New Whatcom Redevelopment: Unanswered Questions About Vehicle Parking

Wes Frysztacki is a Bellingham resident and member of the newly formed Bellingham Sustainable Transportation Roundtable. Anyone interested in joining BSTR is welcome to contact Wes at wf@weslin.net.

Editor’s Note: The former Georgia-Pacific property was initially called New Whatcom. Since the draft environmental impact statement was issued, the name has been changed from New Whatcom to The Waterfront District.

Where are 12,892 cars going to park?

How much will those 12,892 parking spaces cost? Who will pay that cost? How will offering so many parking spaces support sustainability?

How will cars going to and from those 12,892 parking spaces not conflict with the walkability and bikeability of the port’s New Whatcom (now called The Waterfront District) redevelopment project at the former Georgia-Pacific property? How will so many cars circulating about create a safe, attractive and competitively marketable project? Will all of these cars be using the project’s much-acclaimed green streets and park streets?

I have not heard answers to these questions — have you?

The port wants 12,892 parking spaces to support their preferred alternative for the New Whatcom redevelopment project. The Port of Bellingham’s supplemental draft environmental impact statement states, “By 2026, it is estimated that the preferred alternative would provide 12,892 parking spaces onsite” (chapter 3.12, page 16).

Perhaps offering 12,892 parking stalls is a good thing. Isn’t that just a big parking lot or a couple of parking structures? No, it’s not a good thing! And, no it’s more than a few lots or structures!

Consider the following approximate statistics representing the three largest parking space accumulations in Bellingham:

• 4,700 total parking spaces at Bellis Fair mall.

• 3,800 total parking spaces within downtown Bellingham.

• 3,400 total parking spaces for Western Washington University.

The port claims it needs more parking spaces than Bellis Fair mall, downtown Bellingham and Western Washington University (WWU) combined provide today. The total of 11,900 parking spaces for all three of Bellingham’s current largest parking areas is inadequate to fulfill the port’s preferred alternative requirement of 12,892.

New Whatcom has 220 acres. Bellis Fair mall is located on 72 acres. Three Bellis Fair malls would be 216 acres. So, envision three Bellis Fair malls grouped together. Is this the port’s preferred alternative?

The 12,892 parking spaces the port wants represents about one-fourth of the total parking supply in downtown Seattle. The entire University of Washington (UW) complex has 12,000 parking spaces. That is, actually, 300 fewer spaces now than existed in 1989, even though substantial building additions have been made to the campus over the past 20 years.

UW and WWU have excellent transportation demand management programs. WWU, one of the much-anticipated occupants of New Whatcom, has reduced campus access by single occupant vehicles from 36 percent of all trips in 1992 to 20 percent of all trips in 2003.

Likewise, the National Oceanic and Atmospheric Administration (NOAA) has outstanding transportation demand management programs. NOAA pays employees a maximum monthly benefit of $115 if they don’t drive. NOAA employees use alternative means of transportation such as transit, bicycling or walking to get to work.

The New Whatcom redevelopment project DEIS (draft environmental impact statement) and the supplemental DEIS do not properly account for the types of transportation demand management programs and alternative transportation infrastructure used by the types of project participants anticipated or desired.

Instead, these documents essentially assume virtually everyone will drive to New Whatcom. The DEIS even assumes “persons might drive to another area of the site and park again” (chapter 3.12, page 29, second paragraph). This is based on the statement: “Transportation industry research indicates that typically persons are willing to walk up to one-quarter mile.”

Travel behavior assumptions made in the darkness of a technical analysis are dangerous. Someone’s judgment of the travel behavior of a “typical” person from the past may not be right for New Whatcom. Is a “walkable” project one where no one walks more than a quarter mile?

The Institute of Transportation Engineers (ITE) trip generation rates are popular with traffic engineers. But they should be used as a starting point, not a decisive factor as was done in the New Whatcom DEIS and supplemental DEIS chapter 3.12.

There are many pitfalls to the approach used, especially with a project such as New Whatcom. The trip rates are based on data going back to the 1960s. They are from wherever in the U.S. data were collected and made available to ITE. They are for vehicles only and are for an auto-oriented development.

Page 1149 of the ITE’s Trip Generation, 7th Edition, 2003 is the location for land use 710, general office building, one of the major trip rates used in the analysis. The description states, “Nearly all of the buildings surveyed were in suburban locations.” Is a typical suburban auto-oriented office park what we envisioned for New Whatcom?

Page 1149 of the ITE’s Trip Generation manual has the following disclaimer: “Transit service was either nonexistent or negligible at the majority of the sites surveyed … . Users may wish to modify trip generation rates … to reflect the presence of public transit, carpools and other transportation demand management strategies.” This should be done in a context where prospective New Whatcom project occupants such as WWU and NOAA are directly investigated to determine their trip generation history and their desired policy-driven future trip generation modal shares.

New Whatcom’s proposed actions should include the types of conditions in development regulations, development agreements and a New Whatcom planned action ordinance that promote such transportation demand management programs, not ignore them. Shouldn’t the New Whatcom DEIS be assessing the impacts of desired new urban transportation policies and practices, rather than continuing old suburban auto-centric policies and practices that gave us what we have today along the Guide Meridian?

People seem to be pleased when they hear about the Park Street and Green Street concepts. I suggest the roadway cross-sections in Appendix C combined with the vehicle traffic analysis in Appendix M be studied first before assuming these proposals have abundant merit.

The Green Street Environment for the preferred alternative has three dedicated lanes of parking within its right-of-way and the Park Street has four lanes of parking. After cross-sectional space is removed for cars and parking, a residual 124-foot wide linear park remains. This park is encircled by cruising traffic constantly hunting for an empty parking space creating a treacherously unsafe environment for a child chasing after a ball. Where is traffic safety addressed in the DEIS?

A formally structured oversight group of citizens should have been given the opportunity to consider such traffic safety issues and many others that should have been posed within a focused transportation planning process for the New Whatcom site. The city should have formed the proposed transportation commission years ago, but it’s not too late.

A transportation commission would have asked the types of questions posed and many others. The answers to such questions test the types of transportation policies that should have been incorporated into the New Whatcom DEIS. The answers should be an integral component of the proposed actions and elements of future development of the site designated by the city as a planned action pursuant to SEPA.

Instead, the DEIS was prepared using standardized professional practices for smaller suburban developments with emphasis on vehicle trip generation rates and minimum parking supply requirements.

Preparing a project DEIS based on minimum parking requirements is an outdated technical approach for a project such as New Whatcom. Minimum parking requirements are remnants of misguided planning theory from the past.

It is well understood in most major city planning departments that minimum parking requirements increase traffic, increase conflicts with pedestrians, increase safety hazards for bicyclists, increase air pollution, distort urban form, increase housing costs and damage the economy.

Many examples exist of what other city planning efforts have done and what should have been done to prepare a proper transportation plan and DEIS for the New Whatcom redevelopment project driven by the type of transportation policy suitable for Bellingham.

One example is found to the south. The city of Seattle imposed a maximum, not a minimum, parking requirement on the University of Washington over 20 years ago. Seattle offers many transportation policy examples that should have been tested for New Whatcom.

Another example of policy-driven transportation planning can be obtained from our neighbor to the north. Vancouver, British Columbia’s southeast False Creek area comprises a total of 80 acres of former industrial land near downtown Vancouver, a location very comparable to the New Whatcom site. The Vancouver City Council directed that the city explore using southeast False Creek as a model for “sustainable development.” Isn’t that what we want for New Whatcom?

The southeast False Creek policy statement approved by the city of Vancouver in 1999 reads as follows:

“Southeast False Creek is envisioned as a community in which people live, work, play and learn in a neighborhood that has been designed to maintain and balance the highest levels of social equity, livability, ecological health and economic prosperity, so as to support their choices to live in a sustainable manner.”

Isn’t this what we envision for New Whatcom? Vancouver adopted the following vision for transportation and accessibility:

“The transportation network in southeast False Creek will greatly shape the neighborhood’s form and livability. Developing transportation and circulation systems, which focus on pedestrian and bicycle paths and transit linkages, is of primary importance in ensuring a livable and environmentally sustainable waterfront neighborhood.”

Isn’t this the transportation network and circulation system we should envision for New Whatcom? One of the objectives of the southeast False Creek transportation policy is to place greater emphasis on walking and bicycling to make a trip. Chapter 3.12 in either the DEIS or the supplemental DEIS does not represent such a policy.

Instead, the New Whatcom redevelopment project DEIS relies upon parking, roads, bridges and more traffic signals to channel new vehicular traffic. Bicycles must share 12-foot-wide vehicle lanes, not a standard used in major urban redevelopment projects where pedestrian and bicycle infrastructures are given priority.

In Vancouver, the southeast False Creek transportation design guidelines for the Ontario Street right-of-way dedicate three meters (about 10 feet) to a bike path, another three meters to a pedestrian path, another 1.5 meters to a sidewalk in the same cross-section as a 7.5-meter roadway.

Front Street has a different cross-section with 4.2 meters dedicated to bicyclists, 8.8 meters to pedestrians and a reduced roadway for vehicles of 6 meters. This is to accommodate a target mode share with over half arriving by transportation modes other than automobiles.

A January 17, 2005, report from the southeast False Creek steering committee to the Vancouver City Council set a target of “60 percent of all daily trips by non-auto modes based on reduced parking requirements, greater support for car-sharing and co-op vehicles, and increased support for alternative modes such as cycling and public transit.” Isn’t that what the New Whatcom redevelopment project should be offering?

Other new transportation policies and corresponding infrastructure investments were identified for Vancouver’s southeast False Creek, such as making the overall width of the walkway-bikeway 60 feet and requiring grade separation of pedestrian and bicycling modes in high-traffic areas. This is not a recreational facility, but a functional part of the overall transportation network to serve all trip purposes.

The New Whatcom DEIS assumes nonrecreational bicyclists will share 12-foot lanes: “bicyclists would be accommodated within the street right-of-way” (chapter 3.12, pages 48 and 58).

Although extensive level of service (LOS) analysis is performed for vehicles, none is performed for other modes as would be required by Washington state’s Growth Management Act (GMA) in a major urban project where transit, pedestrians and bicyclists are to be given priority. GMA requires a transportation LOS analysis, not a vehicle LOS analysis.

Giving proper attention to LOS impact analysis for transit, pedestrians and bicyclists would have been as appropriate as the attention given to all of the vehicle flows at intersections in the New Whatcom DEIS.

The GMA requires local jurisdictions “… to prohibit development approval if the development causes the level of service on a locally owned transportation facility to decline below the standards adopted in the transportation element of the comprehensive plan, unless transportation improvements or strategies to accommodate the impacts of development are made concurrent with the development. These strategies may include increased public transportation service, ride sharing programs, demand management, and other transportation systems management strategies.”

The New Whatcom DEIS did not adequately consider these GMA-specified strategies.

Such GMA strategies are not foreign to transportation planning in Bellingham. Transportation policy as included in WWU’s institutional master plan places emphasis on these types of strategies. WWU works diligently on the types of alternative transportation connections to campus that should have influenced the transportation planning process for the waterfront redevelopment plan, had there been one. The current WWU modal hierarchy is:

1. Pedestrians

2. Bicycles

3. Transit

4. Vehicles

Isn’t this modal hierarchy preferable for New Whatcom? Instead, chapter 3.12 placed a priority on vehicles. It is predicated on parking those vehicles at the expense of the project participants. Chapter 3.12, pages 49, 58 and 69 all contain the following statement: “It is assumed that adopted standards for the future parking supply onsite would require that each future redevelopment project accommodate its parking demand.”

Is WWU going to pay for the minimum required parking supply specified in the DEIS given their current transportation policies? Will NOAA?

Let’s not burden the port, the city, WWU, NOAA, other project participants and, especially, local taxpayers with the estimated $250 to $450 million dollars it will cost just in providing the parking supply the New Whatcom redevelopment project DEIS assumes is required. How that cost is to be borne is critical, but the DEIS has no economic analysis to assess this critical impact.

The following are the types of actions that could be taken to ultimately correct the deficiencies in the New Whatcom DEIS and supplemental DEIS:

• The DEIS should be approved on a conditional basis with the requirement that the final environmental impact statement be supplemented at a future date with an amended transportation impact analysis based upon the Bellingham City Council adopting a New Whatcom transportation plan.

• A transportation commission to be formed by the city of Bellingham should oversee the preparation of a New Whatcom transportation plan in conjunction with the preparation of a much-needed Bellingham transportation master plan.

• The new transportation commission should immediately receive a briefing on the best practices used for the development of comparable transportation plans. Perhaps the commission would be so bold as to want to explore not just the best practices within the U.S., but exceptional transportation practices from throughout the world.

• The transportation commission should prepare a vision statement for transportation and a set of policy guidelines including modal share targets. This would be submitted to the City Council immediately for consideration before the development of the New Whatcom transportation plan.

• The transportation commission should prepare a proposal for a scope of work needed to conduct the tasks to prepare the New Whatcom transportation plan and amend the New Whatcom EIS. The scope of work should:

• Use the New Whatcom EIS as first phase establishing a baseline representing a “typical” traffic impact study.

• Conduct a second phase to assess the implications of implementing a more sustainable transportation improvement strategy.

• Propose amendments to the EIS.

• Occur in a highly open forum giving citizens ample opportunity to participate.

• Be completed in an expeditious manner so as not to delay any aspects of the development of New Whatcom.

The work included in chapter 3.12 of the DEIS represents standard transportation analysis professional practices used in the past. Is this sufficient for Bellingham? Can we do better? We must if New Whatcom is to be sufficiently attractive in the global marketplace to be the success we want it to be.

The following volumes are available at the Bellingham Public Library reference desk under Local History 307.76 New Whatcom 2008.

• New Whatcom Redevelopment Project: Volume 1/Volume 2

Draft Environmental Impact Statement

Port of Bellingham, January 2008

• New Whatcom Redevelopment Project

Supplemental Draft Environmental Impact Statement

Port of Bellingham, October 2008. §