Summary: Buncombe County Commissioners will vote August 18 on a request to change two Kampgrounds of America (KOA)-owned parcels near US 70 from commercial to residential zoning. County staff recommends approval, but its own report says vulnerable populations may live nearby and that an impact analysis is appropriate. Commissioners should not approve the rezoning first and study its effects later; they should require the analysis before the vote and use it as the starting point for a consistent County-wide anti-displacement framework.

The Facts: At its August 18 meeting, the Buncombe County Commission will hold a public hearing and vote on a rezoning request from Kampgrounds of America. KOA wants the County to change two parcels totaling 6.77 acres at 517 Lazy Bear Boulevard and along US 70 from commercial to residential zoning.

The change would make it easier to use the property for housing, including apartments or a manufactured-home park. It would not approve a particular construction plan, and the zoned maximum density would remain 12 homes per acre. Instead, it would change the kinds of projects that KOA or a future owner could propose on the land. The parcels have public water and sewer service, and one lies partly within the regulated 100-year floodplain. Nearby properties include vacant commercial land, manufactured homes, and an RV park.

The staff report says the property has a high score on the Buncombe Community Index, indicating that vulnerable populations may live near the rezoning, and states: “Impact Analysis is suggested for this parcel.” The public agenda materials do not include such an analysis. County staff and the Planning Board recommend approval.

Presentation slides and other materials are available at the County’s Agendas and Minutes portal.

Our Assessment: We are not suggesting that the County should reject this rezoning; residential zoning for these parcels could allow needed housing in an area with water, sewer, and access to a major corridor. Commissioners should, however, understand the likely effects of this change before voting to change what can be built on the property.

The staff report on this issue actually makes a clear case for the kind of anti-displacement framework we’ve been recommending all year. The Buncombe Community Index found a concentration of conditions associated with vulnerability in the surrounding census block group, including poverty, lower incomes, food insecurity, limited education, housing-cost burdens, and lack of health insurance. Manufactured housing and an RV park are also among the neighboring uses. These findings do not prove that the rezoning would cause displacement, but they provide an evidence-based warning and should trigger the next step established in the County’s Comprehensive Plan: identify the potentially affected populations and analyze how the proposed change could affect them.

Several possible risks deserve examination. New housing supply could benefit the community, but there is no indication of what would be built, what it would cost, or whether it would serve households already struggling with housing costs. Market-rate development could increase nearby land values, rents, or redevelopment pressure. Manufactured-home residents could be particularly vulnerable if they own their homes but rent the land beneath them. People using RVs or other nontraditional housing as longer-term residences might face similar risks, although the public materials do not establish whether such residents are present. The analysis should determine whether these concerns apply and whether a project-specific zoning process, affordability commitments, resident protections, or other safeguards are warranted.

That is why we are puzzled that staff recommend an impact analysis, but then don’t provide one and instead recommend that the rezoning be approved. If such an analysis was done, Commissioners could use its findings to engage affected residents, evaluate alternatives, and identify appropriate safeguards before making a final decision. If they move forward with a vote now and approve this rezoning, the County will have less leverage to address any risks it subsequently finds.

We think the Commissioners should defer the vote until the impact analysis their staff recommended has been completed, published, and used to inform the decision. They could then formalize this approach through the scalable framework described in GAPavl’s full proposal, use existing County plans and tools to identify displacement risks before major decisions, match the response to the level of risk, monitor the results, and adjust when necessary.

Things to do: Email the Buncombe County Commission, asking them not to approve the KOA rezoning until the impact analysis identified by County staff has been completed, published, and discussed – and to use that process as the starting point for a consistent, County-wide anti-displacement framework.

Email Template: You can send an email to the Buncombe County Commission by filling out the form below. Our email tool will send an individually addressed email to the recipients, and enable us to track how many emails were sent overall in the campaign. If you prefer to write your own email, you can copy and paste (and adapt) our template text – please cc: or bcc: info@gapavl.org on your individualized email, so we can better track how many emails were sent.

Important: If you receive a response to your email, please forward it to us at info@gapavl.org so we can reflect that in the report back.

To: alfred.whitesides@buncombecounty.org, amanda.edwards@buncombecounty.org, drew.ball@buncombecounty.org, jennifer.horton@buncombecounty.org, martin.moore@buncombecounty.org, parker.sloan@buncombecounty.org, terri.wells@buncombecounty.org

CC: or BCC: info@gapavl.org

Subject: Complete the staff-suggested impact analysis BEFORE approving the KOA rezoning

Dear Commissioners,

I am writing about the proposed rezoning of two KOA-owned parcels near US 70 in Swannanoa. This could be a very beneficial change: the property has water and sewer service, and residential zoning could facilitate needed housing development. I am not asking you to reject that possibility. I am asking you to understand its likely effects before changing what can be built on the property.

The staff report recommends an “Impact Analysis” because the property has a high score on the Buncombe Community Index, indicating that vulnerable populations may live nearby. Nearby uses include manufactured housing and an RV park. Yet staff recommends approval, and the public agenda materials do not show that the recommended analysis was completed. If it was completed, it should be shared before the vote; if it was not, it should be done before the vote.

The analysis may find that the rezoning poses little displacement risk. But it should examine whether new development could increase nearby land values, rents, or redevelopment pressure; whether nearby manufactured-home residents rent the land beneath their homes; whether people use nearby RVs as longer-term housing; and whether the housing construction ultimately enabled by the rezoning would serve people already struggling with housing costs. It should also identify any protections or commitments warranted by those findings.

The County itself flagged the need to ask these questions. If such an analysis is important enough to recommend, it should be completed so it can inform the rezoning decision. Once the rezoning is approved, new development rights will already have been granted and the County will have less leverage to address any risks the analysis identifies.

Please direct staff to:

• Postpone the rezoning decision until the recommended impact analysis has been completed and published.
• Engage residents identified as potentially affected and discuss the findings at a public meeting before voting.
• Use this process as the starting point for the County-wide framework described in GAPavl’s full proposal: identify risks BEFORE major decisions, scale the response to the risk, monitor results, and adjust when necessary.

Buncombe County should know who may benefit, who may be harmed, and what protections are possible before it makes major land-use and public-investment decisions.

Thank you for your consideration.

Sincerely,

[Name]

[Community or neighborhood]