Mixed Use Centers Letter

The Tacoma Planning Commission is currently reviewing changes to the Mixed Use Centers. Below is my official testimony on this issue, for the record:


Dear Chair and members of the Tacoma Planning Commission:
Please accept the following comments as part of the official record regarding the proposed amendments to the Mixed Use Center regulations. I am submitting this letter on August 14th via the following: mail to the above address, fax to 253.591.2002, and email to planning@cityoftacoma.org.
Let me first state that after decades of waiting, it is a relief to see that Tacoma is finally taking steps toward becoming a more cosmopolitan city by adopting new mixed use regulations that enable better quality development projects, higher densities, and more mobility options. The suburban-style development regulations that have enormously dictated the low-density layout of Tacoma for the past several decades should be eliminated. The general public is beginning to understand that high density is the way of the future, and the city of Tacoma should do everything in its power to enhance Tacoma's urban experience.
Regarding the Mixed Use Center code revisions, I would like to address three main issues: height limits, parking standards, and the proposed MUC district boundaries for a few neighborhoods.
Height Limits
Proposed amendments to the height restrictions are found on pages 25 through 29 of Appendix C.
I believe that setting maximum height limits too low will hinder development of quality mixed use neighborhoods. Building heights can greatly influence human behavior. In general, shorter buildings (1 to 4 stories) are less conducive for encouraging pedestrian activity and more ideal for the car driver.
Medium height buildings (5 to 8 stories) are the middle ground and tend to do a better job of bringing more bicyclists and pedestrians out while slowing down cars. Buildings that are 9 stories or taller are beyond the human scale and can be daunting for pedestrians and cars alike.
I believe that the proposed height limits in the NCX, RCX, CIX, NRX and URX districts should be raised about 20 feet from the proposed standards. This would allow all Mixed Use zoning districts to accompany buildings within the ideal 5 to 8 story height range.
Parking Standards
Proposed amendments to the parking requirements are found on pages 69 through 72 of Appendix C.
I applaud any effort to reduce the minimum parking requirements. In my opinion, off street parking requirements are the number one impediment to the creation of viable mixed use neighborhoods in Tacoma. One of the biggest challenges for architects designing buildings in Tacoma today is trying to conform to the parking regulations. The parking issue is the main reason that some of Tacoma's more successful mixed use areas, such as Sixth Avenue or Proctor, have not seen more new construction. As it stands today, it is often impossible to meet parking requirements for new buildings on small, narrow urban lots. Complying with the parking regulations is also one of the most difficult aspects for potential small business owners.
The current proposal would not require any parking within 200 feet of a prime pedestrian street. 200 feet is less than one city block, meaning the city would still mandate automobile ownership for anyone located further than a half block from a primary pedestrian street. In order to create a true mixed use environment, the city should not require any parking spaces anywhere within any of the mixed use zoning districts. I believe that the market should decide how much parking is necessary, not a city.
If eliminating all minimum parking requirements isn't possible, then the established minimums of one space per residential unit and 2.5 spaces per 1000 square feet of commercial space should be lowered. Not long ago, an amateur study determined that the minimum parking requirements in Tacoma make it one of the most expensive urban places in Washington in which to construct a building. Residential housing developers will pass on the costs of parking spaces to their tenants or purchasers in the form of higher rents and purchase prices. Aspiring entrepreneurs won't be able to follow their dreams because they can't provide enough spaces. Since all of the mixed use centers are serviced by public transit, and one of the goals of mixed use neighborhoods is walkability, it seems silly that the city would still require car ownership through minimum parking standards.
Designation of Zoning District Boundaries
Appendix A shows the proposed MUC district boundaries.
The proposed Mixed Use Centers appear to primarily follow major arterial streets and are elongated in nature. In most cases, the MUCs don't extend beyond a block or two of the arterial street in the district. I believe that the mixed use centers should be extended further outward and should encompass more land area, even if portions of the districts cover low-density residential. The conversion of more single family homes to higher density housing and mixed uses will create stronger neighborhoods in the long run.
I find the designation of some of the mixed use centers at existing large retail complexes interesting. Such proposed MUCs, such as 34th and Pacific, 72nd and Pacific, 72nd and Portland, James Center, Narrows, Tacoma Central, Tacoma Mall and Westgate, are often owned by one or two property management companies that specialize in suburban-style retail. I don't believe there is a high likelihood that the land already occupied by strip commercial structures will be redeveloped as compact, mixed use neighborhoods. I believe more land surrounding such proposed MUCs should have mixed use classifications, however.
Thank you for allowing me the opportunity to comment. I hope you seriously consider my comments while contemplating a recommendation for the City Council.
Sincerely,
Andre Stone