coincidental with the City of Lula city limits. A Norfolk Southern rail line runs along a portion of the southern boundary. Several unnamed tributaries of Hagen Creek have been identified within the site. A 125′ Georgia Power Company easement runs northwest to southeast through the western portion of the site. The site is contains both cleared areas and a random stands of trees with rolling topography. Domestic water is provided by the City of Gainesville and is located in the Lula Road right-of-way. The site will be served by public sewer by Hall County. Please note this entire track proposed for development can be and should be served by an existing sewer line that serves the entire property by gravity, logically this remains the best alternative from both a capital standpoint and an operational standpoint. If the county is to provide sewer service to this development, they ( Hall County) or the developer, the end user, will have a great expense to create sewer pump stations to the property, which will drive capital invest into the millions of dollars and create an annual operational cost in maintaining pump station. Currently, if this property were to be served by Hall County, sewer waste would have to be transported through 7 additional pump stations 14 miles to a treatment facility versus a 1-mile treatment facility operated by the City of Lula. This issue should raise significant environmental concerns for the project as well as unincorporated Hall County. Also, please note NO mention of the previous sewer detention pond, which exists in the form today, is addressed in this document with regards to proposed surrounding property uses. This site has the potential to create a burden due to close proximity to the proposed uses and the cost of cleanup and removal, and should not fall on the city to resolve and should be addressed in advance of any rezoning. The proposed development’s sewage pump stations would be located in the Lake Lanier drainage basin. Any failures of these multiple pump stations would represent potential undesirable environmental consequences to an environmentally sensitive lake that serves as a drinking water supply to many people. (“The U.S. Army Corps of Engineers changed its rules in 2017 to let the lake be used for drinking water. The … water storage contract allows Gwinnett and Forsyth counties along with Buford, Gainesville, and Cumming to pull drinking water from Lake Lanier as long as the lake exists.”)
Pump failures have been studied, accounting for the nature of the failures, the operation and maintenance procedures of the management authority, the aging of the pumps, and the changes in the environment of pumps. The analysis shows that sewage pumps fail relatively often (emphasis added) due to the composition of sewage and the discontinuous operation of the pumps. The interarrival time and the duration of failures are highly variable and independent of the specific function of the pump. The resulting pump failure characteristics have been applied in a Monte Carlo simulation to calculate the impact of failures on combined sewer overflow volumes. The results indicate that the serviceability of sewer systems is significantly affected by failing pumps.
Statistical Modeling of the Serviceability of Sewage Pumps Hans Korving ; François H. L. R. Clemens; and Jan M. van Noortwijk |
The driveway to the building on Lot 9 crosses the driveway that currently provides access to the pond from Toombs Street (?). Will continued access to be provided through the proposed driveway on Lot 9?
Storm Water Detention was not addressed as to who will be required to maintain these 13 stormwater detention ponds to this very sensitive environmental area by the proposed development and again should be addressed prior to any rezoning of the property.
All other dry utilities are located within a reasonable distance for service extensions. There are no known impediments to its successful development for the purposes intended.
Adjacencies
The property is surrounded by residential zonings AR – IV, & PCD in Hall County and a variety of mostly residential zoning in the City of Lula. The obligation to recognize existing and future surrounding property use with regard to residential uses has not been addressed in specifics, as is the function of this DRI. Hall County was aware of a very recent DRI for the adjoining Moss Property on 202 acres and chose not to comment, nor does this proposed DRI address the impact this proposed rezoning will have on the Moss Development, environmentally or adjoining property use, or the significant transportation impact as these proposed development coexist. (SEE Proximity to Other Uses) Potential proposed setbacks and the opportunity to have a building height of 75 feet is considerable and can have a adverse impact on existing and future land uses and should be addressed.
Access
Access to the property is planned from Old Cornelia Highway (US 365) and Lula Road (SR 52), subject to GDOT approval, and from Athens Street, subject to Hall County and City of Lula approval. The failure of this transportation study to address the Moss Development and the Inland Port Development on 365 in the completed traffic study is a mockery of the information a DRI is supposed to address; the idea that the attached transportation study should even be considered without these factors is comical and should be represented with this pertinent information. For reference see the next comment regarding potentially closing through access on Burton /Mcleod Street to residential traffic when this is the only NON-truck route available to residential traffic, forcing residential traffic to commingle with truck traffic routes at the cost of residents. Additionally, a portion of Mcleod Street/Burton Drive may be abandoned in the future with cul-de-sacs places at both ends, subject to Hall County and City of Lula Approval.
Please note that Athens Street is currently closed to truck traffic by the City of Lula, Hall County Government and Georgia DOT. This would create significant changes to Athens St as at least 6 proposed locations could additional locations on Lots 9 – 12 could provide significant additional truck traffic along Athens Street moving both SE to I-85 and NW to SR365.
Providing additional road width for longer turn lanes to SR365 North and SR365 South and a wider turn radius from SR365 North to Athens Street southeast will be difficult and costly due to the topography in the area and the severe drop-off from the road surface to drainage ditches upgraded by Hall County only last year. Additional length of turn lanes will be required to provide a sufficient stack of truck traffic and residential traffic from the proposed subdivision Moss as well as current traffic following Athens Street and SR51 to and from Banks County
Proximity to Other Uses
Nearest distance to undeveloped commercial property – parcel 09080 000003 zoned PCD, at the northwest corner of the site. Existing and potential development of over 600 homes in the surrounding properties.
- Nearest distance to developed commercial property – parcel 09081 000002 zoned PCD, at the northwest corner of the site
- Nearest distance to a single family home – a single family home at 5942 Savannah Lane is located within 70′ of the southeast boundary.
- Nearest distance to a subdivision – The Belton Manor S/D is located approximately 1200 LF east of the property. See inner city development and proposed Moss Development for true impact
Comprehensive Plan Consistency
The project is consistent with the “Activity Center” of the Future Land Use Map, and the primary future land uses notes as this statement as adopted remains very vague as to future uses and should address an extended list of desirable and prohibited uses prior to rezoning.
- Cleveland Hwy/Brockton Lula – commercial uses serving local residents and proving employment opportunities; civic buildings/spaces
- Employment Activity Centers: Master planned business park or industrial park, mid-rise office
- Mixed Use Centers: Retail, office, higher density residential (including multi-family}, civic uses, open/park space
The project is consistent with the Goals, Policies and Objectives of the Comprehensive Plan and is not known or believed to be in conflict with any of the above. See future Lula Land Use Plan and Map.
Hall County Gateway Corridor Overlay District
A portion of the site lies within the Hall County Gateway Corridor Overlay District. The Applicant requests a waiver from Chapter 17.420 of the Hall County Code of Ordinances. The proposed waiver has not addressed, the reasoning behind such a request, should this not be addressed as a variance and allow for public input? The Applicant commits to subjecting the property to similar covenants that have been adopted for Gateway Industrial Centre, experience should tell everyone that commitments are not the same as specific obligations and should never be left up to the current developer or future owner.
See
The purposes of the sections of the County Code from which the Applicant seeks waivers (as stated within those Code sections) support the City’s comments.
“The purpose of the GCOD is:
- To promote the general health, safety, and welfare of the community.
- To improve the efficient operation of traffic around the county.
- To promote safe and efficient movement within the Overlay District for persons using all modes of travel – motorized vehicles, bicycles, and walking.
- To create a sense of place that is aesthetically appealing and environmentally responsible.
- To encourage innovative development projects that set standards for landscaping, community design, and aesthetics.
- To establish consistent and harmonious design standards for public improvements and private property development within the Overlay District so as to unify the distinctive visual quality of the Gateway Corridors.” Sec. 17.420.010, Hall County Code.
Hall County Tree Ordinance
The Applicant requests a waiver from Chapter 17.280 of the Hall County Code of Ordinances. The Applicant commits to subject the property to similar covenants that have been adopted for Gateway Industrial Centre. Again, another area/matter that should be addressed is variance so the reasoning and public input can be heard as defined by law. Developers should not be allowed to pick and choose which ordinances or specific requirements they choose to follow; this is left up to the governing body for the benefit of the public through a specific process not at the whim of the applicant. “Growth and development in Hall County has resulted in the loss of innumerable trees in the area. Tree roots hold soil in place and tree photosynthesis converts carbon dioxide to oxygen. Tree loss has contributed to dramatically increased soil erosion and sedimentation. High growth area, where natural green spaces are diminishing, have fewer trees to transform into oxygen the carbon dioxide or ever increasing harmful vehicular and industrial emissions, resulting in air degradation. . .” Section 17.280.010, Hall County Code.
SEE
The purposes of the sections of the County Code from which the Applicant seeks waivers (as stated within those Code sections) support the City’s comments.
“The purpose of the GCOD is:
- To promote the general health, safety, and welfare of the community.
- To improve the efficient operation of traffic around the county.
- To promote safe and efficient movement within the Overlay District for persons using all modes of travel – motorized vehicles, bicycles, and walking.
- To create a sense of place that is aesthetically appealing and environmentally responsible.
- To encourage innovative development projects that set standards for landscaping, community design and aesthetics.
- To establish consistent and harmonious design standards for public improvements and private property development within the Overlay District so as to unify the distinctive visual quality of the Gateway Corridors.” Sec. 17.420.010, Hall County Code.
Proposed Uses
The project may contain a variety of uses consistent with those allowed in the PIO district (specifically H-B, 1-1 & 0-1} and the Project Dimensional Standards outline below. NON-existent as to allowed uses, this statement as adopted remains very vague as to future uses and should address an extended list of desirable and prohibited uses prior to rezoning.
Uses that will be specifically excluded include:
- Adult Establishments
- Junk Yards
- Asphalt emulsion (water-based} plants
- Astrologers, clairvoyants, fortune tellers, palmists, phrenologists, and related occupations
ORI/Traffic Impact Study
A DRI will be required for the site. A Traffic Impact Study has been commissioned but not completed at this time
Project Dimensional Standards
Inland 365 Business Center – Pl D Development Standards
Planned Industrial Development Standards |
|
Minimum Lot Area | 15,000 SF |
Minimum Lot Frontage | 100′ |
Front Setback from Cornelia Highway (SR 365) | 50′ |
Front Setback from alI other Streets | 30′ |
Side Setback | 20′ |
Rear Setback | 10′ |
Maximum Height | 75′ |
Total Acreage | 302.39 |
Minimum Open Space | 5% |
Maximum Floor Area Ratio | 70% |
Maximum Square Footage | 3,002,000 |
Parking Ratio | • Per Hall County Guidelines |
A maximum Height of 75’ is excessive considering the height of other buildings in the area, and currently, Hall County fire equipment capable of reaching above that height is not available in nearby Hall County Fire EMS Stations.
Conceptual Master Plan
The development of Inland 365 Business Park shall be controlled by the Conceptual Master Plan (the “Plan”) attached as exhibit “A.” The plan is considered conceptual in nature and, as such, may require modifications during the engineering and development process. Modifications to the locations and arrangement of buildings, roads, and other improvements that do not conflict with specific standards and requirements of these conditions may be made by the Developer or End User, so long as such modifications do not change the land use, increase the overall density of the project or reduce any established exterior buffers or setbacks.
Our comments would recognize that this statement above is rather imprecise as to what is specifically allowed and what isn’t. This development can offer a great opportunity for quality managed growth which can be beneficial to the community and the surrounding region. Specifics as to future use and transportation impact must be addressed and measured so as to insure the marketing of the property reflects acceptable specific standards.
Traffic Impact Study
City of Lula Traffic Impact Study Comments
Several key issues factors remain unknown as to this traffic study as previously mentioned in the above comments but are well worth mentioning again.
The “Traffic Study” (Keck & Wood) does not factor in the “Inland Port Transportation Study” that will impact Lula, North Hall, Habersham, and Banks County; without this important document being applied, the current study should not be used as a measuring tool for transportation needs now, and into the future, the very name of this project “INLAND 365 Business Center speaks to the impact the actual INLAND PORT will have on Lula, Hall County, Banks County and Habersham County and must be addressed specifically. Without the specific data, Peak Hour Demand can not be addressed or prioritized as to the implementation and funding of any improvements. The city seeks to improve the efficient operation of traffic around the city and the affected area of the county. The mitigation proposed within the traffic impact study fails to address anticipated future development within Lula, which prevents proper consideration of options to improve the efficient operation of traffic in the area.
Georgia DOT has begun a study of the impact of the Inland Port north of White Sulphur Road along SR365 and east along SR51 and SR52. There is no mention of this Study or preliminary or final recommendations of that study. The impact of funneling this volume of truck traffic through downtown Lula and across the Norfolk Southern main line crossing on SR52 and then again at Athens Street/SR51 in Downtown Lula will create safety issues even with a signal at that intersection.
The adjacent Moss DRI Development was omitted from/to this traffic study and the possibility of 519 residential units not being considered as to transportation impact is imperative in understanding what impact the area will experience and to what extent improvements can be factored and afforded. There is NO WAY accurate Trip Generation could be accurately factored without this specific information.
Hall County has the benefit of being in a MPO, which goal is to address current and future needs within its service area, the failure to not have this important planning body included in the study is paramount in all transportation issues within the boundaries as defined by GDOT.
Any number of proposed intersection improvements, closures, traffic changes, lane additions, and traffic lights have been proposed in the current inadequate study; at no time is there an evaluation of cost, grade, or construction to each particular site or potential funding timetable, as an example, the recommended proposal to close Burton/ McLeod to through traffic fails to address a timeline for implementation, cost of improvements, and who the responsible parties will be as to funding. Further Consider Figure 9, placing signalization to this intersection (Main Street at HWY 51) without recognizing the limitations of rail traffic, blockages of intersection, limits to the radius, and needed improvements for existing traffic conditions, failure to recognize this important piece of the puzzle will be like a domino effect on all other proposed traffic/transportation corridors. Anyone who has visited this site doesn’t have to be an engineer to recognize the deficiencies already in existence by Northfolk Southern Railroad and GADOT but yet none are being addressed in this report or in future improvements.
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