10-20-2025: RE: No. M-25-380 -Proposed Amendments to CZO Sections 1, 2, 3, 4, 19 & 24
October 20, 2025
City Planning Commission
1300 Perdido Street
New Orleans, LA 70112
RE: No. M-25-380 -Proposed Amendments to CZO Sections 1, 2, 3, 4, 19 & 24
Dear City Planning Commission,
Louisiana Landmarks Society supports the staff recommendation and respectfully requests that the City Planning Commission defer consideration of M-25-380. These proposed amendments to the Comprehensive Zoning Ordinance require more thorough public review and clearer legal justification before adoption.
Major Concerns:
1. "Public Need or Benefit" Standard for Conditional Uses The proposed change to conditional use language fundamentally alters the evaluation framework without explaining how this vague standard will be applied. The Commission should provide clear definitions, examples of how this differs from current requirements, and opportunity for meaningful public input before adopting such a significant policy shift.
2. Elimination of Defective Notice Protections The proposed elimination of any recognition that notice can be defective or absent undermines basic due process protections. Property owners and residents have a fundamental right to proper notification of actions affecting their properties. Eliminating the ability to challenge inadequate notice removes accountability and may create legal vulnerabilities for the City.
3. Reorganization of Nine Criteria Without Explanation The motion provides no clear explanation of why the reorganization is necessary, what substantive changes are intended, or how reordering might affect the evaluative framework. This appears to be more than housekeeping and warrants detailed justification.
4. Lack of Clarity on Council Variance Authority The amendments fail to provide clarity on the current policy, process, and procedures that are being used by the Council to approve variances, including where the authority is derived. Given the significant impact these decisions have on neighborhoods, the legal basis and transparent standards must be established.
5. NPP Waiver Authority The motion does not explain how the Council can waive Neighborhood Participation Program requirements when the Home Rule Charter clearly mandates them without providing a waiver mechanism. This raises fundamental questions about Charter compliance and undermines community engagement.
Request for Deferral
Louisiana Landmarks Society respectfully requests deferral until:
1. Comprehensive legal analysis is provided, particularly regarding notice requirements, Council variance authority, and NPP waiver provisions
2. Detailed justifications for each amendment are made publicly available
3. Adequate time is provided for meaningful public review and comment
Our zoning ordinance is fundamental to protecting property rights and neighborhood character. Changes of this magnitude deserve careful consideration, not rushed approval.
Thank you for your consideration.
Sincerely,
Sandra Stokes
Chair of Advocacy
Louisiana Landmarks Society