This letter was written February 13, 2022. It is an excellent summation of some major issues of the December 2021 Draft Gateway Area Plan.
It was submitted to the Planning Commissioners as part of the packet for the April 12, 2022 meeting — two months after it was written and received by the City of Arcata. The letter was also printed in the May 5, 2022 issue of the Mad River Union, and has been posted in its entirety on Facebook.
Andrea Tuttle has a Ph.D. in environmental planning. She is a former director of the California Dept. of Forestry and Fire Protection (CDF), a past member of the California Coastal Commission and of the California Regional Water Quality Control Board (North Coast), and as a principal consultant in the state Senate. She has participated as an observer to the United Nations Framework Convention on Climate Change for the past 12 years.
“3500 units is a mathematically-derived number. It is NOT a “factual” number that reflects the carrying capacity of the city to support such growth. It has no relationship to the ability – or desire – of the town and infrastructure to accommodate that many people.”
“Do not assume that a 20-year planning horizon means that growth will be metered out over time and that impacts will be gradual. In fact, especially under ministerial permitting, savvy investors and developers will immediately cherry-pick development sites before city-provided amenities (e.g. transit, trails) can be built.”
Wastewater Treatment Capacity: “No re-location area is designated for the waste treatment plant.”
“Even with planned upgrades, the treatment capacity of the current plant will be greatly exceeded by 3500 units, in combination with the approx. 1000 new beds anticipated from CalPoly, anticipated ADUs, and other development under consideration.”
“Building height and scale: With apologies to the drafters, the very idea of 8-story housing blocks in Arcata is an insult. It is disingenuous to propose a plan that is dependent on unrealistic building types.”
“Visualization Mock-Ups: The Draft offers no 3-D visualization examples of what different building heights would look like at full-buildout of 3500 units. Mockups should visually place structures in actual neighborhoods to show the impacts of mass and shadows on existing structures and pedestrians.”
The full text of letter:
|To:||Arcata Council and Planning Commission|
|From:||Andrea Tuttle [e-mail address redacted]|
|RE:||Recommendations for Amendments: Draft Gateway Area Plan|
Dear Arcata Council Members and Planning Commissioners,
As a long-time resident of Arcata, I have closely read the Draft Gateway Area Plan with a combination of appreciation for some elements and horror for others. I offer five recommendations for revising problematic portions of the plan.
As an underlying assumption, we should take as given:
• Almost all Arcatans support deliberate land use planning. Most agree we need to provide a fair share of housing for people who want to live here. We are socially and environmentally sensitive and caring. We are not NIMBYs.
• We support mixed use, mixed income and mixed ownership opportunities, and want to support housing needs of our teachers, responders, and employees. The Gateway area offers opportunities for some residential infill.
• We support all the policies addressing environmental protection, riparian corridors, wetlands, open space and parks, renewable energy, EV charging sites, low-carbon alternatives, bike paths and transit systems, low-car dependency, support of arts and protection of historic sites.
• We are here because we love the quality of-life that Arcata provides. Arcata is different from places elsewhere. We feel lucky to be here.
These values bring us together as Arcatans. We endorse the GAP policies that support these attributes.
Problems with the existing draft:
However, my strong opposition to the Draft GAP stems from the assumptions that underlie the promotional tone of the document. The document starts from an assumption that we want to radically convert the current community character to something entirely different.
It designates a high density, urban “sacrifice area” in the area between Samoa and Alliance, in order to house an arbitrarily defined number of people unrelated to carrying capacity and limiting factors.
1) Density and Carrying Capacity: The document starts from an excessive assumption of “needed” population increase derived by cramming population into tall buildings assuming every “under-utilized” parcel is converted to residential use and filled to the brim. The proposed 3500 units is over 5 times larger than the state housing mandate of 610 units.
3,500 units is a mathematically-derived number. It is NOT a “factual” number that reflects the carrying capacity of the city to support such growth. It has no relationship to the ability – or desire – of the town and infrastructure to accommodate that many people. Depending on the multiplier you choose for residents per unit (range of 2 – 3), 3,500 units would mean an increased population of 7,000 to 10,500 people, which would increase the 2020 population by a third- to half-again (i.e., a 37 percent to 55 percent increase over the 2020 U.S. Census Bureau population of 18,875). This is huge.
Wastewater treatment capacity is the principle limiting factor to the number of residences that can be supported in the city. A full-buildout calculation must include the number of beds planned by CalPoly and other areas of the city. A full-buildout calculation will indicate the amount of remaining sewage treatment capacity that can be allocated to the Gateway area ( see further discussion under item 2).
Recommendation #1: Use remaining wastewater treatment capacity to set the cap on the full-buildout number of new residential units in Arcata.
2) Wastewater Treatment Capacity: Even with planned upgrades, the treatment capacity of the current plant will be greatly exceeded by 3,500 units, in combination with the approx. 1,000 new beds anticipated from Cal Poly, anticipated ADUs, and other development under consideration.
• Inequity of a Building Moratorium: When treatment capacity is exceeded, waste discharge violations are issued by the NCRWQCB and a building moratorium is imposed. This will stop development in the entire city, not just the Gateway area. Building moratoria are not lifted until treatment capacity is increased, which will be a lengthy and expensive process probably involving physical relocation of the current plant.
It is unfair to force everyone in the city to stop their project, including ADUs, because over-density in the Gateway area has used up remaining treatment capacity.
• No Re-location area is designated for the waste treatment plant: Continued sea-level rise threatens the existing treatment plant and levees can only be raised so high, especially with increased storm surge. The GAP and CEQA documents should assess alternatives for locating a replacement site somewhere within the city, which may mean placing it in the GAP area. Options for relocation should be analyzed and provisions made for setting aside land now, before residential development fills the limited suitable places that still remain.
• Increased Utility rates for sewage treatment: The CEQA document should disclose increased rates of sewer bills to be levied on existing residents to pay for the expanded treatment plant capacity necessitated by new development. Equity issues of imposing new costs on existing residents in order to accommodate new residents should be disclosed and explained.
Recommendation #2: Address fundamental wastewater treatment issues before approving new development visions. Good planning requires realistic assumptions of underlying conditions.
3) Building height and scale: With apologies to the drafters, the very idea of 8-story housing blocks in Arcata is an insult. It is disingenuous to propose a plan that is dependent on unrealistic building types.
• Geology: It geologically hazardous to build tall buildings on unconsolidated bay and river sediments. This is compounded by our proximity to the Cascadia subduction zone and major ground shaking earthquakes. Engineering solutions may be possible, but costs of deep piles and other techniques will out-price the median market we are trying to provide for. We should not tease developers into thinking there is a bonanza for high rises awaiting here.
• Visual Impact: 5- to 8-Story building heights in Arcata are unacceptable. They are a tremendous violation of community character, when 4-stories are already considered “tall” compared to existing neighborhoods. Intrusive tall blocks emerging from flat land, towering over the rest of the city, visible from much of the entire Humboldt bay area, and blocking views of the horizon from all directions will be an eyesore. Arcata does not aspire to become “an urban core,” and there is no need to inflict that on ourselves.
• Visualization Mock-Ups: The Draft offers no 3-D visualization examples of what different building heights would look like at full-buildout of 3,500 units. Mockups should visually place structures in actual neighborhoods to show the impacts of mass and shadows on existing structures and pedestrians. Aerial and ground-based photos should be used as base layers, with obliques and shadow paths illustrating full-buildout of 3,500 units.
Recommendation #3: Limit building heights to a maximum of four stories, with some sort of design review required for any building over 2 stories.
4) Industrial relocation: The 3500-unit proposal assumes all existing industrial parcels will be designated as non-conforming uses, thereby clouding their ability to remodel, expand and continue the business in place. Some landowners may be interested in rezoning now, and they should be accommodated. But industrial uses, and the jobs they provide, add character to the city and remind residents of the necessary parts of an economy and functions of a city.
Recommendation #4: Planners should take a more fine-grained survey of industrial property owners to determine actual interest in rezoning and offer a more realistic set of rezone options in the plan.
5) Maintenance: New construction looks lovely – bright paint, new materials, fresh landscaping. Poor maintenance and shoddy materials however turn buildings into eyesores of faded paint, rust stains and sagging fences.
Recommendation #5: The development approval process should require ongoing maintenance and upkeep of buildings (e.g. three units or more) as a basic condition, and not simply left to owner-discretion. Formation of a community maintenance district supported by landowner fees should be considered.
The notion of infill development to help meet housing needs is laudable. The Gateway area offers potential space to provide some needed housing. But this needs to be grounded in reality. Most Arcatans support the vision of well-planned, mixed-use, mixed-income, pedestrian-friendly neighborhoods.
But the draft plan needs to be amended to more realistically reflect the capacity of the city to absorb new growth.
• Use carrying capacity of the treatment plant to base feasible population expansion
• Offer a full range of alternative zoning plans to choose among, not just one vision.
• Do not assume that a 20-year planning horizon means that growth will be metered out over time and that impacts will be gradual. In fact, especially under ministerial permitting, savvy investors and developers will immediately cherry-pick development sites before city-provided amenities (e.g. transit, trails) can be built.
I commend this effort as a proposal, but look forward to a realistic second draft. Thank you for the opportunity to comment.
s/ Andrea Tuttle
The image of the letter (PDF) from the Planning Commission packet, April 12, 2022