[NLC] A look at the EE & CRG process: Considering the potential risks to neighborhoods
pconte at picante-soft.com
Wed Jan 26 09:10:39 PST 2011
Thanks to everyone who attended last night's NLC meeting and to Randy
and Alan for organizing an informative and productive discussion and
votes on Envision Eugene.
As noted by a number of CRG members, there's been a dramatic change
in how much attention the CRG is paying to "neighborhood livability."
As recently as two months ago, this critical subject was hardly on
the radar; and now, as one CRG & NLC member put it: "Almost every
other statement in the CRG mentions 'livability.'"
The NLC's overwhelming vote to affirm the NLC's support for the
neighborhood leaders' "livability" letter to the CRG provides further
evidence of broad and deep community support for protecting,
repairing and enhancing neighborhood livability.
= = = = =
One of the important questions raised during the discussion was: What
are potential risks for neighborhoods in the upcoming Council
decisions on February 28. Kevin mentioned potential misapplication of
a "transition area" strategy that has received at least some
discussion in the CRG. There are others, some of which aren't so
obvious, but which are equally important.
To help people get a better "on the ground" understanding, here are
the major risks I can see:
* "Transition areas"
If transition areas are implemented on parcels that are inside an
established, low-density, (mostly) single-family detached
neighborhood area, the results have a potential for negatively
impacting the residential area. In any case, such an approach could
significantly reduce the size size of the contiguous SF residential
area, reducing it's stability. If transition areas were applied
around neighborhood parks and school areas (as proposed on the draft
map of potential transition areas that staff presented to the CRG),
there could be a significant degradation of the current connection
from SF residential areas to parks open space.
Solution: Have clear and complementary descriptions for "Transition
areas" and "Opportunity Sites". Transition areas should be areas
between commercial and higher density residential uses and
lower-density, single-family neighborhoods designed to minimize
negative impacts from more intensive development on nearby
lower-density, single-family neighborhoods. In general, transition
areas should have the least intensity beginning at the outer edge of
the lower-density, residential areas and increasing in intensity away
from this edge and towards a core commercial center.
Opportunity Sites are single or multi-parcel sites that are approved
for more intensive development because they have compatible designs
on appropriate sites. OS provides the proper mechanism to allow more
intensive development within a neighborhood where it would enhance
* Exposure from current R-1 standards.
This one is critical for areas in River Road, Santa Clara, Laurel
Hill Valley, Crest Drive and other NAs with single dwellings on large R-1 lots.
The current wording of the first strategy under the City Manager's
"neighborhood livability" pillar is:
Do not increase allowed densities in neighborhoods or implement
efficiency measures that impact neighborhoods unless they are in
accordance with the goals and recommendations of Infill Compatibility
This is a good strategy, based on the time-tested principle of "first
do no harm."
The R-1 zone allows a density up to 14 dwellings per acre. That's one
dwelling per 3,100 square feet (approximately), or about 2/3 the
current minimum for standard R-1 lots of 4,500 s.f., and much less
than the typical lot size in some of the areas I've mentioned. The
code, however, allows small lots and row house lots down to 1600 s.f.
Thus, current "allowed" densities leave these areas exposed to
incompatible redevelopment. Unless this is exposure is quickly
addressed, many areas could lose their defining character. (See also
the next item.)
Solution: Move rapidly to implement infill compatibility standards
that will protect the character and livability of the kinds of areas
I've mentioned. This is necessary because even the current lot and
development standards allow incompatible lot divisions and
development in these areas.
* Adopted findings that don't use appropriate land categories for
average density assumptions
This one is very subtle and "legalistic", but potentially could be a
huge problem. In short, if the City adopts findings with assumptions
about future densities that are defined on vary broad categories --
for example, "Average density for all level, low-density residential
land" -- then it may be very difficult or impossible for Council to
subsequently adopt development standards for small subareas, if those
standards would have the potential to limit densities in these
subareas below the assumed density for the whole category. This
problem is most obvious in areas, such as River Road and Santa Clara,
that have undesignated, natural storm water drainages. but it also
affects other areas with large, R-1 lots.
* Not identifying an adequate variety of housing types.
This problem is similar to assumptions about density. Limiting
housing type mix to just three categories (detached, up to 4 units
attached, and over 4 units attached) misses important subcategories,
including "high-occupancy apartments (HOAs)" (5-bedroom student
apartments), and others. The problems in this category are two-fold:
a) It may be hard to adopt appropriate standards to prevent the kinds
of negative impacts arising from HOAs, and b) it neglects the
important strategic tool for a Eugene "vision" that encourages (e.g.,
by code changes or incentives) desirable forms of housing, e.g.,
small courtyard cottage development. This problem also is a component
of the potential problem with using too coarse aggregation for
density assumptions, since the density assumptions are also based on
housing type, as well as land designation.
* Traffic impacts
While there's been plenty of casual mention of transportation issues
in the CRG, neither staff nor the CRG have adequately integrated
transportation constraints and potential traffic implications into
the strategies. The City Manager has somewhat surprisingly said on
multiple occasions that he believes all "multi-family" (i.e.,
attached) housing can be accommodated on land within the current UGB.
Although I'm not aware of any actual analysis supporting this
conclusion, it appears to be based on the assumption that
redevelopment in downtown and along transit corridors, such as W.
11th Ave., and River Road is where the new, denser residential
development will go.
If this assumption were adopted in findings, it would probably
require a transportation analysis and assumptions about future
actions to provide adequate transportation capacity. Right now, it
appears "EmX" is the glib answer anytime these questions arise.
However, a more realistic view is that along certain corridors,
higher-density development would require either increasing the road's
capacity for cars and trucks and/or getting waivers from the State to
allow development that would push traffic congestion above the normal
limits set by the State. In either case, the implications of where
the traffic generated by 34,000 new residents occurs is not just
about energy and climate, it's also very much about traffic impacts
through and beside our residential neighborhoods.
* WYDKYDK ("wid-kee-dik")
"What You Don't Know You Don't Know" may be the biggest problem with
the current EE and CRG process. Even with my experience and attention
to details, I'm not at all confident that I understand all the
unintended consequences that might arise from the current, very
loosely described "strategies" because there has been very inadequate
public airing of the assumptions and there's not a single map you can
go look at an say "Wow! I didn't realize that was what was meant by
[fill-in the blank: 'transition areas', 'CCC's', 'allowable density', etc.]."
Hopefully, these examples will help folks understand the critical
importance of the other motion adopted by the NLC last night:
NLC Advisory Motion #2
The Neighborhood Leaders' Council requests the decision process for
Envision Eugene follow a schedule that allows City-chartered
neighborhood organizations a reasonable opportunity to inform
organization members, discuss staff recommendations among the
organization boards and general memberships, deliberate on comments
and/or testimony to be submitted on behalf of the organizations, and
present comments and/or testimony to staff, Planning Commission and
City Council in a timely manner.
While the CRG has clearly made a number of folks feel good about the
process, the same thing was also true among a much, much larger
segment of Eugene's population during the "Shaping Eugene's Future"
process in the 1990's. That process was the basis for not only
Eugene's Growth Management Policies (GMP), but also many of the
claims subsequently made about Eugene residents' "consensus" on how
the City should grow. The actual result on the ground, however, was
the "LUCU" (Land Use Code Update), which was a huge disaster for neighborhoods.
Let's not leap over the same cliff again.
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