PLANiTULSA final draft, my comments

Today at 4 at Tulsa City Hall is what may be the final session of the Tulsa Metropolitan Area Planning Commission's public hearing on the PLANiTULSA comprehensive plan. (You can download the June 2010 Final Draft of the PLANiTULSA policy documents here.) Work obligations preclude me from attending today, but I have submitted the following comments to the TMAPC via e-mail:

In general, this is a solid plan that should be moved forward to the City Council. Rereading the plan again, I was pleased by the emphasis on connectivity (something sadly neglected in the build-out of south Tulsa, to the detriment of traffic flow), walkability, and a much more sensible approach to parking, including shared parking districts and realistic parking ratios. I'm pleased to see an important role for historic preservation, particularly in the downtown area. I applaud the inclusion of "protects and stabilizes existing neighborhoods" in the list of criteria to guide zoning decisions (Land Use Policy 5-7, p. LU-80).

That said, I have several concerns, particularly with the land use chapter, and I urge the TMAPC to amend the document to address these issues:

* While the Land Use plan sets out a new "policy structure" for land use planning (p. LU-56), it also seems to provide several large loopholes that seem to undercut the new policy structure and keep Tulsa in the mode of reactive, spot "planning."

For example, p. LU-62: "Small area plans need not be used for more routine planning actions, such as developments or subdivisions of land under single ownership. In these instances, a subdivision, zone change, PUD or other process under the zoning code is sufficient." Surely there should be a size limit on this exclusion. This loophole would seem to allow some very large developments to bypass any scrutiny of connectivity, walkability, and fit with the overall plan.

Then on p. LU-75, these statements would have Tulsa continuing to zone first and plan later, retrospectively correcting the comprehensive plan to reflect zoning decisions made in conflict with the plan.

"[The Land Use Plan] should be amended to conform to zoning changes.... Housekeeping updates and maintenance to reflect development approvals should be made annually."

Instead, a zoning change proposal in conflict with the comprehensive plan should trigger a review of the plan for the surrounding area. If a small area plan is in place, it should be reviewed in light of the proposed change. If there is no small area plan, a zoning change proposal in conflict with the overall land use plan should lead to the creation of a small area plan for the area of the proposed change and its environs. Land development doesn't happen in isolation, and good planning requires consideration of the impact of a proposed zoning change on the surrounding area.

Under our current system, INCOG staff treats a zoning change in conflict with the plan as if it were isolated from its surroundings, and so they only propose a spot change to the comprehensive plan. That's not planning; it's bookkeeping. The language I quoted above from pages LU-62 and LU-75 seems to suggest that this spot planning approach will continue indefinitely, to the city's detriment.

* The paragraph on Existing Residential Neighborhoods (p. LU-33) should merge the language of the previous version with the June draft, in order to make it clear that the goal of the "clear and objective ... development standards" is to ensure that infill in a stable neighborhood is consistent with character of the neighborhood. I propose the following substitute for the third sentence of the paragraph:

"Development activities in these areas should be limited to the rehabilitation, improvement or replacement of existing homes, and small-scale infill projects, as permitted through clear and objective setback, height, and other development standards of the zoning code. These clear and objective development standards in the zoning code should be designed so that infill development complements the character of the neighborhood and is consistent in form, scale, rhythm and proportion as seen from the street."

This language is consistent with that on p. LU-54 which discusses "older neighborhoods that are looking for new ways to preserve their character and quality of life" and mentions Florence Park as a neighborhood where the aim is to "maintain present character."

* Statements specifying the Tulsa Metro Chamber (p. LU-20, p. LU-67) as a partner in economic development should be changed to refer to the business community generally. Over years and decades, how the business community expresses itself organizationally may change. Long-time organizations may fail to adapt to changing conditions and may be supplemented or supplanted by newer expressions of business-to-business cooperation. New organizations may be more or less formal, may be focused on specific neighborhoods or regions of the city on on particular market segments. City government should plan to work with all of them.

It is imprudent for a flexible, future-oriented comprehensive plan to prescribe a fixed, privileged position for a controversial organization of questionable effectiveness. Such rigidity interferes with the dynamism we need in Tulsa's business community. Business organizations, just like individual businesses, should prove their worth in the free market, rather than using privileged government connections to protect themselves against competition. It is especially inappropriate to specify a privileged position for the Tulsa Metro Chamber in a land use policy plan. That the Tulsa Metro Chamber felt it necessary to insert themselves into a land use policy document only demonstrates their weakening political position and organizational confusion.

I note that the economic development chapter appropriately lists the Tulsa Metro Chamber as only one among many potential business-community partners for the city (e.g. p. ED-8). Priority 2, Goal 3 (p. ED-18) should, however, be changed to begin "The City and the business community work closely with institutions of higher education...."

* Finally, a technical comment about the quality of the online PDF documents: The maps and charts are almost illegible, because of the image compression method used to reduce the document size. Zooming in to get a closer look reveals pixelation and other artifacts, blurring details. Often, the colors used in a map's legend don't match the colors that appear in the map (e.g. the transportation map). I urge the PLANiTULSA team to make higher resolution versions of the maps and charts available to the public, using non-lossy compression methods such as PNG. JPEG compression is designed for use with photos, not for maps or graphics that use a small number of distinct colors with sharp boundaries.

I would also urge making documents, maps, and charts available in the native format in which they were originally laid out (e.g., Photoshop, GIS, AutoCAD). Those Tulsans with the appropriate software would be able to download the files and turn layers of content on and off to see the details more clearly.