November 13, 2023

RE: Northern South Park draft Land Development Regulations

Dear Teton County Planning Commissioners,

As the valley’s only housing advocacy group, ShelterJH has been vigilant throughout the Northern South Park (NSP) planning process. Thank you for considering our comments on the draft NSP Land Development Regulations (LDRs) today.

ShelterJH has advocated for our vision for Northern South Park since the first upzone proposal in 2020: an inclusive, sustainable, and walkable neighborhood that furthers our community’s goal to build homes for locals. We wholeheartedly supported the Neighborhood Planning Process and were pleased with the outcome. We were particularly encouraged to see the phasing and integration of free-market and deed-restricted units mentioned in the Neighborhood Plan, alongside a commitment from the Gill team to provide infrastructure for their portion of the site. Unfortunately, the draft LDRs leave essential questions unanswered, namely: when and where will different types of homes be developed?

This summer, the Commission spent multiple meetings discussing different mechanisms for phasing the development of deed-restricted homes with free-market homes; however, the draft LDRs lack an explicit regulatory tool to ensure that deed-restricted homes are constructed alongside free-market homes. The LDRs must directly address and require that deed-restricted homes are built and occupied proportionally with market-rate homes.

We also want the LDRs to require that the landowners provide infrastructure to deed-restricted lots to facilitate the development of homes locals can afford. The community will be responsible for the cost of constructing the deed-restricted homes by securing philanthropy and/or public funding; we need to ensure that these lots are as “shovel ready” as possible to manage the financial burden the public will face to construct deed-restricted homes. Therefore, the community needs a guarantee that the land conveyed for affordable units will be equipped with comprehensive infrastructure on a reasonable scale.

Finally, integration is another outstanding question unaddressed in the draft LDRs. We understand the Gills’ intention to transfer 45 acres of land to deed-restricted housing developers; however, we want to ensure that the 45 acres’ worth of deed-restricted housing (i.e. the 70% requirement) is integrated throughout the NSP development. It is undesirable to allow the deed-restricted homes to occupy a discrete portion of land segregated from free-market homes on either landowner’s parcel. An integrated Northern South Park is essential to further community vitality and foster social cohesion. As written, we are not confident that the LDRs guarantee integration. The added benefit of meaningful integration is that there will necessarily be sufficient infrastructure available to deed-restricted lots interspersed throughout the parcel, alleviating our concerns in the previous paragraph.

ShelterJHs’ membership has voiced these collective concerns regarding phasing and integration since the original upzone proposal was denied in 2020. Now that LDRs are drafted, we insist that the regulations definitively and permanently codify the vision represented in the Neighborhood Plan in which the community earnestly participated. These LDRs need to lay the groundwork for a successful, integrated neighborhood; incentivize the landowners to opt in; and permanently protect the community’s investment.

At the end of the day, ShelterJH and the landowners in Northern South Park share a common goal: provide more housing for our hard-working local community members. If the LDRs are not crystal clear, the community risks rubber stamping a development of free-market homes unaffordable to families and without clear public benefit. Now is the time to clarify these LDRs and protect our community’s potential to house local workers, families, and retirees in NSP.


Clare Stumpf on behalf of the ShelterJH Board of Directors