THE MANY FAILINGS OF OUR NEW RURAL LAND USE PLAN
(or, WHY "OPTION A" GETS AN "F")
by Dan T. Coenen

A critique of Option A could take many forms. One might appeal to emotion, drawing on art and literature to celebrate the power of natural landscapes. One might rely on the value of historic preservation, emphasizing continuity with the past and the importance of maintaining our community's sense of place. One might turn to the discipline of economics to bemoan the predictable under-valuation of common resources like clean air and water when balanced against competing short-term, financial concerns. One might cite political theory to highlight the tendency of legislative bodies to subordinate the goals advocated by proponents of a generalized and diffuse (but very real) public interest. And one might even turn to matters of faith, emphasizing our long-recognized "deep spiritual ties to the land." (N.Y.Times, p.A21; 1/8/01.)

This set of comments takes none of those routes. Instead it looks closely at the legal past and the legal present in an effort to disclose more particular failings of our newly adopted land-use plan. With land-use rules, like other laws, the devil is often in the details. So it is, this commentary suggests, with the ill-advised Option A.

Of course, any evaluation of Option A will reflect a set of values, and this appraisal is built in large part on what we might call "anti-sprawl" values. The recent and serious difficulties faced by Atlanta suggest that these values should carry great weight in our own nearby community. There is also strong reason to conclude that these values are already widely and deeply shared by the citizens of Athens/Clarke County. Most important of all, Option A in fact threatens these values by greatly encouraging urban sprawl, as well as the traffic congestion, increased taxation, environmental degradation and loss of community identity that sprawl inevitably brings with it.

The line of argument offered here, however, is meant to do more than reveal Option A's incompatibility with anti-sprawl values. It also seeks to show, for example, that Option A contains internal inconsistencies, that it is unfair, and that it departs markedly from the history that gave it birth. For these and other reasons, the argument offered here is not directed only to those who strongly embrace anti-sprawl values. The argument instead is that Option A - for ordinary citizens and taxpayers, for the business community, for the University, for government officials, and for AR landowners - is fraught with potential to do much harm, including by frustrating the very goals it was meant to serve.

THE BASIC PROBLEM

On December 19th, the Athens/Clarke County Commission overrode Mayor Doc Eldridge's veto of ordinances that massively rezoned our county. In doing so, our Commission put back in place the controversial "Option A" zoning plan that, two weeks earlier, it had applied to the entire 26,000 acres that make up our community's now-rural area. The primary consequences of Option A are clear. First, it gives large landowners sweeping new rights (but not necessarily value-maximizing rights) to immediately build out residential subdivisions throughout the rural areas of our county. Second, by removing the need to secure a rezoning to engage in such development, Option A steals away the public's pre-existing right to monitor newly proposed subdivisions in the context of open processes that render our representatives accountable to citizen scrutiny. In short, Option A gives us more development and less democracy.

The problems with Option A, however, do not stop here. In fact, those problems are so numerous that it is difficult to present them in a short and straightforward way. At the risk of oversimplification, however, it seems fair to say that Option A suffers from five major failings. First, Option A undercuts important rights of the public while failing to provide any compensating benefit. Second, Option A invites the helter-skelter suburbanization of all rural land in our county. Third, subtle features of Option A cause it to undermine its own professed objective of protecting "open space." Fourth, Option A - for no sound reason - actually increases, rather than decreases, permissible building densities in the AR zone. And finally, Option A is wrong in spirit because, in the eyes of local residents, it is unfair, unresponsive to citizen input, and reflective of a missed opportunity to forge a "win-win" strategy to protect both public and private interests.

OPTION A: THE COMPROMISE THAT WASN'T

Understanding what Option A has done requires an understanding of the laws it replaced. One of those laws, section 9-1-97(b)(1) of the pre-Option A code, specified that splitting up any AR tract "for three or more lots" required without exception formal Commission approval in the context of a full-scale rezoning. A second law provided that the single-lot break-offs authorized without rezoning could occur no more often than once every two years. Under these laws, when a landowner broke off a single lot, it could be, as a rule, just short of one acre in size. For this reason, some have suggested that Option A in essence simply carried forward AR landowners' preexisting right to develop their land at a one-unit-per-one-acre density. The key point, however, is that the pre-Option A two-year phase-in rule (as well as another rule that required a rezoning in the AR zone whenever "a new road is proposed") left no doubt that landowners had one, and only one, legal right with respect to putting residential lots in the AR area: they could, at most, break off single lots for a family member, an on-site employee or an isolated sale on a once-every-two year basis. Commissioner Ford accurately described the pre-Option A legal setting when she wrote: "In the current code, all AR property must be rezoned before subdividing, a process most developers would like to avoid."

Beginning in 1997, our community undertook a comprehensive review and revision of our zoning ordinances. In this process, after receiving extensive community comment, our Commission unanimously endorsed certain core planning objectives for our county. These goals included: (1) "to avoid the costs and problems associated with urban sprawl," (2) to "preserve the rural character . . . of our community," and (3) to see to it that "commercial, industrial and residential subdivisions" would be "prohibited" in the rural area. (See Guiding Objectives and Comprehensive Plan, section 9-8.)

In an effort to realize these goals while simultaneously providing fair treatment to AR landowners, a practical "trade-off" proposal was advanced. Under this proposal, AR landowners would give up the essentially nominal and unusable one-house-per-about-one-acre building density recognized under preexisting law. In return, these landowners would receive the entirely new right to build out residential subdivisions, immediately and free of any rezoning, so long as they did so at greenspace-preserving low densities. AR landowners stood to gain another potential benefit from this proposed reform; lowering permissible building densities on a uniform basis, after all, might well cause land values to rise by "locking in" the area's aesthetic attractiveness and appealing rural character. In any event, under this "trade-off" proposal, rural landowners would retain the same right they previously possessed to seek a rezoning at any time to develop subdivisions unrestricted by otherwise-applicable density rules.

In the summer of 1999 - after two years of public input and professional study - this approach appeared to be endorsed by our Commission when it unanimously approved and submitted to state authorities the Comprehensive Plan for Athens-Clarke County and the City of Winterville. This Comprehensive Plan - which was created for the specific purpose of directing the later drafting of the binding zoning ordinances that came to include Option A - contained a section entitled "Rural Lands Protection." In keeping with the previously identified goal of retaining a rural "greenbelt" in the outlying areas of our county, this section specified that: "It is the goal of this plan that overall densities in this area not exceed 10 acres per unit." In ongoing discussions, variations on this goal of one-unit-per-ten-acre zoning were identified, including one-unit-per-five-acre zoning and even one-unit-per-2.5-acre zoning, depending on the developer's greenspace-preserving clustering of house lots. All of these low-density levels were based on (and, in general, were less restrictive than) zoning densities employed in other communities seriously committed to open-space protection.

Just how our Commissioners moved from these low-density goals to the adoption of Option A is not clear. What is clear, however, is that Option A repudiated the previously identified objectives of protecting our rural areas from sprawl, did not effect a greenspace-preserving trade-off for the benefit of both landowners and the general public, and in fact simply bestowed on AR landowners new rights (but again not necessarily value-enhancing rights) to build suburban developments in what had been identified as the future "greenbelt" of our county.

To see why this is true, it is again necessary to consider preexisting legal requirements. As we have seen, pre-Option A law gave AR landowners only one right with respect to residential development in the absence of a rezoning: the right to break off one or possibly two lots, approximately one acre in size, on a once-every-two-year basis. Option A, however, keeps in place this preexisting "lot break-off" right by specifically providing in section 9-5-5: "The subdivision of up to two additional lots at least one acre in size shall be permitted no more than once every two years." In fact, section 9-5-5 appears to go even farther than the law it replaced because that law was most logically read to authorize creation of only one additional lot every two years. (After all, the preexisting section 9-1-97(b) required a rezoning for any subdivision "for three … lots," and the phrase "for three lots" is most naturally read to refer to the original lot plus two additional lots; in other words the new rule clearly authorizes creation of "two additional lots" without a rezoning, while the previous law, on its most reasonable interpretation, required a rezoning in those same circumstances.)

What was and is most critical about Option A, however, is that in addition to retaining (and apparently enhancing) the single-lot "break-off" right that landowners enjoyed under preexisting law, Option A also gives AR landowners a broad additional set of rights to build out so-called "conservation subdivisions." In particular, under Option A's new section 9-5-4, residential subdivisions at "an average density of one unit per acre" are permitted without a rezoning so long as "50% of the total acreage is retained as 'open space.'" (In other words, if the developer of a 100-acre tract sets aside 50 acres as "open space," the developer can use the remaining 50 acres to build out 100 houses on 100 half-acre lots.) In short, section 9-5-4 gives AR landowners an entirely new right they lacked under previous law: the right to put in place large-scale residential subdivisions at an average density of one-unit-per-one-acre without any need to secure a rezoning.

The key point is that Option A did not effect any trade-off of landowner and public rights; rather, it retained (and in fact probably doubled) the single-lot break-off right AR landowners had previously enjoyed. Then it layered on top of that right a new right to build out major residential subdivisions without any need to endure the uncertainties and open public scrutiny that are part of the rezoning process. What did the public get in return? They got the unwelcome news that all of our county's supposed greenbelt was now open to suburban residential development.

A CALL FOR SPRAWL

Most Athenians have seen and experienced the relentless growth and choked roads that surround Atlanta. As a result, during the planning process, members of our community voiced a deep-seated desire to avoid our own community's becoming yet another faceless place in the ever-sprawling sea of Atlanta suburbs. A key idea for preserving our own community's distinctive identity and geographical self-definition was to surround it (at least in large part) with a non-suburban "greenbelt" that would possess a rural, non-suburban feel. Some proponents of Option A have suggested that it will largely achieve this objective by channeling future development into so-called "conservation subdivisions." Option A, however, was neither conceived nor structured to avoid suburbanization. In fact, Option A threatens both the general public and AR landowners with the land-value-reducing prospect of crazy-quilt residential development throughout the AR area. Here are three reasons why.

1. A first clue to Option A's suburbanizing consequences lies in section 9-5-1, which sets forth the ordinance's purpose. The clue is provided by little-noticed, but very telling, revisions that were made to this section late in the drafting process. Consistent with the aims of the Comprehensive Plan, the first four drafts of our would-be land-use ordinance (which did not include Option A) specified that: "The purpose of the AR district is to maintain an area of rural use within Athens-Clarke County. Application of the zone will insure that the farming, forest and scenic values of these areas are protected.…" In Draft 5 (which did include Option A), however, this statement of purpose was radically altered. While continuing to give lip service to "rural use" and "farming, forest and scenic values," the new statement of purpose also set forth new goals: "to protect…the single-family residential character" of the district and "to promote and encourage a suitable environment for family life." In short, the revised statement of purpose that accompanies Option A openly discloses its goal of encouraging residential development.
2. Any doubt about the suburban-development focus of Option A is removed by the evaluations of recognized experts. John Fregonese - to whose firm our county paid hundreds of thousands of dollars for expert assistance - advocated one-unit-per-ten-acre density in the AR area. He also described the consequences of Option A in these terms: "over the long term, what you'd get is kind of like a golf course subdivision - houses on half-acre lots with some green space in between them." (Athens Daily News and Banner Herald 12/10/00.) Smart-growth expert Randall Arendt, who closely studied the Commission's proposed treatment of the AR area, likewise described Option A in no uncertain terms. He called it "essentially a suburban development ordinance." (Athens Daily News 12/5/00.)
3. Unfortunately, Option A will do more than lead to the suburbanization of the entire AR zone. It also all but ensures that this suburban development will occur in a visually disjointed and land-value-threatening way. This is so because Option A allows all forms of housing - from mansions, to high-priced homes, to accessory dwelling units, to "Class A" manufactured homes, to starter houses of 1000 square feet (see section 9-15-15) - to spring up throughout the AR area in an undirected, helter-skelter fashion. This outcome creates the risk that the area of our county singled out in the planning process to serve a special beauty-enhancing role will instead evolve into an unattractive hodge-podge of buildings. Such a result would not serve the interests of anyone, and it would be especially harmful to those persons who actually live and own land in the AR area. At the least it is clear that AR landowners will not, under Option A, enjoy the once-intended benefit of value-adding greenspace preservation. We turn now to examining why.

WHERE'S THE GREEN SPACE, ANYWAY?

In theory, a principal benefit to be received under Option A was that future developments in the AR zone would take the form of so-called "conservation subdivisions" that would include large expanses of protected green space. In fact, however, Option A ended up being written in a way that will frustrate, rather than advance, the goal of green space preservation. This is the case for three separate reasons.

1. At first glance, Option A suggests that developers of new subdivisions in the AR area must "guarantee" that there be a "permanent retention" of 50% of all subdivided land as open space. (See section 9-5-4.) Close inspection reveals, however, that Option A fails to ensure anything even close to genuinely "permanent" protection of set-aside open land. The reason why is that the ordinance does not require developers to put in place permanent conservation easements; rather, Option A requires only that the developer secure "deed restrictions" or "covenants," which are rescindable under state law after 20 years. At the very best, Option A permits planning officials to determine the duration of open-space protections. Senior planner Bruce Lonnee put the point this way: "I hate to sound like Forrest Gump, but permanent is as permanent does. It really boils down to how these things are applied." (Athens Daily News and Banner Herald, 12/10/00.) And, of course, "permanent" protections that depend on the discretion of government officials are not really permanent at all.
2. A second, and no less serious, problem with Option A's treatment of conservation subdivisions arises because the ordinance's definition of "open space" does not ensure the protection of green space in what was supposed to be the greenbelt. One reason why is that the new ordinance defines "open space" both to permit "landscaping" and to include "recreational facilities." As a result, under Option A, supposedly protected open space may be covered with tennis courts, golf fairways, heavily landscaped entranceways, football and baseball fields, swimming pools and apparently even miniature golf courses. (Informative in this regard is a definitional provision in section 9-2-1 that describes "uses which by their nature are recreational" to include "golf courses, driving ranges, miniature golf," etc.)
3. Another reason why Option A's treatment of green space is inadequate is because the "open space" set aside as part of a "conservation subdivision" need not be contiguous or located in such a way as to preserve the rural appearance of the countryside. In practical effect, Option A permits cookie-cutter lots, less than a half acre in size, along every existing and newly built road in the rural area, so long as those lots are adjoined by an essentially hidden stretch of landscaped backyards made subject to common ownership. For this reason - and other reasons we now shall explore - developments throughout the entire AR area are likely to have no different appearance than traditional suburban residential subdivisions.

A PROPENSITY FOR DENSITY

We have seen that Option A transformed a little-used ability to engage over a long period in one-lot-at-a-time development into a broad right to create large-scale residential subdivisions immediately or at any point in the future. As if the removal of any need to secure a rezoning were not enough, Option A in its present form also provides developers with something else: the right to build out subdivisions at overall densities markedly greater than pre-Option A law envisioned and allowed. Here is why.

1. Pre-Option A law - in keeping with ordinary practice - prescribed a minimum lot size for the AR zone; thus, as we have seen, each lot in the zone had to be a minimum of nearly one acre, not including roads and rights of way. Under Option A, however, subdivision developers do get to include a subdivision's roads and rights-of-way (which may make up upwards of 20% of subdivision acreage) in creating lots with an average density of one unit per acre. This result occurs because section 9-2-1 defines the term "gross acreage" to mean "[t]he total acreage of a lot prior to making site improvements," and section 9-5-4 provides that lots may be built in the AR zone "applying an average density of one unit per acre on the total gross acreage." Put another way, in contrast to pre-existing law, Option A computes the number of buildable lots on a pre-site-improvement, rather than a post-site-improvement, basis. The consequence is that far denser development is now permitted in the AR zone than was permitted before.
2. There is another way in which Option A subtly increases permissible building densities in our rural area. Because some AR land - such as land occupied by ponds, floodplains, or swamps - is simply not buildable, such land under prior law carried with it very limited development value. If, for example, an AR landowner owned 20 acres, half of which was swampland, he might at most have been able to create only 10 one-acre house lots because each lot (as we previously saw) had to be about one acre in size. Under Option A, however, the same landowner would be permitted to build out 20 one-house lots. Why? Because he could set aside the swampland as "open space" and then cluster 20 homes on the 10 non-swampland developable acres of his "conservation subdivision." This result increases the prospect of sprawl in our outlying areas without contributing in a significant way to open-space preservation. It also bestows an unearned windfall on those AR landowners who were lucky enough once to have purchased tracts of largely unbuildable land.
3. Other problems related to density arise from Option A's treatment of minimum lot sizes. To begin with, Option A reduces the previously required minimum lot size in the AR zone from 40,000 square feet (which is just less than one acre) to15,000 square feet (which is just more than 1/3 acre). This change will probably have limited effect in the short run because of Option A's focus on average density; it could set the stage for much denser development in the future, however, as the non-permanent protections placed on conservation subdivision open space begin to expire. Another problem created by the interaction of conservation subdivision rule and minimum lot sizes arises because sections 9-5-3 and 9-15-14 (in conformance with preexisting local law) require that minimum lot sizes must be about 1.2 acres in those areas not serviced by public water and sewer systems. This 1.2-acre minimum-lot-size rule is salutary to the extent it constricts developers' ability to build out higher density half-acre lots (at the otherwise operative one-unit-per-one-acre average density) within the non-open-space areas of conservation subdivisions. Precisely because this rule imposes this restriction, however, it will create powerful incentives to extend water and sewer lines into rural areas. And any expansion of these services will only increase demands on already overextended systems, result in higher taxes and invite the continuing ripple effect of more extensions and more sprawl. The joint operation of Option A and the 1.2-acre minimum-lot-size rule also portends another problematic effect: these rules, as a practical matter, allow critical building density choices to be made in the context of decision-making about where water and sewer lines should run, rather than in the focused light of proceedings that specifically concern land-use and density questions.
4. Option A's significant expansion of development rights in the AR zone does not stand alone. Indeed, one of Option A's most troubling features lies in its interaction with our new zoning ordinance's treatment of development rights in non-AR areas. Early on in the planning process, a decision was made to channel development within our county from outlying rural areas to in-town areas already serviced by roads, schools, fire and police stations, and the like. For this reason, authorized building densities were increased in many non-rural areas, while a low-density target of one-house-per-five-or-ten-acres was recommended for the rural zone. It is important to recognize that when the Commission adopted Option A - authorizing increased development density throughout the AR area - it also left in place its preexisting authorization of higher density development in non-AR areas. As a result, by adopting Option A, our Commission gave the green light to faster and denser development not only in the AR zone, but throughout the entire county. Again, more traffic, more taxes and more sprawl are the predictable results.

UNFAIRNESS, UNRESPONSIVENESS AND UNREALIZED OPPORTUNITY

Option A is marked by a final set of shortcomings that result largely from the context in which it was enacted. First, the timing of Option A's enactment has created a grave risk that our community will now be unable to put in place a workable transferable development rights program that is mutually beneficial to AR landowners and the general public. Second, as a matter of both process and substance, Option A is widely viewed as unfair. And third, Option A has harmed citizen confidence and trust in our local government for the simple reason that it departs dramatically from the strongly expressed views of a large segment of our community.

1. As our Commissioners considered adoption of Option A, they knew that the state legislature was likely soon to pass a law that would facilitate local implementation of workable transferable development rights (or "TDR") programs. These programs have been used successfully elsewhere to protect rural areas in a way that creates fairness for rural landowners by giving them transferable rights. (For example, in Montgomery County, Maryland, pre-TDR zoning in the rural area permitted one residential unit per five acres. Pursuant to the TDR program later adopted by the county, each rural landowner of 25 acres received one on-site development right and four transferable development rights, thus shifting the overall authorized density in this zone to one-unit-per-25-acres. Rural landowners, however, could then sell their TDRs at a free-market price to landowners in specified non-rural zones, who had to acquire those rights if they wished to build at densities greater than otherwise permitted by law. The practical effect of the program was to channel development to in-town areas from outlying areas in a way that generated a compensatory monetary benefit for rural landowners.) Because our new zoning ordinances simply gave away new rights to develop many urban lots at higher densities, however, it undercut the workability of any TDR program by greatly constricting the potential demand for TDRs. In addition, by simultaneously dispensing new development rights to rural landowners prior to implementing a TDR program, Option A threatens any future program by so greatly inflating the supply of TDRs claimable by AR landowners that those TDRs may lose all value. Our Commission would have been wise to make zoning choices for the AR area in connection with fashioning a new TDR program. Instead, the Commission jeopardized the chances of ever developing a TDR program by forging ahead with Option A.
2. In the eyes of many, Option A is also unfair. It is seen as unfair in part because, in a sort of bait-and-switch fashion, it departed from the goals the Commission had led the community to believe it would pursue for the AR area early on in the planning process. It also is unfair because (as we saw earlier) it needlessly rewards landowners who happen to own largely undevelopable land and favors them arbitrarily over landowners who paid full value for wholly developable tracts. Another form of unfairness results from Option A's distinctive treatment of any "[s]ubdivision of less than ten acres" and in particular its requirement that lots in these have a minimum size of one acre. (See section 9-5-3.) Under a "nightmare" reading of this section, developers can simply exempt themselves from conservation-subdivision open-space requirements so long as they develop AR property in ten-acre increments, and thus build out true cookie-cutter subdivisions on a one-unit-per-one-acre basis all over the AR zone. Fortunately, the more logical reading of this section is that less-than-10-acre residential developments can be immediately put in place only if they are structured as conservation subdivisions in which all lots located on the 50% buildable portion of the tract have a minimum size of one acre. This reading of Option A, however, produces an anomalous result. Why? Because under this interpretation, the smallest landowners end up with significantly fewer development rights than the largest landowners. This is the case because landowners with lots larger than ten acres are permitted immediately to build out conservation subdivisions at an pre-development average density of one-unit-per-acre. Thus, for example, the owner of a 100-acre tract may create 100 residential lots, averaging ½-acre per house, on 50 acres designated for building purposes. Under Option A, however, the owner of an 9-acre tract (if he is authorized to create a conservation subdivision at all) can generate at most four residential lots because, under section 9-5-4, only 50% of the land is developable and, under section 9-5-3, each newly-created buildable lot must have a "minimum lot area" (that takes no account of a subdivision's roads and right-of-way) that is actually (and not merely on average) at least one acre in size. In short, Option A provides the smallest landowners with (at best) an immediate right to develop their land at less than half the average maximum density available to the largest landowners.
3. For many, Option A is also unfair because it reflects a stark departure from, and no meaningful compromise with, the strongly expressed will of a large segment of the citizens of Athens/Clarke County. Representing many members of our community, the Athens Grow Green Coalition and the Athens-Clarke Heritage Foundation publicly opposed Option A. A Steering Committee, appointed by the Mayor and Commission to examine land use throughout the county, expressed a preference for the alternative Option B, or something like it, over Option A. Some 400-500 local citizens attended a candlelight vigil to protest the Commission's adoption of Option A. Hundreds of local citizens personally contacted the Mayor to urge him to veto this action of the Commission. In large numbers, members of the community expressed opposition to Option A by writing letters, speaking out at meetings, and displaying "Stay Green" yard signs. The editorial boards of the Athens Daily News and Banner Herald and of the Atlanta Constitution editorialized against adoption of Option A. These expressions of sentiment were tellingly consistent with recent results at the polls, where voters in November expressed unmistakable support for smart growth and green space preservation. (See Atlanta Constitution 11/13/00: "Athens election called mandate for smart growth"; Athens Daily News and Banner Herald 12/31/00: noting that "voters picked 'green' candidates in two districts" on Nov. 7.) For many local citizens, the Commission's action in adopting Option A reflected an undemocratic decision simply to ignore these many voices.
4. Could it be that the shortcomings of Option A resulted, at least in part, from a lack of focused give-and-take among the full Commission? While it is clearly true that some Commissioners devoted much effort to studying the AR area, it also is true that Option A surfaced while many other issues raised by the countywide rezoning program were pressing for attention. Indeed, at the very meeting that the Commission approved Option A, Commissioner Ken Jordan stated: "We never even got around to discussing AR. We kept putting it off and putting it off." (Athens Daily News 12/5/00).

* * * * *

Perhaps the greatest irony in our Commission's adoption of Option A arises from its timing, for the need for sound and cautious land-use planning has never been more acute. As the year 2000 closed, the U.S. Census Bureau announced what everyone who lives in the Athens area already knew: that population growth in northern Georgia over the last decade has been "staggering" -- in fact "a mind-warping 110,000 additional people every year" in metropolitan Atlanta alone. University of Georgia demographics expert Doug Bachtel captured the widespread sentiment of our community in responding to these numbers. As he stated: "There's a point in time where that growth gets dysfunctional…. Growth for growth's sake is not the way to go.… We've really got to start doing a better job planning for this growth." (Atlanta Journal-Constitution 12/29/00).

Over the past three years our community has insistently asked our Commission to develop forward-looking land-use laws designed to curb sprawl, to reduce traffic congestion, to protect our environment, and to fend off the Atlantification of Athens-Clarke County. Option A undermines, rather than advances, these goals. For this reason, reform is imperative.