I arrived at London Heathrow airport at around 11:30 AM. Immigration was quick, using e-gates that only people with passports from select countries can use. The distance between the arrival gate, immigration, and the train station was immense. Much longer than even the new, longer distance at SLC. I took the Heathrow Express to Paddington (paid for via contactless credit card), and then took Underground lines to King’s Cross (again, paid via contactless).
At King’s Cross (KGX) I bought a ticket on LNER Azuma service to Edinburgh Waverley, which was leaving in 20 minutes. The train passes through countryside but “calls” at York, Durham, and Berwick-upon-Tweed; nearing Edinburgh the East Coast Main Line hugs the North Sea coast.
After arriving at Waverley I walked up the stairs to High Street and then over to my hotel. I dropped things off in the room and headed over to the base of Arthur’s Seat and hiked up to the peak before sunset.
Once back down at city level, I walked around the city and then got a pie and pint at Halfway House (which I had seen on the walk up the stairs several hours prior).
The view from halfway up the hill to Arthur’s SeatTop to bottom, left to right: Rapeseed field in Scotland, Waverley station in Edinburgh, an LNER Azuma service train in St. Pancras station (London), people watching the departure boards at St. Pancras, and the Edinburgh city center as seen from halfway up the hill to Arthur’s Seat.
Day 2 (Wednesday)
I checked out of the hotel at 11 AM and walked over the to Left Luggage business at Waverley station to store my big backpack for the day. After that I walked over to the platform where a ScotRail DMU train was waiting to depart for Cowdenbeath. (I bought tickets at a machine.)
I alighted (disembarked) the train at North Queensferry and walked down the hill to the riverside to get a better view of the Forth Bridge (the first one, that carries two railway tracks). I also used a public toilet at a little car park here. (I placed all of my Forth Bridge photos below.)
The hill back up to North Queensferry station was pretty steep and I hoofed it to make the next train in the return direction so I could get to the other side of the River Forth to Dalmeny. (Trains are only ever 30 minutes on this line.)
Once in Dalmeny on the south side of the Firth of Forth (a river estuary) I walked down the hill to the riverside, which is in (South) Queensferry, and over to a pier where I bought a ticket for the day’s final sailing of the 90-minutes-long Maid of the Forth river cruise – I didn’t plan ahead for this, it was something I spotted and the schedule worked. When you’re traveling solo, you don’t have a hotel, and your train leaving the city isn’t for another nine hours you need stuff to do to fill the time – but the river cruise turned out to be a pretty awesome way to spend the time and £17.
Back at the dock I walked over to the town of (South) Queensferry. Both towns are named such because former Queen Margaret of Scotland used both points to cross the river. Queensferry has some great urbanism: being set in a hill, there are shops on the flat part at the bottom of the hill, then a large sidewalk above them and entrances to shops and row houses next to this sidewalk – the hill is completely disguised.
Next to Queensferry are two road bridges over the River Forth. The old one was found to have structural issues and is used only for taxis, pedestrians, cyclists, and transit. Adjacent to it is the bridges’ maintenance and monitoring facility and a public viewing deck that offers views of all three bridges. There’s another public toilet here, and a kiosk.
I walked back over to Dalmeny (the town under the Forth Railway Bridge) and had my dinner early at The Rail Bridge Café. I ate a plate of haggis, neeps, and tatties (haggis is “savoury pudding containing sheep’s pluck (heart, liver, and lungs), minced with onion, oatmeal, suet, spices, and salt, mixed with stock”, and neeps are mashed turnips, and tatties are mashed potatoes). It was delicious and I would like to have it again.
After four hours in the towns around the Forth Bridge, it was time to head back to Edinburgh. I boarded ScotRail back to the city and alighted at Edinburgh Gateway, a station to transfer to trams to the airport or city center. I took the tram to the city center and alighted at Princes Street, the main shopping street.
From Princes Street I walked to the Leith River and on to Leith and Newhaven. I walked around Leith to a bus route that would take me back to Waverley station.
Once at Waverley station I retrieved my left luggage and paid £15 (which is a convenience for not having to spend half an hour to return to the hotel up the hill to get it if I had left it for free and less secure at the hotel).
I bought some snacks at M&S Food and ate them in the station waiting room until I found out at which platform the Caledonian Sleeper would be waiting. (I used the National Rail website to find out because its late departure meant it would be a while before it showed up on the overhead departure screens.)
I boarded the train, found my room, and immediately started changing into pajamas and brushed my teeth. I was in bed by the time the train departed at 23:40. The sleeper train has a lounge car, but I don’t think the timing of this train allows it to be used conveniently.
[overnight train, waking up on Day 3] The train arrived at London’s Euston Station at 6:30 AM, about 37 minutes earlier than the Caledonian Sleeper’s “tips and tricks” webpage indicated. This is also when the attendant brought everyone in my carriage their coffee and breakfast snack.
Passengers must disembark by 7:30 AM, and that’s about when I did. I exited the station and walked two blocks to my hotel for the next three nights in London. Continue to day 3…
Forth Bridge photos
Forth Bridge seen from Maid of the ForthMaid of the Forth boatForth Bridge, seen from where I ate dinnerForth Bridge, seen from Maid of the Forth (far away)Forth Bridge, overlooking QueensferryScotland flag from the Maid of the Forth boat
Transportation so far
Heathrow Express (non-stop service from Heathrow Airport to London Paddington station)
Jubilee Line
Victoria Line
LNER Azuma service on the East Coast Main Line (top speed is said to be 125 MPH)
ScotRail (provides intercity and regional services but I took it only to towns 25 minutes away from Edinburgh)
This is the first post in what might become a video series about the Chicago zoning code. I picked business live/work unit because they’re a rarely seen “use” (an establishment) in Chicago, likely in part due to how few buildings are zoned to allow them and that the rules setting their minimum size might make eligible spaces doubly harder to find.
There is no order! An authentic “Zoning 101” would probably start by describing zoning, but I’m assuming you know that Chicago has a zoning code that defines what can and cannot be built or practiced on every property in the city. Business live/work units are one of those many things the code defines and regulates.
A business live/work unit is distinguished from an artist live/work unit in the Chicago zoning code in that it allows more business types – i.e. more than the creation or practice of art is allowed – but it requires that they happen on the ground floor. Artist live/work units are allowed in more zoning districts as of right (no additional permission necessary) above the ground floor.
What do you want to learn about next? Leave a comment or @ me on Twitter (stevevance).
Links to the relevant parts of the Chicago zoning code:
Currently, the Lightfoot administration has proposed spending about $188 million to support the construction of 318 affordable dwelling units in three office and hotel buildings that would accomplish a couple of goals. The housing would reduce the segregation of downtown living, and it would increase the population of downtown which could use more people to support all of the businesses and infrastructure that already exist.
The building at 111 W. Monroe St. From Block Club Chicago: “This proposal by Prime/Capri Interests, LLC, will create 349 apartments, 30 percent affordable, plus a hotel on the lower floors and 130 spots of underground parking. The hotel would be created without city funding, developers said.”
the city projects it will generate $120 million in in 2022 (source)
the city spent $76 million in 2021 ($63 million was surplused and the rest was spent on plans, studies, and “Costs of construction of public works or improvements”)
That’s a lot of money that the mayor’s office gets to choose how to spend!
It’s unlikely that the Lightfoot administration can rally the necessary approvals to dedicate the money before Brandon Johnson and a new city council is sworn in on Wednesday, May 15.
If the Johnson administration wanted to review the alternatives to that proposal, what would those be?
The alternatives
Spend $188 million to support the construction of 318 affordable units
Surplus the money; if the city did this, it would receive $44.81 million into the general budget.
Spend the same or less money on…something else. This could include beautifying the street or attracting residential development through another strategy that doesn’t spend the money on buildings construction (according to suggestions in a Crain’s article).
Do nothing. The money would stay in the account, grow, and generate interest.
What are other ways to spend the money?
With the cash flow shown in the “how much money” list above, it seems that the city could accomplish alternatives 1 and 2.
Over the years I waffled once or twice about adding a third unit, in the basement. I hired a structural engineer to draw up plans for the replacement center beam in the basement’s ceiling. To “future proof” the plans, I also asked him to draw a plan and create specifications for a floor excavation in order to achieve a code-compliant ceiling height in the potential basement unit.
The basement, looking towards the front entry. Notice how smooth the floor is.
The waffling was based on the cost of the necessary digging down. Excavation will add about $25,000 to the cost of the project. (That’s based on one bid, the only bid that called it out specifically. I asked all three bidders to separate the costs of the basement unit so that I would know exactly how much the basement unit – excavation, walls, finishes, etc. – would cost as an “add on”.)
I think my architect also helped convince me to design and get bids for a third unit because of the flexibility it could provide for me and my tenants (which may include one or more family members), as well as the possibility of additional rental income.
I’ve settled on adding the third unit, and I’m excited to do it, in part because of my well-known enthusiasm for accessory dwelling units. (A note about Chicago’s ADU ordinance: this property is outside the ADU pilot area but it has unused zoning capacity per both the FAR and minimum lot area per unit standards so the additional unit is allowed without the ADU ordinance.)
Excavation
The Chicago Building Code requires that the ceiling height be a minimum of 7′-6″ in most of any dwelling unit (that’s measured from the finished floor to the finished ceiling). A limited amount of area is allowed to be lower to get around existing or newly installed pipes and ducts in the ceiling.
To achieve that, crews will demolish and remove the existing floor slab (which I’ll be a little sad about because the previous owner did a nice job pouring it) and excavating earth 10″ down. They’ll also underpin the foundation walls in an alternating pattern of rectangles around the perimeter. I hope I can explain underpinning well (otherwise watch Darren Voros’s video): This means they’ll dig under half of the foundation dispersed around the perimeter (the A sections), leaving unexcavated space between each to hold up the other half of the foundation (the B sections); then they’ll switch and repeat the process for the B sections.
A foundation wall detail showing the 10″ of excavation and the addition of a perimeter drain tile.
Water
After every rain storm I go and check the house. The basement has been dry every time. I’m surprised, and thankful, that it seems that water doesn’t seep into the basement.
One time I noticed that there was water pooling on the basement floor – when a rain storm had not occurred. It turned out that when I closed the water service line I didn’t close it well enough and water was very slowly leaking out. Tightening the valve handle was a simple resolution.
During the excavation there will be a perimeter drain tile system installed under the floor slab to steer water toward an ejector pit. An ejector pit is different than a sump pump in that it has a mechanism to grind the house’s sewage before pumping it to the city’s sewer main. I believe an ejector pit is a requirement when the lowest dwelling unit’s plumbing (i.e. the toilet) will be below the city sewer main.
Bob Vila’s website describes interior drains like this:
Similar to exterior drain tile, an interior French drain features a perforated pipe that carries water to a collection pit where it can be pumped to the surface. This type of drain is located along the interior perimeter of the basement and lies below floor level.
All You Need to Know About Basement Drains, Glenda Taylor and Bob Vila
Apartment
The new dwelling unit is drawn as a 1-bedroom apartment with a small bedroom that has two short windows and a closet. It has a large, combined living room, dining room, and kitchen.
The entryway is partially separated from the big room using a hall closet, creating a sort of mud hall. The bathroom is of a typical size for small apartments in Chicago and there’s a considerably sized utility room for laundry and storage. Overall, the apartment has an area of about 720 s.f.
I believe in-unit storage to be an important amenity. My current apartment is a studio and I selected it in part because it had good layout with a lot of scattered storage (there’s a walk-in closet, a large nook between the living area and the bathroom, a small closet, and a linen closet in the bathroom).
When I was looking for a new place to live in 2022 I didn’t want to have to move any of my stuff into a storage locker in the building or a storage unit in another building.
Other space in the basement
The rest of the basement, about 100 s.f., will have two hybrid heat pump water heaters, the ejector pit, electrical panels, and a little bit of room for storage. There’s also a rear entryway and the basement apartment will have a rear exit through here.
Several things happened in November that has inspired me to finally document the story about a building whose history I had previously researched but never shared. It’s the story of a rear-courtyard-style building two blocks from the Garfield Park Conservatory that had 18 dwelling units, was demolished in the 1990s due to unpaid water bills, and rezoned – along with many other buildings nearby and across the city – to allow the next owner to build only seven dwelling units.
Those three things, for the curious: A question was posed to the speaker at a recent real estate group luncheon about the prevalence of downzoning in Chicago and the impact that might have on limiting some redevelopment of vacant lots; the city’s launch of ChiBlockBuilder, a program that replaces and expands upon the former $1 Large Lots program; and a meetup I attended with other urban planners to discuss, among other topics, zoning, transit, and cannabis dispensaries.
I make a few contentions in this blog post about zoning in Chicago. Among them:
Downzoning is a municipal practice that reduces how densely a property can be developed; in this context, the number of dwelling units allowed.
The zoning text and maps have progressively downzoned the city between the first zoning code and today’s zoning code; this blog post reviews the zoning text changes using a case study of a single building.
The zoning text and map at the time allowed an 18-unit building to be built on a particular property in East Garfield Park but the current zoning text and map allows only a seven-unit building to be built.
Introducing the vacant lot at 3454 W Fulton Blvd
There is a vacant lot owned by the City of Chicago at the northeast corner of Fulton Boulevard and St. Louis Avenue in East Garfield Park, in view of the renowned Garfield Park Conservatory. The lot has an area of 7,500 square feet.
The group of six three-flats is at the northeast corner of Fulton & St. Louis, or at the top-left corner of the image. The image is a screenshot of a Sanborn map, volume 11, sheet 84, last revised in 1950. Access to the HIG – Fire Insurance Maps online database is via the Chicago Public Library (a library card is required).
For what it’s worth, the southeast corner lot had 15 units, the southwest corner lot had 18 units. Then there’s the northwest corner lot that had a rear-courtyard-style building with interior corridors with 45 units (that’s 250 percent more units on a lot that’s 150 percent larger). (See Sanborn map volume 11, sheet 83, to visualize the corners on the west side of St. Louis Ave.)
The timeline of construction to demolition to city ownership to resale
The flats were built between 1922 and 1949, according to Sanborn maps (link to 1922 map, volume 11, sheet 83, hosted by the Library of Congress, which shows a vacant lot, while the 1949 version above shows the building).
In February 1992, the City of Chicago’s water department filed a statutory lien on the property to claim and to notify the owner that there was unpaid water service balance of $2,593.89.
If the building was dilapidated and had been cited, I did not find evidence in the documents available at online Cook County and City of Chicago sources. There is evidence, however, that the property was sold in 1988 a five-year delinquent tax sale.
The lot had six adjoining three-flats for a total of 18 units until its demolition, by the City of Chicago, on February 12, 1992 (read the lien the city filed against Exchange National Bank, in the amount of $14,754, to cover the cost of demolition).
Seven years later, on March 1999, the City of Chicago acquired the lot after succeeding in its lawsuit against Exchange National Bank in the Cook County Circuit Court’s Chancery Division (case number 95 CH 3958).
I’m going to repeat this part: Available evidence shows that the City of Chicago demolished the building due to unpaid water bills. I believe that political and planning circumstances – and policies – have changed such that if the situation were repeated in 2022 the building would not be demolished. For example, there is a coalition program called the Troubled Buildings Initiative that the city helped found in the mid-2000s to place buildings in this and similar situations into “receivership”, to ensure that the building does not get demolished and can actually be stabilized and improved (renovated). This is a better way of handling the problem!
Fast forward twenty-three years from the acquisition in 1999 to now. The lot is for sale to eligible neighbors – for the second time this decade – for use as a landscaped space (side yard, garden, plaza) or redeveloped (anything allowed by zoning, but you may need assistance learning to decode the zoning code).
The lot was first for sale in the Large Lots program during one or more of the tranches promoted between 2015 and 2018. The lot is now for sale since the ChiBlockBuilder program launched on November 17, 2022.
The property shown on the ChiBlockBuilder website. The property is highlighted in green on the map.
The rules are different between the former Large Lots program and ChiBlockBuilder. In the past, anyone who owned property on the same block or across the alley could apply to acquire the lot. All lots were sold for $1.
Now, through ChiBlockBuilder, interested buyers who want a low-cost acquisition must own and live in a property adjacent to the lot. This lot has only one eligible neighbor; I don’t know if the owner lives there. If they do, they can acquire the property for 10 percent of its market value.
That’s another difference between Large Lots and ChiBlockBuilder: All properties for sale (which is a subset of all properties that will eventually be for sale) have already had their market value appraised.
The market value for 3454 W Fulton Blvd is $29,953 or $2,995 for eligible applicants. There’s one other group of potential buyers that can obtain lots for 10 percent of market value and that’s non-profit organizations who have a proposal for a landscaped-based project.
The other day the City of Chicago added a wood fence around part of the vacant lot. The RV is parked on another city-owned lot, and the semi-trailer belongs to the water department because of underground work being conducted in the neighborhood.
What does zoning allow?
Successful neighboring owner-occupant buyers are able to do anything with the vacant lot that zoning allows. Although, without an expertise in reading the Chicago zoning code or a tool like Chicago Cityscape, it will be hard to know what that is.
A screenshot of ChiBlockBuilder showing the FAQs that provide links to identify a property’s zoning district and to the Chicago zoning code documentation.
My real estate information company, Chicago Cityscape, automatically generates a “Zoning Assessment” for every parcel in Chicago.
At 3454 W Fulton Blvd, the Zoning Assessment estimates that, currently, seven dwelling units are permissible, 11 fewer than what were extant there back in 1992.
Downzoning takes effect: Zoning codes of 1923, 1944, 1957, and 2004
Downzoning is a process – through either a change in the map (the zoning district assigned to a property) or a change in the text – that reduces the number of dwelling units permissible on a given lot.
1923
In the 1923 zoning code, Chicago’s first, the allowable density of building on this lot was controlled by the “2nd Volume District” which established very simple rules: a ground coverage limit of 75 percent, and a height limit of 66 feet. The building height could be higher with an upper floor setback.
A graphic from the 1923 zoning code shows how height limits varied based on upper floor setbacks and distance from the street.
Multiplying the lot size of 7,500 s.f. by 0.75 equals a maximum building footprint of 5,625 s.f. Multiply that by six floors and there’s a maximum floor area of approximately 33,750 s.f. This created an FAR of 4.5.
1944
In the 1944 zoning code, the allowable density of building on this lot was still controlled by the “2nd Volume District” but the maximum density had been reduced: a ground coverage limit of 45 percent, and a height limit of 45 feet (the current zoning code applies a height limit of 38 feet on the lot in question, while ground coverage is dictated by FAR and setbacks standards that the 1944 zoning code didn’t have).
Multiplying the lot size of 7,500 s.f. by 0.45 equals a maximum building footprint of 3,375 s.f. Multiply that by four floors and there’s a maximum floor area of approximately 13,500 s.f. This created an FAR of 1.8.
Yet neither the 1923 nor the 1944 zoning codes had a limit on the number of dwelling units. The number of dwelling units was thus limited by whatever building code standards there were and the unit sizes the builder wanted to market.
1957
The 1957 zoning code introduced a more stratified Use + Density schedule of districts more similar to the current zoning code than the two prior codes. The map was drawn to place 3454 W Fulton Blvd into an “R4” district.
1957 zoning code map sheet 1-J (which is the same grid index/sheet number as the current zoning code’s map). Image from the HathiTrust database, page number 171 of 348 (page 91 of the zoning code, though). 3454 W Fulton Blvd is outlined in a pink-colored box near the center of the image.
In 1957, the R4 zoning district applied a new density rule that there can only be one dwelling unit per 900 s.f. of lot area. This differs from the prior two codes which did not have a standard establishing a maximum number of units.
Since the lot has an area of 7,500 s.f., that equals eight dwelling units allowed.
The 1957 zoning code introduced the minimum lot area per unit standard. The standard in R4 zoning districts was that there had to be 900 s.f. of lot area per unit the owner desired to build. That number increased to 1,000 s.f. in the 2004 (current) zoning code, reducing the number of units allowed to be built on this vacant lot. Scan is from the HathiTrust (scanned page 24).
The 1957 zoning code also introduced a floor area ratio (FAR) of 1.2 to control building size, and front, side, and rear yard setbacks that controlled lot coverage. Remember that this lot had an effective allowable FAR of 4.5 in 1923 and 1.8 in 1944.
I think it needs to be pointed out that the most dense residential-only zoning district in the 1957 zoning code – R8 – allowed more than twice the number of units on a given lot than the most dense residential-only zoning district in the current zoning code – RM-6.5. It was a matter of requiring 135 s.f. of lot area per dwelling unit prior to 2004 and 300 s.f. of lot area per dwelling unit since 2004, respectively.
In practical terms, if the lot was zoned R8 in 1957-2003 then 55 units would be allowed; if it was zoned RM-6.5 in 2004-2022 then 25 units would be allowed.
2004
In the current zoning code, adopted in 2004, the lot’s “R4” zoning district designation was converted to “RT-4”. The code was updated to reduce the density rule from requiring 900 s.f. of lot area per dwelling unit to requiring 1,000 s.f. of lot area per dwelling unit. Since the lot has an area of 7,500 s.f., that means seven dwelling units are allowed here (also, the zoning code says the number must be rounded down in instances where there is a maximum standard). That’s a difference of one unit, so hardly an indictment of the downzoning of this lot that occurred between 1957 and 2004.
The current zoning code has a table in 17-1-1406-A that instructs readers how to convert from the 1957 zoning code districts to the current zoning code’s districts.
The FAR stayed the same between the 1957 and 2004 zoning codes, at 1.2 (far below 4.5 in 1923 and less than 1.8 in 1944).
Allowed zoning summary
I contend that there was a severe decline in the number of dwelling units allowed between Chicago’s first and fourth (current) zoning codes, manifested through a reduction in reduced height limits and lot coverage between 1923 and 1944 and the introduction of the maximum number of units standard (called “minimum lot area per unit”) in 1957. The zoning code in 2004, as it pertains to this lot, looks very much like the zoning code in 1957.
Chart that compares the zoning standards of height, lot coverage or FAR, and units allowed, amongst the four iterations of Chicago’s zoning code.Thank you to Daniel for compiling the different zoning codes’ standards.
Miscellanea
Another big change between the 1957 and 2004 zoning codes was the amount of parking required: in the equivalent zoning districts, the 1957 zoning code required 0.75 spaces per dwelling unit while the 2004 zoning code requires 1 space per dwelling unit, which is still the case as proximity to transit has no bearing on RT-4 zoning districts.
The 1923 had a cap on the number of garage parking spaces of one space per dwelling unit. This cap went away at some point, and has been reinstated in a limited basis in the “Connected Communities” ordinance adopted in 2022.
The 1923 zoning code allows more “auxiliary” uses in “apartment districts”, such as the one governing the vacant lot in question, compared to the current RT-4 zoning district, including: a boarding or lodging house, and an apartment hotel with a restaurant or dining room that is entered from within the lobby. (I don’t think apartment hotels exist anymore in Chicago.)
In 2022, the Chicago City Council adopted a zoning code amendment called “Connected Communities” which would allow the next owner of this vacant lot to build housing without any car parking – like it was in the 1920s – if they were to also obtain an upzone (that is, a zoning map amendment to a higher-density zoning district) to RM-5 or higher. This is because the lot is near enough to an eligible transit service.
P.S. The other type of downzoning (or upzoning) is to change the map. This means to reassign certain parcels to a different zoning district. Chicago city council members do this constantly, often for unknown or unexplained reasons. When it is explained, it’s often to ensure that a property owner must proposed a project to the alderperson and then obtain their permission to (usually) upzone.
When the zoning is changed one parcel at a time, or several parcels for a single property owner, this process of downzoning – or upzoning – gets an additional name: spot zoning. This is generally bad urban planning and development policy and has been part of political corruption. Chicago used to have a department policy that rezonings (changes to the zoning map) had to cover at least 10,000 s.f. of contiguous parcel area at a time (just a little bit larger than three standard size lots).
Several examples of alderperson-initiated downzoning in the 2010s include (from memory):
Former alderperson, and chairperson of the City Council’s zoning committee, Danny Solis, downzoned a large residential property in Pilsen to “M” (industrial); the property owner, PMG, sued Solis and the City of Chicago. The settlement was that the city would buy the land from PMG at market rate. This is now the 18th & Peoria development site, and the city is conducting public meetings to determine how to develop it.
Alderperson Roberto Maldonado submitted dozens of downzoning ordinances to City Council in ~2020, to change vacant lots in Humboldt Park and Logan Square from RT-4 (which would allow a three-flat) to RS-3 (which would allow a single-detached house, and in rare locations, a two-flat). The planning department staff had to limit his submissions to a few per month because they could not handle all of his ordinances amongst their other work processing real zoning change applications.
Alderperson Carlos Ramirez-Rosa downzoned a commercial district along Milwaukee Avenue north of Diversey Avenue to allow a lower density and lower height. Any developer that proposed more than allowed has to go through the 35th Ward Community Zoning Process (I have not personally experienced this process but I appreciate that it’s well-documented and seems to be applied consistently). The scope of the downzoning was reduced after some pushback.
