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Saturday, February 4, 2023

Form-Based Code

Articles, information, questions, answers, statements, facts, opinions

We all want a good plan — or, better yet, an excellent plan — for the Gateway area.  The growth and future of Arcata depend on it.  It is my view that the December 2021 draft plan is an infeasible plan, and does not offer Arcata and Arcatans a realistic or beneficial future.

I support infill and growth — but it must be done well.  I am all in favor of bike lanes, lower car usage, affordable housing, and equity opportunities of home ownership.  My concern is that with this plan, as it has been shown to us, it will be impossible to follow through on what has been promised.  I want a good plan, a truly possible plan, a plan that is a framework for creating what we know we can create and and have here in Arcata. Let’s move forward.

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Ben Noble:  Form-Based Code Presentation – June 29, 2022       Listen & Read:  Click here

Ben Noble is the City/Planwest independent consultant who is developing the Gateway Form-Based Code.

This is a MUST-SEE presentation for everyone who is involved in the Gateway planning process.  The Gateway draft plan provides policies and directions.  The Form-Based Code is what makes it happen — or not.  Getting a good (or excellent) Form-Based Code in place is crucial to the success of any Gateway plan.

Ben Noble:  Form-Based Code Workshop & Presentation – August 16, 2022

On August 16, 2022, Delo Freitas of Arcata’s Community Development Department presented a presented a workshop (via Zoom) on Form-Based Code. The main speaker was Ben Noble, the City’s Gateway Form-Based Code consultant.

This was Ben’s 2nd presentation on Form-Based Code. In the presentation was an emphasis on building height and massing.

As part of the workshop aspects of this presentation, there were polls of the people present on Zoom, done using the Slido app.  The results of the Slido polls can be seen here.


What makes a good form-based code?

Many form-based codes meander away from the fundamental principles that make them attractive in the first place. From the website of Smart Growth America.

A possible 6-story design for Arcata

Here's a 6-story building that could work in Arcata, with some modifications. Originally proposed for Santa Cruz, it incorporates many of the design elements and features people here have said are important.

We want Arcata to look like this?

Would you want to live here? Various photos of "Ugh" -- And we say:  Please not in Arcata. This page will be updated as new examples of "Ugh" roll in, so come back for more if you want. 

Other work Ben Noble has done? It’s not a good situation.

Arcata's consultant on the Form-Based Code, Ben Noble, and top City Staff have been unwilling or unable to provide suitable examples of his work. Why is the public being stonewalled? Is there something to hide?

Meriam Park, Chico: Where Form-Based Code didn’t work out so well

Why the Chico Meriam Park development in Chico is a terrible example of Form-Based Code

Issues with Ben Noble’s presentation

Ben Noble’s Form-Based Code presentation is good -- but far from perfect. The presentation could have been soooo much better.  Here's what was missing.

Redwood City Downtown Plan

Redwood City's Downtown Precise Plan includes Form-Based code and Planning Commission review. It all took 4 years to develop. The code can serve as a model for Arcata.

Redwood City DTTP – Explore the document

Redwood City's Downtown Precise Plan includes Form-Based code and Planning Commission review. It all took 4 years to develop. The plan can serve as a model for Arcata.

Redwood City has PlanComish review

Redwood City's Downtown Precise Plan was adopted in 2011, after three or four years of development.  It is helpful to us because it incorporates a well-designed Form-Based Code -- and has a blend of Discretionary Review and Ministerial Review.


The negative transformation of the former Arcata / Copeland / Myrtletown Lumber / Nielsen Feed site to the EdgeConnex data center was more than I could accept.  Clearly if a building like this can be allowed to be introduced into what is a thriving commercial / pedestrian area of Arcata, then all is not right with Arcata’s planning department.  Yes, I know, with whatever code is adopted as part of any new Gateway plan, a building like this could not be built in way.  But the fact that it was — when there was plenty of opportunity to make changes to the zoning for this section of 11th Street — indicates a lack of thoughtfulness on the part of the planning department.  And the “oversight” of the fence — its height, type, and location relative to the sidewalk are all wrong — shows us the need for more than just in-department single-person Ministerial Review.

If you have not yet seen it in person, I recommend that you drive / bike / walk over to 11th Street, just west of 11th & K — across the street from Portuguese Hall.  To see it in person is chilling.


In Arcata, 63% of the housing units are rentals, and 37% are owner-occupied.  Are you concerned?  What types of new development would be required so that we would have more opportunity to own our homes? This article looks at the possibilities.  Hint: It’s not going to be easy.

In April, 2021, Arcata contracted with Planwest Partners to create a plan for the Gateway area, develop the form-based code, assist with General Plan amendments, write the Environmental Impact Report (EIR), and more.  This article looks at the schedule that accompanied that contract, and requests that the City Council have Planwest revise their schedule and deliver on the Form-Based Code.  We need to see it.

  1. The work that’s been performed is terribly behind what was scheduled.
    As we can see, the schedule was unrealistic from the start.
  2. We haven’t seen any indication of Planwest’s engagement on many of the Tasks listed.
    Which tasks are they doing, and which are they not going to do?
  3. The Form-Based Code was scheduled to be released simultaneously with the draft Gateway plan, and open to public comment simultaneously with the draft plan.  Any Gateway plan cannot be adequately evaluated until we can see the Form-Based Code — simple as that.

The Gateway draft plan has brought up strong discussions about whether Ministerial Review is appropriate or beneficial — or necessary — for Arcata.  “Ministerial Review” involves a project being approved by one person, typically the Zoning Administrator, the Community Development Director, or a person assigned to that job. It’s an alternative to “Discretionary Review,” which involves public input and approval by the Planning Commission (and, prior to its dissolution in March 2020, Design Review Committee approval).

Is it one or the other?  Or could there be a blend?



Transcription of the Gateway Plan introductory video – Click here.

If you only read one article on this website, please read this one.  The video is about 1 hour.  All the commentary is in red and green. – You can easily skim through the article and just read the red and green — or, even shorter, you can skim and read the sidebars.

To City Council members, Planning Commissioners, and all others who want to explore many (but certainly not all) of the flaws in the details of this December 2021 draft Gateway plan.


For six eight months now, the depiction above has been the only visualization offered to the public about how buildings might actually be constructed in the Gateway area.  Yes, this is just a possible build-out — the Gateway plan does not determine what will actually get built.  But this is what the authors of the plan gave us.  We have strong hopes that these 3D modeling images will allow us, for the first time, to see just what is being proposed in this plan.

My opinion: The video still shows 6-story and 8-story buildings in a shape that no one in their right mind would ever construct.  The purple 8-story buildings are roughly 50 feet square — needle-like towers.  The new, proposed “plaza” area is bordered on the South, East, and West sides 4-story and 6-story buildings, thus creating solar shading across the designated open space.

My primary objection to the December draft plan is that it is filled with promises and wishful thinking that, in my opinion cannot possibly take place. 

It reads like a marketing brochure, not a plan. It offers little substance on such major issues as affordable housing or how 3,500 housing units could in practical terms be built.  The streetscape images shown do not resemble Arcata streets. Even its promised bicycle lanes are questionable as to whether they can be constructed as shown. To a great extent, the plan seems based on starting with a blank-slate in Arcata — that is, with all existing buildings torn down, as though we were starting with empty land.

It is my view that the December 2021 draft Gateway plan is a bogus plan and needs to be reconsidered in its entirety.

Not that it should be tossed out — but that it needs to be gone through line-by-line, to separate what is merely “aspirational” (i.e. unachievable) and what is feasible.

A plan that is not feasible is not a plan at all.