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Buffalos Green Code

The basis for the work of the Western New York Environmental Alliance (WNYEA) the Environmental Declaration of and Shared Agenda for Action provide a framework through which we view the Green Code process and will view its outcomes. WNYEA knows that our environmental resources are immeasurable assets; they have direct impacts on our quality of life and our economy. As such, there is not a dichotomy between economy and environment; rather the environments stewardship should be seen as a source of sustained wealth for all of us. WNYEA continues to believe in the importance of Buffalos Green Code and is happy to participate in this ongoing process. The administration should again be commended for its efforts in this important arena. As outlined in the attached document (page 1), there are several main elements in the approach to the plan that could use attention to make the document stronger, more functional, and more effective: 1) Definitions and Metrics must be added for clarity and progress evaluation. 2) Corridors and District place types need additional development and refinement to adequately capture the nuanced purposes of these spaces while protecting good urban design. 3) Although a good starting point, parcels should not be the only scale used to determinate and define place type, consider instead both the smaller intra-parcel scale and the larger surrounding street function as well. 4) Both definitions of and plotting of place types should be a reflection of what we aspire these places to be, not just a reflection of existing conditions. 5) The code must go beyond permissive, it must be proactive to achieve environmentally responsible development. In our letter to the administration in February of 2011, we laid out several elements that must be included in the final Green Code to achieve the aim of a truly environmentally innovative development framework. The attached document is arranged according to these themes and subheadings:
Environmental Justice Smart Growth Retail Waterfronts Vacant Land Corridors and Streets Public Space Access to Green Space Open Space Districts Natural Resource Protection and Access Urban Agriculture Public Health Healthy Lifestyles Safe Environments Public Safety Economic Integration Clean Energy Public Engagement

While no city has yet to adopt workable policies across the entire spectrum of these issues, the ongoing Green Code process affords an opportunity to adopt best practices from around the country and beyond. In learning from the successes of others, Buffalo will be in a position to achieve a cohesive and interdisciplinary approach to a responsible and sustainable city for all its residents. The Western New York Environmental Alliance is committed to helping to bring this project to fruition, and is happy to assist the City and its consultants further as the plan moves toward completion, whether that is continued participation in advisory committees and working groups, working directly with city staff to develop standards for specific issues and uses, translating best practices and policies from other cities to accommodate Buffalos unique on the ground conditions, or enhancing public participation through our broad networks. The many member organizations that contributed content for this review of the draft would like to again thank the administration for pursuing this review of the land use plan and zoning code. We would like to request meeting to discuss these potential areas for improvements to the Green Code. Please review the attached recommended language changes to the draft principles and let us know how we may be of assistance in the months ahead.

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Green Code
The Western New York Environmental Alliance Submits the following comments to the draft land use plan unveiled by the City of Buffalo in October 2011.
WNYEA Public Comments November 2011

Buffalos

The draft land use plan released at the end of October was residents rst look at the proposals the City has crafted based on public input from across the city and from across various sectors and interests. Though the attached review is long, it should not be interpreted as a criticism of the direction of the project. Our belief is that what will draw people to Buffalo will be our ability to generate cutting edge urban thinking, design and development with a focus not just on the present but on the long term future of the City and the region. While there are many positive elements within the draft land use plan, there is room for improvement.

The Western New York Environmental Alliances goal is to forge a stronger, more innovative document, and a broader, more intensive dialogue is the way to achieve this aim.
We look forward to working with the City to improve the components addressed herein so that the nal version of the Green Code is one that can be successful for our city as well as provide a model for other regions attempting to build a framework of a sustainable city in the 21st Century and beyond.

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3) Parcel lines should not be the only determinant of where one place type Before addressing specic elements, ends and another begins, a broad there are several challenges within the look at context and a more nely ! In this document methodology and/or form of grained analysis are in order. Multiple document, but we are condent each place types and uses may or may not be can be addressed in future revisions. appropriate within a given parcel based Environmental Justice (page 3) on the topography, environmental Smart Growth (page 4) sensitivity, potential for stormwater 1) The document would benet capture, existing habitat values, etc. of ! Retail (page 5) greatly from a denitions section the various sections of that parcel. This clarifying the use of various terms. ! Waterfronts (page 5) is particularly true in open space Additionally, aside from simply having designations, along waterways, and in ! Vacant Land (page 6) principles and worthwhile but areas designated as Districts. On the nebulous goals for land use, a other end of the spectrum, it would be ! Corridors and Streets (page 6) successful document will include a set benecial for a more coherent grouping Public Space (Page 9) of measurable indicators and metrics of place types at the scale of the street to hold development accountable to or block. Ensuring that place ! Access to Green Space (page 9) those elements residents have held up classication do not shift multiple times ! Open Space Districts (page 10) to inform the future of Buffalo. within a small stretch will enhance the ability to create cohesive a sense of Natural Resource Protection and Access place. ! (page 11) 2) The document envisions the city as a collection of place types Urban Agriculture (page 12) Neighborhoods, Districts, and 4) Mapping and plotting of place Public Health (page 13) Corridors. While there is utility in types is too often dened by the dividing the city conceptually into ! Health Lifestyles (page 13) existing land use and conditions, these categories, there remains a need rather than the conditions we would ! Safe Environments (page 14) to insure that each of these types of aspire to see. Likewise, the places are well integrated with each descriptions outlined in the Place Based Public Safety (page 14) other. Though the document Planning Handbook adhere too closely Economic Integration (page 15) acknowledges as much, it is worth to the existing form of these place types emphasizing here that designation as a and not what the desired form would Clean Energy (page 16) District should not be an excuse to be. Though coding aspirationally may dispense with quality urban form Public Engagement (page 16) create non-conforming uses, these and urban design, but should instead grandfathered building types would place an additional responsibility on not be displaced by the zoning code these spaces to ensure an appropriate, until such time as a major welcoming and vibrant sense of place. redevelopment occurred in their place Likewise, the denition of Corridor and, as such, should cause no practical strikes an appropriate tone and vision concern for existing uses. for these designations, but the specics of corridor typologies are unfortunately largely 5) Though the draft is permissive to underdeveloped within the remainder environmentally sustainable practices, of the draft and is not reected Photo by Thomas Herrera-Mischler to be truly green it must instead be adequately in the mapping. proactive by requiring, or at the very least incentivizing, progressive patterns and innovations in building, land use and site planning.
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Photos by Anthony Armstrong unless otherwise noted

Principles of Sustainable Development

The draft land use plan starts with an impressive and concise understanding and outlining of the development and decline of the City. This rich context provides a great basis on which to restore and rebuild Buffalo moving forward. What this context also provides is a reminder of the conditions that produced instances of inequitable, unjust, and short-sighted decision making throughout our history. While it is important to build on the strengths and qualities that make Buffalo unique, this code provides an opportunity to correct some of these past mistakes while ensuring future development occurs in a more sustainable, deliberate and equitable way.

Environmental Justice
For all of the principles and policy goals outlined in the draft plan, the draft land use plan fails to even invoke environmental justice terminology. In an impoverished city with vast disparities of race and class, which contains a disproportionate amount of contamination, the revision of the zoning and land use code must be used as an opportunity to mitigate existing environmental inequities while preventing future degradation from occurring. We must directly acknowledge the challenge of the historical and current industrial and transportation pollution that we face if we ever hope to overcome them to provide equality and opportunity for all residents. Through the lens of environmental justice, it is imperative to address the legacy waste in our community. Given the regions industrial past, there remain many environmentally contaminated sites in the city. In fact, in Erie County there are 24 schools within a half mile of a Superfund site (WNYEA/Urban Design Project, Mapping Waste p. 134). Many of these sites have been cleaned up but that often means that the contamination is still on site, is monitored, and the sites are not open to the public. Not only should there be clean fresh and healthy places to access in the city, there should be protections in place to identify and limit access to sites where there is potential contamination that could affect human health and The plan needs to adopt a clear development, especially in children. denition of environmental justice as the fair treatment and meaningful In addition to addressing and involvement of all people regardless of monitoring past pollution, a formrace, color, national origin, or income based rather than use-based code with respect to the development, provides opportunities for the fusion of implementation and enforcement of both a clean environment and economic environmental laws, regulations and activities. Given the new technologies policies. available to industries, it is possible for
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residential areas to be located near working industry but only if comprehensive environmental regulations are met. However, one area that still needs to be addressed is residential proximity to high volumes of automobiles and trucks. Too often surrounding neighborhoods have poor air quality and noise that continues unabated. These areas including neighborhoods near the Peace Bridge, I-190 and Route 33, and other residential areas near high volume roads should receive extra attention to mitigate and eliminate these negative effects. Relieving the health and wellness burden in these communities should be a top priority of the Green Code.

Adopt a clear denition of environmental justice.

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Smart Growth
The principles of Smart Growth (sidebar) that focus on creating neighborhoods with a higher quality of life and more lifestyle options are certainly laudable and applicable to future development in Buffalo. In its general application, though, Smart Growth on its own is too narrow a tool for addressing the challenges and development patterns in Buffalo, and the Citys Queen City in the 21st Century Comprehensive Plan acknowledges as much. For instance, Smart Growth is largely silent on the repurposing of vacant land or on the reinterpretation of neighborhoods that have lost their viability within the regional market. For the next 20 years or longer the city is likely to contend with this reality; however, major elements of the current draft of the land use plan do not deviate far enough from the growth-at-all-costs mindset that has been in direct conict with the reality of Buffalos trends for the last six decades. But rejecting this growth-rst mentality as out of context with reality in Buffalos challenged communities does not mean we should resign ourselves to lower densities and lesser expectations of vibrant urban neighborhoods. This density is critical to maintain local services with a minimum density of 11 units/acre Buffalos average parcel density. As noted in the plan (Green Development text box on pg 29), we should strive to concentrate redevelopment in neighborhoods where public life is a key component. The highest achievement of a land use plan would be to direct and facilitate the growth of social capital as much as it directs the investment of nancial capital.
Draft Land Use Plan Comments

But because ensuring smart, accessible, integrated neighborhoods requires more than conventional land use planning, any land use plan can offer only an incomplete picture of the elements of Smart Growth within a citys future development. This drafts framework of place types is a bridge to this broader goal, but work remains to ensure the rhetoric of Smart Growth and the reality of future development are indeed linked. There are several components of the draft land use plan where these connections are either misaligned or working at cross purposes. The Place Based P l a n n i n g Handbook, for instance, needs more clarity in its intent and denitions. For example, as employment patterns continue to shift, do the proposed place types limit or allow the kind of small-shop innovation and incubation that is the only producer of net new jobs in the national economy? Restricted classication types that are generally restricted to residential uses provide no indication if, or under what circumstances, homebased businesses are allowed. Further, multiple place types have been excluded from the Placed Based Planning Handbook. For example, though both are referenced on pages 18 and 19 in the draft land use plan, Open Space typologies are not broken out and Corridors have been omitted entirely.

S M A RT G R O W T H PRINCIPLES
CITYS COMPREHENSIVE PLAN
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1. Mix land uses 2. Take advantage of compact building design 3. Create a range of housing opportunities and choices 4. Create walkable neighborhoods 5. Foster distinctive, attractive communities with a strong sense of place 6. Preserve open space, farmland, natural beauty, and critical environmental areas 7. Strengthen and direct development towards existing communities 8. Provide a variety of transportation choices 9. Make development decisions predictable, fair and cost-effective 10. Encourage community and stakeholder collaboration in development decisions

Elements of the draft do not deviate far enough from the growth-at-all-costs mindset that has been in direct conict with the reality of Buffalos trends for the last six decades.

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Retail
Other categories and classications provide more direct challenges to a sustainable vision of the city. For example, while separating suburban retail development from mixed-use neighborhood centers is laudable, it is ultimately ill-advised to encourage suburban, car-dependent development patterns anywhere in Buffalo. More emphasis, instead, needs to be placed on repairing the substantial damage that this unsustainable development pattern has already done to the city and its neighborhoods. Just because many sites throughout the city are currently single-use and non-urban, this should not relegate these sites to a continuing underutilization in the citys future place type modeling and mapping classications. Permitting Retail Strips is problematic, particularly when scattered throughout otherwise pedestrian friendly commercial areas. This type of spot zoning is detrimental to the overall goal of a people-centered city and degrades quality of life immensely. Full scale redevelopment of these single-use sites must be a priority in the plan. Special classication should not be given to Retail Districts that would permit them to continue to ignore the fabric of the city. Conversely, such sites should be seen as opportunities to reknit fragmented neighborhoods by continuing or restoring the street grid, linking neighborhoods along underutilized corridors, and eliminating the need for reliance on the automobile to meet basic daily needs. However, even where such sites are anticipated to remain suburban in form in the near term, provisions in the land use plan and zoning code should at least require improvement over existing conditions. For instance, requiring onsite stormwater treatment, particularly for larger scale buildings and large parking lots, requiring new outbuildings to properly front the street and to prioritize the pedestrian, establishing a maximum building footprint for big box stores, requiring a greater mix of uses, such as upperlevel ofce or residential uses, while likewise requiring new buildings to be adaptable for non-retail use given the regions over abundance of retail square footage and the continued shift in retail patterns nationwide.

Permitting Retail Strips is problematic, particularly when scattered throughout otherwise pedestrian friendly commercial areas.
Photo by Kevin Hayes

Special classication should not be given to Retail Districts that would permit them to continue to ignore the fabric of the city.

Waterfronts
Other major questions arise on the place types agged for sensitive waterfront land. The zoning designations listed as the Outer Harbor, Buffalo River and Scajaquada Creek Browneld Opportunity Areas (BOAs) areas should reect a "Yet to Be Determined" designation. Though the BOA process is obviously going to be a complex multi-pronged deliberation, there is a strong environmental case to made retaining these parcels as open
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space. The current designations including "light" and "heavy" industrial zoning reected in the published maps is prejudicial to an outcome that may very well not reect the highest and best use of this land. In fact, the land use and place type mapping throughout this document needs to do a better job of prioritizing parcels as crucial to watershed and waterfront access particularly but not solely where these lands are currently fallow.

The Outer Harbor, Buffalo River and Scajaquada Creek Browneld Opportunity Areas (BOAs) areas should reect a "Yet to Be Determined" designation.

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Vacant Land
It is not just adjacent to our waterways should it be limited temporally. From and should be encouraged and/ or that the highest and best use of a community gardens to tot-lots to new designated for each community (see property may be non-conventional civic spaces, using land for community Public Space, below). Best practices development. In general, vacant land is amenities not only creates from other cities set aside sites in each an underutilized asset that is not given neighborhood cohesion, but also often sub-neighborhood to coincide with a adequate attention in this draft plan. increases aggregate land values (and specic number of households or Though the plan expands use and thereby property tax) to a higher degree population. ...WORK REMAINS TO ENSURE THE RHETORIC OF SMART GROWTH AND THE development options as an interim than a single new structure would REALITY OF neighborhoods, contribute. Specic to this point, steps in distressedFUTURE DEVELOPMENT ARE INDEED LINKED... reinterpretation of land use must not be community gardens must be Vacant land is an limited to communities in distress, nor recognized as a viable long term use,

SMART GROWTH... A STARTING POINT

underutilized asset that is not given adequate attention

Corridors and Streets

Another missing place type, the C-TM (Metro Rail) is listed in the corridor descriptions (p.19) as an element in the land use plan, but is not visible in the future place type maps. Clarity about what the existing Metro Rail Corridor will mean in the new zoning code and zoning map is needed. The code also should plan for development along proposed corridors such as the route from downtown through the east side to the airport. Each light rail stop should not just reect a desire for enhanced density in the privately held lands, but a particular focus on place making in the public realm should also be expressed. Making each of these nodal assets a unique and welcoming destination will grow the importance, attractiveness, economy and These designations are exceedingly connectivity of the corridors over time. important as the City implements its Complete Streets policy and as As a whole, as it is currently drafted, consideration is given to converting the Transportation Corridor (C-T) is a highways to boulevards to improve blunt restrictive classication that livability and attract investment misses the importance of the synergy throughout the city. The design of our between the public spaces of our streets streets must correspond appropriately and the land use types desired. Streets to the neighborhood place-based types are the elements of our city which not in accordance with the placed-based only connect us but also represent the development strategy as laid out in the largest component of land in direct draft plan. As the future land use plan public control. The land use plan needs sets the stage for establishing a new to have stronger and more specic regulatory framework of the private language to facilitate the range of realm with a place-based development transportation options necessary to strategy, all transportation corridors reinforce healthy communities and and facilities should be included in the recognize streets as valuable public place-based maps and not lumped into places. a single ambiguous category.

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Streets are the elements of our city which not only connect us but also represent the largest component of land in direct public control.
Photo by JoelMann Photo by Green Options Buffalo

In addition to the current Transportation Corridor (C-T) place types, Boulevard, Avenue, Streets and Alley/Lane need to be recognized distinct types of streets and coded as such. Table 1 (attached) should be utilized to dene all common street types, which can then be subdivided into specic special street type classications, such as Main Street, Woonerf, Festival Street (see table 1.1), where appropriate. These street types provide mobility for all modes of transportation with a greater focus on pedestrian, cyclists and transit users. It is linked more closely to the adjoining land-use and the need to create a safe environment for all people, rather than strictly following the conventional but

dated application of functional Also in the Corridor Place Types, in classication in determining geometric addition to Greenways (C-TG) as a criteria. place-type, Blueways/Waterways (CTBL) should be included to highlight By dening the street types in the multitude of waterways through accordance with the adjoining place the city that are both natural and types, a framework for street design capped. guidelines will begin to take shape. As a preliminary step, many of the Current best practices in zoning goes transportation related comments in the further than dening corridors and attached mark-up of the land use plans street design, though, and typically draft principles reect the need to code incorporates all subdivision and public our streets to reect and institute works standards directly in the zoning national best practice guidelines. To code. Buffalo should join the ranks of establish clarity and precision around cities like Miami and Denver that have these transportation elements, the plan successfully adopted this model, so all should fully incorporate the policy the regulations that guide development framework of the Sustainable in the city are moving in the direction Transportation Agenda issued by Green of sustainability and smart growth. Options Buffalo (attached as appendix).

To establish clarity and precision around these transportation elements, the plan should fully incorporate the policy framework of the Sustainable Transportation Agenda issued by Green Options Buffalo.

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Table 1: Street / Facility Types Street Type Boulevard* (conventionally arterials) Avenue* (conventionally collectors) Street* (conventionally local streets) Alley/Lane Description Comment

Traverses and connects districts and Often has a planted median neighborhoods within cities; primary a longer distance route for all vehicles including transit Traverses and connects districts, links May or may not have a median streets with boulevards. For all vehicles including transit. Serves neighborhood, connects to adjoining neighborhoods; serves local function for vehicles and transit Link between streets; allows access to Narrow and without sidewalks garages

*May have segments with specialized functions and features such as a Main Street segment.

Table 1.1: Special Street Types

Street Type Main Street

Description Slower vehicle speeds, favors pedestrians most, contains the highest level of streetscape features, typically dominated by retail and other commercial uses Located between an urbanized neighborhood and park or waterway

Comment Functions differently than other streets in that it is a destination

Drive Transit Mall

The traveled way is for exclusive use by buses Excellent pedestrian access to or trains, typically dominated by retail and and along the transit mall is other commercial uses critical. Bicycle access may be supported. A through street for bicycles, but short distance travel for motor vehicles Contains traffic calming, ush curbs, and streetscape features that allow for easy conversion to public uses such as farmers markets and music events Slow, curbless street where pedestrians, motor vehicles, and bicyclists share space May support caf seating, play areas, and other uses Usually a local street with low traffic volumes

Bike Boulevard Festival Street

Shared Space (Woonerf)

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The Natural Environment

The depopulated city offers excellent opportunities to try non-conventional redevelopment of vacant properties, essentially a rare chance to rebuild a 19th century city with a 21st century understanding of environmental impacts and synergies. However, it is critical to develop a policy that outlines which of these non-conventional uses is transitional (where the sites will be incorporated into other uses over time), and which are permanent (to be permitted and protected in the long term). Using green open space as an example: If a vacant property is to be used for recreation space for the neighborhood, will that space be incorporated into the permanent open space prole of the city, or will it someday become housing to provide sufcient density in the neighborhood to support local services? Each place type designation requires this kind of thoughtful consideration and denition.

Public Space
It is critical to develop a policy that outlines which nonconventional uses are transitional and which are permanent.

Access to Green Space

As stated earlier and acknowledged in the draft plan (p. 38), the City should adopt a policy that every resident should be able to access a designated park or greenspace within a quartermile of where they live. However, more denition is needed for what types of facilities or which delineation of Open Space and what acreage or area will fulll this requirement. Upon being identied, though, these spaces need to be protected in the zoning code and not be considered transitional uses, and a corollary standard needs to be adopted for Community Gardens. This should include not just neighborhoods where there is substantial vacant property but areas that are currently densely populated, such as the upper west side. Anywhere there are not parks or open spaces for public use, new facilities should be provided and protected within the one quarter-mile benchmark. However, this may include play streets that limit trafc where open land is unavailable. The play street or woonerf (referenced in the Corridor section above) is a concept well established in Europe where some streets are designated primarily for pedestrian use but permit use by cars for access and parking, but not thoroughfare trafc.

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Open Space Districts

Modications should also be made to the denitions for types of Open Space Districts. As referenced in the introduction to this letter, not all parcels can be dened as a single land use or place type. All open spaces should provide multiple use opportunities, not just one: recreation and habitat, stormwater management and sports, clean air and passive recreation, and so on. In fact, nearly all Open Space Districts contain or should contain more than one of the Olmsted, Recreational, Civic or Natural divisions currently outlined (p. 18). In the Place Based Planning Handbook, the D-OO Olmsted denition should remain, yet it should be more explicit that the place and usage types within each park are to be dened by the Olmsted Conservancys Plan for the 21st Century. The denition of D-OR Recreational is appropriate for playelds, etc. within parks as open space designed to accommodate active recreational uses, both structured and informal. D-OC Civic captures the character of these smaller spaces well, yet the City is largely lacking in this type of gathering space in many neighborhoods a situation that should be addressed. Likewise the D-ON Natural denition is appropriate, yet walking or biking trails that are part of a broader system should be indicated as places in the Corridor typology. There should, however be additional delineations of Open Space, including: D-OG Community Gardens either plot based or communal (whether within parks or integrated within a neighborhood block); D-OI Park/ Informal Recreation resembling Olmsted aesthetic or otherwise highlighting Buffalos heritage (the city should add more such parkland particularly along the waterfront and on the east side); D-OP Conservation/ Protected Areas spaces that have high habitat value and should be protected (see Table 2). Additionally, many open spaces in the city are owned by institutions or are private, and, again because of the parcel based divisions, this is not reected in the current draft. Unfortunately open space is too often a term to describe underutilized land, blank lawns or berms which do not provide benets to humans or to the environment. Policies should govern the use of undeveloped land, for example, within campuses, school grounds or existing ofce parks, with a mix of with regulations and incentives to provide public access and accommodations to on-site productive open space.

Table 2: Open Space District Revisions

Open Space District D-OO Olmsted D-OI Informal Recreation D-OR Recreational D-OC Civic D-OG Community Gardens D-ON Natural D-OP Conservation/ Protected Area
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Description Large, meadow-like parks designed by Olmsted with a primarily passive, pastoral, or picturesque character

Comment The various place types within these parks should be explicitly guided by the Plan for the 21st Century

Contemporary public park space More such parkland should be added resembling Olmsted aesthetic or particularly along the waterfront and otherwise highlighting Buffalos heritage on the east side Open space designed to accommodate Appropriate for ball elds and courts active recreational uses, both structured within parks, school facilities, etc. and informal A formal space that takes on the Goal should be to introduce more of character of a civic green of plaza usually these central gathering places, of small to medium scale. potentially at least one per planning community Open space designated for communal or Appropriate within parks or on plot based ornamental and vegetable previously vacant land a target gardening amount of protected space should be established per community Naturalized open space or conservation Walking or biking trails that are part area with no, or few, active uses aside of a broader system should be from walking or biking trails indicated as places in the Corridor typology Spaces that have high habitat value and should be protected
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Natural Resource Protection and Access

An environmentally focused code must address the relationship between green infrastructure and the built form.

In many ways Green Infrastructure should be the primary principle underlying the new landuse plan. This inverts our usual planning strategy because it assumes the city is a network of green that provides quality living for all residents, multiple uses of open spaces, a healthy environmental, networks of green (such as Olmsted Parkways) and productive landscapes. Housing, services, and work places are then placed within the green structure, rather than having natural areas subsumed by or accommodated within the city. Though a new conception, in many ways this city in a park concept builds on Olmsteds grand vision. For a fundamentally environmentally focused code, the relationship between built form and systems in the land use plan must adequately address the relationship between the green infrastructure and the built form. This is consistently absent throughout the current draft of the plan. As stated

above, consider the entire city a green city into which gray infrastructure and built form are inserted (its historic evolution) so that policies regarding built form include consideration of trees, stormwater management, clean air, playing outside and so on.

there is a 100 foot setback along the Buffalo River for habitat protection. This strategy should be used in other places for habitat protection and water quality improvement. The goal should be shable and swimable waters: there should be no exceptions to the Clean Water Act protection for waterways Within this framework it is vital to even when adjacent landuse is identify and protect existing natural commercial and industrial. resources areas, and it is critical to identify areas currently not recognized Another strategy is considering all and to protect them as well. Consider open and green spaces for stormwater not only protecting existing waterways, management assistance. That includes for example, but research the possibility existing parks, natural areas, median of daylighting historic waterways such strips, ofce parks, incentives for as the Scajaquada Creek where it has homeowners and so on. Getting the been channelized. water into the ground where it falls is the most achievable way to avoid Daylighting buried streams would be a overwhelming the sewer system and to major step to capturing the recharge ground water. The City environmental benets provided by should continue to work with Buffalo urban waterways, but whenever Sewer Authority on the Long Term possible habitat should be restored to Control plan with an emphasis on assist in cleaning the water and green infrastructure. protecting the shoreline. Currently,

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Urban Agriculture

SEEDING

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The National Policy & Legal Analysis Network to Prevent Childhood Obesity (NPLAN) released Seeding the City: Land Use Policies to Promote Urban Agriculture in October 2011. The guide acknowledges the various types of Urban Agriculture, from home gardens to community gardens and urban farms. It also promotes the many benets of Urban Agriculture in the form of health, environmental Sustainability, and economic vitality. Seeding the City establishes goals for comprehensive planning including: protecting existing and promoting new urban agriculture in each of its forms, maximizing opportunities to incorporate urban agriculture into new development, and to promote urban agriculture through ongoing programming and partnerships. It also provides model zoning ordinances across a variety of circumstances and conditions. Seeding the City is available for download at www.nplanonline.org.

As noted in our initial letter to the administration, important justications for providing clarity for urban agriculture include: access to local, fresh and healthy food for urban residents; direct environmental benets in reduced carbon footprint, increased biodiversity, storm water management strategies and organic waste reuse; education and employment access in job skills and entrepreneurial training and supplemental income, experience with nature and food production; neighborhood development through beautication and blight abatement in addition to reduced crime through community stewardship and opportunity. The draft land use plan acknowledges that urban agriculture will play an expanding role in the City of Buffalo (Section 9.3). However, the current language does not go far enough in dening the parameters of urban agriculture or in ensuring that its role is lasting and accessible to all. Whether or not urban agriculture ever provides

an economic boon to the city in terms recognized in GDP-approved metrics, it is clear that it improves the economy of and opportunities for of families and neighborhoods. The land use plan must explicitly allow for the establishment of urban agriculture on public and private property by adopting zoning regulations that permit home gardens, community gardens, urban husbandry (bees, chickens, sh, etc.) as appropriate to all ve neighborhood place types. It must also ensure that urban agriculture can ourish into an extended growing season with appropriate guidelines on the design of greenhouses, hoop houses, and the like. Guidelines should include uses, quality design, and standards governing safety and aesthetics. Sales of produce grown on public and private land should be allowed as a conditional or permitted use, with appropriate limitations on location, size, and time of operation in place-types throughout the city.

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Photo by Michael Clarke

The Built Environment

As in our initial letter, this section on the built environment is not meant to necessarily address structures as a building code would, but rather to address the physical space, relationships and associated interactions and behaviors that the design and siting of buildings and public works create. Reversing the detrimental effects of policies favoring auto-centric and use-separated zoning remains a key goal of WNYEA for the Green Code.

Public Health
The Green Code can provide the opportunity for all communities to be healthy now and in the future by lessening health inequity. The acknowledgement of the Green Codes role in public health in the principles section of the land use plan (p. 40) is welcomed, but the section as written is underdeveloped and does not address the full complement of possible initiatives and regulations that should be codied to improve wellness within the city. The code can address public health by facilitating both behavioral and environmental changes.

The Green Code can address public health by facilitating both behavioral and environmental changes.
Healthy Lifestyles
The most apparent opportunity in the Green Code is to affect behavioral changes by encouraging active lifestyles largely through improvements to the built environment. This includes a host of actions to increase physical activity among residents. The creation of safe, accessible and walkable neighborhoods and routes will facilitate biking and walking as attractive active transportation alternatives integrating activity into daily activities. Creation and proper maintenance of a variety of parks, playgrounds, and recreation/ community centers with seasonally appropriate uses and activities will also
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provide increased opportunities for allowing land access for community discrete and intentional physical gardens and urban agriculture at a activity. variety of scales and through distribution by facilitating food Healthy living extends, also, to healthy stands, markets, and healthy corner eating. Currently, unequal resources store initiatives. In the same way that for and access to quality food are the current zoning code restricts prevalent across the city, and the Green conicting or potentially harmful uses Code should employ a variety of (such as liquor stores) with a dened different strategies appropriate to the radius of schools, the land use code specic challenges and opportunities in should also designate zones of the city each community. The Green Code can that restrict development of unhealthy afford residents greater opportunity to food options such as fast food obtain healthy, affordable, and restaurants. culturally appropriate food in their own neighborhood through production by
Draft Land Use Plan Comments

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Safe Environments
Behavior change will help contribute to communities. Air, water, and soil burdens placed on or lifted from increased health outcomes, but, when it quality should be analyzed throughout individuals, but also to the demands on comes to public health, the impact of the city and the presence of raised our social service sector. For instance, ambient environmental factors cannot levels of toxicity in or adjacent to though accessibility is referenced in be overlooked. Pollution from the neighborhoods should add additional street design and in place type regions industrial legacy, from freight levels of scrutiny for adjoining land adjacency, this needs to extend to and high volume commuter trafc, and uses and place types while providing a buildings as well. Though ADA ...WORK REMAINS TO ENSURE THEaddressing theseOF SMART GROWTH ANDpublic spaces, RHETORIC harmful provides regulations for THE from our persistent combined sewer blueprint for REALITY OF FUTURE DEVELOPMENT ARE INDEED LINKED... overow issues disproportionally elements. it is important, too, to integrate impacts low-income communities of visitablity as a minimum component of The Green Code also needs to consider color. As stressed in the Environmental accommodation within the ongoing demographic shifts and what Justice section above, the Green Code development and retrotting of private kind of accommodations will need to be needs to go farther in identifying and spaces as well. made for an older population. These eliminating environmental burdens on considerations apply not just to the

SMART GROWTH... A STARTING POINT

Public Safety
Though many of the elements of creating a safe public environment will be delineated in the zoning code rather than the land use code, it is important to reinforce the notion that safety is in large measure dened by place. A place that feels safe will be a welcoming and therefore active space creating, in effect, a self-fullling cycle of perception and reality. But the corollary is also true. A place that is designed poorly will feel unsafe, and thus become unwelcoming, unused, and, thereby, unsafe. This applies from streets to parks to apartment complexes. It applies in neighborhoods, districts and corridors.
Draft Land Use Plan Comments

Perhaps in no category is the notion that we shape our buildings, and afterwards our buildings shape us more appropriate. Urban design is a crucial component of promoting a vibrant and safe public realm. At minimum, basic principles of crime prevention through environmental design should be included in the land use plan: natural surveillance (eyes on the street), access control (privacy gradients and dened entries), image (proper maintenance/ broken windows theory), and territoriality (clearly dening public/ private space).

Places that are designed well promote public safety. Places that are poorly designed quickly become unsafe.

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Economic Integration
As stated in our original letter, Buffalo cannot achieve sustainable communities without sustainable employment. The inclusion of Retail Districts as a future place type (see Smart Growth above) is one such example where the draft land use plan fails to reduce logistical barriers to employment (i.e., time and expense of transportation and childcare) and perpetuates reliance on private automobiles for accessing daily needs. Integrating economic development and community development means integrating and erasing the lines between where those activities were establishing connections. The plan provided the model for much of needs to go much further in this regard. Buffalos Browneld redevelopment strategy. Focusing on the existing The draft plan furthers this otherness of infrastructure along the Belt Line as a community and economy by placing an preservation and reuse strategy is more emphasis on the expansion of ofce and sustainable and less resource-intensive industrial parks (Section 3.1). Yet these approach to growing jobs in Buffalo. It sites tend to yield disappointing should be given priority in the plan employment densities even at full over ofce and light industrial parks. build-out. They are almost always caught in the car-dependent trap that The Belt Line provides a specic plagues Retail Districts and example of how valuable the existing disadvantage low-income households rights of way are and can become. through their inaccessibility via public Preserving rights of way for linkages transit, walking, or cycling from between communities and economic neighborhoods. opportunity should be a priority. They

The Belt Line offers a model of development that focuses on adaptive reuse of former industrial buildings and integrates into existing neighborhoods.

Photo by mark.hoganon Flickr

encouraged in the previous zoning The Larkin District revitalization, code. however, provides a more sustainable and urban means of building on The plans goals to enhance connections Buffalos heritage to provide new between the Central Business District opportunities for commercial and light and adjacent neighborhoods (Section industrial development that 1.2) is a good start, but can be improved strengthens existing communities. This and broadened. However, inclusion of means of redevelopment should be other districts requires establishing prioritized and the "Belt connections rather than the mixedLine" (referenced in Section 3.2 in the use ideal of full integration instead of draft plan), where many of Buffalos single use zones. The language that large scale structures are positioned, addresses medical and educational provides a framework for linking these districts is telling (Section 2.1) in that it secondary centers together in the future solely focuses on mitigating conicts and to neighborhoods today. Reusing rather than addressing shared benet. former industrial structures along the As long as these types of us vs. them Belt Line for environmentally-friendly, dichotomies are allowed (or regulated) mixed-use redevelopment is likely to to persist, conict will be the dominant yield stronger results than the order of the relationship and we will be conventional greeneld style economic forever relegated to settling for development which has unfortunately practicing mitigation and
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should not be turned over to private ownership or private development. Another plank of the historic transportation network on which Buffalo thrived and requires revitalization is the Ellicott grid and radial network. Though referenced in the plan (Section 10.3), this reference is insufcient on its own. The restoration of this network including streets like Genesee, Busti, the Terrace, and 7th should be visible in the future place type maps and reserved for restoration in the future zoning code and zoning map. A detailed plan for the restoration of lost neighborhoods, like the Italian Colony referenced in the plan, should be focal points for rebuilding downtown and fostering stronger connections to adjacent neighborhoods.

Draft Land Use Plan Comments

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Clean Energy
As the plan notes, early in Buffalos development the Citys energy sourcechanged almost from decade to decade horse power, water power, coal and steam, hydroelectric(p.4). This draft has begun to establish principles that do, in fact, anticipate the scaling up of existing green technology while paving the way for Buffalo to build on our legacy of energy innovation to become a hub for new clean energy in the future. Particularly as fresh water becomes more precious, Buffalo will be well positioned for retaining and attracting residents if it can also craft an energy independent future as carbon based fuels likewise noted in our initial letter, a separate become more rare and expensive. City initiative will need to focus on to those remedies that heal the existing In addition to considering energy city by creating a suite of conservation (p.20) the plan is right to accompanying policies and practices look to energy production as well. The that align municipal operations and Green Code should employ as many capital investment with the intent of the tools as possible within zoning new code. A large component of this regulations to incentivize energy companion policy would need to conservation (energy smart incentivize existing buildings and uses mechanicals and increased insulation), to comply with the spirit of the code. clean on site production (i.e. Ideally the ongoing planning process geothermal, active and passive solar, for land use and zoning review will small scale wind) in addition to produce recommendations for this vital environmentally sensitive building aspect as well. methods in new construction, changes of use, and substantial renovations. As

Photo by TonyDude919 on Flickr

Public Engagement
The City has made a commitment to public engagement that has been demonstrated through its many public meetings, the Green Code website, and the Community Advisory Committee. Robust turnout at the Citys Planning Day in October underscores the fact that the public is, and has a desire to remain, engaged in this process. However, there are elements in the plan that are underrepresented and the City should strongly consider formation of targeted issue advisory or focus groups such as environmental justice, vacant land reclamation and reinterpretation, youth and educational facilities, and green energy to augment the ongoing process. In addition, the public meetings still to come need to do a better job of accommodating families and children. Successful expanded engagement techniques make it easier for those who want to come to traditional meetings by providing childrens activities, and even bus fare wherever possible. WNYEA member organizations have heard from a number of residents that they have been unable to attend meetings in their communities over just these concerns. To reiterate our previous statements, though these extra efforts represent an increase in costs, in relation to the project scope, the benets of a better process are well worth the minimal expense.
Draft Land Use Plan Comments

Board of Directors
Bob Knoer Chair Judith Einach Vice Chair Loren Smith Secretary Arthur Wheaton Treasurer
Anthony Armstrong Justin Booth Jay Burney Erin Heaney Megan Mills Hoffman Kerri Bentkowski Li Thomas Herrera-Mishler Micaela Shaprio-Shellaby Terry L. Yonker 16

Economy
1 Reinforce downtown as a regional hub.
1.1 Activate the downtown core. 1.2 Enhance connections between the CBD and adjacent neighborhoods. 1.3 Reintroduce a high quality public realm.

Neighborhoods
6 Reinforce walkable neighborhoods.
6.1 Support efforts to revitalize neighborhood centers. 6.2 Build on existing neighborhood strengths. 6.3 C apitalize on neighborhood assets. 6.4 Maximize housing choice and affordability. 6.5 Establish interim alternative uses and improve m anagement practices for vacant land. 6.6 Increase public safety through effective urban design

2 Support the emerging knowledge economy.

2.1 Support the growth of regional educational and m edical anchors. 2.2 Embrace arts and culture as economic drivers. 2.3 Improve the visitor experience in Buffalo.

7 Improve transportation options.

7.1 Improve street design. 7.2 Encourage walking and cycling. 7.3 Promote transportation alternatives.

3 Grow employment centers.

3.1 F acilitate office and industrial park development. 3.2 F acilitate m ixed-use redevelopment along the Belt Line. 3.3 Support a working waterfront. 3.4 Devote resources toward brownfield and greyfield reclamation. 3.5 Promote and facilitate entrepreneurship, home based business and green energy innovation 4 Increase retail activity. 4.31 Support neighborhood retailers and entrepreneurs.

Environment
8 Enhance natural resources.
8.1 Protect and restore sensitive habitats. 8.2 Enhance riparian environments.

9 Reinvigorate public health.

9.1 Promote healthy and sustainable environments 9.21 Promote active living. 9.32 Create a healthy local food systemEnable healthy food production and distribution.

4.2 Reintegrate retail with the urban environment

4.1 F acilitate development of retail centers. 4.2 Identify appropriate s ites to cluster retail strip development.

10 Preserve natural, cultural, and historic resources.

10.1 Protect and enhance open spaces. 10.2 Support waterfront access and usage. 10.3 Preserve cultural and historic resources.

5 Optimize access and circulation.

5.1 Reinforce Metro Rail ridership. 5.2 Support efficient m ovement of goods. 5.3 C onnect with C anada.

Implementation
Future Place Type Maps - General Principles

Economy
Planning for a sustainable economy means helping ensure that both current and future businesses are able to successfully operate and grow. The plan aims to promote place- based economic development by targeting downtown investments, fortifying employ- ment centers, reclaiming brownfields, and improving accessibility, capitalizing on our potential for green energy production, and promoting entrepreneurship in a changing economy. The principles support downtown as a regional center by introducing strategies to reinforce its density, accessibility, compact form, and range of uses. The plan will help diversify the citys employment base by supporting emerging industries that need places to grow. It will define the knowledge corridor that stretches along Main Street from the University of Buffalo to the heart of downtown, and help capture the citys share of consumer and visitor dollars. Convenient shopping is an amenity for visitors, a necessity for residents, an anchor for neighborhoods, and an economic benefit to the citys economy. The recognized principles encourage mixed-use centers in every neighborhood, and protect the intimate and pedestrian-oriented character, and allow for the transition of conventional suburban arterials to mixed-use centers where appropriate. The plan also attempts to reintegrate locates additional destination retail where it is possible to cluster big box developmentinto the fabric of the city. The plan and its principles will help maintain the citys employment base. It supports development of employment centers, such as those along the Belt Line. The plan also reinforces ongoing work to reclaim industrial land in Brownfield Opportunity Areas in South Buffalo, Black Rock, the East Side, and the Inner and Outer Harbors.

1 Reinforce downtown as a regional hub. 1.1 Activate the downtown core. Permit the full range of uses, such as office, residential, hospitality, civic, retail, and entertainment, to activate the streets of downtown. Accelerate development of emerging neighborhood clusters within the Central Business District to create a mixed-use, 24/7 downtown. Encourage centralization of regionally significant government facilities to downtown Buffalo. Support the continued growth and intensification of the Buffalo Niagara Medical Campus and the University at Buffalos Downtown Campus. Focus structures of the greatest height and intensity near the Main Street Transit Mall. Support regional development policies that attract residents and employers back to transit-serviced locations of the urban core. Encourage green building technologies (including on-site stormwater management) that can bolster downtowns image and attract innovative businesses. Re-establish and Restore Joseph Ellicotts original street grid pattern in the Central Business District and within urban renewal areas (I.e. The Waterfront Urban Renewal Project) Restore all one-way streets to two-way Enhance linear connections to adjoining neighborhoods with pedestrian-oriented frontages and multi-modal accommodations along radials such as Erie, Niagara, Delaware, Main, Genesee, Broadway, and Seneca. Reduce the negative impact of streets that serve as barriers between the CBD and adjacent neighborhoods, such as the Elm/ Oak arterials, South Elmwood, Tupper and Goodell. Support enhanced multi-modal transportation connections between the CBD and adjacent neighborhoods wherever possible. Encourage mid-rise redevelopment within the downtown edge to provide ap- propriate transitions in scale from the CBD to adjoining neighborhoods. Improve connectivity between the Inner Harbor/Erie Basin Marina and the Downtown core under the 190 (short-term); through a high capacity Boulevard (long term). 1.3 Reintroduce a high quality public realm.

1.2 Enhance connections between the CBD and adjacent neighborhoods and beyond.

 Downtown should be green and welcoming with ample provision of trees/ vegetation, planted medians, and natural stormwater management. Establish a street grid within the CBD where pedestrian-oriented frontages will be aligned and multi-modal accommodations provided. Prioritize road diet initiatives on downtown streets to properly allocate space for motor vehicles, cyclists, and pedestrians and green infrastructure. Reestablish two-way traffic on streets that are currently one-way. Avoid new surface parking lots within the CBD core; allowing development of structured parking that meets design, mixed-use, and environmental standards. Limit Prohibit skywalks and tunnels that divert pedestrian traffic from sidewalks. Complete the Cars Sharing Main Street Project while preserving rapid-transit prioritization, access and quality of service. Continue improving Niagara Square and other public squares and green spaces into a more beautiful, clean, comfortable, and pedestrian-friendly public spaceplaces. 2 Support the emerging knowledge economy. 2.1 Support the growth of regional educational and medical anchors. Encourage multi-building educational and medical institutions to establish or update campus plans to facilitate development that integrates with neighborhoods with the benefit of public input. In consultation with surrounding residential neighborhoods, develop strategies that address town and gown conflicts and provide joint benefits. 2.2 Embrace arts and culture as economic drivers. Recognize cultural tourism uses such as the Martin House Complex, Richardson Olmsted Center, and the Theatre District, Museum District, and Michigan Street Baptist Church. Support public art installations in strategic locations including streetscapes. 2.3 Improve the visitor experience in Buffalo. Facilitate the development of visitor accommodations, including hotels, inns, hostels, and bed-and-breakfasts, in appropriate places across the city. Develop Implement strategies for improving the appearance of first impression corridors and entry points into the city. Support Erie Canal Harbor Development Corporations efforts to rReestablish the historic street grid and canal network of downtown and Canalside.

 Support Create improved transit connections to the Buffalo Niagara International Airport. Work with Amtrak on an improved downtown train station. Support NFTA plans for improvements to the Metropolitan Transportation Center. 3 Grow employment centers. 3.1 Facilitate office commercial and industrial park development. Reserve Ensure available land for economic development office campuses and industrial uses, encouraging that are such environments to developed in an urban character and integrated into neighborhoods where possible. Accelerate provision of reuse-ready structures and facilitate existing vacant land for shovel-ready landuses where appropriate and reuse-ready structures. Capitalize upon highway, rail, and Peace Bridge multimodal access points for cargo-oriented development, while ensuring neighborhoods are not negatively impacted from freight activity. Minimize conflict between employment districts and residential neighborhoods through appropriate edge edge form, scale and use, not through suburban treatments and designs such as grassy berms. 3.2 Facilitate mixed-use redevelopment along the Belt Line. Continue to act upon the economic potential of existing and emerging employ- ment centers, such as the Larkin District, Tri-Main, and Northland. Permit the widest range of adaptive reuse options, including office, residential, and light industrial, to facilitate reinvigoration. Integrate adjacent neighborhood centers into Belt Line employment areas. Support Establish ongoing service improvements and the development ofto transit routes that connect to Belt Line employment centers. 3.3 Support a working waterfront. Protect marine commercial and water-dependent and enhanced industrial uses which do not degrade the environment or impact neighborhoods in the zoning code. Facilitate repurposing of vacant waterfront land and structures for employment uses through ongoing brownfields planning and heritage preservation efforts. Incorporate green infrastructure into all streetscape projects to reduce CSOs and establish a healthy marine ecosystem to support water-dependent uses.

3.4 Devote resources toward brownfield and greyfield reclamation. Incorporate planning efforts to reclaim brownfields across the city through New York States Brownfield Opportunity Areas (BOA) Program. Actively seek out development solutions for underperforming retail sites, such as Central Park Plaza. Support infrastructure investments that reintegrate brownfields and greyfields back into the regional economy while enhancing and reinforcing urban character. Prioritize brownfield redevelopment within neighborhoods, both to eliminate health risks and provide accessible employment opportunities within communities.

3.5 Promote and facilitate entrepreneurship, home based businesses and green energy innovation Permit non-noxious, non-nuisance start ups and businesses in all areas of the city regardless of building type. Allow for growth of urban agriculture and food related industries in a variety of settings and applications Promote and incentivize shared commercial tenancies as well as retail/ production spaces, particularly along commercial strips and urban centers Permit and encourage the development of clean energy on a variety of scales, both for on-site use and for commercialization, including district and geothermal heating, solar, wind, and agri-fuel technology where appropriate. 4 Increase retail activity. 4.31 Support neighborhood retailers and entrepreneurs. Actively Eencourage and incentivize walkable retail development in neighborhood centers. Establish legal clarity for corner shops and small-scale retail uses (such as ) in residential areasneighborhood place typesneighborhood place types. Develop transparent and predictable regulations for mobile food vendors, including food trucks, wagons, bikes, and carts. 4.12 Reintegrate retail with the urban environmentFacilitate development of retail centers. Reserve sites for retail centers in appropriate locations. Establish guidelines for retail centers that provide for the safety and comfort of pedestrians, cyclists, transit users, and motorists alike. Establish edge treatment guidelines for retail centers that allow for appropriate transitions to adjacent neighborhoods.

 Mitigate the environmental impacts of existing car-dominated retail centers by connecting to multi-modal transportation options and deploying green infrastructure solutions; restrict the development of auto-oriented retail centers in the futureers; restrict the development of auto-oriented retail centers in the future.. 4.2 Identify appropriate sites to cluster retail strip development. Prohibit retail strip development that is out of character and form with traditional urbanism. Focus retail strip development on the outskirts of neighborhoods. Target locations along high-volume arterials; proximate to highway access points; industrial sites no longer marketable for their original purpose; and adjacent to established retail centers. 5 Optimize access and circulation. 5.1 Reinforce Metro Rail ridership. Create great places at Metro Rail station areas by emphasizing mixed-use, high- density neighborhood centers. Prioritize traffic calming and walkability improvements that would help hu- manize and activate Main Street. Pursue efforts to provide public safety through environmental design. Strive for the maximum population and employment densities near Metro Rail stations. Support further study of Metro Rail expansion alternatives and encourage the development of light rail ready neighborhoods along these routes. The light rail system should be expanded to provide better access to residents with stops located within a 14 mile of all residential and commercial parcels. Enhance pedestrian facilities within a one (1) mile radius of all transit stations. Enhance bicycle facilities within a three (3) mile radius of all transit stations. Protect corridors for rail and water freight transportation. Support infrastructure improvements that increase freight movement efficien- cies and reduce carbon emissions. Review designated truck routes to ensure consistency with both economic development, and neighborhood stability and environmental justice objectives.

5.2 Support efficient movement of goods.

 Protect strategic excess roadway, rail, air cargo, and port capacity to attract economic development. 5.3 Connect with Canada. Promote the International Railway Bridge as a cross-border freight connection. Support efforts to improve passenger-oriented traffic flow travel over the Peace Bridge, to capitalize on the growing knowledge and leisure economy in downtown Buffalo and the Buffalo Niagara Medical Campus. Reduce the environmental health burdens of international freight on the West Side while minimizing the impacts onrestoring Front Park and surrounding neighborhoods.

Neighborhoods
Planning for sustainable n eighborhoods means preserving the character of n eighborhoods while encouraging redevelopment consistent with the prevailing pattern. The plan identifies five major n eighborhood types that have been identified based on their character, form, and mix of uses. The principles encourage integrated mixed-use development at the center of neighborhoods. Neighborhood centers provide important services to residents and create a greater sense of place. The plan identifies a mixed-use center in every neighborhood where one already exists or where one might b e d eveloped to promote p edestrian safety, comfort, and interest. High quality public space is vital to community cohesion, yet many n eighborhoods of the city are deficient presenting a situation that n eeds to b e remedied. Green infrastructure from street trees to stormwater managing landscape treatment is also a crucial component of quality of life on every b lock of the city. The plan will expand use and development options, particularly in distressed neighborhoods. It is important that vacant land is managed creatively, keeping it in active or passive uses in the short term, and making the most of its development potential over the longer term where appropriate to promote increased d ensity and regeneration. Where Where vacancy existsareas are predominantly vacant, the plan will allow transitional uses such as community gardening, side and back lot programs, or urban agriculatureagriculture and also acknowledges the appropriateness of these uses in some of the Citys parks. In environmentally sensitive areas and in some heavily distressed communities it may be appropriate to pursue a naturalization program which creates amenities for residents while providing valuable ecological services., while keeping open longer-term options for redevelopment. In strong n eighborhoods or ones where vacancies are less s evere, community space n eeds will be a ccommodated and infill programs opportunities will b e facilitated. Where superblocks are in transition p laces where the street pattern has been disrupted to create d istrict or campus- like areas the plan will a llow redevelopment consistent with an adjacent n eighborhood to reconnect with the city-wide street pattern once again.
GREEN DEVELOPMENT IN DISTRESSED NEIGHBORHOODS While Buffalo has many strong neighborhoods, there are others that suffer from abandonment. This has created areas in the city where most of the housing stock has been demolished, leaving large tracts of vacant land. This situation is particularly apparent in the Broadway- Fillmore neighborhood. Vacant land created by abandonment can become an asset. The pending zoning ordinance will allow the land to be used for its potential to: employ local residents in activities such as silviculture, growing ornamentals, and other forms of urban farming; expand recreational amenities and restore ecologically sensitive lands; provide areas for producing new forms of renewable energy; and address the citys stormwater problems. Even left as green space, the land holds value given its proximity to downtown, secondary employment centers, and major transportation corridors. While permitting new activities such as those listed above, the city must be clear about which lands are to be permanently green and which are transitional or temporary spaces and must also protect the traditional development patterns in these neighborhoods for future housing or commercial reuse in the later category. However, until its demographic trends improve, Buffalo must encourage development towards neighborhoods where the majority of the urban fabric remains intact. To the extent that housing and commercial development is permitted in neighborhoods with significant vacancy, the city must ensure that it meets the highest standards. As part of the zoning ordinance, the city will consult with residents about adopting standards such as LEED-ND in these areas to ensure high quality development.

6 Reinforce walkable neighborhoods. 6.1 Support efforts to revitalize neighborhood centers. Identify the mixed-use, walkable neighborhood centers from major centers such as Seneca/Cazenovia and Jefferson/Utica, to pedestrian pockets or four- corners such as Clinton/Baitz and Five Points and target their regeneration as focal points for daily life. Prioritize revitalization efforts within neighborhood centers located on transit routes with strong market potential and stakeholder commitment. Coordinate transit planning with efforts to rebuild neighborhood centers. Rebuild weak market neighborhood centers through focused infill and reha- bilitation within the pedestrian shed. Safeguard the economic potential of neighborhood centers with zoning provi- sions that protect their intimate, pedestrian-oriented character. Remove restrictive regulatory barriers while encouraging and providing incentives for new to smart, compact development; Encourage and provide incentives for new smart, compact development. 6.2 Build on existing neighborhood strengths. Identify and support the form and character elements of traditional neighbor- hoods according to Buffalos distinct urban transect. Reinforce the distinctive roles of neighborhood centers, where economic and social activity is concentrated; and neighborhood edges, intended as places of less intense activity. Recognize the role of neighborhoods in providing a balanced mix of shopping, work, schooling, recreation, and all types of housing. Reinforce and enhance traditional networks of straight streets and short blocks that provide equally for pedestrians, bicycles, and automobiles. Locate and design civic buildings to promote their public status on prominent, visible, and accessible sites, including important street intersections and sites that terminate a street view or face an important natural or cultural feature. Introduce regulatory tools to protect Buffalos existing and desired neighbor- hood character, including guidelines on building type, height, disposition, visual and functional permeability, parking, signs, landscaping, and ancillary structures. Support the creation, rehabilitation and maintenance of greenways and trails, parks, playgrounds and recreation facilities so that all residential areas in the City of Buffalo have access within a 1/4 mile distance of their homes.

6.3 Capitalize on neighborhood assets.

 Focus infill development and promote productive uses near existing walkable neighborhood centers and civic spaces, schools, community centers, and senior centers to recognize their value as community hubs. Focus public realm improvements within walking distance of reconstructed schools, particularly those that increase the safety and comfort of children walking and cycling to school following the Safe Routes to School Model. Permit Pursue productive neighborhood sensitive reuses of historic school buildings scheduled to close. Build upon neighborhood planning efforts such as the Larkin District Plan, Al- lentown Neighborhood Strategy, and Fruit Belt Neighborhood Strategy. Assess existing vacant, abandoned and left over open spaces as potential assets. Allow housing types of every variety in their appropriate locations, taking into special consideration the needs of the elderly, children, and the mobility-impaired. Remove barriers to housing affordability, such as restrictions on granny flats, minimum parking requirements, excessive lot area standards, and limits on multifamily housing. Focus affordable housing initiatives around priority transit routes to foster combined housing and transportation savings. Reintegrate superblock developments back into neighborhoods. Establish legal clarity for home-based businesses and workshops. Establish legal clarity for residential renewable energy systems, such as small wind, solar thermal/photovoltaic, and district geothermal systems. 6.5 Establishinterim alternative alternative uses and improve management practices for vacant land. Support Prioritize the use of vacant land to expand parks, recreation, gardens, and habitat areas, and other innovative uses. Develop a typology of interim reuse strategies for vacant land, including corner gateways, cut-throughs, multiple parcel connections, split lot greening, and rain gardens, among others. Establish criteria for which uses and which spaces are transitional uses and which are permanent land use changes. Permit and promote and promote the development of community gardens on public lands, with landscaping and beauticiationbeautification standards that ensure community benefit. Work with community organizations toAllow develop pilot projects for aesthetically-pleasing and environmentally beneficial constructed wetlands, forest 6.4 Maximize housing choice and affordability.

reserves, municipal orchards, and urban agriculture within high-vacancy blocks to reduce City maintenance expenses. Minimize regulatory barriers to adaptive reuse of vacant properties to prevent blight and abandonment. Continue integrating the Citys data systems into a single point of entry as a precursor to a Buffalo Niagara Property Intelligence Network for anticipating and reacting to neighborhood trends and specific property interventions. Establish a land bank under New York States enabling legislation that consolidates vacant property acquisition, management, and disposition within a single entity. Revamp city policy so that all vacant parcels and properties are acquired within the land bank. Implement a clear and rigorous classification system to determine which are appropriate for short term redevelopment and which are appropriate for other uses. Create a clean and green strategy which employs local residents through non- profit partners to beautify and maintain vacant lots. Incorporate strategies for the inclusion of eyes on the street through mandatory fenestration coverage, regulations on fence heights and types, and other means of visual surveillance of public and semi-public space. Provide guidance for the design of spaces and buildings to create perceptible and clearly delineated gradients and access points between public and private realms. Strictly enforce maintenance standards and building codes Mandate the incorporation of symbolic barriers indicative of defensible space, particularly in campus and larger institutional settings 7 Improve transportation options 7.1 Improve street design. Code the streets identifying all corridor place types by adopting the: The Complete Streets Thoroughfare Assemblies, Transit-Oriented Development and Bicycling Modules in the SmartCode, which can be accessed here: http://www.transect.org/modules.html Develop a complete streets design manual and specifications based upon the street codes to ensure that in all roadway facility upgrades, including lane-marking contracts, all appropriate bicycle and pedestrian facilities as well as stormwater management mitigation are included as a matter of course. Code Buffalos existing overbuilt highway infrastructure to begin the discussion of upgrading our highways to pedestrian-friendly, bikeable, high-capacity urban boulevards that reconnects to the Joseph Ellicott radial street grid pattern.

6.6 Increase public safety through effective urban design.

Incorporate by reference the National Association of City Transportation Officials' Urban Bikeway Design Guide (2010) as the implementation guide for the City's Complete Streets Policy. Map a conceptual framework for the full build-out of a Buffalo bicycle facility network, including a system of on-street bicycle lanes and cycle-tracks as well as off-street paths (including rails to trails). Establish city policy to include the development and maintenance of a minimum of ten (10) miles of bicycle facilities annually. Incorporate by reference the Institute for Transportation Engineers Designing Walkable Urban Thoroughfares: A Context Sensitive Approach (2010) as the guide for the design of new and reconstructed streets in Buffalos neighborhood contexts. Map a conceptual framework for the implementation of walkable urban thoroughfare improvements in focused areas over time. Adopt a targeted approach for streetscape beautification and right-sizing of Buffalos priority mixed-use neighborhood centers, taking into account the need to deploy limited resources to sites that will generate high returns on investment. Establish city policy to include the maintenance and repair of a minimum of ten (10) miles of pedestrian facilities annually. Identify candidates for road diet strategies across the city that would rationalize traffic flow and align roadway capacity with desired design speeds. Maximize on-street parking facilities and charge market-rate pricing to ensure the availability and convenience of parking for motorists, while creating dedicated on- street spaces for car sharing initiatives. Provide sidewalks along both sides of all general access streets, with the excep- tion of alleys. Maximize on-street parking facilities and charge market-rate pricing to ensure the availability and convenience of parking for motorists, while creating dedicated on- street spaces for car sharing initiatives. Maximize on-street parking and consider dedicated spaces for car-sharing initiatives. Strive forImplement reasonable design speeds for general access streets that calm traffic, reduce pedestrian crossing distances, and promote efficient motor vehicle movement. Introduce features that have been shown to effectively improve roadway safety, such as timed pedestrian signals and curb extensions. Craft maximum block size standards to facilitate a connective street network, and avoid cul-de-sacs.

 Plant and maintain native shade trees between the street and sidewalk along all neighborhood streets. Ensure street lighting of the proper scale, aesthetics, and intensity. Reduce the negative effects of highways high-capacity roadways on adjacent neighborhoods. 7.2 Encourage walking and cycling. Support the NFTAs goals to implement Bikes on Buses on all vehicles in the Authoritys bus fleet. Incorporate the City's bicycle parking policy directly into the general provisions of the Zoning Ordinance for simplicity and ease of use by the investment community. Consider ways to strengthen the bicycle parking policy. Increase the number of youth attending neighborhood schools by 50% so children can choose to walk or bicycle because it is safe, accessible and convenient. Increase the number of students walking and cycling to school in the City of Buffalo. Enhance pedestrian facilities within a one (1) mile radius of all transit stations. Enhance bicycle facilities within a three (3) mile radius of all transit stations. Use road maintenance, construction and reconstruction projects as opportunities to create great pedestrian environments, focusing investments around neighborhoods, employment centers, parks, and schools. Implement the Citys 1998 of Buffalo Greenway plan to provide further bike and pedestrian connectivity. Routes should be prioritized 1) to extend or loop existing trails (such as the Erie Canalway Trail); 2) to provide linkages between existing parks; 3) to access local destinations (such as the Central Wharf); 4) in recreationally under-served neighborhoods; and 5) to utilize existing abandoned rail beds in and adjacent to neighborhoods (such as the DL&W). Complement walkability investments with land use policies that encourage mixed uses within close proximity to each other. Furnish sidewalk widths to facilitate maximum pedestrian use, and install pedestrian ramps at all street corners in accordance with ADA. Ensure striping of crosswalks and ensure pedestrian crossings are as-of-right (pedestrians do not need to push a button to be allowed to cross the street) and provide adequate time to comfortably cross the roadway. Permit and implement mid-block crosswalks, using a combination of striping, signage and signalization as appropriate. Set requirements for street furnishing and amenities such as benches, garbage cans and recycling stations.

 Plan for and implement a phased series of road diets in response to reduced traffic volumes, increasing space for pedestrians, cyclists, and tree lawnsgreen infrastructure wherever possible. Embrace Mayor Browns Bicycle Mobility Project by continuing to install bicycle facilities as part of routine roadway construction projects. Continue installation of bicycle racks in neighborhood centers through ongoing implementation of Mayor Browns Commercial District Bicycle Rack Program. Encourage sidewalk cafes to enhance street activity and attract more pedestrian traffic. 7.3 Promote transportation alternatives. Support the construction of a new downtown Amtrak station built to express the highest ideals and noblest traditions of the city. Planners should consider reserving a location near the foot of Main Street for such a station. Establish as a regional priority a proposed extreme makeover of the NFTAs Metropolitan Transportation Center. As intercity bus travel rises, the first impression provided to visitors to Buffalo will be vital. Align land use policies with high frequency bus corridors to identify focal areas for public and private investment. Support the conversion to hybrid technology of all vehicles in the NFTAs bus fleet to increase transit rider comfort and environmental performance. Call for Bikes on Buses to be implemented on all vehicles in the NFTAs bus fleet to encourage intermodal transit. Call for a design competition for a new standard Buffalo bus shelter, modeled after similar competitions in Toronto and New York. The light rail system should be expanded to provide better access to residents with stops located within a 14 mile of all residential and commercial parcels. Protect rail-to-trail opportunities and incorporate vacant rail corridors into greenway plans where appropriate. Support a robust transit system by focusing compact neighborhood development and employment density in areas with high transit accessibility. Revisit Reverse policies that give undue preference to automobile use at the expense of transit, such as minimum parking requirements. Support the NFTAs efforts to rationalize schedules and fares, increase service frequency, and create a priority bus network. Consider streetcars as another mode of public transportation.

Environment
Planning for a sustainable environment means creating compact neighborhoods and districts that will save energy and protect the quality of air, water, and land. Natural systems become part of the solution to lessen the impacts of urban living, while pro- tecting against the abuse of resources that threaten the citys long-term development objectives. Parks and open spaces provide tangible economic, environmental, and social benefits. The plan will protect open space, support an accessible and integrated network of open spaces, and work to ensure that no residence is located more than a quarter-mile from an open space. Consistent with these principles, the plan applies to areas that can support the long- term goals of both open space expansion and riparian setbacks. Principles will help conserve water as recreational, economic, and habitat resources by fitting the ecological function of locations on the waters edge, while working to expand access to the water. Stormwater and snow melt management and the emerging response to Buffalos combined sewer overflow problem will be addressed by using vacant lands to reduce runoff into the sewer system. GREEN INFRASTRUCTURE: UNDER DEVELOPMENT

Green Infrastructure can provide an array of environmental s ervices through natural processes in the city. These b enefits will b e reinforced through zoning including the role of vegetation in weather modification and pollution control, habitat and its connectivity, productive landscapes, and so on. A major role that Green Infrastructure can play in the City is to h elp In order to reduce the volume and frequency of overflow events from the citys combined s ewer system. The Buffalo Sewer Authority (BSA) is currently d eveloping a Long Term Control Plan (LTCP) in accordance with the national Combined Sewer Overflow (CSO) Control Policy issued b y the United States Environmental Protection Agency (USEPA) in 1994. The LTCP identifies the necessary improvements to comply with the requirements of the Clean Water Act, including attainment of current or revised water quality s tandards. The BSA is a lso in the midst of Consent Decree negotiations with the USEPA and the New York State Department of Environmental Conservation (NYSDEC) regarding the updated LTCP. The final LTCP will b e a multi-million dollar, multi-year program to abate impacts of CSOs and improve water q uality. The LTCP will u ltimately recommend a combination of traditional or gray infrastructure improvements, a long with more innovative green infrastructure improvements. While the gray infrastructure solutions will primarily b e located underground, in the right-of-ways, or on publically-owned properties, the potential green infrastructure solutions may require use of private properties such as vacant lots or brownfield sites. The BSA is represented on the Buffalo Green Code Technical Advisory Committee. At this point it is too early in the LTCP process to be able to identify specifically how the Green Code can assist BSAs LTCP process. When the LTCP is completed next year, the city will work to incorporate comprehensive green infrastructure s trategies into the zoning ordinance.

8 Enhance natural resources 8.1 Identify, Pprotect and restore sensitive habitats. Reconnect fragmented ecosystems with linear open space systems and establish buffer requirements for protection. Encourage native landscaping and tree planting. Preserve and enhance the urban forest by providing suitable growing environ- ments for trees; and increasing tree canopy coverage and diversity. Incorporate old growth tree protection and replacement-in-kind provisions into the zoning code. Restore the night sky by basing permissible levels of brightness on the type of place being lit, use the best principles of the Dark Sky Initiative recognizing that light should not be directed upward nor to the side as light can travel hundreds of miles. Institute a form of tree preservation / canopy protection, incentivize increased canopy on private land and increase efforts on public lands and streets. Create, regulate and enforce controls to protect slopes, flood plains, wetlands, farms, and coastal waters and streams from inappropriate development. Establish standards for maintaining stream and river banks, including the removal of invasive species and planting of naturalized riparian vegetationovergrowth. Restore naturalized edges on nonworking waterfronts. Allow Encourage and incentivize on-site and district stormwater and snow melt management practices tailored to urban context. Minimize impervious surfaces and allow and require the use of permeable pavement. Implement Continue to test green infrastructure solutions, such as constructed wetlands, green streets, downspout disconnection, rain gardens, bioswales, and green and blue roofs, to minimize combined sewer overflows. 9 Reinvigorate public health 9.1 Promote healthy and sustainable environments Redefine Open Space Districts to include community gardens, clean-and- green, and other non-traditional gathering spaces that promote healthy living. Support and promote innovative development strategies including open space requirements, zoning incentives and others.

8.2 Enhance riparian environments.

Ensure development and design standards that promote public safety and community health. Combine park & recreational planning with programming to target obesity and poor health among citizens in neighborhoods, particularly where these conditions as prevalent and engage public/private partner ships to address community health in these neighborhoods. Mitigate and move to eliminate the impacts of highways and high volume roadways on neighborhood residents. Advance Support the scheduled, phased implementation of both the Complete Streets Policy and the Healthy City on the Great Lake addendum recommendations to the Comprehensive Plan. Prioritize ongoing sidewalk maintenance in all seasons to encourage walking, taking into special consideration the needs of the young, the aged and the mobility-impaired. Support, adopt and implement plans for Safe Routes to Schools and Safe Routes for the Elderly.

9.1 2 Promote active living.

Assess and improve the quality, upkeep, safety and cultural appropriateness of existing neighborhood play spaces and Support ensure the creation, rehabilitation, and maintenance of parks, playgrounds, recreation facilities and open spaces within a mile of all city residences. Ensure opportunities for structured and unstructured physical activity in all seasons (ice rinks, sledding hills, splash pads and pools, etc.) Implement the Citys Bicycle Master Plan as per the criteria in Section 7 above. Remove barriers toEncourage and provide incentives for developing grocery stores, healthy corner stores, outdoor markets, and farm/ers garden stands throughout the city, prioritizing underserved neighborhoods and facilitate the acceptance of EBT/SNAP payments in all venues.at convenient locations throughout the city, while preventing vendors from selling individual items and stolen property.

9.23 Enable Create a healthy local food systemproduction and distribution.

Restrict unhealthy food options, such as fast food restaurants, adjacent to or near school facilities while encouraging on-site or adjacent gardens and facilitating acquisition of land for these purposes where appropriate. Ensure that urban agriculture can flourish on public and private property by adopting zoning regulations that permit home gardens, community gardens and urban farms where appropriate.

 Protect existing and allow for the establishment of new small-scale urban agriculture, with appropriate guidelines on the design of greenhouses, hoop houses, and the like. Ensure that urban agriculture can flourish on public and private property by adopting zoning regulations that permit home gardens, community gardens, urban husbandry (bees, chickens, fish, etc.) and urban farms where appropriate. Permit defined Allowurban agriculture activities in high-vacancyall five neighborhoods as a long-term use place types, with guidelines for uses, quality design, and strict standards governing safety and aesthetics. Allow produce sales as a temporary a conditional or permitted use, with appropriate limitations on location, size, and time of operation, in multiple place- types throughout the city. Promote economic development and neighborhood revitalization through the creation of a strong local food system, including encouraging new innovations in the production, processing, distribution, sale, consumption and disposal of food and lend support to the development of a regional food policy.

9.3 Promote healthy and sustainable environments Redefine Open Space Districts to include community gardens, clean-and-green, and other non-traditional gathering spaces that promote healthy living Support and promote innovative development strategies including open space requirements, zoning incentives and others Ensure development and design standards that promote public safety and community health Support and promote innovative building technologies including water catchments, green buildings, green roofs and others 10 Preserve natural, cultural, and historic resources 10.1 Protect and enhance open spaces. Inventory permanent, appropriated, left-over, and informal open spaces in the city and createdevelop criteria for protection protections for them. Identify the typological characteristics of various open space types and reinforce these characteristics through provisions in the zoning code. Identify and Pprioritize open space investments within neighborhoods with a park or public space deficit so that all residential areas in the City of Buffalo have access within a 1/4 mile distance of their homes. Ensure high-quality design of open spaces to promote (1) human use (user comfort, safety, accessibility, and year-round use); (2) economic use (; enhance the quality of place;, and increase value to adjacent properties and environmental

services); and (3) habitat value (type of habitat, connectivity, protection for sensitive areas and so on). Prevent further encroachment of parks and open space for city/ state/ federal/ private infrastructure and promote future park restoration. Code land adjacent to Buffalos overbuilt highway infrastructure along the waterfront (190/ Routes 5) to plan for reuse as highways are calmed and upgraded to pedestrian-friendly, bikeable, high-capacity urban boulevards that reconnects to the Joseph Ellicott radial street grid pattern. Support planning initiatives for the Niagara River Greenway, Buffalo River Greenway, Black Rock Channel Greenway, the DL&W (The Del) Greenway and Outer Harbor Greenway. Support on-going efforts to restore the health of the citys water bodies such as the cleanup of watershed contaminated lands, green infrastructure in public rights-of-way, the establishment of vegetated buffers, and the establishment of appropriate land uses adjacent to these water bodies. Establish a pedestrian-scaled framework of streets, blocks, and development parcels at the foot of Erie Street. Recognize Scajaquada Creeks ecological and recreational potential including 1) supporting the ongoing corridor redesign by NYDOT; 2) eliminating untreated sewer and stormwater outfalls into the creek; 3) establishing a continuous linear park; and 4) taking steps toward daylighting the buried portion of the creek. Integrate the land use policy framework of the City of Buffalos Local Waterfront Revitalization Program (LWRP) into the zoning code. RequireConsider a minimum 100 foot buffer zone along nonworking waterfronts into the zoning code to ensure public access. Require development to acknowledge both the water and the street as principal frontages, to avoid treating either entrance as a back door. 10.3 Preserve cultural and historic resources. Reestablish lost elements of the Ellicott street network, and reserve former rights-of-way for restoration. Reestablish lost and incomplete elements of the Olmsted park and parkway system, and reserve its borders for the highest grade of development. Align land use and zoning efforts with the forthcoming Buffalo Preservation Plan.

10.2 Support waterfront access and usage.

Implementation
Future Place Type Maps - General Principles The place-types on the Future Land Use Maps reflect the recommended use for each block. Neighborhood place-types are a mix of residential, support services, open space, and civic institutions, distinguished by the relationship of the building to the lot and the block. Ensure a minimum of 11-12 units/acre to ensure sufficient density for local services. Clusters of residential blocks should be encouraged to develop centers. These pedestrian-oriented place-types should always be mixed-use in character, with a walkable building form. Residential superblocks that do not fit the character of the adjacent neighbor- hood are encouraged to redevelop as place-types more consistent with the block and street patterns of the surrounding neighborhood. Where an increase in intensity or mix of use would be appropriate, neighbor- hood and retail blocks within a 5-minute walk of transit stations have been changed to a more intense form of development. Automobile-oriented convenience retail is located contained at the edges of neighborhoods, adjacent to existing retail centers, along high-volume arterials, or near limited-access highway interchanges and is phased out as redevelopment occurs. Heavy manufacturing districts are changed to light manufacturing, unless there is an existing or planned heavy manufacturing use. Open spaces generally reflect only those lands that are publicly owned or man- aged. The need for additional open spaces requiring land acquisition should be addressed in a separate study. However, many open spaces in the city are owned by institutions or are private. Lands associated with office parks could be provided with incentives to provide public access and accommodations and currently, there is a 100/setback along the Buffalo River for habitat protection. This strategy could be used in other places for habitat protection. Abandoned transportation corridors, and City-owned land that is part of a long- term plan for expanding transportation networks, are designated as open space. should be designated as a separate category as they have been, in the past, appropriate for other uses and should have been saved for transportation corridors. Blocks that would benefit from the greater intensity of a downtown develop- ment character, such as those along the radials extending out from the central business district, on Main Street between Goodell and North, and west of the BNMC, are designated Neighborhood Urban Core place-types.

A SUSTIANABLE TRANSPORTATION AGENDA Background Mayor Byron W. Brown announced on Earth Day 2010 the start of a process to implement the Buffalo Green Code, an exciting initiative to transform Buffalo's neighborhoods along place-based principles. In 2011, this ambitious two-year effort to create a new land use plan and zoning code for Buffalo is well underway. Our zoning reform effort will act as the foundation for the new place-based economic development strategy for Buffalos neighborhoods in every section of the city, the Mayor said at the project announcement in the Larkin District. The new zoning ordinance will be known as the Buffalo Green Code. It will embody 21st century values about economic development, sustainability, and walkable, green urbanism. The new Buffalo Green Code includes the first citywide land use plan since 1977 and the first zoning code since 1951. The project is an unparalleled opportunity to actualize the smart growth and sustainability objectives of Buffalo's Comprehensive Plan (2006). Green Options Buffalo congratulates Mayor Byron Brown on his leadership for taking on this bold and ambitious project. It is in the spirit of collaboration with Mayor Brown's initiative for a Buffalo Green Code that Green Options Buffalo submits for the Citys consideration its Sustainable Transportation Agenda. This Sustainable Transportation Agenda is our organization's take on how to create a more competitive Buffalo that embraces healthy, environmentally sustainable, and community-friendly transportation. Introduction Mayor Byron W. Brown is moving forward on a new land use plan and zoning code for the City of Buffalo. This initiative promises to make Buffalo healthier, wealthier, and more attractive to talent and investment. Cities across North America and Europe are competing to be the most livable, the most vibrant, the most sustainableall in an effort to gain the upper hand in the global competition for knowledge workers and the capital needed for job creation. As a global economy makes these resources even more mobile, high quality places will continue to have an advantage in attracting and retaining these resources. Quality of place matters more than ever.

Sustainable Transportation Agenda

As has been demonstrated in many successful cities, Green Options Buffalo believes that in order to create a competitive city, sustainable transportation policies are vital and indispensable. As the City of Buffalo rolls out a new land use plan to inform an entirely new zoning code, we are reminded that transportationthe public realm of streets, sidewalks, bicycle facilities, transit corridors, and the likedirectly impacts and largely determines the use of the land. Transportation uses themselves compose a significant share of the citys land area, and an even larger share of the land under the direct public control. A land use plan cannot be credibly advanced without addressing the key linkages between transportation, land use, and economic development. Peer cities like Pittsburgh, Madison, Grand Rapids, Minneapolis, Chicagoall are realizing the economic development and talent attraction dividends of sustainable transportation policies and investments. Buffalo has already started to engage in this competition through the adoption of a Complete Streets Policy, the Mayor's Bicycle Mobility Project, the GBNRTC's Bicycle & Pedestrian Master Plan, and the NFTA's Transit Service & Restructuring Survey. Already Buffalo ranks high among the top 100 cities in sustainable transportation performance. The U.S. Census American Communities Survey (2009) reveals: Buffalo is #7 in the country in car-independence, with 31.42% of all households going car-free, a higher rate than in San Francisco (28.56%) and Chicago (28.85%). Buffalo is #20 in the country in bicycle commuting, with a bike modal share of 1.35% (up from 0.43% in 2000). The percentage of commuters using bikes to get to work in Buffalo more than doubled with a 158% increase from 2000 to 2009. Buffalo is #12 in the country in both the walk to work and the transit to work categories. Buffalo has nearly the same proportion of people making work commutes by transit (12.52%) and by walking (5.43%) as Portland, Oregon (12.89% and 5.47%, respectively), widely cited as a leader in sustainability. Walking and taking transit to work increased by 19% and 7%, respectively, from 2000 to 2009. Buffalo must tell the story of these successes and build upon them. But the city has a long way to go before it is competitive with the most successful and forward-thinking peer cities. Buffalo should consider making a primary objective to be at least #7, or as high as our highest current ranking, in all of these categories among cities nationally. This will require assertive and coordinated efforts to transform Buffalo's transportation policies and infrastructure, yet the pay-off will be in increased livability, sustainability, and economic competitiveness. This transformative process must begin with Buffalo's new land use plan and zoning code.

Sustainable Transportation Agenda The Sustainable Transportation Agenda outlines seven agenda items to achieve this #7 performance benchmark: 1. 2. 3. 4. 5. 6. 7. Create a biking city. Embrace walkable urban thoroughfares. Code the streets. Transform the highways. Create gateways. Take transit. Don't forget the cars.

As suggestions for the upcoming land use plan and zoning code, these ideas are submitted to inspire the conversation about what kind of city Buffalo can become. Green Options Buffalo hopes its Sustainable Transportation Agenda will be a valuable contribution to ongoing community dialog on the Green Code. Create a biking city. Creating a Buffalo that invites its citizens to bike its streets will require new and innovative approaches to bicycle planning. The 2009 National Household Travel Survey indicates 28% of all trips in the United States are one mile or less, so shifting more of these trips from car to bike is achievable. Minneapolis is consistently rated Americas #1 biking city, so snow and cold arent limiting factors. Small efforts have already produced more bicycle use in Buffalo. More comprehensive efforts will indubitably generate more. Increasing Buffalo's bicycle use will improve peoples health, produce personal and public cost savings, and reduce the per-capita carbon footprint. To create a biking city, the new land use plan should: Incorporate by reference the National Association of City Transportation Officials' Urban Bikeway Design Guide (2010) as the implementation guide for the City's Complete Streets Policy. The NACTO Urban Bikeway Design Guide provides cities with the state-of-the-practice solutions that help create complete streets that are safe and enjoyable for cyclists. Map a conceptual framework for the full build-out of a Buffalo bicycle facility network, including a system of on-street bicycle lanes and cycle-tracks as well as off-street paths (including rails to trails). Include mileage goals for complete build-out. Support the NFTAs goals to implement Bikes on Buses on all vehicles in the Authoritys bus fleet. Set a commuter mode share target for bicycling.

Sustainable Transportation Agenda

To reinforce bike-friendly development patterns, the new zoning code should: Incorporate the City's bicycle parking policy directly into the general provisions of the Zoning Ordinance for simplicity and ease of use by the investment community. Consider ways to strengthen the bicycle parking policy. Embrace walkable urban thoroughfares. Creating a Buffalo where walking is a pleasure will require a retrofit of infrastructure that has long favored the car over the pedestrian. To tip the pendulum back toward walkability, the City should pursue pedestrian comfort as a priority objective for all street design. To create a walking city, the new land use plan should: Incorporate by reference the Institute for Transportation Engineers Designing Walkable Urban Thoroughfares: A Context Sensitive Approach (2010) as the guide for the design of new and reconstructed streets in Buffalos neighborhood contexts. The guide assists communities in improving mobility choices and community character through a commitment to creating and enhancing walkable communities and restoring the multiple functions of urban streets. It provides guidance and demonstrates how context-sensitive design principles and techniques may be applied where community objectives support new urbanism and smart growth: walkable, connected neighborhoods, mixed land uses, and easy access for all modes of transportation. Map a conceptual framework for the implementation of walkable urban thoroughfare improvements in focused areas over time. Adopt a targeted approach for streetscape beautification and right-sizing of Buffalos priority mixed-use neighborhood centers, taking into account the need to deploy limited resources to sites that will generate high returns on investment. Set a commuter mode share target for walking. Code the streets. Creating a Buffalo where people linger in and cherish their streets will require redesigning them for people. A number of American cities, such as New York and San Francisco, have come out with manuals and toolkits to guide the design of streets. Other cities, such as Miami, have created regulatory manuals in which street design methods are directly integrated into zoning codes. These form-based codes almost always include basic design regulations for street typologies matched to neighborhood and district contexts.

Sustainable Transportation Agenda

These cities policies have been essential elements in facilitating livability and placemaking objectives. Using the ITE's walkable urban thoroughfares design manual as a starting point, the City might consider including design regulations for new and reconstructed streets as part of a unified zoning ordinance. This would necessarily require the repeal of Buffalos 1969 subdivision ordinance and the incorporation of replacement zoning regulations that more closely match the smart growth objectives of Buffalos Comprehensive Plan. This process is easier than one might think. The street design guidelines in the Smart Code, a model form-based code, are only two pages in length. Transform the highways. Creating a Buffalo where value is restored will require a re-think of its overbuilt highway infrastructure. As projects in New York, San Francisco, Portland, and Milwaukee have demonstrated, highway removal can be achieved without negatively impacting regional mobility. Replacing highways with boulevards has in fact attracted hundreds of millions of dollars in new investment and saved billions of dollars that would have been spent on highway reconstruction and maintenance. Cities everywhere, including New Orleans, Louisville, St. Louis, Syracuse, and Seattle, are now giving serious consideration to upgrading highways to pedestrian-friendly, high capacity boulevards reconnected to their street grids. In fact, the removal of the Claiborne Expressway in New Orleans was first proposed by Jacques Gourguechon, now on the project management team for the Buffalo Green Code. A study by Harvard economist Ed Glaeser determined that every new highway passing through a central city reduced its population by about 18%. In Buffalo, highways trampled historic neighborhoods, emptied arterial streets of retail-sustaining commuter traffic, fueled the flight of people and jobs to the suburbs, and divided neighborhoods from each other and from the waterfront. Buffalos land use plan can begin the highway-removal discussion by declaring key corridors as highways without futures. Planning for the conversion of these corridorsincluding portions of Route 5, the Kensington, the Scajaquada, and I-190to attractive, traffic calmed boulevards is now realistic and mainstream. Such bold steps can return economic activity and value to city neighborhoods. Will Buffalo take the leap and join progressive cities like Syracuse?

Sustainable Transportation Agenda Create gateways. Creating a Buffalo that is a pleasure to visit will require new intercity gateways. Grand Rapids is building a new $4.6 million Amtrak station. Schenectady, NY is building a multimodal station, too, to the tune of $13 million. St. Louis recently completed its downtown Gateway Transportation Center for $31.4 million. Even Niagara Falls, NY, is moving forward on a $44 million multimodal station prepped for high-speed rail at its historic U. S. Customs House. Buffalo already has an amazing airport. Now its time to build a new Amtrak station and a Metropolitan Transportation Center that proclaims to visitors: you have arrived in a great place! Trains and buses represent the most sustainable forms of intercity travel. Encouraging these modes of travel can only make Buffalo greener and more prosperous. With gas prices and short-trip tourism on the rise, intercity rail and bus are also the two fastest growing modes of travel. To create a visitor-friendly city, the new land use plan should: Support the construction of a new downtown Amtrak station built to express the highest ideals and noblest traditions of the city. Planners should consider reserving a location near the foot of Main Street for such a station. Establish as a regional priority a proposed extreme makeover of the NFTAs Metropolitan Transportation Center. As intercity bus travel rises, the first impression provided to visitors to Buffalo will be vital. Its time to make intercity bus traveland Buffalochic! Take transit. Creating a Buffalo where public transit is a first choice, not a Plan B or Plan C for getting around town, will require some new ideas. In 1971, Mayor Frank Sedita proposed constructing a light rail rapid transit system linking downtown Buffalo to its suburbs. The NFTA followed. Fifteen years after this idea was introduced by the Sedita administration in its 1971 downtown plan, the Metro Rail was a reality. Its time to complete Seditas vision by completing the Metro Rail system, with new linkages to UBs North Campus and the Buffalo Niagara International Airport. While forging these connections may take time, its never too early to start the planning work. The land use plan and zoning code should anticipate these investments by making

Sustainable Transportation Agenda future Transit Oriented Development (TOD) neighborhoods transit ready while strengthening rules that direct high-intensity development to Metro Rails existing station areas. In 1950 the last of Buffalos streetcars were decommissioned by the International Railway Company (IRC). Cities across the nation, including Cincinnati and Portland, are reintroducing streetcar systems as smart growth and economic development drivers. In every case, these comparatively inexpensive fixed-rail investments are yielding huge job, investment, and development dividends for their respective cities. In Buffalo many of the citys bus corridors, such as the Elmwood and the Hertel/Fillmore, have ridership numbers that exceed that of the cutting-edge streetcar systems. Planners should give serious consideration to suggesting streetcar displacement of some of these high ridership bus routes, giving Buffalo back this Cadillac of public transit options. The Obama administration recently revised federal rules to make it easier for cities to secure federal funding for streetcar projects, so the time is ripe to consider a Buffalo Streetcar Feasibility Study. To make Buffalo more transit-friendly in the near term, the land use plan should: Support the NFTAs efforts to rationalize bus schedules, increase service frequency in the central city, and create a high frequency (<15 min. peak hour frequency) bus network. Align land use policies with high frequency bus corridors to identify focal areas for public and private investment. Support the conversion to hybrid technology of all vehicles in the NFTAs bus fleet to increase transit rider comfort and environmental performance. Call for Bikes on Buses to be implemented on all vehicles in the NFTAs bus fleet to encourage intermodal transit. Call for a design competition for a new standard Buffalo bus shelter, modeled after similar competitions in Toronto and New York. Set a commuter mode share target for transit. Dont forget the cars. Creating a Buffalo where motorists can get from place to place safely and efficiently while really enjoying the trip will require a new look at urban mobility.

Sustainable Transportation Agenda In the last century, moving cars fast was the only objective. Todays traffic engineering takes a more holistic approach to street design. This sustainable approach guarantees motorists can move slower, without undue delay; more efficiently, without dangerous speeds; more pleasurably, without running over the neighbors cat. To make Buffalo more motorist friendly, the land use plan should: Call for the conversion of all remaining one-way streets, unless right-of-way dimensions preclude it, to two-way streets to make the city easier to navigate. Establish a citywide roadway design speed of a maximum 20 mph to ensure motorist safety. Identify candidates for road diet strategies across the city that would rationalize traffic flow and align roadway capacity with desired design speeds. Maximize on-street parking facilities and charge market-rate pricing to ensure the availability and convenience of parking for motorists, while creating dedicated onstreet spaces for car sharing initiatives. CONCLUSION Green Options Buffalo is pleased to contribute its thoughts on Buffalos future. Since planning initiatives like the Buffalo Green Code happen perhaps once every generation, we realize the singular importance of the effort and the likelihood that a similar opportunity will not arise again in the near future. Creating a more competitive Buffalo, we believe, is the objective of the new Green Code. Buffalo needs to compete by offering higher-quality places, value-adding development, and more and higher quality transportation options. Buffalo needs to compete by investing for triple-bottom line returns: economic, social, environmental. Buffalo needs to compete by embracing change as well as its finest traditions. As the City of Buffalo moves forward on this ground-breaking initiative, Green Options Buffalo offers the following general suggestions to the City: Include indicators of success. Assign related indicators of success to new policies in the land use plan to determine how well these policies are functioning. As management consultant Peter Drucker puts it, If you cant measure it, you cant manage it. Defining indicators of success and crafting a methodology to examine successes and failures will help create accountability.

Sustainable Transportation Agenda Explain ties to the bigger picture. Help build the argument for why design matters by describing how the Green Code fits within the larger movement to reposition Buffalo in an increasingly competitive global economy. Why is this process important? That needs to be explained lucidly to the public to create excitement and buy-in. Link to peer cities as resources Pick up the phone, read other plans, check out websites from other cities. Share your stories and ask other planners around the country for lessons learned. Consider a peer review for any final product. Link concepts with tools and graphics Provide design tools and graphics, not merely concepts and narrative. It is essential to include simple, clear graphics to help explain the new land use and zoning policies as well as more abstract issues such as maintaining a human scale, creating street enclosure, or improving multimodal transportation. The recently adopted Connecting El Paso, for example, is especially easy to navigate and understand, using photographs and illustrations as examples to describe key concepts, along with simple text. Publicize Never underestimate the power of publicity. After this forward-thinking plan and code are adopted in 2012, hire a branding firm to take market the final product to a national audience. Get all the awards, recognition, speaking engagements, and media coverage the City can muster. This project can help sell Buffalo! Special thanks to the City of Buffalo for its consideration of this Sustainable Transportation Agenda. Green Options Buffalo promotes healthy, environmentally sustainable, and community-friendly transportation. We hope the Green Code will, too!