dissenting:
The proponents’ property was zoned FA-1, which is a farming district residential zone with minimum lot size requirements of 100,-000 square feet or approximately 2.30 acres. Maj. op. at 1341. Under the Larimer County Land Use Plan (the master plan), the proponents’ property was included in a rural area. The master plan specifies that rural uses “should be related to agriculture or other uses requiring large land areas....” The proponents’ subdivision application initially contemplated lot sizes of 3 acres per unit. Later, proponents’ amended their application to include surrounding 35 acre tracts and thereby increase the average lot size to 10 acres. The use sought by the proponents was in compliance with the applicable zoning on the property. However, it did not comport with the master plan.
In my view, the proponents’ property was inappropriately down-zoned by virtue of the master plan. Further, the subdivision regulations only refer to the master plan as a guideline, and the standards set out in the master plan governing a proposed subdivision in a rural area are insufficiently specific.
For those reasons, I do not believe that the county could deny the proponents’ subdivision application on the basis of noneompliance with the master plan, and I therefore respectfully dissent. I would affirm the court of appeals result in Condor v. Board of County Comm’rs of Larimer County, No. 94CA0848 (Colo.App. May 4, 1995), although differing in my rationale for that outcome.
I.
Land use regulation represents an uneasy compromise between private landowner rights and community interests. The power to plan for and regulate the use of land is an outgrowth of the police powers afforded to local governments by the state in order to promote the public health, safety and welfare and to encourage and facilitate orderly growth. King’s Mill Homeowners Ass’n, Inc. v. City of Westminster, 192 Colo. 305, 557 P.2d 1186 (1976).
There is a distinction between planning for the use of land and regulating that use, as we recognized in Theobald v. Board of County Comm’rs, 644 P.2d 942, 948 (1982). See also §§ 30-28-101 to -137, 12A C.R.S. (1986 & 1996 Supp.). Master plans are the broadest exercise of the planning function delegated to local governments. They are initially adopted by county planning commissions1 in order to “accomplish the harmonious development of the county in terms of the general welfare of the inhabitants and the efficient and economic use of its land.” Johnson v. Board of County Comm’rs, 34 Colo.App. 14, 18, 523 P.2d 159, 161 (1974), aff'd sub nom. Colorado Leisure Prods. Inc. v. Johnson, 187 Colo. 443, 532 P.2d 742 (1975). The master plan must include all of the unincorporated territory of the county and is necessarily and definitionally sweeping in scope. As we held in Theobald, the master plan is the “planning commission’s recommendation of the most desirable use of land. Conceptually, a master plan is a guide to development rather than an instrument to control land use.” Theobald, 644 P.2d at 942 (emphasis added) (citations omitted).
The actual regulation of land use, on the other hand, is accomplished first through zoning and second through subdivision regulations with regard to the design of the subdivision and the platting of individual lots therein. Zoning, unlike a master plan, is not *1352merely a guide to development but is instead the direct implementation of land use controls. The effect of zoning is to delineate the permissible and impermissible uses of specific parcels of property. A landowner may not choose to use the property in a way that conflicts with the applicable zoning. On the other hand, when the zoning approval is in place, the landowner, absent a legal down-zoning, cannot be refused the right to make authorized use of the property.
Because it is merely a guideline, a master plan in and of itself can have no direct effect on land use unless it is adopted through proper means. This court has previously recognized two means by which the master plan may become enforceable. First, in Theobald we stated that “[i]n order to have a direct effect on property rights, the master plan must be further implemented through zoning, with proper notice and hearing.” Id. at 950. After Theobald, we decided Beaver Meadows v. Board of County Commissioners, 709 P.2d 928 (Colo.1985). In Beaver Meadows, we recognized that provisions of a master plan adopted in a Planned Unit Development (PUD) plan are enforceable because the general assembly “required that a PUD plan must be in general conformity with the county’s master plan or comprehensive plan.” Id. at 936 n. 6 (emphasis in original) (citing § 24-67-104(1)®, 10 C.R.S. (1982)).2
It is my view of the teachings of our cases and of statutory enactments that a master plan can be enforced as a land use regulation only if: 1) the general assembly acts, as it has in the area of PUDs, to permit incorporation of master plans into certain land use regulations; or 2) the board of county commissioners acts, in compliance with all due process requirements, to incorporate the plan into the zoning ordinances. Absent such actions, a master plan is an advisory document that cannot serve as the basis for denial of a subdivision application.
II.
The question before the court in this case is whether the board of county commissioners may deny proponents’ subdivision application based solely on noncompliance with master plan provisions that the board adopted as part of the county’s subdivision regulation requirements. Maj. op. at page 1344. In light of the applicable authority, I answer that question in the negative.
The majority concludes that to require the master plan to be adopted through zoning ordinances rather than through subdivision regulations would elevate form over substance. Maj. op. at 1347 n. 13. I disagree. First, it is my view that zoning restrictions and subdivision regulations are separate tools with distinct purposes. Zoning ordinances regulate the use of specific plots of land, whereas subdivision regulations set the standards for county approval of a proposed subdivision plat. § 30-128-133, 12A C.R.S. (1996 Supp.). Zoning is limiting and preclu-sive as to authorized uses; subdivision regulations are general and inclusive and are designed to govern the layout and platting of the subdivision. In law schools, property rights are envisioned as a bundle of sticks. Zoning deprives the landowner of some of the sticks in that bundle by reducing the uses to which the land may be devoted. Subdivision regulations, in contrast, do not diminish the bundle of sticks. They merely impose standards that must be followed if the landowner wishes to take advantage of one aspect of ownership by creating individual lots that can be developed and sold.
Subdivision regulations are applicable when a landowner attempts to divide his or her land into multiple individual lots. Subdivision regulations are
intended to protect the community from the creation and development of poorly designed and ill-equipped neighborhoods. These regulations commonly imposed standards for the subdivision of land which required that new streets be efficiently constructed and logically related to the *1353existing street system. They required that the newly developed land be provided with basic services essential to modern living, and that the municipality be protected from the financial impact of initial installation costs. And they required that subdivisions be consistent with the zoning regulations of the community.
Robert M. Anderson, American Law of Zoning § 1.15 (3d ed.1986). Thus, a person who wishes to subdivide his or her land must first look to the applicable zoning ordinance to see if such density and use is permitted and, if so, then meet the requirements imposed by the subdivision regulations.
Presumably because of that difference, the courts and the general assembly generally require more stringent due process when a governmental entity is enacting or amending zoning regulations than when it is adopting subdivision regulations. To enact or amend a zoning regulation, the board of county commissioners must hold a public hearing and give at least fourteen days notice in a newspaper of general circulation in the county. §§ 30-28-112 and 116, 12A C.R.S. (1996 Supp.). The notice must state the place where the full text of the proposal may be examined. Id. In addition, the notice must state the place where a map of the proposal may be viewed. Id. This requirement enables the public to readily discover the exact location of the legal description contained in the public notice.
Strict compliance with notice requirements for zoning is mandatory. The legislative intent in enacting the zoning statute is that “overall plans or changes should be given such publicity as will reasonably inform those owners affected, as well as the public, of what is proposed.” Holly Dev. Inc. v. Board of County Comm’rs., 140 Colo. 95, 105, 342 P.2d 1032, 1038 (1959). The purpose of such publicity is to give fair warning to such persons so that they may appear at the public hearing and have an opportunity to be heard. Sundance Hills Homeowners Ass’n v. Board of County Comm’rs, 188 Colo. 321, 325, 534 P.2d 1212, 1214 (1975). The meaning of the notice must be intelligible to the layman and any ambiguity is to be resolved in favor of the public. Holly, 140 Colo. at 101, 342 P.2d at 1036; Hallmark Builders and Realty v. City of Gunnison, 650 P.2d 556, 560 (Colo.1982).
In contrast, a county’s adoption of subdivision regulations has never been as strictly circumscribed, either by statute or by ease law. While adoption of subdivision regulations does require a public hearing and fourteen days notice in a newspaper, the notice does not need to explain where the exact text may be examined. § 30-28-133, 12A C.R.S. (1996 Supp.). Instead, all that is required is for a copy of the proposed regulations to be filed with the county clerk and recorder of the county. Id. In addition, there is no requirement that a map plotting out the proposed changes be available for public inspection. Furthermore, there is no case law emphasizing an imperative need to ensure that the public is apprised of the proposed changes.
If a landowner is to be precluded from subdividing land on which the zoning would otherwise permit such a use, I view the adoption of subdivision regulations as an inappropriate means of accomplishing that end. That landowner would not have any reason to be on notice that his or her land was being effectively down-zoned through the adoption of the regulations. If the county wishes to achieve that down-zoning, it should do so by specific amendment of the zoning ordinances.3
For instance, Larimer County would have the authority to create a special category of zoning labeled “Rural Residential” in which lot sizes would be required to be larger than in other areas zoned Residential. Such a procedure would preserve the benefits of regulating growth and development in accordance with a general plan, while still protecting the landowner. Under that hypothetical, *1354the zoning on the rural landowners’ property would be changed and the notice provisions associated with amendatory zoning would be invoked. Further, the landowner would be assured that a subdivision application would be reviewed under consistent, specific standards applicable to all similarly zoned property.
The majority suggests that the master plan provisions adopted by the subdivision regulations would be enforceable as to the landowners in this case only if drafted with sufficient exactitude to ensure that any action taken by the county will be rational and consistent and that judicial review of that action will be available and effective. Maj. op. at 1350. The majority remands this case for a determination of whether the necessary exactitude is present.
I share the majority’s factual concern, but it leads me to a different legal conclusion. Zoning requires a higher degree of notice and specificity than the subdivision regulation adoption process. Neither the notice relating to prospective adoption of the subdivision regulations nor the ultimate language incorporated into the subdivision regulation is required to be “sufficiently detailed to provide all users and potential users of land with notice_” Beaver Meadows, 709 P.2d at 936. I would therefore conclude that subdivision regulations, which merely reference a master plan as a guideline, inherently provide inadequate due process protection because authorized uses of land under the applicable zoning resolution may be precluded. Subdivision regulations are an inappropriate vehicle by which to impose constraints on land use; rather their function is to control subdivision design. A master plan can guide the development of subdivision regulations, but cannot control review of a subdivision application.
III.
Further, in my view, Larimer County did not, in fact, adopt the master plan into its subdivision regulations. Compliance with the master plan is not made a specific condition of approval of a subdivision application. Rather, the regulations refer to the master plan as providing guidance. For example, they state that the intent is “[t]o assure that the Master Plan is used as a guideline in all proposals for development,” R. at v. VIII, p. 21, and that the Board of County Commissioners is instructed to “use the Master Plan as a guideline in the evaluation of each development proposal.” R. at v. VIII, p. 24. Moreover, the regulations merely state that “consideration should be given to the Larimer County Comprehensive Plan” (also called the Master Plan, R. at v. VIII, p. 21) in designing and planning subdivisions, R. at v. VIII, p. 47; they do not mandate compliance with the master plan.
Additionally, the master plan itself does not specify the lot size required for subdivisions in rural areas. Rather, the language of the master plan may be read to infer that subdivisions will not be approved at all in the rural areas of the county. The lack of specificity in the master plan provides insufficient notice to landowners and invites inconsistent application.
Therefore, under the terms of the regulations themselves, I do not believe that the board may deny the proponents’ subdivision application based solely on noncompliance with the master plan. The regulations refer to the master plan as an advisory, not a mandatory, document and the master plan itself is lacking in specificity.
rv.
A master plan is just what it claims to be — a planning tool. Absent legislative directive similar to the PUD statutes, I do not believe such a plan can be converted into a land use regulatory constraint unless specifically adopted through zoning resolutions with all the procedural safeguards inherent in that process.
Hence, I respectfully dissent from the majority opinion. I would agree with the court of appeals in overturning the Board of County Commissioner’s denial of the subdivision application.
I am authorized to say that Justice HOBBS joins in this dissent.
. § 30-28-106, 12A C.R.S. (1986).
. However, we found in Beaver Meadows that the regulations inherent in the applicable comprehensive plan set forth standards and safeguards that were insufficient to ensure that county action in response to a PUD application would be rational and consistent and that judicial review of that action would be available and effective. Beaver Meadows, 709 P.2d at 938.
. I do note that zoning is not required in this state, whereas every county must adopt subdivision regulations. If there are counties in Colorado with master plans and without zoning, I would continue to view any attempt by those counties to implement the master plan through subdivision regulations as inappropriate. Uses should not be precluded except through a zoning resolution.