Colin Fiske – April 21, 2023

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    Planning Commissioners,
    You’ve got a busy schedule over the next week! I am writing on behalf of CRTP to provide comments on agenda items
    for each of your three upcoming meetings. As always, please feel free to reach out to me if you would like to discuss any
    of these items in greater detail.
    Saturday, 4/22
     It is crucial that projects which meet objective standards (which will be contained in the Gateway form‐based
    code) be subject to ministerial (not discretionary) approval. The objective standards will ensure that project
    conform to community priorities, while the ministerial approval will ensure that projects can actually be built
    and not subjected to unproductive, years‐long reviews such as those we’ve sometimes seen in the past.
     We understand the desire for public meetings on a large project, even when that project will be subject to
    ministerial approval. However, we fear such a procedure would lead to even more frustration and anger from
    both the Planning Commission and the public, since the inevitably subjective opinions on the project will have to
    be disregarded in favor of applying the adopted objective standards.
     Regarding the community benefits program, a program like this must balance a number of considerations,
    including the importance of each benefit to the community, the cost of each benefit to the developer, and the
    overall impact of the program on the feasibility of potential projects. We imagine that staff and consultants
    considered these variables when developing the point system, and we do not object to the general scheme. But
    we have some concern that the system as proposed could lead to transportation‐related benefits being left out
    of many or most projects.
     We have the following specific comments on proposed benefits:
    o We encourage you to provide points for nonprofit, land trust, and/or co‐op housing, along with tribal
    housing (the last one is already proposed).
    o The benefit related to dedicating setbacks to expand the right‐of‐way says that points will be awarded
    for dedicated ROW used for pedestrian uses or off‐street parking. Dedicating land for pedestrian use is
    great, but not for off‐street parking. As the Commission has previously discussed, we should not be
    incentivizing off‐street parking in the Gateway area. In fact, exactly the opposite should be encouraged.
    o For commercial or mixed‐use projects, points should be awarded for providing free bus passes to
    employees, not just residents.
    o The latest draft of the Plan calls for encouraging “unbundling” of parking and residential rents. This
    should be a benefit with available points in the program.
    o There should be more specificity provided on what it means to “exceed requirements” for bus stop
    facilities.
    Tuesday, 4/25
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     Regarding building height and shading, we reiterate our position that taller buildings are necessary to provide
    levels of density required for walkability, bikeability, and to support high‐quality transit. If measures are taken to
    mitigate shading concerns, you should be careful not to excessively reduce effective density.
     Regarding the Public Safety Element, we request that you add a policy (or amend policy PS‐5b) to commit to
    working with AFPD to jointly investigate purchasing smaller fire trucks, in order to reduce the perceived need for
    bigger and thus more unsafe streets designed solely to facilitate fire access. Such trucks are in use in many cities
    around the world, especially where buildings and street designs predate the automotive era.
     Also in the Public Safety Element, under Crime Prevention and Response, we request that you add a policy
    stating that the city does not support the use of armed police officers for traffic enforcement. In recent years,
    racial disparities in traffic stops has been widely exposed and reported in national and state media, and the
    frequently lethal results of putting armed officers in charge of enforcing traffic laws have also been well
    documented. A bill in the state legislature could soon present more opportunities for unarmed civilian staff to
    enforce traffic laws rather than police, and Arcata should be ready to take advantage.
    Thursday, 4/27
     Regarding the “bike rack” items for Gateway Mobility and the Circulation Element, please refer to my emails to
    you on 4/7 and 4/12. In summary, we encourage you to adopt new or amended policies committing to public
    transit improvements and Class IV protected bikeways on busy streets, and abandoning the unhelpful
    “functional classification” system for roads (instead prioritizing safety and low speeds on all city streets).
     It is also critical that you follow up your important decision from April 11 to de‐prioritize level of service (LOS)
    and use it only to lower speeds and encourage mode shift with corresponding changes to the rest of the
    Circulation Element, including removal of references to “LOS deficiencies” and removal of projects motivated
    solely by such “deficiencies” from the Circulation Element (and the Capital Improvement Plan).
     It appears that some items on which you already voted (such as LOS and downtown parking management) still
    appear in the “bike rack.” We ask that you correct this error.
    ‐‐
    Colin Fiske (he/him)
    Executive Director
    Coalition for Responsible Transportation Priorities