Advocates: CityPlace EIR Highlights Need for Level of Service Reform

What the view of CityPlace from Mason Street would look like. Image: Market Street Holdings LLC
What the view of CityPlace would look like from Mason Street. Image: Market Street Holdings LLC

At the heart of the San Francisco Planning Department’s 328-page Draft Environmental Impact Report (DEIR) for CityPlace, sustainable transportation advocates have pinpointed one glaring flaw. In assessing the impacts of new off-street retail parking, the environmental analysis [pdf] concludes that building a 167-space garage will have the same effect on traffic as building no garage at all.

“This environmental analysis has really pitted this project against pedestrian safety and the livability of this neighborhood,” said Tom Radulovich, the executive director of Livable City.

CityPlace is a 250,000 square foot retail project planned for Market Street that the Mayor has trumpeted as essential for the area, “a key pillar in the continuing revitalization of Mid-Market that will bring hundreds of jobs and new revenues to boost our City’s economy and thousands of new pedestrians and shoppers to activate one of the most blighted blocks of Market Street.”

Radulovich along with attorney Arthur Levy and Walk SF had filed an appeal of the Planning Commission’s certification of the DEIR, arguing that it failed to adequately address and mitigate the dangers to pedestrians and bicyclists. Levy was also concerned the St. Francis Theater, designed by architect John Galen Howard, will be demolished and that the glass structure won’t fit in with the visual and historic character of Market Street.

Supporting the appeal seemed politically impossible for the Board of Supervisors. Instead, Supervisor Chris Daly, who represents the area, with help from Judson True, an aide to Supervisor David Chiu, brokered a deal [pdf] before the supervisors meeting Tuesday.  Market Street Holdings LLC (Urban Realty), the project’s sponsor, agreed to charge a 20 cent per vehicle exit fee at the CityPlace garage that would eventually add up to $1.8 million for “bicycle and/or pedestrian and/or transit improvements.” That pleased the supervisors and the DEIR was certified on a 9-0 vote, giving the final clearance.

The rejection of the appeal followed a public hearing in which the advocates laid out their case, and the project’s sponsors were allowed a rebuttal.

"If your model's broken, you can't distinguish between the retail project that's done everything it could to reduce the number of vehicle trips it creates versus the one that generates way more vehicle trips than it ought it
"We need to be a city that does everything it can to ensure the livability of neighborhoods and to ensure pedestrian and bicycle safety ," said Tom Radulovich of Livable City.

“What we are talking about today are really issues of life and death. The fact that this project and this EIR are not mitigating the impacts that they’ll have on this community,” Radulovich told the supervisors.

The neighborhood, he argued, which houses many low-income residents, seniors and children, is dangerous enough and doesn’t need any more auto traffic spilling into the six affected intersections. Sixth Street, immediately adjacent to the project, is one of the city’s worst streets for pedestrian fatalities and injuries.

“In helping Market Street we can’t make 6th Street even worse,” Manish Champsee, the president of Walk San Francisco, testified. “Three of the top five intersections for pedestrian safety are on 6th Street.”

The DEIR analysis, instead of looking at automobiles as the real danger to pedestrians, assessed the impacts to pedestrians based on increased foot traffic and conflicts with other pedestrians.

Radulovich said the analysis flew in the face of the Planning Department’s own parking code, Section 150 [pdf], and the city’s General Plan, “which states that if you have a short-term parking need in the downtown, don’t add more parking, convert long-term parking to short-term parking because adding more parking creates more automobile trips.”

“We do not want to stop the project. We want to improve environmental analysis in this city.” –Andy Thornley, SFBC

“The notion that providing 200 more parking spaces will not create more [automobile] trips is ludicrous, frankly,” said Andy Thornley, the program manager of the San Francisco Bicycle Coalition, whose offices along with Livable City and Walk SF have been been located in the Mid-Market area for many years.  “We do not want to stop the project. We want to improve environmental analysis in this city.”

Thornley said as San Francisco moves away from using intersection Level of Service (LOS) to analyze transportation impacts and toward evaluating automobile trip generation (ATG) “it’s very troubling to see an environmental document come forward that makes such a flimsy estimate of auto trip generation.”

The advocates argue that allowing CityPlace and other projects excessive parking sets a bad precedent and runs afoul of a Transit First policy and neighborhood plans that are supposed to guide transportation and land use decisions.

CityPlace’s sponsor argues that despite the 4,500 spaces in more than a dozen nearby city-owned garages, parking in the building is needed for the project to succeed because of the type of value-based “household goods, electronics and sports equipment” stores they are seeking. Drivers, they argue, need to transport large purchases. According to the San Francisco Business Times, the stores being sought include TJ Maxx, JCPenney, Ross, Dick’s Sporting Goods and Big 5 Sporting Goods.

Jim Abrams, who presented the CityPlace transportation plan to the Planning Commission, argued the parking in the building would be much less than similar retail spaces in dense, urban areas such as Brooklyn and Queens, and would be setting an example by providing “the lowest amount of parking of any comparable center in the country.”

By contrast, though, some nearby stores including Macy’s, Bloomingdales, Barneys and Nieman Marcus offer no parking in the building for their driving customers. The San Francisco Examiner recently reported that Target wanted to move into the Metreon where there is no on-site parking.

The view from Stevenson Street, where drivers will enter and exit the parking garage. Image: Market Street Holdings LLC
The project rendering of Stevenson Street, where drivers will enter and exit the parking garage. Image: Market Street Holdings LLC

“I think the fundamental decision to drive or not is whether you have a prospect of finding parking,” said Bill Wycko, the head of Major Environmental Analysis for the San Francisco Planning Department.

Wycko, responding to a question from Supervisor Daly, said his office is not able to effectively analyze ATG for shopping trips because there has been no research and surveys conducted on retail auto trips, which would offer some evidence for how retail parking affects driver behavior. Instead, the analysis is based on commuter surveys.

“Intuitive or not, the relationship between supply in parking and how people travel, other than the obvious situation where you don’t have a car, you don’t drive, is not as obvious as you would think and for shopping trips the substantial evidence, the real evidence, is largely non-existent,” said Wycko. “We can all have our hunches and our intuition but that’s kind of not what we use in [California Environmental Quality Act analysis].”

Wycko did acknowledge the city is engaged in a monumental process to overhaul LOS and replace it with ATG, which will presumably require planners to analyze trip generation associated with parking spaces.

“There is an effort to take a different approach and as part of that approach one of the things we’ve been urging is that there does need to be follow-up monitoring because one reason there isn’t data, especially local data, is that there hasn’t been this sort of, okay, if you do this, what’s the behavior pattern? If you do that, what’s the behavior pattern?”

In an interview with Streetsblog, John Rahaim, the Planning Department Director, said he supports eventually transitioning to ATG but feels the issues raised by transit advocates in the appeal probably don’t belong in the CEQA process.

“Whether we should be looking at the safety issues, and the pedestrian and vehicular conflicts is an important question. I don’t think it’s a CEQA issue, however. I would love to figure out a way to get at those issues outside of the CEQA process, which is a cumbersome process, frankly.”

Both Livable City and Levy are considering a lawsuit.

“I think that EIR is a very poor document. I think it’s legally defective. I feel that the Board of Supervisors was under a lot of political pressure to move this project along. That part of Market Street has been neglected and been a problem for a long time,” said Levy, who added that he would like to see the project move forward, but not it until it fully addresses the issues raised in the appeal.

The project is now scheduled to break ground in 2011 and despite the surcharge that will be directed toward bicycle, pedestrian and transit improvements advocates are skeptical they’ll happen quickly.

Radulovich said he was disappointed the letter outlining the compromise “wasn’t water tight” and didn’t include language guaranteeing the money and the improvements would come immediately. True later tried to assure him that the money paid to the SFMTA would secure improvements sooner rather than later.

“We feel strongly that the MTA is well positioned to use the money for this parking surcharge to in some way finance up front improvements for bicyclists, pedestrians and transit riders. So we feel confident that while it’s untested, the parking surcharge is a mechanism that will not just give money over time but provide for some up front money and that’s really up to the MTA to figure out the best way to do that,” said True.

SFMTA spokesperson Paul Rose said CityPlace had already separately paid $200,000 to the agency, $50,000 of which will be used for a study to see what improvements are needed, and the rest will be put toward implementation.

“The full scope will of course need to be developed based on the initial study,” said Rose.

Radulovich said transit advocates were an influential force in getting the sponsor to commit the money, and hoped that mid-block crosswalks — where a majority of pedestrian injuries and fatalities occur in the area — bulbouts and protected bike lanes would be included.

  • I’d be interested in hearing more about any potential lawsuit. I got $50 for that effort. At a minimum, we have to increase the cost of harming the city.

    The lesson will be learned by developers quickly — cross us, and we’re going to Lawsuit City, regardless of whether or not the entire political establishment signed on or not.

    If Livable City feels strongly enough that this is a bad enough idea to contest in court, then count me in. In fact, I’d be inclined to sue this developer and/or the City just for the heck of it. That we probably have a case is just the cherry on top.

    I think we should also continue to push not just for ATG (and Idaho stops and all the rest), but to get direct and indirect safety impacts included in CEQA. CEQA is, ultimately, to protect citizens from bad projects — how can we ignore such a large and influential part of ‘the environment’ when doing an ‘environmental impact report’? I mean, car emissions pollution is bad, but I think getting run over by a car/truck/bus is worse.

  • andrew

    This campaign just makes advocates look bad. Always saying no, no, no, no, no to any development, just because it’s not exactly perfect, and perfectly happy to accept another X years of blight in a blighted area to maintain ideological purity.

    Can’t you see the bigger picture, that mid-Market needs serious investment? Of course, to the purist, the lack of economic activity is no problem, because it lets the bikes cruise through more quickly. And the “anti-displacement” types certainly don’t want anything to drive out the drunks.

    But in this case, and a broken clock is right only twice a day, Chris Daly was right and Tom et al. were dead wrong. If this is what my Livable City membership fees are going for, I’ll spend it on beer next year.

  • andrew, the city is allowing for additional UNNEEDED parking. There are AMBLE amounts of parking at garages less then a 5-10 min walk away.

    Target is planning on going into the Metreon with zero parking. The mall between 4th and 5th has no parking. CityPlace is suppose to be lower cost retail for those in the neighborhood which really means it doesn’t need parking. I thought it was a good appeal, especially since the DEIR was a joke – same amount of traffic if there is parking or not? A 5 year old can tell you that just simply can not be true.

  • Oops, or AMPLE.

    As bad as it may seem that they were “trying to block” the project, we’ll have to live with increased congestion in the area for many many years. Just as we have had to live with the damage done by the “big dig” for BART in the 60s.

  • andrew –

    The article even highlighted the clear statement that they don’t want to stop the project, they want a better analysis of the parking’s impacts and adherence with the Downtown Plan and Transit First Policy. Aren’t you glad to see your Livable City membership going towards keeping a watchdog on new downtown projects that not just provide more parking at all, but provide more than the Downtown Plan even allows?

    I don’t think anyone disagrees that Mid-Market needs investments like CityPlace, but added traffic only worsens blight on streets and will compromise that goal.

  • This campaign just makes advocates look bad. Always saying no, no, no, no, no to any development, just because it’s not exactly perfect, and perfectly happy to accept another X years of blight in a blighted area to maintain ideological purity.

    what a perfectly smug, factually incorrect comment. boring, too. a trifecta!

  • Jake

    So how about the city closes and redevelops one of the nearby garages it owns?

  • Joel

    I’m a huge supporter of the livable streets movement, and I know the major groups considering this lawsuit say they want to see this project go through. But you have to stop and ask yourself: what if it doesn’t go through? What if the lawsuit stops a project that would activate Market street sidewalks and create jobs for Bay Area residents? Can we afford to spend money on a fight that might ultimately chase away Market Street renewal? Or should we try using the same money to fund livable streets improvements on Market Street and other parts of the city?

  • What if the lawsuit stops a project that would activate Market street sidewalks and create jobs for Bay Area residents?

    you mean, like, what will Bay Area residents do without a few hundred more extremely low-end part-time retail jobs without benefits? i dunno — probably just go on living like they are now, i suppose.

    and, as pointed out, the idea is not to stop all development everywhere (though I might like to do that) — it’s to build better projects. it’s not rocket science. right now, the developer has said, like George W. Bush, it’s my way or the highway, you’re either with us or against us. we say, “That’s bullshit.” if a project is important enough to build at all, then it’s important enough to build right.

    Can we afford to spend money on a fight that might ultimately chase away Market Street renewal?

    Market Street renewal is going to happen with or without this flawed project — it can’t be stopped. We the People would rather proceed with a project that is much less flawed, much less dangerous, much less deadly.

    On another note — this might sound stupid — but is there any chance to convert parking to….some other use in the future? You know, just drop the electrical and plumbing in there for future conversion? And/or, could we not use this ‘trade-off option’ as a bargaining chip with our leader, The Almighty Developer?

    You know — “hey dudes, we don’t want the parking, but we’ll give you an extra floor if you nix the parking — whatcha say, Mayo…..errr, The Almighty Developer?”

  • St. Petersburg College in Florida seems to have converted some/most of a downtown parking garage into a multi-use facility. Here’s a google maps pic while under reconstruction.

    If they can reconstruct a garage after the fact, they can built it in a way that it can be easily converted to habitable space in the future.

    Shoot — give ’em a couple of floors of office space if they really want it. SF can’t afford any more parking.

    If the mall is having trouble getting loans w/o the parking, then have the city guarantee part or all of the loan — I’m cool with that. If the project fails, the city of SF will take it back and do something even better with it.

  • Manish

    Andrew…none of the appellants, including Walk San Francisco, Livable City and Arthur Levy, want this project to die. We all support CityPlace getting built. However, we also feel that the traffic impacts that this project creates should be mitigated and that rather than a gigantic glass box, the project fit in the with the character of the neighborhood. Points that the developer agreed to.

  • @andrew – the developer isn’t stupid, this is San Francisco and they expected some sort of troubles along the way. Occam’s razor – they expect to make a lot of money on this development no matter what. Given that – it is incumbent upon the City to demand the project meet the City’s needs. If these little givebacks were going to kill the project, we’d never have gotten this far.

  • I agree completely that more parking generates more automobile trips and that it is absurd to claim that adding this parking generates zero trips.

    Nevertheless, I think this would be the wrong project to sue on. Everyone agrees that Mid-Market needs an economic boost, and a suit against this project would make us look bad.

  • Sounds like Chris Daly did a good job of increasing the mitigation fees collected from the developer for the additional parking spots above what the downtown plan allowed.

    What bugged me most is the gun put against the City’s head with the claim that they had to get all of the parking or the project didn’t pencil out, meanwhile Target is cool with zero parking onsite a block or so away at the Metreon.

    Sad thing is that we may see Ross and/or Marshalls abandon their current spaces for the new shopping center, adding to the high visibility vacancy of Virgin Megastore and other spots near the cable car terminus alone Market/Powell.

    This year’s election is sooooo important to not pick moderates who are rubber stamps for developers and will happily give developers all the parking they want. Jim Meko is my first choice, a 61 year old, 33 year SoMa resident who has not owned a car since 1969. Debra Walker is my second choice.

  • andrew

    Market Street renewal is going to happen with or without this flawed project — it can’t be stopped.

    I applaud your optimism, but since it hasn’t happened yet after 30 plus years, why do you think now will be different?

  • andrew

    @Charles Exactly.

  • Dave

    Thanks to Livable City and Walk San Francisco for fighting this one. They just won $1.8 million for improvements to Market Street!

    If you ride a bicycle or walk on Market Street, donate to one or both of those groups:

    http://www.livablecity.org/donate
    http://www.walksf.org/join/

  • “we try using the same money to fund livable streets improvements on Market Street and other parts of the city?”

    That’s the job of the city. Livable streets organizations should be advocating for the city to implement said improvements but they sure as hell shouldn’t be paying for them.

    I applaud the steps that the various groups took and continue to take on this project – they negotiated good concessions and otherwise moved the project in a more positive and productive direction.

    Any attempt to ‘play nice’ with developers is a one-way street. Without both carrots and sticks they will pay no heed to the impacts of their development on city resources or really anything other than their bottom line.

    “Of course, to the purist, the lack of economic activity is no problem, because it lets the bikes cruise through more quickly. And the “anti-displacement” types certainly don’t want anything to drive out the drunks.”

    Both of these statements are absurd straw arguments and sound like they came straight from Nevius’ keyboard or a GGRA press release.

  • “However, we also feel that the traffic impacts that this project creates should be mitigated and that rather than a gigantic glass box, the project fit in the with the character of the neighborhood.”

    The “character of the neighborhood”! Ha! Sounds like Manish hasn’t been on Market Street lately. The anti-car movement lost this one. Even progs on the BOS understand that anything that can be done commercially on Market Street should be allowed, not discouraged.

    Levy, by the way, helped save the derelict, completely undistinguished Harding Theater on Divisadero, which is still empty and blighting the middle of the Divisadero corridor years later.
    http://district5diary.blogspot.com/2010/09/anti-car-folks-oppose-cityplace-today.html

  • I applaud your optimism, but since it hasn’t happened yet after 30 plus years, why do you think now will be different?

    because now there is an incipient and growing mass popular movement for ‘livable cities’, there is critical mass on Market Street revitalization, there is new bike infrastructure on Market Street that is slowly but surely allowing people to ride their bikes on Market – adding to the livability of the street and with it desirability of investing there, the 3rd street corridor is now developing/developed – making underutilized areas of the city, like mid-Market, one of the best new investment areas, etc. etc. etc.

    Market Street — anywhere on Market Street — is the new ‘in’ address in the city. The last thing we can afford there is a huge parking lot.

  • On the desirability of investing on major bike corridors/areas, this NYT article just showed up:

    Yosemite. Denali. SoHo?

    The downtown Manhattan neighborhood known for tourists and chain stores is, with New York City itself, becoming something of a destination for outdoor types. Or so a big West Coast retailer is betting.

    Recreational Equipment Inc., an outdoor company based in Kent, Wash., announced Thursday that it would open its first New York City store in SoHo next fall, a few blocks from the New York flagship store of Eastern Mountain Sports.

    SF is already an outdoors mecca — and that’s basically against all attempts at government to stop it. As we continue to allow normal people to ride bikes, we’re gonna see a surge of outdoor/cycling/camping/hiking/etc. activity. Mid-market is ground zero for that surge. The only decent sports stores we have are somewhere in Marin (aka, The Presidio), and another somewhere down near San Jose (aka, 16th/Potrero/Mission). Market Street has a golf store on it. For real? Incredible.

  • I vote for a ‘Preview’ button! It’s even more necessary because the comment system chops/hacks submitted HTML. 🙁

  • Peter, REI has a store at 7th and Brannan, though I get the point of your post. I, however, saw no mention of parking (included or not) in that NYT’s article.

  • Peter, REI has a store at 7th and Brannan, though I get the point of your post. I, however, saw no mention of parking (included or not) in that NYT’s article.

    ah! you’re right. i didn’t bother to actually look up ‘major sports stores’ on google maps — i guess those 2 locations (of the Sports Basement stores) are basically my mental map of sports stores in the city.

    and that brings up what i think is an interesting, if only semi-related, point — that REI at 7th/Brannan is ‘over there somewhere’ — in that mix of pseudo-sometimes-occasionally-one-way streets/highways and no bike lanes. if i had to pick a place to end my life quickly, i’d just cruise around those streets over there for a little while. shoot – even the bus drivers honk at you over there. 🙂

    my point with that article was that real bicycle infrastructure is attracting real business investment. Market Street is starting to see some very limited ‘real’ bike infrastructure, which means investment dollars are going to be looking at the area much more seriously than in the past.

    adding _any_ parking in the area is really an absurdity — it’s not even worth talking about.

    that we’re getting so much new parking added is really a crime against the City and its residents. it’s not yet actual assaults being carried out against residents right now/today, but as soon as the garage is operational we _will_ be assaulted with/by cars/trucks/SUVs physically and psychologically.

    these are real assaults that will be carried out, probably with impunity, by real people driving real, big motorized vehicles. and these assaults have now been granted legal status/sanctioning. that, to me, has to be a crime against humanity, by definition. even if Cheney didn’t order the smashing of some kid’s testicles, he created the conditions that made it possible, and so he should be held responsible. our Supervisors just created the conditions that made it possible for us to be assaulted/humiliated/terrorized/killed/murdered. i’m fine if our Supervisors and The Developer get lawyers, but they should all be arrested and tried in a court of law. someone has to be held responsible.

    and we shouldn’t give up the fight. we should block development/use of the garage just like protesters are blocking the entrance to the Fell Street Arco Gas Station. we have to resist as much as we can, however we can. it’d be best to file a lawsuit now, in the early stages, before the assaults can even begin.

  • Peter – Mike’s Bike’s is at 8th and Howard. We took MUNI to Civic Center and walked 3 blocks to pick up my son’s new Hotwalk. MUNI even allowed him to take his bike on Metro on the way back.

    Performance is at 6th and Brannan. Warm Planet, 4th and Townsend. Pacific bikes is on 4th.

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