City Releases Draft of Downtown Plan and Code

City Manager Mike Webb holds up a hard copy of the draft report at Wednesday’s League of Women Voter’s forum on the General Plan

This week the city released a draft of the Downtown Davis Specific Plan and a Draft Downtown Form-based Code.  What follows will be a 90-day public review and comment period which ends on January 14, 2020.

The draft documents are available at: https://www.cityofdavis.org/downtownplan

The city appointed a 19 member Downtown Plan Advisory Committee that began holding public hearings in December 2017.  They have had 6 pop-up workshops and 20 focus group meetings over the last more than 20 months.

“In our shared opinion, the most important part of this process is about to begin: public review and input about the draft Downtown Specific Plan. We urge everyone in our city to review the Plan, whether at a high level or in detail, and to consider how well it reflects our community – particularly, how well it establishes a vision and a foundation for how our community will develop in the coming decades,” write Chair Meg Arnold and Vice Chair Michelle Byars in a letter summarizing the report.

The letter notes 17 recommendations for the DPAC.  These include unanimous support for “integrating accessibility through universal design,” and strong support for creating greater certainty, thoughtful transitions, a taller central core of the downtown, a more useful urban center, unanimous support for adding housing capacity along with affordable housing, and maintaining local businesses.

They also add opposition to adding a public parking garage, while having strong support for innovative parking management, such as parking maximums.

According to the plan, “Downtown will further the community’s reputation as a leader in sustainability and a model of sustainable urbanism. It will embrace the concept of Triple Bottom Line sustainability that gives equal emphasis to ‘people, planet and profit.’”

The goal is that “Downtown Davis (will be) a carbon neutral, equitably accessible, water efficient, zero waste, resilient community by 2040.

“The Specific Plan Goals will be realized through a Downtown vision that reinforces the community’s aspirations and is uniquely Davis,” the report notes.  “Over the years, Davis has established a reputation as a progressive leader in promoting sustainability, and has been at the forefront of initiatives and legislation that have made an impact at the regional and national level.”

The plan lays out six goals which “address the key issues and opportunities identified” and “reflect the community vision that has evolved during the Specific Plan Process.”

Goals:

  1. A memorable identity for Downtown that celebrates Davis’ unique culture
  2. Compact development that incorporates sustainable practices and infrastructure
  3. A feasible, equitable development program that builds a resilient economy and increases housing access and choice
  4. A sense of place reinforced with appropriate character, balanced historical preservation and thoughtful transitions to context
  5. An active and inclusive public realm that promotes civic engagement and health
  6. A safe connected, multimodal network that uses innovative mobility and parking solutions

Under goal number two, they note: “Downtown will model a holistic approach to sustainability, with an equal emphasis on its economic, social and environmental aspects. Further, it will aim to become carbon-neutral by 2040.”

The report writes, “Integral to Downtown’s development approach is the strategy of compact development that focuses on infill and redevelopment of opportunity sites with a variety of residential and mixed-use buildings, supported by shops, services, open spaces, and other amenities within easy walking distance.”

These policies are intended to be used as a guide for decision makers to consider future actions in order to implement the Specific Plan goals.

2.1 Enhance Downtown’s character with compact and walkable infill development.

2.2 Promote the rehabilitation of historic buildings for adaptive use, reducing the carbon impact of demolition and reconstruction.

2.3 Incentivize private developers to include sustainability features and energy efficient systems in new development, renovation and expansion projects that exceed minimum City requirements.

2.4 Prioritize alternate transportation and encourage a car-free lifestyle for Downtown households and workers.

2.5 Consider sustainability strategies at all levels of reinvestment and decision-making.

2.6 Provide leadership in sustainability through demonstration projects on City property.

Goal three notes, “Downtown will have a diversified development program that can adapt to match market conditions while striving towards broader community goals. Downtown will evolve from being primarily a commercial destination to a vibrant, mixed-use district.”

Among the key sub-goals here are prioritizing “innovation and knowledge sector jobs to build synergy with UC Davis and attract a diverse set of employers,” as well as, “Encourage the creation of new commercial space in Downtown to attract a variety of employers and support new businesses.”

A key point: “The Specific Plan seeks to provide more affordable housing in Downtown, while considering feasibility concerns to ensure that aspirations for equitable housing can become reality.

“The analysis of market conditions has shown that there is adequate housing demand, but supply has been hampered due to constrained infill conditions (such as small parcel sizes) and a cumbersome regulatory process.

“The Specific Plan recommends a strategy of requiring new development to comply with citywide affordability requirements to provide below-market rate units, as well as incentivizing the private sector to provide housing units that are affordable by design.”

It also focuses on housing in several parts.

They wish to “encourage affordable housing at all levels through a focus on market-rate, affordable-by-design housing, allowing microunits, and complying with City requirements to provide below-market rate housing for new development.”

They will also “encourage Missing Middle Housing types to provide a variety of house-form housing types that will fit well in Downtown and enable appropriate transitions to adjacent neighborhoods such as Old North and Old East.”

Further, they seek to “[b]alance rental and ownership housing, and encourage diversity in housing sizes and types to cater to diverse population groups, including workforce housing, empty nesters, students, etc.”

Finally they will “[i]ncentivize developers to integrate universal design and sustainability strategies exceeding City requirements into building and site design.”

They note, “Missing Middle Housing refers to a range of building types that are seen in cities and towns across the country and were a fundamental building block in pre-1940s neighborhoods.”

The report adds, “Combined together (and usually with detached single-family homes), Missing Middle building types help provide enough households within walking distance to support public transit and local businesses, and they are found within many of the most in-demand communities across the United States.”

One of the big pushes is to create an “active and inclusive public realm that promotes civic engagement and health.”

Here they note, “Downtown will strengthen its public realm in ways that support its role as an active neighborhood as well as a citywide and regional destination of choice.

“The public realm is the backdrop for public life, community conversations and civic engagement. The public realm includes streets, sidewalks, plazas, parks, alleys, and mid-block passages—spaces that any individual should be able to visit and enjoy freely and comfortably. An inclusive public realm encourages day-to-day, spontaneous interactions with community members of diverse backgrounds and beliefs, and can assuage social isolation,” they write.

Finally, any plan for the downtown has to plan for mobility and parking solutions.

“Downtown will provide transportation options for all users and be designed for the future of transportation,” they write.

Some of the key components here include making downtown a place where “daily needs can be met without a car,” improving the transit service which will include electric shuttles and other modes to make travel accessible and comfortable.

They will “[e]stablish a clear hierarchy of streets that balance vehicular traffic with the needs of pedestrians and cyclists, prioritizing different modes based on the physical context.”

They will design the streets to be adaptable to future transportation modes and balance “short and long-term needs, and evaluate progress, by implementing comprehensive Parking and Transportation Demand Management strategies.”

The report writes, “This includes offering incentives for converting underutilized private parking into shared, available-to-the-public parking, and reserving sites for future public parking structures if and when needed.”

The plan seeks to “manage curb and public parking as a strategy that recognizes and responds to the varying parking needs of Downtown’s neighborhoods.”

Finally, they look to “[e]liminate minimum off-street parking requirements for new development, as well as additions, expansions and renovations of existing development.”

A future article will look at the downtown neighborhoods and districts.

—David M. Greenwald reporting


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  • David Greenwald

    Greenwald is the founder, editor, and executive director of the Davis Vanguard. He founded the Vanguard in 2006. David Greenwald moved to Davis in 1996 to attend Graduate School at UC Davis in Political Science. He lives in South Davis with his wife Cecilia Escamilla Greenwald and three children.

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35 comments

  1. “Downtown will evolve from being primarily a commercial destination to . . .”

    . . . a semi-residential district.

    Why is that a goal?  Aren’t downtowns supposed to be primarily commercial destinations (for the city as a whole)?

    How can one claim (in one article) that there’s a “shortage” of commercial space, while claiming in (another article) that downtown should move away from being a commercial destination?

    No wonder that the article also notes a goal of “opposition” to a parking garage.

    1. Ron, there are many different segments of commercial … retail, services, groceries/necessities, manufacturing, restaurants, gas stations to name just a few.  The old saying location, location, location applies.  The commercial activities of Mori Seiki would not be a good fit for any Downtown anywhere, nor would a Downtown location be a good fit for the transportation requirements of a commercial venture like Mori Seiki.  Similarly the sale of groceries and necessities has a long and proven history of dispersed/distributed locations throughout the overall footprint of an urban area.  Concentration in the Downtown area is a model that America evolved away from decades ago.

      So, bottom-line, you can continue to try and paint “commercial” with a broad brush, but the “paint” of that broad brush simply won’t stick.

      1. Not disagreeing with you Matt, but in fact that’s pretty much been true since the invention of the automobile. For better, and worse.

        That said, there’s activities (such as office space) which have remained a focal point of some downtowns.  There’s also commercial activities which aren’t a good fit with residential space, and end up compromising commercial activities.

        Not necessarily a comment regarding downtowns, but purposefully requiring “mixed-use” appears to be a phony concept, in some locations.  Simply a way for developers to build residential in a commercial location.  (I find the Del Rio development at 5th and Pena to be questionable, for example. Pretty sure that it was previously zoned for commercial activities, as the parcels around it are.

        But again, the “problem” with downtown hasn’t been defined in the first place.  And, if the goal is now to make it a “non-destination” for commercial activities, then that’s also questionable – to say the least.  Especially since Davis’ downtown has remained relatively intact, compared to other communities which have pursued peripheral developments, allowing their downtowns to die.

        I would say that if retail is dying, simply “throwing more people” at it isn’t going to solve the problem. Davis has already been steadily growing.

        I also see nothing wrong with downtown as a restaurant/entertainment area.

  2. “Downtown will model a holistic approach to sustainability, with an equal emphasis on its economic, social and environmental aspects. Further, it will aim to become carbon-neutral by 2040.”

    Moving commercial activity away from downtown out toward freeway/commuter-oriented peripheral sites is not “holistic”, nor is it “carbon-neutral”.

    The broad goals in this plan don’t match reality. Just a lot of puffery.

        1. If you’re referring to this, “ Downtown will evolve from being primarily a commercial destination to a vibrant, mixed-use district.””

          That doesn’t say they are moving commercial activity away from the downtown, it only says that they plan to add mixed use to the downtown.

          So I repeat the question.

        2. “From” as in “moving away from”.

          I started out asking a question, myself:

          Why is that a goal?  Aren’t downtowns supposed to be primarily commercial destinations (for the city as a whole)?

           

           

        3. It’s fine to ask that question.  It’s not fine to falsely state that the goal is to move commercial activity out of the downtown.  That’s not what the passage you quoted states.

        4. It’s “fine” that you’ve let us know what’s “fine”, and what’s not “fine” with you.

          Also noted that you had no response to the question.

          Regarding “moving away from” – it’s a logical conclusion, if commercial activity is being eliminated and/or displaced from one location to another, as a result of someone’s plan. Especially an existing “primarily commercial destination”.

        5. I got involved in this conversation to specifically respond to your point about commercial moving away.  And no, it’s not a logical outcome when the plan retains the same commercial space as before.  It’s a false claim.

        6. Again, the plan itself states that the goal is to move away from being primarily a commercial destination. (As a side note, I suspect that this “goal” was also behind the recent effort to block Davis ACE’s plan to build its own small, solar-covered parking lot.)

          Why is that a goal? In fact, shouldn’t the goal be to strengthen its role as being primarily a commercial destination?

          I have a question for you specifically, as well.  In addition to the questions you haven’t responded to, above.

          How is it that “moving away” from being primarily a commercial destination fits into “a pro-business stance”?  (In reference to the question you recently asked me.) For example, how does attempting to block Davis ACE’s plans match that stance?

          1. I will be reading the report before commenting on its contents, but with respect to your multiple comments already on this thread: adding residential to downtown commercial districts is a central tenet of new urbanism. http://www.newurbanism.org/
            It does not remove commercial square footage. Implementation usually involves changing zoning to allow mixed-use buildings that have commercial/retail on the ground floor and residences above them. It brings more people downtown, which theoretically adds buying power and consumer demand for the businesses that are there. It’s nothing new; we were discussing this in urban planning classes I took in the 1970’s.
            Key concept is that it does not reduce the total amount of space devoted to business purposes. It just adds more people. Planning for traffic (all kinds) and parking (all kinds) becomes paramount to the success, as the perception of a congested downtown is one of the major hurdles downtown retailers face. My own opinion, for what it’s worth, is that there’s often a lot of jargon and wishful thinking about getting people out of their automobiles, but that there’s rarely the infrastructure provided to actually do that. But I’ll read the report and see what specifics they have in that regard. If there are proposals for things like electric shuttles, for example, I’m curious how those will be paid for and whether there is sufficient demand for them in a city with a compact center like Davis.

        7. ” . . . but with respect to your multiple comments already on this thread . . .”

          Made in response to multiple challenges (primarily from one other commenter, but now spreading to two).  As is usually the case.  Which is not preventing anyone else from commenting, should they choose to do so.  Hopefully, respectfully – as I try to do.

          No one even made a comment until I did.

          ” . . . new urbanism.”

          I’d apply your following thought, to the term above:

           “My own opinion, for what it’s worth, is that there’s often a lot of jargon . . .”

          Regarding your following comment:

          “Key concept is that it does not reduce the total amount of space devoted to business purposes.”

          In fact, it does, in terms of “opportunity cost” (there are certainly downtowns that have a much denser commercial sector/activity than Davis currently has), limitations regarding the types of businesses that can mix with residential, as well as the following issue that you brought up:

          “Planning for traffic (all kinds) and parking (all kinds) becomes paramount to the success, as the perception of a congested downtown is one of the major hurdles downtown retailers face.”

          But not necessarily limited to retailers.

           

           

           

           

        8. Ron O.

          The proposal is to increase local retail space with multistory buildings that also contain the customers (residents) who live in that same building. If the customers are required to travel to the downtown retailer instead, they are less likely to do so, so less retail space can be economically supported. So in the end, more retail space is created downtown through a dynamic process. This is how many smaller communities are now reviving their downtowns. Asheville NC is one such example.

        9. Richard:  That may be true, if the goal is to move-away from being a commercial destination. Again, I don’t see why that should be a “goal”.

          One difference regarding Davis (compared to other towns) is that it has resisted peripheral development efforts, resulting in a downtown that’s healthier than others.

          Also, commercial development is not limited to retail.  There’s opportunities for restaurants, office buildings, start-ups, light industrial, etc.  That is, if they’re not all displaced by pursuing semi-residential uses.

          I’m not seeing much regarding downtown that needs “fixing”, with the possible exception of allowing denser commercial usage.

  3. ” . . . but with respect to your multiple comments already on this thread . . .”

    As a side note, I’m sometimes not able to “edit” my comments to include or clarify the points I’m trying to note.  I’m still getting used to this situation (which is the result of a technical problem, with the Vanguard’s website), but it has sometimes led me to make multiple comments (which might normally be incorporated into one).

    Until that’s fixed, will try my best to ensure that my comments are as accurate/complete as reasonably possible.

    1. It’s not a technical glitch, it’s actually a conspiracy.  Since you have to make more comments, you’ll reach your new limit faster.  Soon:  silver robots.
       

    2. I attended several of these meetings.  There was wide consensus and compromise.  Then, after all that work, the entire process was almost derailed after consensus was reached.  Even those who favored different ideas on certain issues — overall stood up for the consensus, and in the end, cooler heads prevailed.  Though imperfect, the goals of disparate groups and interests were considered and rolled into the final plan.

      One main issue of consensus that was almost destroyed was the perimeter of downtown and the transition to adjacent neighborhoods.  This was marked as four stories on a map by ‘accident’, and when pointed-out, the DPAC members were assured it was a mistake — then a meeting later it was stated that was a misunderstanding, and it really was four stories!  That’s when the sh*t hit the fan, and almost destroyed the DPAC plans.

      The difference between three and four stories is everything (despite many people during the Trackside crises saying ‘it’s only one more story, what’s the problem?’.  Pleeeeeeeez, those people were development ideologues who ignored the reality of that transition.  What we’ll have with the published plan is 1-3-5 from I Street to G Street — which is a reasonable transition.  1-4-5 is not a reasonable transition, and would make the concept of the ‘missing middle’ being solved as per the consultants — well, an absolute joke.  And no, setbacks and so-called half-stories do not make a building shorter.

      The only exception in the plan was the Trackside property, as a planned development.  Trackside will either end up being the wart exception to an otherwise good plan, or the insanity of one story houses in a historic neighborhood next to a four-story wart will finally be put to rest.

      A representative from Old East Davis stated that they believed the published plan was one the Old East Davis neighborhood may be able to get behind and support (so stated because our neighborhood has not discussed the plan yet and taken a position).  It certainly does meet many disparate goals, with decent transition and the potential for high density and high building height just a block into downtown.

      That’s pretty amazing — that consensus could be reached with neighbors and developers and other city interests.  I think it’s an imperfect but pretty damn good vision.

      I urge the citizens of Davis to consider joining the DPAC in the approval of this vision for downtown.

      ———————–>

      [And having said that . . . if anyone really wants to blow this Sh*t up and start a Davis civil war . . . suggest four stories along the perimeter again.  Ha!  You know someone will try.

      AND . . .

      This three stories has to be SOLID . . . no exceptions or ‘half-stories don’t count’ or claiming in ten years that ‘times have changed and the plan doesn’t apply anymore’  — Nope!  None of that!  Go away you . . . consensus has spoken.]

    1. Sorry, David – I’m “tagging out” for awhile.

      Sometimes, those who apparently don’t like my comments direct questions toward me, and then subsequently complain when I respond.

      Hope that this response doesn’t “count” as a response!

      In any case, the door is wide-open, for anyone else to make a comment.

        1. I’d suggest you just do your “calibration” regarding DT and ARC without my response to your question regarding the Cannery.

          Go ahead and make whatever point you have in mind.

          1. There’s a fundamental flaw in his argument. He’s argued that ARC is a housing project even though the distribution of commercial to housing is overwhelmingly commercial. He’s arguing the same for the proposed downtown plan. So I want to know how he evaluates Cannery – is now a commercial project because there is a small commercial component or is it still a housing project even with a mixed-use component? Without that calibration, anyone trying to respond to him is just spinning their wheels.

        2. David:  Thought I’d check back in, to see what you came up with.

          I think you need to work on your “calibration” some more.  I never said any of those things.

  4. I attended several of these meetings.  There was wide consensus and compromise.  Then, after all that work, the entire process was almost derailed after consensus was reached.  Even those who favored different ideas on certain issues — overall stood up for the consensus, and in the end, cooler heads prevailed.  Though imperfect, the goals of disparate groups and interests were considered and rolled into the final plan.

    One main issue of consensus that was almost destroyed was the perimeter of downtown and the transition to adjacent neighborhoods.  This was marked as four stories on a map by ‘accident’, and when pointed-out, the DPAC members were assured it was a mistake — then a meeting later it was stated that was a misunderstanding, and it really was four stories!  That’s when the sh*t hit the fan, and almost destroyed the DPAC plans.

    The difference between three and four stories is everything (despite many people during the Trackside crises saying ‘it’s only one more story, what’s the problem?’.  Pleeeeeeeez, those people were development ideologues who ignored the reality of that transition.  What we’ll have with the published plan is 1-3-5 from I Street to G Street — which is a reasonable transition.  1-4-5 is not a reasonable transition, and would make the concept of the ‘missing middle’ being solved as per the consultants — well, an absolute joke.  And no, setbacks and so-called half-stories do not make a building shorter.

    The only exception in the plan was the Trackside property, as a planned development.  Trackside will either end up being the wart exception to an otherwise good plan, or the insanity of one story houses in a historic neighborhood next to a four-story wart will finally be put to rest.

    A representative from Old East Davis stated that they believed the published plan was one the Old East Davis neighborhood may be able to get behind and support (so stated because our neighborhood has not discussed the plan yet and taken a position).  It certainly does meet many disparate goals, with decent transition and the potential for high density and high building height just a block into downtown.

    That’s pretty amazing — that consensus could be reached with neighbors and developers and other city interests.  I think it’s an imperfect but pretty damn good vision.

    I urge the citizens of Davis to consider joining the DPAC in the approval of this vision for downtown.

    ———————–>

    [And having said that . . . if anyone really wants to blow this Sh*t up and start a Davis civil war . . . suggest four stories along the perimeter again.  Ha!  You know someone will try.

    AND . . .

    This three stories has to be SOLID . . . no exceptions or ‘half-stories don’t count’ or claiming in ten years that ‘times have changed and the plan doesn’t apply anymore’  — Nope!  None of that!  Go away you . . . consensus has spoken.]

    1. “Go away you . . . consensus has spoken.”

      I don’t have a serious disagreement with what Alan M. has said, but I will point out that consensus also spoke with the 1961 CASP and more recently with the Parking Taskforce, and likely many other examples in between. Conditions change, sometimes quickly, so while I agree that we should show deference to ‘consensus,’ it should not be viewed as an absolute, even if ignoring it rekindles the long running ’civil war.’

      1. Consensus is also determined by those present, those “active” (or ‘activists’)… not always (actually, seldom) representative of the community at large… see also, discussion re: CC Districts… that is reality… no matter how some pretend to represent “the people”…

        Some (many) folk are more focused on making a living, paying bills, raising a family, living with neighbors, etc. To use a term I hate, “the silent majority”… but it is real…  and usually, ignored, by those with strong ‘agendas’… and try to insist that everyone believes as they do, else they are ‘bad people’…

        1. Consensus is also determined by those present, those “active” (or ‘activists’)…

          Better to rely on pacifists . . . the inactive . . . or those not present.

          not always (actually, seldom) representative of the community at large…

          Well, that’s, like, your opinion, man.

          see also, discussion re: CC Districts… that is reality… no matter how some pretend to represent “the people”…

          Not the same dynamic.

          Some (many) folk are more focused on making a living, paying bills, raising a family,

          All good pursuits . . .

          living with neighbors,

          Why are they living with their neighbors?  They should be sleeping in their own house.

          etc. To use a term I hate, “the silent majority”…

          That’s why you used it, I’m sure.

          but it is real

          People who are raising families and working full time and don’t know what’s going on in local politics because they don’t have time . . . that’s real.  And that some are watching Monday Night Football and the Kardasians instead . . . that’s real too.

          and usually, ignored, by those with strong ‘agendas’…

          Actually, those with ‘strong’ agendas, the ones you agree with who those you are defining here as having strong agendas that you don’t agree with, usually don’t ignore the ‘silent majority’ at all.  In fact, they usually claim to represent them — an equally ridiculous stance.

          and try to insist that everyone believes as they do, else they are ‘bad people’…

          A knife that cuts both ways.  A spoon that is slurped from both sides.  A fork that pokes tongs into your flesh as you grab a chicken breast off your plate with the other end.

      2. I don’t have a serious disagreement with what Alan M. has said, but I will point out that consensus also spoke with the 1961 CASP and more recently with the Parking Taskforce, and likely many other examples in between. Conditions change, sometimes quickly, so while I agree that we should show deference to ‘consensus,’ it should not be viewed as an absolute, even if ignoring it rekindles the long running ’civil war.’

        What was pointed out in the meetings was that the DPAC was attempting to bring the various interests together to discuss the form of a future downtown, and without consensus of even the participants, attempting to bring this to the public would be near impossible.  Put in a more positive spin, the representatives of the various interests worked this out so that the plan has a good chance of being accepted generally.

        If a more narrow group had worked it out, they would have left out the goals of other groups, who would then have attacked the plan – whichever side that was.  As I pointed out at Council when we asked that their be neighborhood reps on the DPAC, “we will be there, one way or the other, wouldn’t it be better if we were part of the process up front?”.  I believe this is a well-reasoned plan that allows for significant growth, tall-ish building in the core, public spaces, and transitions — this shows that more inclusive/diverse civic planning-ish committees are ultimately more productive.

        Now of course, all this could be attacked by yet further extreme forces — such as what happened to Lincoln40 — who worked directly with neighbors, were completely honest and upfront and thoughtful about their plans, worked with people who were displaced, and STILL got sued.  (Because apparently, no good deed goes unpunished.)  Those forces may attack this plan as well.  May God have mercy on your souls.

        Of course, I’m being a beyondanda in defining the differences of opinion as ‘civil war’.  But if the groups in the room can’t represent and work out a plan, there is going to be more difficulty in getting any sort of plan passed without even the more moderate players digging in for something more reasonable.  This allows the developers to know what the build field really looks like, and those nearby to know there are some real protections. I think this played out well.  So far, so good.

        I’m not so much a believer in the ‘quickly changes circumstances’ idea.  The whole point of planning is so that form and character are preserved when the pressure is on, not so that we cave as a city when the heat is on.  It’s a different belief system — but I don’t see the point of planning at all if the rules change when the thermometer hits 81°.

        1. “but I don’t see the point of planning at all if the rules change when the thermometer hits 81°.”

          Such as when a ‘beloved’ local business demands a private parking lot, something that had been specifically precluded by ALL of the downtown planning documents of the previous few decades…

        2. “In response to a much larger proposed global change . . . paid parking”

          Which came about in response to a consensus recommendation that the store owner was a party to.

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