[NLC] A look at the EE & CRG process: Considering the potential risks to neighborhoods

[Paul Conte]

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 
the neighborhood.
* 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 
Standards.
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.]."


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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.

-- Paul 
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