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HomeGateway PlanCity PlanningSuggestions for May 29, 2024: Gateway Area Plan, Gateway Code, General Plan, and EIR

Suggestions for May 29, 2024: Gateway Area Plan, Gateway Code, General Plan, and EIR

To:          Honorable Mayor Meredith Matthews, Vice-Mayor Alex Stillman, Councilmembers Stacy Atkins-Salazar, Sarah Schaefer, and Kimberley White.
CC to:    Community Development Director David Loya, City Manager Karen Diemer
 
From:        Fred Weis
Date:         May 29, 2024
Subject:    Suggestions for review and revision of certain topics of the Gateway Area Plan, Gateway Code, Program Environmental Impact Report, and General Plan Comprehensive Update
 
Note:  This document is submitted pursuant to §1094.5 for the May 29 and June 5, 2024, public hearings and other dates as may be the case.
 
 
Dear Mayor and members of the Arcata City Council —
 
As you must be aware, the Council is in a difficult situation hereYou are being asked to approve a set of documents that are incomplete.
 
Why the Community Development Director and the Planning Commission chose to provide you with deficient documents is an entirely separate conversation. The important thing now is to repair the documents.
 
To the extent that I can, I am going to put aside what I want. (With some exceptions, of course.) I will state “In my view” marked in purple as is appropriate. 
 
Instead, I will offer what I see as what it will take to get these documents into a form that you can, with honesty and integrity, vote to adopt them.
 
Included here are, in my view, the more important or easily fixed missing or incorrect items. There are other issues in these documents — some big ones. But here I am only listing ones that can be quickly fixed.
 
I hope this is helpful.
 
Finally, if you could use 2-1/2 minutes of comic relief, the audio and lyrics of a then-famous folk music group called The Gateway Singers performing “The Ballad of Sigmund Freud” from 1958is at arcata1.com/the-gateway-singers-ballad-sigmund-freud
 
Thank you.
 
— Fred Weis
707-822-4400
 
——————————
How this memo is organized — to make this easier for you. 
Starts with a list, then greater detail, then even more specific detail.
  1. Contents:  A list of the topics
  2. Bullet points:  Short explanations of the topics
  3. Longer explanations and links on some (not all) topics.  
 
Contents
GP = General Plan   GAP = Gateway Plan
 
The 5 largest issues — In order of importance:
  1.  Inclusionary Zoning — easy to correct (GP)
  2.  Protect the linear park and “woonerf” (GAP)
  3.  Ministerial Review (GAP)
  4.  Remove “LU-9” Implementation Measure for upzoning of Bayview, Sunset, Northtown, upper I & J Streets neighborhoods.  (GP)
  5.  Consider removal of LU-1f “Development of a diversity of housing types.” 

Also significant — and some are easy to change

  1.   Protect the L Street corridor trail — General Plan Policy CM-5e-7 —  quick and easy to correct    (GP)
     This change is very easy and will greatly help public perception.
  2.  Environmental Impact Report issues. States requiring central air conditioning as mitigation for traffic noise. Numerous errors of fact. In terms of  a potential lawsuit, I believe the existing Final EIR is vulnerable.
  3.  No requirement for indoor bike storage / secured bike parking — quick and easy to correct    (GAP)
     Increase the requirement for short-term bike parking (currently inadequate)   (GAP)
  4. “Tenement housing” policy  — quick and easy to correct    (GP)
  5.  Gateway Area Plan policies that were transferred to the General Plan — some need re-wording   (GP)
    • IMPORTANT: In my view  any Gateway-worded policies that are in the General Plan should be re-worded or removed before the 5-person City Council has any discussion on the General Plan.

      As long as there are Gateway-specific policies that were transfered to the General Plan and not re-worded with general City-wide wording, the City is vulnerable to a negation of the approval vote, on the basis of disregarding the FPPC recusal rulings. The word “Gateway” and Gateway-appropriate policies can be in the General Plan, of course.

      But a policy cannot, in my viewbe worded as it had been — as though it were in the Gateway Area Plan. Such as General Plan policy D-8n: “Through the Gateway Area community benefit program, allow increased development intensity and simplified development processes for projects that provide….”   In my viewthat is worded as a policy for the Gateway area only.

  6.  Overall notes and comments
——————————
Bullet points
GP = General Plan   GAP = Gateway Plan
 
1. Inclusionary Zoning — easy to correct (GP)
  • There are no currently no specifics on Inclusionary Zoning. 
  • The Council has agreed on the actual numbers, so adding Inclusionary Zoning should be easy. 
  • The Community Development Director wants the specifics of Inclusionary Zoning to be in the Land Use Code. This is okay.
  • What would work is a clearly-written Implementation Measure for adding Inclusionary Zoning to the Land Use Code.
  • Possible wording for this Implementation Measure is below.
  • The intention must be clear.
  • The Director may say that an Implementation Measure is not needed. In my view, it is absolutely needed.  Without it, you have nothing. The Implementation Measure should be declared as immediate.
 
2. Protect the linear park and “woonerf”
  • This has been discussed many times. The current Gateway Code gives no protection to the L Street linear park and woonerf area.
  • The “woonerf” section of the L Street corridor linear park needs to be defined, with aims and goals.
    (Note: The way we’ve been using “woonerf” here in Arcata is not strictly speaking what a woonerf is. We can discuss this at another time. I believe many of us are in agreement about what we are looking for Arcata for this.)
  •  The article on Arcata1.com that speaks to this is:
    A successful woonerf and linear park in the L Street corridor needs Gateway Code policies
    arcata1.com/a-successful-woonerf-and-linear-park-in-the-l-street-corridor-needs-gateway-code-policies/
    Note: That article calls for commercial storefronts along the woonerf section. That may not be feasible, and I will modify that suggestion.
  • A simple change will go a long way. In my view, more is required — but what’s outlined below would be a big improvement.
  • A system for partial protection of the linear park already exists in the Gateway Code but is not now applied to the linear park
  • It is written for “Privately Owned Publicly Accessible Open Space” but could apply to the woonerf section of the L Street corridor.
  • Please see:  “Figure 2-61: Privately Owned Publicly Accessible Open Space” in the Gateway Code. See page 60 in the current “May 14, 2024 v2 Resolution No. PC-24-05” version. 
    www.cityofarcata.org/DocumentCenter/View/14200/Gateway-FBC20240514_PC-Adopted or
    arcata1.com/general-plan-gateway-area-plan-gateway-code-latest-versions/#gateway-code

    Paragraph 8 starts with “In order to activate and enliven open space areas, the following shall be required on sites with ground-floor non-residential uses.”
  • This change would still not project the L Street corridor linear park and woonerf from solar shading caused by adjacent taller buildings. More work will be needed. But it would be a start.
  • Consider having creation of the Linear Park and Woonerf area as an Implementation Measure in order to be certain that the needed protections take place.
  • Solar shading of the linear park is not a theoretical matter. In my view, this is not a question of a “trade-off” or an accommodation for providing housing. If the L Street linear park is in shadow for all but a few hours of the day — Spring, Summer, Fall, Winter — thenin my view we will have failed to create and preserve a vital, vibrant, wonderful area of Arcata.
 
3.  Ministerial Review: The Zoning Administrator (David Loya) would be the single person approving buildings up to four stories.   (GAP)

  • This is a large issue, and can be put off until the June 5 meeting or longer if needed.
  • As the change to the Gateway Code states, the Zoning Administrator (David Loya) would be the single person approving 4-story buildings. 
  • For almost a year, it was set that 4-story buildings would go to the Planning Commission.
  • Despite the Planning Commission Chair stating that this would not be changed, it was changed.
  • The change was made by the Community Development Director, without any discussion with the Planning Commission.
  • The change was likely made to clear up a poorly-written section of the Gateway Code.
  • The change is not shown as a “tracked change” in the Gateway Code document.
  • To make such a substantial change without having this be clear to the PC and the Council is a very bad process.
  • In my view:  For at least five projects or five years — or longer — all Gateway projects should come before the Planning Commission. There is very little downside to this, and much strength for improvements to the projects. See below for more on this. It is likely the Community Development Director will disagree — but for different reasons than what I am talking about.
 4.  Remove “LU-9” Implementation Measure for upzoning of Bayview, Sunset, Northtown, upper I & J Streets neighborhoods.  (GP)
  • By having this as an Implementation Measure, it is almost guaranteed that this will be accepted as General Plan policy.
  • In my viewthis should be the other way around. I suggest removing this from the General Plan as an Implementation Measure. The General Plan can be amended to include this re-zoning later if a future Council so wants.
  • As it is, it would be very easy for a Planning Commission two years from now enact this Implementation Measure. To include this as an Implementation Measure would show the Council’s support of it.
  • This measure would allow four and possibly five-story (with State density bonus for low-income student housing) buildings in a Neighborhood Conservation area.
  • The clause “Rezone in Neighborhood Conservation Areas should recognize key design characteristics of these
    neighborhoods.” has already proven to be easily over-ridden and of very little value.
  • Even more important and more likely in my view is the addition of “Local” or “Neighborhood-serving commercial uses” includes convenience stores, hair salons, coffee shops, small retail stores, sandwich shops and restaurants, and so forth.
    These would be approved, likely, by the Zoning Administrator. If an existing single-family rental home were to be converted to a coffee shop/sandwich shop (open 12 or more hours a day) or to office use, the neighbors would not even have to be informed, as the change would be permitted.
  • For a fictitious representation of what four-story buildings might look like in the Bayview neighborhood, see:
    Four-Story Buildings do not belong in the Bayview, Sunset, and Upper I & J Street Neighborhoods
    arcata1.com/no-4-story-buildings-in-bayview-sunset-i-j-streets/
    Bayview fake 11-Union 1.jpg
    Bayview fake - Dentist office 12-B.jpg
 
5. Consider removal of LU-1f  — “Development of a diversity of housing types.”  (GP)
  • This policy calls for “an appropriate balance between single‐family housing on individual lots and multi‐unit housing types.” 
  • This is a carry-over from the General Plan 2020. 
  • In my view, this policy is obsolete and invites liability.
  • In my view this cannot possibly be accomplished as described.
  • In my view this is essentially an invitation to a future lawsuit from the Realtor or builders associations. 
  • Please consult with the Community Development Director on any potential downside to just removing it entirely.
 
Also significant — and some are easy to change
1.  Protect the L Street corridor trail — General Plan Policy CM-5e-7  (GP)

  • This is a very minor issue — and quick and simple to fix. 
  • This changewill greatly help public perception.
  • The current policy looks as though it protects the L Street trail. But as it is worded, it does not.
  • The “no net loss of trails” part of the policy is very good. The Council has already voiced your support of that. But when wording on the L Street trail was inserted into the policy, it was not written so as to absolutely prevent that trail from being moved.
  • In my view, it is very unlikely that the L Street path will be moved. So why not put this into writing?
  • In the interest of reducing the anxiety of people who are currently upset, Policy CM-5e can be easily modifiedAdding or changing ten words or so will take the Council three minutes to accomplish. If you choose to do this before oral communications, it will save time, I would think — and change complaints into gratitude.
  • Suggested alternatives for changes to the wording of this policy are below.


2.  Environmental Impact Report issues.
  • There are too many errors in the Draft EIR and Final EIR to list here — errors of fact.
  • In my view this is a highly potential “attack point” for the City’s vulnerability to a future lawsuit. 
  • It is clear from the timing and lack of discussion that the Planning Commissioners did not review the Final EIR document.
  • As just one example, the EIR recognizes that traffic noise may have already exceeded allowable standards in certain sections of Arcata, including along Alliance Road and K Street. What is proposed as a “mitigation measure” is to have the the developers — at their expense — do an accurate sound-level measurement survey (which the EIR engineers did not do — instead they relied on data from 1997). And then — and I am not making this up — require the building’s developer to install a central air conditioning system…so that tenants can keep their windows closed, in order to keep the noise out.
    This is wrong on so very many levels, not the least of which is climate-change issues from energy use from air conditioning.
    A more appropriate mitigation measure would be to have the traffic on Alliance and K Street slow down.  Lower speeds equate to less traffic noise. But that is not what the EIR supplies as a mitigation.
  • The Environmental Impact Report is deficient in dozens of ways. It is just a report, and does not  have to be factual. But: By voting on  it and certifying it, the City Council is attesting to your approval. If that’s not what you want to do, then schedule an extension to study this further.


3. No requirement for Indoor bike storage / secured bike parking — quick and easy to correct    
Increase the requirement for short-term bike parking (currently inadequate)   (GAP)

  • The Gateway Code does not require indoor bicycle storage for tenants or employees.
  • The Community Development Director told the Planning Commission that indoor storage was required, multiple times. This was not true.
  • In the current Code, all that’s required is that there be a security camera. It is not even required that there be a fence.
  • How this got past the bicycle-advocate community here in Arcata is a mystery to me.
  • To see pictures of what indeed is possible according to the Gateway Code, see What does the Gateway Code say about Tenant and Employee bicycle parking?  arcata1.com/gateway-code-tenant-employee-bicycle-parking/
  • Short-term bike parking (restaurants, stores, friends visiting, office visits, etc) is inadequate. 
  • A 2,000 sq.ft. restaurant that could hold 80-100 diners would be required to have only 4 bike parking spaces. For the staff of that restaurant, it would require only 1 space.  In my view this sends the wrong message about what we are promoting in Arcata on bicycle use.
 

4. “Tenement housing” policy(GP)
  • Very simple to correct.
  • The LU-2b policy had said:
         “Tenement housing shall be allowed in zoning districts where applicable.”
    The City Council wanted this line removed. Instead, this was incorrectly changed to:
         “Co-housing shall be allowed in zoning districts where applicable.”
  • We all agree that “tenement” is a terrible choice of words. There is a definition of “tenement housing” that fits what the policy refers to, but it’s a non-typical use.
  • “Co-housing” is not what this is. That is an error.
  • What this policy is referring to is:  Housing that has a shared bathroom and, optionally, shared kitchen arrangements. Some SRO housing is in this category, but not (I think) all SRO housing.
  • In my viewthe concept for this style of housing is sound. As a personal aside, I lived in a “no kitchen at all, bathroom down the hall” long-term hotel housing as a community college student in my 20s for 1-1/2 years, and it worked great for me. I’m very fond of this style of housing as an economical alternative.
  • It can be put in the General Plan as just what it is:
    Housing that has a shared bathroom and, optionally, shared kitchen arrangementsshall be allowed in zoning districts where applicable.”
  • The Community Development Director may say that this is already allowed, and does not have to be concretely stated.  In my viewthere is a definite advantage to stating this explicitly.
 
5.  Gateway Area Plan policies that were transferred to the General Plan — some need re-wording   (GP)
  • There were (I think) 86 or 87 policies that were developed for the Gateway Area Plan that were transferred to the General Plan.
  • Some require further re-wording, as they still are worded as specific to the Gateway area.
  • Examples include D-8n and D-9o (General Plan page 5-17, PDF page 212)
  • As the Council knows and has discussed, there are four Opportunity Zones, of which the Gateway area is one. In time, each will have their own individual form-based code and (likely) community benefits program.  Policy LU-1y states this clearly.
  • Therefore, any reference to “the form-based code” or “the community benefit program” as a singular (not plural) code or program needs to be corrected. Examples are:  LU-3f, LU-1t, 5.2 Policies. Gray areas (could be improved) include LU-1aa, D-8, D-8a, and the Contents. Correct usage is LU-1y.
    This is non-negotiable. In my view it is a matter of simple English. The Community Development Director has disagreed.  
  • IMPORTANT:  As long as there are Gateway-specific policies that were transfered to the General Plan and not re-worded with general City-wide wording, the City is vulnerable to a negation of the approval vote, on the basis of disregarding the FPPC recusal rulings. The word “Gateway” and Gateway-appropriate policies can be in the General Plan, of course. But a policy cannot, in my viewbe worded as it had been — as though it were in the Gateway Area Plan. Such as General Plan policy D-8n: “Through the Gateway Area community benefit program, allow increased development intensity and simplified development processes for projects that provide….” In my viewthat is worded as a policy for the Gateway area only.
 
 
Overall notes and comments

  • What I have listed here are not all the issues in these documents. As I have noted elsewhere, the Gateway Code was in many ways written in an imprecise and sloppy manner. Some of that has been corrected and some not.
  • There are a variety of policies and topics that in my view do not reflect the discussions of the City Council and of the Planning Commission — and particularly do not reflect the conversations and recommendations of some City Committees.
  • I have noted in this memo some of the areas in which in my viewthe City is opening itself to potential future legal action. Much of these vulnerable areas can easily be fixed.
  • While there has been much commendable effort to remove misspellings, typographical errors, and other accepted English-language efforts from these City documents, some still remain.
  • There are still a substantial number of factually-incorrect statements and information in these documents. Whether this matters or not is up to the Council. For example, to refer to the Tom Perrett’s Tomas / Open Door Clinic building as “a one-story metal industrial building” is about as false a description as it can be.
  • It is my view that the Planning Commission has not done its job. They have not supplied you, the City Council, with documents that can be approved.  In my view this has made your task a great deal more difficult. Your choices include:
    • Noting what you want changed, and returning the documents to the Commission.
    • Making the changes you’d like to see on your own.
    • Accepting what are in my view deficient documents.
    • A blend of the above.
Important:
  • Over this past time of over two years, the Community Development Director has made notes about revisions and additions as discussed by the City Council and the Planning Commission. 
  • In what I regard as a too-great number of cases, the revisions he has made to the General Plan and Gateway Area Plan documents were deficient or incorrect. 
  • In my viewit has been far too often the case that in those areas where he disagreed with the decisions of the Council or Commission, there were errors, omissions, or a complete disregard for decisions of the Council or Commission. This can be documented.
  • In my viewI regard this a very unfortunate situation. This is why, in my view, I do not regard the Community Development Director as reliably interpreting the decisions of the City Council or Planning Commission.
  • This can be seen in small items — such as the Council’s directive to remove the line on “Tenement housing” and seeing the Director instead insert “Co-housing” as his choice of wording — and on very large matters — including a failure in my view to adequately plan for the Linear Park and Woonerf in the L Street corridor.
I wish the Councilmembers the best of good wishes in getting these documents straightened out.
 
————————
Miscellaneous notes and further information
 
Not complete, but may be useful as included here.
 
 
1.  Inclusionary Zoning   (GP)
Foremost of what is absent is any specifications on Inclusionary Zoning. The Council has agreed on the actual numbers, so adding Inclusionary Zoning should be easy. The Community Development Director wants the specifics of Inclusionary Zoning to be in the Land Use Code. The Land Use Code is not being discussed at this time.
 
What would work is a clearly-written Implementation Measure for adding Inclusionary Zoning to the Land Use Code. It would be listed in the Land Use Element of the General Plan, likely on page 2-26 with the other Land Use Element Implementation Measures. It would be worded somewhat like LU-1, such as:
LU-10  City-wide Inclusionary Zoning.
Revise the City’s Land Use Code so that land use regulations provide for Inclusionary Zoning in a manner that is consistent with figures and specifications as determined by the Community Development Department and City Council. 
Time Frame:  Year 1.
This can be worded differently, but the intention must be clear.
 
 
2.  Protect the linear park and “woonerf” (GAP)
See above.
 
3. Ministerial Review:  The Zoning Administrator (David Loya) would be the single person approving buildings up to four stories.  (GAP)
 
This is a larger issue than can be discussed at the May 29 meeting, I think. Tabling the discussion until the June 5 meeting (or later) may be more productive. 
 
The building heights of projects that get approved by the Zoning Administrator versus by the Planning Commission was changed.
It was changed without any discussion, and the change is not shown in the “tracked changes” document. 
 
Skip or skim this section if you want.
 
For almost a year, the draft Gateway Code had the approval of new building projects be set as Zoning Administrator approval for buildings up to 3 stories (40 feet height, actually — including the roofline) and a Planning Commission hearing set for buildings at 4 stories (over 40 feet) and higher. 
 
Even though Planning Commission Chair Scott Daviesat the Commission’s April 23, 2024, meeting, said that this would not be changed — that it was  not open to discussion by the Planning Commission —  this level of building heights was indeed changed.
 
To be fair, the way this was written in the Gateway Code was clumsy. It needed to be improved. It was yet another example of the lack of attention to detail that we saw in the Gateway Code document.
 
But to change this at this late date — and without any discussion or track-change notice — is very bad…and wrong.
 
In his speaking, Community Development Director David Loya regularly refers to “ministerial review” as though it were a virtual automatic approval process that is done by a single person. This is not true.
 
The City’s Form-Based Code consultant, Ben Noble, pointed out the differences between “zoning administrator” review and ministerial review that includes Planning Commission review.
Ben Noble spoke on Ministerial Review at his first workshop (remotely) on June 29, 2022. 1 hour 34 minutes
It starts at about 59 minutes in. On YouTube it’s at:  youtu.be/owRO-PuQA7M?si=3lBCKNOKZPrSqoht&t=3527
Unfortunately the voice is muffled. 
On Arcata1.com is a full transcription and enhance audio of the workshop, with participants’ questions, and a full table of contents so you can jump to the section you want.
The ~20-minute section on Ministerial Review is here:  arcata1.com/ben-noble-fbc-june-29/#Recommended-M
 
What I believe is best for Arcata
 
With the notion of objective standards of the form-based code, a project must (by State law) in theory be approved if it meets the objective standards. But in the real world nothing is black and white. There is often room for interpretation. I would far rather have the seven sets of eyes, brains, and the collective experience and sensibilities of the entire Planning Commission look at every project — every single project.  As we have seen, if it’s a good project, it sails right through.
 
With approval based on objective standards, this is not an adversarial situation. To repeat:  The projects will be approved. With Planning Commission participation, the projects will also be improved. Very often the developers appreciate these suggestions.
 
The development of a Form-Based Code is new for Arcata. The Planning Commission recognizes that they will have to “tweak” and adjust the Gateway Code periodically — after they see what policies of the Code and the Community Benefits Program are working and which are not.
 
If the Planning Commission does not see the projects at a hearing, how are they going to know “give and take” was part of the approval process? 
 
By State law, these projects will be approved. And by having input from seven Commissioners — plus input from the Community Development Director and from the public — a project will become even better
 
How Redwood City does Ministerial Review with their form-based code — for 13 years now — is shown at Redwood City has PlanComish review   arcata1.com/how-redwood-city-handles-ministerial-planning-commission-review/
 
 
 
4.  Remove “LU-9” Implementation Measure for upzoning of Bayview, Sunset, Northtown, upper I & J Streets neighborhoods.  (GP)
See bullet points above.
 
 
 
5.  LU-1f  “Development of a diversity of housing types.”
From the ” May 29, 2024 Draft” page 2-9. PDF page 36. Highlighting added.
 
LU-1f  Development of a diversity of housing types.
The land use plan map shall provide enough land in the various residential use categories to allow for development of a variety of types of new housing units and residential environments. The purpose shall be to achieve an appropriate balance between single-family housing on individual lots and multi-unit housing types.
 
From the General Plan 2020.
Land Use Element, page 2-9.  Highlighting added.
” LU-2b Diversity and choice in residential environments.
The land use plan map shall provide sufficient quantities of land in the various residential use categories to allow for development of a variety of types of new housing units and residential environments. The purpose shall be to maintain an appropriate balance between single-family housing on individual lots and multi-unit housing types. The City shall encourage residential developments which collectively provide a variety of choices
———————-
 
Less significant, but still important

1.  Protection of the L Street corridor trail — General Plan Policy CM-5e-7  (GP)

This is a very minor issue — and quick and simple to fix. As I have explained to the 20 or so people who have contacted me about this, the chance of the L Street trail being moved is very small. But as the “no net loss of trails” policy is written, the policy does not explicitly prevent the L Street trail from being moved.
 
The “no net loss of trails” part of the policy is very good. The Council has already voiced your support of that. But when wording on the L Street trail was inserted into the policy, it was not written so as to absolutely prevent that trail from being moved.
 
CM-5e has been controversial for reasons that can very easily be removed.
 
In the interest of reducing the anxiety of people who are currently upset, Policy CM-5e can be modified. Adding or changing five or ten words will take the Council three minutes to accomplish. If you choose to do this before oral communications, it will save time, I would think — and change complaints into gratitude.
 
The current policy looks as though it protects the L Street trail. But as it is worded, it does not.
Currently:
  7. In general, retain and expand the current total linear feet of Class I trails within the City, including the L Street segment of the Bay Trail North/Annie Mary Trail. even i If current facilities must be realigned or relocated to other routes, ensure no net loss of trail length and connectivity. In limited circumstances, the City shall retain the discretion to allow an applicant to demonstrate removal or relocation of Class I Trail sections would improve active transportation access and connectivity. Collaborate with the Great Redwood Trail Agency and other landowners and agencies to retain and expand the Class I trail and Class 4 bikeways throughout the City.
 
Possible addition to CM-5e:

“This policy specifically does not allow sections of Class I trail in the L Street Corridor to be relocated or removed from that L Street Corridor, unless it is to be replaced with separated bicycle and pedestrian pathways within that same corridor.”

Or simpler:

“The L Street corridor trail will not be relocated or removed out of the L Street corridor.”

Or even simpler:

“The L Street corridor trail will not be relocated.”

But there is some ambiguity here, in that “relocated” could mean just moving it a foot or two. So the 2nd wording is probably better.

Since the City (and David Loya) seem to be absolutely positive that the L Street Linear Park pathway will not be removed or relocated, it would make sense to add one sentence to the Policy so that any future reader knows exactly what is allowed and what is not allowed. It could be argued that the section of the Great Redwood Trail system that will be running through the L Street corridor will not be removed or relocated.

I say, great: Let’s put that in writing.
The Arcata1.com article that covers this is https://arcata1.com/l-street-stays-in-place but not necessary for you to read it.