The following letter was sent from the Western New York Environmental Alliance Standing Committee to the City of Buffalo and the Buffalo Green Code consultants.
Dear Mayor Brown:
The Western New York Environmental Alliance (WNYEA) is an umbrella group that connects local groups working on environmental issues so that they can together foster and accelerate positive change in policy and practice. WNYEA was created through the efforts of the Community Foundation for Greater Buffalo (CFGB) in 2009 to unite the many organizations working to restore and preserve our region’s natural environment. Now comprised of more than sixty-five organizations, WNYEA is the region’s preeminent environmental collaborative.
WNYEA would like to commend you and your administration for the ambitious rewrite of the City of Buffalo’s outdated land use and zoning code. While zoning may not be a topic of conversation around many dinner tables, we nonetheless recognize its importance as the fundamental road map for development in our city and, by extension, the basis for the lifestyle and quality of life within our neighborhoods. Further, we would like to also express our optimism and enthusiasm for approaching this rewrite as a “Green Code”, which we hope will not only embody environmentally focused best practices from other regions, but also set a new standard for sustainability for America’s cities.
While the Green Code cuts across multiple environmental interests represented by WNYEA, among WNYEA’s committees the Urban Regeneration Task Group – comprised of roughly 100 members – underscores the vast and growing interest in revitalizing Buffalo’s neighborhoods in the face of decades of population loss and industrial decline. This recent history certainly provides a set of real and pressing challenges, but it also presents a singular opportunity to rethink and remake the city as a unique location for advancing a municipal triple bottom line of people, planet and prosperity. In that regard, WNYEA respectfully submits this open letter containing the following recommendations as core principles that will need to be reflected in a land use plan and zoning code in order for this project, and for Buffalo, to obtain these lofty goals.
PRINCIPLES OF SUSTAINABLE DEVELOPMENT
Our region’s development pattern of the last sixty years has been unsustainable. According to the bi-county Framework for Regional Growth, from 1950 to 2000 developed areas tripled from 123 square miles to 367 square miles, but from 1960 and 2000 the region lost 137,000 residents and early Census indications are that number will fall even farther. Meanwhile, the legacy of heavy industry and the infrastructure that supported it rings our communities and continues to pose wellness and livability challenges, particularly for traditionally underserved populations. The land use and zoning code’s ability to set a clear, sustainable and equitable path cannot be overlooked.
Environmental Justice
For too long our zoning has often placed poor people and people of color closest to polluting industry and contaminated property. Environmental Justice is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation and enforcement of environmental laws, regulations and policies. By viewing the Green Code through this lens, we must acknowledge the interlocking barriers to developing healthy communities. Environmental Justice should be a theme running throughout every aspect of our new land use plan and zoning code by protecting communities from toxics and undesirable infrastructure, while creating access to fresh, healthy and local food, employment opportunities, and safe places to play to foster a quality environment for all residents to reach their potential.
Smart Growth
The concepts of smart growth are well expounded and endorsed in the City’s Comprehensive Plan as well as the Framework for Regional Growth and many other regional planning documents. However, too often in this region, these plans become of the variety that collect dust on a shelf rather than impact people’s lives for the better. The Green Code represents an opportunity to translate these plans to action, by ensuring smart, accessible, integrated mixed-use and mixed-income communities are not just encouraged but required in future development.
THE NATURAL ENVIRONMENT
Given Buffalo’s vast depopulation and tremendous thinning of the built environment, the amount of population growth that would be necessary to fill all of the 16,000+ vacant lots that now exist in the city is not feasible in the short term. How, then, can the new zoning code promote non-conventional redevelopment in ways that increase the quality of life for current and future residents? Through small to large scale land areas involving short, medium and long term uses and solutions – from habitat areas to community gardens, urban agriculture and temporary event sites – the zoning code must protect public spaces and sensitive natural areas and accommodate currently proposed uses and projects while also being flexible enough to encourage future innovations.
Public Space
Buffalo has a great opportunity to provide easily accessible and high quality parks and green space – including community gardens, sports fields, historic landscapes, scenic views, access to water, urban squares, and more – for all of its residents. Ideally, every resident should be able to access a park or greenspace within a quarter-mile of where they live, and consideration should be given that each neighborhood can define what type(s) of park(s) are needed for its residents. We should look to our abundance of vacant lots and former industrial sites to meet our greenspace needs for neighborhoods and regional destinations, and should use this opportunity to integrate development and maintenance of public space with education and employment opportunities within communities. [Click here for more…]
Natural Resource Protection and Access
The new Green Code must protect our waterways and environmentally sensitive areas while providing residents with easy access to natural surroundings. The code must respect, complete, and enhance our existing and proposed community greenways and identify prime opportunities for increasing naturalized areas. The code should also ensure that all public infrastructure projects and all new and re-development projects will incorporate best management practices that minimize or eliminate stormwater discharge into the City’s Combined Sewer Overflow system through on-site management as well as use of surplus land. Zoning must also affirm and protect public access and setback requirements to all waterways, and institutionalize increased habitat value and sedimentation and erosion controls for all waterfront adjacent development.
Urban Agriculture
Urban Agriculture can address a plethora of existing social and infrastructure issues through thoughtful land reuse and design. Even small-scale urban agriculture has multiple ancillary benefits including: access to local, fresh and healthy food for urban residents; direct environmental benefits 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, as well as experience with nature and food production; neighborhood development through beautification and blight abatement in addition to reduced crime through community stewardship and opportunity.
THE BUILT ENVIRONMENT
For sustainable cities, zoning isn’t just about directing the form of a building or what happens within. Zoning’s real power comes from the relationship between structures and systems, from the ability to shape experiences, ease burdens and enhance opportunity. The auto-centric policies of the mid-twentieth century were born of an era that tried to engineer a way out of social problems; that tried largely to impose an unnatural order of separation on complex interwoven systems. In Buffalo, the unintended consequences of this strategy have been disappointing to say the least. Complex systems require complex solutions, and in order to achieve our vision of a safe, equitable and healthy community, we need to focus on the needs of the people that ultimately comprise our city.
Public Health
Health begins where we live, learn, work and play – it starts in our families, in our schools and workplaces, in our playgrounds and parks, and in the air we breathe, water we drink and food we eat. The conditions in which we live and work have an enormous impact on our health. The Green Code provides an opportunity to promote active and healthy neighborhoods within our city by adopting a more health-friendly land use plan and zoning code, as well as urban design strategies, as a vital component of planning for communities and individuals. Health also plays a role in all aspects of land use planning – transportation, parks and recreation, housing and public facilities – and should be included within those elements and as a stand-alone component of the land use plan.
Public Safety
Though criminal acts have many and deep seeded causes, efforts to enhance public safety are too often confined to narrow definitions of law enforcement. However, the design of buildings, streets and neighborhoods has a direct impact on the safety of people in those places. The principles of crime prevention through environmental design need to be considered and codified in Buffalo’s zoning. Some of these apply to each place or building: perceived ownership of public and private realms; appropriate access control for people and vehicles; image and appearance; and “eyes on the street”. Others, still, apply to the relationships or transitions between buildings and places: activity support and complimentary land uses; circulation guides and predictors; and value added avoidance of use conflicts all will reduce the opportunities for criminal behavior.
Economic Integration
Buffalo can not achieve sustainable communities without sustainable employment. Spaces for economic development must be provided in a way that enhances neighborhood stability and creates opportunities and career pathways for all of Buffalo’s residents. Planning must be directed to a reduction of those barriers which reduce the logistical barriers to employment (i.e., time and expense of transportation and childcare), and for the provision of easy access to daily needs that does not require automobile access. New uses must compliment, foster, and strengthen entrepreneurial activity and neighborhood ownership, rather than drain value and vitality from existing communities. Sustainability requires opportunities for economic development that are integrated with, rather than separate or isolated from, community development.
Clean Energy
Both nationally and internationally there are strong efforts being made to reduce reliance on fossil fuel sources and cut carbon emissions in order to avoid projected climate disasters, and to create jobs through the deployment of renewable energy and energy conservation measures. Buffalo can lead in this effort by creating certainty for developers and installers as they look to adapt and scale up geothermal, solar, wind and energy efficiency technologies in and for the city’s homes, buildings and land. Though aspects of residential and small scale commercial applications will need to be regulated by building codes, wherever possible the Green Code should set out appropriate siting criteria for various clean energy technologies while giving homeowners and business owners reliable and expedited processes to make their buildings energy efficient, comfortable, and inexpensive to heat and power.
PUBLIC ENGAGEMENT
WNYEA encourages a robust public engagement process throughout all aspects of the land use and zoning review and rewrite. Members of WNYEA and the Urban Regeneration Task Group have been and will continue to be engaged through the established public outreach process for the Buffalo Green Code, but we encourage the City and its consultants to recognize and address the fact that this is an under-resourced community with planning fatigue. In a region where often our planning is superb while our implementation is lacking, many have lost faith in a process that in many ways has not produced the hoped for tangible positive results within neighborhoods.
Enhanced Outreach
Building a big tent for community input means encouraging and respecting all voices while being careful not to allow those with larger personalities to dominate the process. In a largely disadvantaged community, where many are rightly more concerned with putting food on the table than influencing public policy, public participation means doing more than setting meeting dates and encouraging people to attend. As acknowledged by the establishment of the Community Advisory Committee, community engagement means leveraging existing networks. But it also means meeting residents on their own terms. It means going to where people already are and accepting their input in their voice that addresses their concerns. Other successful engagement techniques make it easier for those who want to come to traditional meetings by providing children’s activities, food and even bus fare wherever possible. Though these efforts represent an increase in costs, in relation to the project scope, the benefits of a better process are well worth the minimal expense.
Managing and Meeting Expectations
Input into land use and zoning must also be coupled with education about these somewhat arcane regulations. As the blueprint for rebuilding Buffalo, the zoning code rewrite will require making a series of difficult choices. In envisioning the ideal community, is easy to ask for the best of all worlds, but the limits of markets, scale and capital are not often so kind. This does not mean settling for less, but it does mean acknowledging these natural limits. It means vetting the implications of hierarchies of need and various design scenarios and bringing the expertise of professionals to bear in a way that is neither didactic nor demeaning, but is instead a helpful facilitator of the best achievable outcome. This is no small task and, for that, we are pleased at the caliber of the team that has been assembled to take it on.
For the great hopes that WNYEA has for the revised code, we also acknowledge that the Green Code is only the beginning. By its nature the Green Code will have limited impact on existing structures and uses. Though creating the DNA for the future of the City of Buffalo, we must also look to those remedies that heal the existing city by creating a suite of accompanying policies and practices that align municipal operations and capital investment with the intent of the new code. Likewise, companion legislation that incentivizes existing buildings and uses to comply with the spirit of the code will be necessary to accomplish the transformative change we all desire. We hope that the existing planning process for land use and zoning review will produce recommendations for this vital aspect as well.
This letter, which has been composed with input and content from many of our members, and more information on each of the topics and themes presented above can be found at www.GrowWNY.org. Thank you for your attention to this important matter, and we look forward to continuing our work together in the future.
Sincerely,
From the GrowWNY website, a hyperlocal source of information about living green–powered by more than 150 organizations collaborating for our regional environment.
Reprinted by permission.