Sandoval County commissioners affirm P&Z approval to allow cluster housing in Placitas; appeal denied 3-2

Sandoval County commissioners on Oct. 14 upheld a Planning & Zoning Commission decision to amend a special‑use (SU) designation on a 1.85‑acre parcel in Placitas to allow small‑scale cluster housing, denying an appeal by a nearby neighbor.

Jennica Jacoby, a land‑use attorney with the Rhodey law firm representing appellant Catherine Clark, told the board the P&Z approval was “arbitrary and capricious and in violation of county ordinance” because the commission did not analyze required criteria in the Sandoval County zoning ordinance and the Placitas Area Plan. Jacoby argued the SU parcel historically allowed professional‑office uses and that cluster housing rules limit density to whatever residential entitlement previously existed — which, she said, was none for this site — making the applicant’s proposed density of 3.78 dwelling units per acre unlawful without a proper plan amendment.

“There's no evidence that this property ever allowed 4 dwelling units per acre,” Jacoby…