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Dear Commissioners:
The Coalition for Responsible Transportation Priorities (CRTP) continues to strongly support the Gateway Area Plan for its focus on encouraging equitable infill development designed to support walking, biking, rolling and public transit as primary modes of transportation. The implementation of the Plan relies on the proposed Gateway Area form-based zoning code (“draft code”), and we are pleased to have the opportunity to comment on that draft code now.
For the most part, the draft code lives up to the promise of the Plan to encourage a walkable, bikeable, transit-oriented community. We particularly support reduced parking mandates, strong “pedestrian realm” and trail/greenway design standards, transportation demand management (TDM) measures such as unbundled parking, and frontage standards to create a welcoming pedestrian environment.
However, there are areas where the draft code could and should be strengthened, including:
1. Eliminate all remaining parking mandates for existing and future uses.
2. Remove setback and de facto setback requirements.
3. Increase minimum heights and densities.
4. Prohibit structured and podium parking and do not allow garage doors on public streets.
5. Require adequate long-term and short-term bike parking.
6. Allow a car-free community square.
7. Ensure efficient and objective project review and avoid future planning conflicts.
8. Consider increasing required non-residential ground floor frontage area.Following are our detailed comments:
1. Eliminate all remaining parking mandates for existing and future uses.
The draft code has eliminated minimum parking mandates for most future land uses (see Table 2-32), a decision we strongly support. However, parking mandates are retained for “employment uses” and hotels. This is illogical and unhelpful. The same reasons to eliminate parking mandates for residential and commercial uses apply to these other uses as well: the mandates have no scientific basis, they encourage and subsidize driving, and they create significant unnecessary costs and logistical difficulties for new development.
Additionally, Section 9.29.080.B states that “all off-street parking and loading requirements” that apply elsewhere in the city also apply in the Gateway Area, except for “all land uses established after the Gateway Area Plan is adopted.” This implies that existing uses must maintain compliance with minimum parking mandates found in adopted city code. This requirement is unnecessary, inconsistent with the goals of the Gateway Area Plan, and could prevent the productive reuse of areas currently devoted to parking.
All minimum parking mandates should be eliminated for both existing and future land uses in the Gateway Area.
Additionally, we ask that Section 9.29.080.F.4 be amended to prohibit parking areas beside buildings as well as in front of them. In other words, all parking areas should be behind buildings. Parking lots between buildings create an unwelcoming pedestrian environment.
2. Remove setback and de facto setback requirements.
The best practice for creation of a pedestrian-friendly neighborhood is to build to the edge of the sidewalk or pedestrian zone. This both creates a more welcoming, person-scale pedestrian environment, and allows development at higher densities to support greater walkability. The Gateway Area is meant to be a pedestrian-friendly environment, but instead of build-to lines (BTLs) at or near the sidewalk, the draft code requires significant setbacks on most street-facing frontages (see Tables 2-21, 2-23, 2-25 and 2-27). It is possible that these “setbacks” are meant to accommodate the pedestrian realm dimensions specified in Section 9.29.070.A, but this is not specified, and the dimensions do not fully align. In any case, Section 9.29.070 will itself accomplish the goal of a setback occupied by an enhanced pedestrian environment without the need for additional setback requirements elsewhere.
Although similarly unclear, maximum allowable setbacks in the code are also far too large. As one example, Section 9.29.050.A.3 allows up to 25 foot setbacks on “active” frontages. If this is read to allow “pedestrian-friendly” building to be set back up to 25 feet from the sidewalk or pedestrian zone, it will create a distinctly pedestrian-unfriendly environment. In many other cases, the draft code includes no maximum setback at all, further exacerbating this problem.
Additionally, Section 9.29.060.G.2 specifies that ground-floor frontage standards meant to enhance the pedestrian environment do not apply if a building is set back more than 20 feet from a sidewalk. Combined with the minimum and maximum setbacks found in Tables 2-21, 2-23, 2-25 and 2-27, this could allow or even require buildings to be set far back from the sidewalk while
providing no pedestrian frontage enhancements.
The draft code also creates de facto setbacks in the form of excessive minimum frontage zones for residential buildings. Table 2-30 establishes minimum pedestrian frontage zone widths which are greater for residential frontages than for “active” non-residential frontages (15 feet vs. 5 feet). We strongly support frontage zones on busy sidewalks. However, a frontage zone should be where the building and its activities interact with the sidewalk—creating space outside of the pedestrian clear path for active uses—not a passive buffer or setback from the sidewalk. As such, it does not make sense for the zone to be bigger for residential frontages than for public-facing commercial frontages. Uses such as “landscaping” listed for residential frontage zones in Section 9.29.070.B.2 betray that the intended purpose of this extended “frontage zone” is likely as a setback, which is neither necessary nor appropriate. 5 feet is a reasonable minimum frontage zone for all building types, as it can accommodate outdoor dining and displays for commercial frontages as well as features such as stoops and doorways for residential frontages. While some developers may desire a larger zone for ground-floor residential to accommodate specific design features, we can think of no compelling reason to require it, and doing so effectively reduces potential housing production and density without adding to the quality of the pedestrian realm.
We strongly encourage you to remove all minimum setbacks, as well as de facto setbacks in the form of extended residential “frontage zones,” and instead establish BTLs at the back of the pedestrian zone in all Gateway sub-districts, with BTL percentages of 75% or greater.
3. Increase minimum heights and densities.
We reiterate our request that minimum building heights in the Gateway Area be increased from 2 stories to 3 stories (see Tables 2-22, 2-24, 2-26 and 2-28). Additionally, this minimum height should apply to all buildings. Currently, a footnote in each of these tables indicates that the minimum height applies only to residential uses, leaving open the possibility of low-density commercial or mixed-use buildings. Walkability and bikeability requires not only residential density but also a dense mixture of uses, keeping homes and businesses close together. This makes building height important for all uses, since taller buildings allow for more homes and businesses close together.
The minimum residential density for Gateway Ministerial Permit eligibility should also be increased. Currently, Section 9.29.020.B.3 proposes a minimum of only 25 units/acre, which is quite low; it could conceivably be achieved with small single-family homes with accessory dwelling units (ADUs). Furthermore, allowing a ministerial approval pathway for a mixed-use project that devotes 2/3 of floor area to residential with no corresponding density requirement could allow for very low-density projects. After increasing the minimum dwelling units/acre, the two criteria listed in Section 9.29.020.B.3.a should be connected by “and” (not “or”) to ensure appropriate residential density in all projects.
Finally, the potential for building height to contribute to walkable and bikeable density should not be overly constrained by stepback requirements. In particular, the “enhanced upper story step back” requirements proposed for certain locations (see Figure 2-38) should be eliminated. Theyare justified as being necessary to mitigate impacts on adjacent low-density residential uses, but their application on the proposed map appears haphazard. As proposed they will unnecessarily lower density without creating an orderly transition of uses.
4. Prohibit structured and podium parking and do not allow garage doors on public
streets.
Parking garages and podium parking simply cannot create a pedestrian-friendly environment, no matter how they are screened or obscured. Section 9.29.060.I.2 attempts to mitigate the potential impact of such structures, but experience in countless cities and towns shows this will never be fully successful. Furthermore, some of the standards proposed for obscuring structured parking, such as “the appearance of habitable use,” are clearly subjective and therefore not appropriate for a form-based code. Instead, structured parking—including podium parking—should simply be prohibited in the Gateway Area.
Section 9.29.060.I.2 also limits the number of garage door openings onto street frontages, which we appreciate. Again, however, this is a partial measure which will fail to create a fully welcoming pedestrian environment, and in this case will pose actual safety risks to pedestrians. Garage doors should simply be prohibited from facing public streets.
5. Require adequate long-term and short-term bike parking.
Paragraphs 1 and 2 of Section 9.29.080.G, regarding bike parking, seem to provide two different and contradictory forms of a bike parking requirement. Paragraph 2 specifically refers to vehicular parking mandates which will not apply in the Gateway Area and inappropriately ties vehicle parking—which the city should be discouraging—to bicycle parking—which the city should be encouraging. Paragraph 2 should be removed from the code.
It is also important to differentiate between short-term bike parking, required for residential guests and visitor-serving uses, and long-term, secure, weather-protected bike parking, required for residential and employment uses. We request that the employment and residential use bike parking requirements listed in Table 2-34 (mislabeled “12-34”) be clarified as requiring longterm secure parking spaces, and that a smaller number of short-term bike parking spaces also be required for these uses. Secure, weather-protected facilities at home and at work are critical for the feasibility of biking as a mode of transportation.
6. Allow a car-free community square.
Section 9.29.090.B.2.c requires the future community square in the Barrel District to have “street frontage on at least 2 sides.” This implies that there must be vehicular access to the square. Arcata already has a Plaza with vehicular access on all sides, and has retained it despite substantial support for a car-free Plaza over many years. There is no reason to preemptively foreclose on the possibility that a new public square could be car-free, particularly in the Gateway Area. We request that you remove the requirement for street frontages for the Barrel District community square.
7. Ensure efficient and objective project review and avoid future planning conflicts.We reiterate our concern that having the Planning Commission review certain projects for their conformance with objective standards (see Table 2-19) will be a frustrating and ultimately unproductive exercise. We suggest that conformance with code standards be determined by a more appropriate review authority such as the Zoning Administrator.
Additionally, although we appreciate the intent of the contemplated Barrel District Master Plan, we are concerned that the future planning process to develop this Master Plan would be redundant with the present planning process and could result in inconsistencies within the Gateway Area Plan. We suggest that the goals of a Master Plan could perhaps be achieved simply by applying the concepts in the Gateway Area Plan and the standards found in the draft code, avoiding an additional lengthy and potentially conflicting process for planning development on the same area of land.
8. Consider increasing required non-residential ground floor frontage area.
Section 9.29.050.A defines “active” frontages as explicitly non-residential, and this term is used throughout the code. We find this term misleading and confusing, as ground-floor residential frontages also can and should be designed to create an “active” and welcoming pedestrian environment. We request that you remove the term “active frontage” from the code and describe these frontages more accurately as “non-residential ground floor.”
Figure 2-36 shows a small area where “active” (non-residential ground floor) frontages are required, primarily along 8th and 9th Streets. We believe that non-residential ground floor frontages are most valuable along current and planned major corridors, which include not only 8th and 9th but also K Street and Samoa Boulevard, and we encourage you to consider expanding the required area to include these corridors.
Additional Comments
We submit the following additional comments on the draft code:
• We reiterate our suggestion that the city re-name the sub-districts within the Gateway
Area in consultation with the Wiyot Tribe (see Section 9.29.010.B).
• The list of transportation demand management (TDM) measures found in Section
9.29.080.C is not a complete list of effective measures in all circumstances. Measures not
listed include employee shuttles, guaranteed ride home programs, health insurance
premium discounts, work schedule flexibility, and more. The text should be amended to
note that the list is not exhaustive, and also that the TDM plan requirement cannot be met
solely with measures that are already required elsewhere in the code.
• Section 9.29.070.B.4 implies that street trees are required, but provides only a minimum
spacing (not a maximum). With no maximum spacing, a developer could conceivably
meet the requirement with a single tree.
• Section 9.29.020.D.4.b requires non-residential projects to be very large to be eligible for
a Gateway Use Permit. However, the goal of development in the Gateway Area should be
intensity or density, not size. We suggest that the job and commercial square footage
thresholds should be set relative to lot size, not as absolute numbers, to allow for
moderately sized but high-intensity projects.• Table 2-19 includes an apparent internal inconsistency. As currently written, it appears
that projects 40-47 feet in height could either get a Zoning Administrator or Planning
Commission hearing, with no clarity provided on the circumstances under which each
review authority would apply.
• Section 9.29.080.A should provide a clear definition of “greenway,” including how it
differs from a “linear park” (Section 9.29.090.C). Additionally, it is unclear why such a
large “frontage zone” setback is required for greenways (see Table 2-31).
• Section 9.29.080.F.2.a should allow two one-way curb cuts or one two-way curb cut, not
both.
Thank you for your consideration of our comments.