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    W E S T E R N N E W Y O R K E N V I R O N M E N T A L A L L I A N C E

    The basis for the work of the Western New York Environmental Alliance (WNYEA) the Environmental Declaration of and Sha

    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 econom

    As such, there is not a dichotomy between economy and environment; rather the environments stewardship should be seen as a

    ource 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.

    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 atten

    o 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 nuan

    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, cons

    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 ju

    reflection of existing conditions.

    5) The code must go beyond permissive, it must be proactive to achieve environmentally responsible development.

    n our letter to the administration in February of 2011, we laid out several elements that must be included in the final Green C

    o achieve the aim of a truly environmentally innovative development framework. The attached document is arranged accordin

    hese themes and subheadings:

    Environmental JusticeSmart Growth

    RetailWaterfrontsVacant LandCorridors and Streets

    Public SpaceAccess to Green SpaceOpen Space Districts

    Natural Resource Protection and AccessUrban AgriculturePublic Health

    Healthy LifestylesSafe Environments

    Public SafetyEconomic IntegrationClean EnergyPublic Engagement

    While no city has yet to adopt workable policies across the entire spectrum of these issues, the ongoing Green Code process aff

    an opportunity to adopt best practices from around the country and beyond. In learning from the successes of others, Buffalo

    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

    City and its consultants further as the plan moves toward completion, whether that is continued participation in advis

    committees and working groups, working directly with city staff to develop standards for specific issues and uses, translating

    practices and policies from other cities to accommodate Buffalos unique on the ground conditions, or enhancing pu

    participation through our broad networks.

    The many member organizations that contributed content for this review of the draft would like to again thank the administra

    for pursuing this review of the land use plan and zoning code. We would like to request meeting to discuss these potential area

    mprovements to the Green Code. Please review the attached recommended language changes to the draft principles and le

    know how we may be of assistance in the months ahead.

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    W E S T E R N N E W Y O R K E N V I R O N M E N T A L A L L I A N C E

    raft Land Use Plan Comments

    The Western New York Environmental Alliance Submits the following comments

    the draft land use plan unveiled by the City of Buffalo in October 2011.

    WNYEA Public Comments November 20

    The draft land use plan released at the end of October was residents first look at the proposals the City has crafte

    based on public input from across the city and from across various sectors and interests. Though the attachreview is long, it should not be interpreted as a criticism of the direction of the project. Our belief is that what w

    draw people to Buffalo will be our ability to generate cutting edge urban thinking, design and development with

    focus not just on the present but on the long term future of the City and the region. While there are many positi

    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 final version

    the Green Code is one that can be successful for our city as well as provide a model for other regions attempting

    build a framework of a sustainable city in the 21st Century and beyond.

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    raft Land Use Plan Comments

    In this document

    Environmental Justice (page 3)

    Smart Growth (page 4)

    Retail (page 5)

    Waterfronts (page 5)

    Vacant Land (page 6)

    Corridors and Streets (page 6)

    Public Space (Page 9)

    Access to Green Space (page 9)

    Open Space Districts (page 10)

    Natural Resource Protection and Access

    (page 11)

    Urban Agriculture (page 12)

    Public Health (page 13)

    Health Lifestyles (page 13)

    Safe Environments (page 14)

    Public Safety (page 14)Economic Integration (page 15)

    Clean Energy (page 16)

    Public Engagement (page 16)

    Before addressing specific elements,

    there are several challenges within the

    methodology and/or form of

    document, but we are confident each

    can be addressed in future revisions.

    1) The document would benefit

    greatly from a definitions section

    clarifying the use of various terms.

    Additionally, aside from simply having

    principles and worthwhile but

    nebulous goals for land use, a

    successful document will include a set

    of measurable indicators and metrics

    to hold development accountable to

    those elements residents have held up

    to inform the future of Buffalo.

    2) The document envisions the city as a

    collection of place types

    Neighborhoods, Districts, and

    Corridors. While there is utility in

    dividing the city conceptually into

    these categories, there remains a need

    to insure that each of these types of

    places are well integrated with each

    other. Though the documentacknowledges as much, it is worth

    emphasizing here that designation as aDistrict should not be an excuse to

    dispense with quality urban form

    and urban design, but should instead

    place an additional responsibility on

    these spaces to ensure an appropriate,

    welcoming and vibrant sense of place.

    Likewise, the definition of Corridor

    strikes an appropriate tone and vision

    for these designations, but the specifics

    of corridor typologies are

    unfortunately largely

    underdeveloped within the remainder

    of the draft and is not reflected

    adequately in the mapping.

    3) Parcel lines should not be the o

    determinant of where one place t

    ends and another begins, a broad

    look at context and a more finely

    grained analysis are in order. Multi

    place types and uses may or may no

    appropriate within a given parcel ba

    on the topography, environmental

    sensitivity, potential for stormwatercapture, existing habitat values, etc.

    the various sections of that parcel. T

    is particularly true in open space

    designations, along waterways, and

    areas designated as Districts. On th

    other end of the spectrum, it would

    beneficial for a more coherent group

    of place types at the scale of the stre

    or block. Ensuring that place

    classification do not shift multiple ti

    within a small stretch will enhance tability to create cohesive a sense of

    place.

    4) Mapping andplotting of placetypes is too often defined by the

    existing land use and conditions,

    rather than the conditions we wo

    aspire to see. Likewise, the

    descriptions outlined in the Place BaPlanning Handbook adhere too clos

    to the existing form of these place ty

    and not what the desired form wou

    be. Though coding aspirationally m

    create non-conforming uses, these

    grandfathered building types would

    not be displaced by the zoning code

    until such time as a major

    redevelopment occurred in their pla

    and, as such, should cause no practi

    concern for existing uses.

    5) Though the draft is permissive to

    environmentally sustainable practic

    to be truly green it must insteadbproactive by requiring, or at the v

    least incentivizing, progressive

    patterns and innovations in

    building, land use and site plann

    Photo by Thomas Herrera-Mischler

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    For all of the principles and policy

    goals outlined in the draft plan, the

    draft land use plan fails to even invoke

    nvironmental justice terminology. In

    n impoverished city with vast

    disparities of race and class, which

    ontains a disproportionate amount of

    ontamination, the revision of theoning and land use code must be used

    s an opportunity to mitigate existing

    nvironmental inequities while

    preventing future degradation from

    occurring. We must directly

    cknowledge the challenge of the

    historical and current industrial and

    ransportation pollution that we face if

    we ever hope to overcome them to

    provide equality and opportunity for

    ll residents.

    The plan needs to adopt a clear

    definition of environmental justice as

    he fair treatment and meaningful

    nvolvement of all people regardless of

    ace, color, national origin, or income

    with respect to the development,

    mplementation and enforcement of

    nvironmental laws, regulations and

    policies.

    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 thatcould affect human health and

    development, especially in children.

    In addition to addressing and

    monitoring past pollution, a form-

    based rather than use-based code

    provides opportunities for the fusion of

    both a clean environment and economic

    activities. Given the new technologies

    available to industries, it is possible for

    residential areas to be located

    working industry but only

    comprehensive environme

    regulations are met.

    However, one area that still needs t

    addressed is residential proximity

    high volumes of automobiles

    trucks. Too often surroun

    neighborhoods have poor air qu

    and noise that continues unaba

    These areas including neighborho

    near the Peace Bridge, I-190 and R

    33, and other residential areas near

    volume roads should receive e

    attention to mitigate and elimi

    these negative effects. Relieving

    health and wellness burden in t

    communities should be a top priorithe Green Code.

    Principles of Sustainable Development

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

    Adopt a clear definition o

    environmental justice.

    Environmental Justice

    Photos by Anthony Armstrong unless otherwise

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    SMART GROWTH

    PR INC I P L E S

    I N T H E C I T Y S

    C O M P R E H E N S I V E P L A N

    1. Mix land uses

    2. Take advantage of compactbuilding design

    3. Create a range of housingopportunities and choices

    4. Create walkable neighborhood

    5. Foster distinctive, attractivecommunities with a strong sensplace

    6. Preserve open space, farmland,natural beauty, and criticalenvironmental areas

    7. Strengthen and directdevelopment towards existingcommunities

    8. Provide a variety of transportachoices

    9. Make development decisionspredictable, fair and cost-effecti

    10. Encourage community andstakeholder collaboration indevelopment decisions

    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 itsgeneral 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 thathave 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 conflict with the reality of

    Buffalos trends for the last six decades.

    But rejecting this growth-first 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 (GreenDevelopment 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 financial

    capital.

    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 acitys 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

    definitions. 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 classification

    types that are generally restricted to

    residential uses provide no indication

    if, or under what circumstances, home-

    based 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 outand Corridors have been omitted

    entirely.

    Smart Growth

    Elements of the draft do not

    deviate far enough from the

    growth-at-all-costs mindset

    that has been in direct conflict

    with the reality of Buffalos

    trends for the last six decades.

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    Other categories and classifications

    provide more direct challenges to a

    ustainable vision of the city. For

    xample, while separating suburban

    etail development from mixed-use

    neighborhood centers is laudable, it is

    ultimately ill-advised to encourageuburban, car-dependent development

    patterns anywhere in Buffalo. More

    mphasis, instead, needs to be placed

    on repairing the substantial damage

    hat this unsustainable development

    pattern has already done to the city and

    ts neighborhoods. Just because many

    ites throughout the city are currently

    ingle-use and non-urban, this should

    not relegate these sites to a continuing

    underutilization in the citys futureplace type modeling and mapping

    lassifications.

    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 lifeimmensely. Full scale redevelopment of

    these single-use sites must be a priority

    in the plan. Special classification

    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 underutilizedcorridors, and eliminating the need for

    reliance on the automobile to meet

    basic daily needs.

    However, even where such sites

    anticipated to remain suburban in f

    in the near term, provisions in the

    use plan and zoning code shoul

    least require improvement over exis

    conditions. For instance, requiring

    site stormwater treatment, particulfor larger scale buildings and l

    parking lots, requiring

    outbuildings to properly front the st

    and to prioritize the pedestr

    establishing a maximum buil

    footprint for big box stores, requi

    a greater mix of uses, such as up

    level office or residential uses, w

    likewise requiring new buildings t

    adaptable for non-retail use given

    regions over abundance of retail sqfootage and the continued shift in r

    patterns nationwide.

    Retail

    Permitting Retail Strips is

    problematic, particularly when

    scattered throughout otherwise

    pedestrian friendly commercial areas.

    Special classification should not be

    given to Retail Districts that

    would permit them to continue to

    ignore the fabric of the city.

    Other major questions arise on the

    place types flagged for sensitive

    waterfront land. The zoning

    designations listed as the Outer Harbor,

    Buffalo River and Scajaquada Creek

    Brownfield Opportunity Areas (BOAs)

    reas should reflect a "Yet to Be

    Determined" designation. Though the

    BOA process is obviously going to be a

    omplex multi-pronged deliberation,

    here is a strong environmental case to

    made retaining these parcels as open

    space. The current designations

    including "light" and "heavy" industrial

    zoning reflected in the published maps

    is prejudicial to an outcome that may

    very well not reflect 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.

    Waterfronts

    The Outer Harbor, Buffa

    River and Scajaquada Cree

    Brownfield Opportuni

    Areas (BOAs) areas shou

    reflect a "Yet to B

    Determined" designation.

    Photo by Kevin Hayes

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    Another missing place type, the C-TM

    Metro Rail) is listed in the corridor

    descriptions (p.19) as an element in the

    and use plan, but is not visible in the

    uture place type maps. Clarity about

    what the existing Metro Rail Corridor

    will mean in the new zoning code and

    oning map is needed. The code also

    hould plan for development along

    proposed corridors such as the route

    rom downtown through the east sideo the airport. Each light rail stop

    hould not just reflect a desire for

    nhanced density in the privately held

    ands, 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

    connectivity of the corridors over time.

    As a whole, as it is currently drafted,

    the Transportation Corridor (C-T) is a

    blunt restrictive classification that

    misses the importance of the synergy

    between the public spaces of our streets

    and the land use types desired. Streets

    are the elements of our city which not

    only connect us but also represent the

    largest component of land in direct

    public control. The land use plan needs

    to have stronger and more specific

    language to facilitate the range of

    transportation options necessary to

    reinforce healthy communities and

    recognize streets as valuable public

    places.

    These designations are exceedi

    important as the City implement

    Complete Streets policy and

    consideration is given to conver

    highways to boulevards to imp

    livability and attract investm

    throughout the city. The design of

    streets must correspond appropria

    to the neighborhood place-based ty

    in accordance with the placed-b

    development strategy as laid out indraft plan. As the future land use

    sets the stage for establishing a

    regulatory framework of the pri

    realm with a place-based developm

    strategy, all transportation corri

    and facilities should be included in

    place-based maps and not lumped

    a single ambiguous category.

    SMART GROWTH... A STARTING POINT...WORK REMAINS TO ENSURE THE RHETORIC OF SMART GROWTH AND THE

    REALITY OF FUTURE DEVELOPMENT ARE INDEED LINKED...

    Corridors and Streets

    It is not just adjacent to our waterways

    hat the highest and best use of a

    property may be non-conventional

    development. In general, vacant land is

    n underutilized asset that is not given

    dequate attention in this draft plan.

    Though the plan expands use and

    development options as an interim

    teps in distressed neighborhoods,

    einterpretation of land use must not be

    imited to communities in distress, nor

    should it be limited temporally. From

    community gardens to tot-lots to new

    civic spaces, using land for community

    amenities not only creates

    neighborhood cohesion, but also often

    increases aggregate land values (and

    thereby property tax) to a higher degree

    than a single new structure would

    contribute. Specific to this point,

    community gardens must be

    recognized as a viable long term use,

    and should be encouraged and/

    designated for each community

    Public Space, below). Best prac

    from other cities set aside sites in

    sub-neighborhood to coincide wi

    specific number of households

    population.

    Vacant Land

    Vacant land is

    underutilized asset that

    not given adequate attentio

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    n addition to the current

    Transportation Corridor (C-T) place

    ypes, Boulevard, Avenue, Streets and

    Alley/Lane need to be recognized

    distinct types of streets and coded as

    uch. Table 1 (attached) should be

    utilized to define all common street

    ypes, which can then be subdivided

    nto specific special street typelassifications, such as Main Street,

    Woonerf, Festival Street (see table 1.1),

    where appropriate. These street types

    provide mobility for all modes of

    ransportation with a greater focus on

    pedestrian, cyclists and transit users. It

    s linked more closely to the adjoining

    and-use and the need to create a safe

    nvironment for all people, rather than

    trictly following the conventional but

    dated application of functional

    classification in determining geometric

    criteria.

    By defining the street types in

    accordance with the adjoining place

    types, a framework for street design

    guidelines will begin to take shape. As

    a preliminary step, many of thetransportation related comments in the

    attached mark-up of the land use plans

    draft principles reflect the need to code

    our streets to reflect and institute

    national best practice guidelines. 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 (attached as appendix).

    Also in the Corridor Place Types

    addition to Greenways (C-TG) a

    place-type, Blueways/Waterways

    TBL) should be included to highl

    the multitude of waterways thro

    the city that are both natural

    capped.

    Current best practices in zoning further than defining corridors

    street design, though, and typic

    incorporates all subdivision and pu

    works standards directly in the zon

    code. Buffalo should join the rank

    cities like Miami and Denver that h

    successfully adopted this model, s

    the regulations that guide developm

    in the city are moving in the direc

    of sustainability and smart growth.

    Streets are the elements of our

    city which not only connect us

    but also represent the largest

    component of land in direct

    public control.

    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.

    Photo by JoelMann Photo by Green Options Buffalo

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    Table 1: Street / Facility Types

    Street Type Description Comment

    Boulevard*(conventionally arterials)

    Traverses and connects districts andneighborhoods within cities; primary a

    longer distance route for all vehiclesincluding transit

    Often has a planted media

    Avenue*(conventionally collectors)

    Traverses and connects districts, linksstreets with boulevards. For all vehiclesincluding transit.

    May or may not have a med

    Street*(conventionally local streets)

    Serves neighborhood, connects toadjoining neighborhoods; serves localfunction for vehicles and transit

    Alley/Lane Link between streets; allows access togarages

    Narrow and without sidewa

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

    Table 1.1: Special Street Types

    Street Type Description Comment

    Main Street Slower vehicle speeds, favors pedestrians

    most, contains the highest level of

    streetscape features, typically dominated by

    retail and other commercial uses

    Functions diferently than oth

    streets in that it is a destinat

    Drive Located between an urbanized neighborhood

    and park or waterway

    Transit Mall The traveled way is for exclusive use by buses

    or trains, typically dominated by retail and

    other commercial uses

    Excellent pedestrian access to

    and along the transit mall is

    critical. Bicycle access may be

    supported.

    Bike Boulevard A through street for bicycles, but short

    distance travel for motor vehicles

    Usually a local street with low

    trac volumes

    Festival Street Contains trac calming, flush curbs, and

    streetscape features that allow for easy

    conversion to public uses such as farmers

    markets and music events

    Shared Space

    (Woonerf)

    Slow, curbless street where pedestrians,

    motor vehicles, and bicyclists share space

    May support caf seating, pla

    areas, and other uses

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    As stated earlier and acknowledged in

    he draft plan (p. 38), the City should

    dopt a policy that every resident

    hould be able to access a designated

    park or greenspace within a quarter-

    mile of where they live. However,

    more definition is needed for what

    ypes of facilities or which delineation

    of Open Space and what acreage or area

    will fulfill this requirement. Upon

    being identified, 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-

    benchmark. However, this may inc

    play streets that limit traffic w

    open land is unavailable. The

    street or woonerf (referenced in

    Corridor section above) is a con

    well established in Europe where s

    streets are designated primarily

    pedestrian use but permit use by

    for access and parking, but

    thoroughfare traffic.

    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 impact

    and synergies. However, it is critical to develop a policy that outlines which of these non-conventional uses i

    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 profile ofthe city, or will it someday become housing to provide sufficient density in the neighborhood to support loca

    services? Each place type designation requires this kind of thoughtful consideration and definition.

    It is critical to develop a policy that outlines which non-

    conventional uses are transitional and which arepermanent.

    Public Space

    Access to Green Space

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    Modifications should also be made to

    he definitions for types of Open Space

    Districts. As referenced in the

    ntroduction to this letter, not all parcels

    an be defined as a single land use or

    place type. All open spaces shouldprovide multiple use opportunities, not

    just one: recreation and habitat,

    tormwater management and sports,

    lean 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

    urrently outlined (p. 18).

    n the Place Based Planning Handbook,he D-OO Olmsted definition should

    emain, yet it should be more explicit

    hat the place and usage types within

    ach park are to be defined by the

    Olmsted Conservancys Plan for the 21st

    Century. The definition of D-OR

    Recreational is appropriate for

    playfields, 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 thistype of gathering space in many

    neighborhoods a situation that should

    be addressed. Likewise the D-ON

    Natural definition 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

    on the east side); D-OP Conserva

    Protected Areas spaces that have

    habitat value and should be prote

    (see Table 2).

    Additionally, many open spaces in

    city are owned by institutions or

    private, and, again because of

    parcel based divisions, this is

    reflected in the current d

    Unfortunately open space is too o

    a term to describe underutilized l

    blank lawns or berms which do

    provide benefits to humans or to

    environment. Policies should go

    the use of undeveloped land, example, within campuses, sc

    grounds or existing office parks, wi

    mix of with regulations and incent

    to provide public access

    accommodations to on-site produc

    open space.

    Open Space Districts

    Open Space District Description Comment

    D-OOOlmsted

    Large, meadow-like parks designed byOlmsted with a primarily passive,pastoral, or picturesque character

    The various place types within theseparks should be explicitly guided bythe Plan for the 21st Century

    D-OIInformal Recreation

    Contemporary public park spaceresembling Olmsted aesthetic orotherwise highlighting Bufalos heritage

    More such parkland should be addedparticularly along the waterfront andon the east side

    D-ORRecreational

    Open space designed to accommodateactive recreational uses, both structuredand informal

    Appropriate for ball fields and courtswithin parks, school facilities, etc.

    D-OCCivic

    A formal space that takes on thecharacter of a civic green of plaza usually

    of small to medium scale.

    Goal should be to introduce more ofthese central gathering places,

    potentially at least one per planningcommunity

    D-OGCommunity Gardens

    Open space designated for communal orplot based ornamental and vegetablegardening

    Appropriate within parks or onpreviously vacant land a targetamount of protected space should bestablished per community

    D-ONNatural

    Naturalized open space or conservationarea with no, or few, active uses asidefrom walking or biking trails

    Walking or biking trails that are partof a broader system should beindicated as places in the Corridortypology

    D-OPConservation/ Protected Area

    Spaces that have high habitat value andshould be protected

    Table 2: Open Space District Revisions

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    n many ways Green Infrastructure

    hould be the primary principle

    underlying the new landuse plan. This

    nverts our usual planning strategy

    because it assumes the city is a network

    of green that provides quality living for

    ll residents, multiple uses of openpaces, a healthy environmental,

    networks of green (such as Olmsted

    Parkways) and productive landscapes.

    Housing, services, and work places are

    hen placed within the green structure,

    ather than having natural areas

    ubsumed by or accommodated within

    he city. Though a new conception, in

    many ways this city in a park concept

    uilds on Olmsteds grand vision.

    For a fundamentally environmentally

    ocused code, the relationship between

    built form and systems in the land use

    plan must adequately address the

    elationship between the green

    nfrastructure and the built form. This

    s consistently absent throughout the

    urrent 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.

    Within this framework it is vital to

    identify and protect existing natural

    resources areas, and it is critical to

    identify areas currently not recognized

    and to protect them as well. Consider

    not only protecting existing waterways,

    for example, but research the possibility

    of daylighting historic waterways such

    as the Scajaquada Creek where it has

    been channelized.Daylighting buried streams would be a

    major step to capturing the

    environmental benefits provided by

    urban waterways, but whenever

    possible habitat should be restored to

    assist in cleaning the water and

    protecting the shoreline. Currently,

    there is a 100 foot setback along

    Buffalo River for habitat protec

    This strategy should be used in o

    places for habitat protection and w

    quality improvement. The goal sh

    be fishable and swimable waters: t

    should be no exceptions to the CWater Act protection for waterw

    even when adjacent landuse

    commercial and industrial.

    Another strategy is considering

    open and green spaces for stormw

    management assistance. That inclu

    existing parks, natural areas, me

    strips, office parks, incentives

    homeowners and so on. Getting

    water into the ground where it falthe most achievable way to av

    overwhelming the sewer system an

    recharge ground water. The

    should continue to work with Bu

    Sewer Authority on the Long T

    Control plan with an emphasis

    green infrastructure.

    Natural Resource Protection and Access

    An environmentally focused code must address the

    relationship between green infrastructure and the built form.

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    E E D I N G T H E C I T Y

    he National Policy & Legal Analysisetwork to Prevent Childhood Obesity

    NPLAN) released Seeding the City: Landse Policies to Promote Urban AgricultureOctober 2011. The guide acknowledges the

    arious types of Urban Agriculture, fromome gardens to community gardens andrban farms. It also promotes the manynefits of Urban Agriculture in the form of

    ealth, environmental Sustainability, andonomic vitality.

    eeding the City establishes goals formprehensive planning including: protecting

    xisting and promoting new urbangriculture in each of its forms, maximizingpportunities to incorporate urbangriculture into new development, and toromote urban agriculture through ongoingrogramming and partnerships. It alsorovides model zoning ordinances across aariety of circumstances and conditions.

    eeding the City is available for download atww.nplanonline.org.

    As noted in our initial letter to the

    administration, important justifications

    for providing clarity for urban

    agriculture include: access to local,

    fresh and healthy food for urbanresidents; 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, experience

    with nature and food production;

    neighborhood development through

    beautification and blight abatement in

    addition to reduced crime throughcommunity 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

    defining the parameters of urban

    agriculture or in ensuring that its role is

    lasting and accessible to all. Whetheror not urban agriculture ever provides

    an economic boon to the city in te

    recognized in GDP-approved metri

    is clear that it improves the econom

    and opportunities for of families

    neighborhoods.

    The land use plan must explicitly al

    for the establishment of urban

    agriculture on public and private

    property by adopting zoning

    regulations that permit home garde

    community gardens, urban husband

    (bees, chickens, fish, etc.) as approp

    to all five neighborhood place types

    must also ensure that urban agricul

    can flourish into an extended growiseason with appropriate guidelines

    the design of greenhouses, hoop

    houses, and the like. Guidelines sho

    include uses, quality design, and

    standards governing safety and

    aesthetics. Sales of produce grown

    public and private land should be

    allowed as a conditional or permitte

    use, with appropriate limitations on

    location, size, and time of operation

    place-types throughout the city.

    Urban Agriculture

    http://www.nplanonline.org/sites/phlpnet.org/files/Urban_Ag_SeedingTheCity_FINAL_20111021.pdfhttp://www.nplanonline.org/sites/phlpnet.org/files/Urban_Ag_SeedingTheCity_FINAL_20111021.pdfhttp://www.nplanonline.org/sites/phlpnet.org/files/Urban_Ag_SeedingTheCity_FINAL_20111021.pdf
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    The most apparent opportunity in the

    Green Code is to affect behavioral

    hanges by encouraging active lifestyles

    argely through improvements to the

    built environment. This includes a host

    of actions to increase physical activity

    mong residents. The creation of safe,ccessible and walkable neighborhoods

    nd routes will facilitate biking and

    walking as attractive active

    ransportation alternatives integrating

    ctivity into daily activities. Creation

    nd proper maintenance of a variety of

    parks, playgrounds, and recreation/

    ommunity centers with seasonally

    ppropriate uses and activities will also

    provide increased opportunities for

    discrete and intentional physical

    activity.

    Healthy living extends, also, to healthy

    eating. Currently, unequal resources

    for and access to quality food areprevalent across the city, and the Green

    Code should employ a variety of

    different strategies appropriate to the

    specific challenges and opportunities in

    each community. The Green Code can

    afford residents greater opportunity to

    obtain healthy, affordable, and

    culturally appropriate food in their own

    neighborhood through production by

    allowing land access for commu

    gardens and urban agriculture a

    variety of scales and thro

    distribution by facilitating f

    stands, markets, and healthy co

    store initiatives. In the same way

    the current zoning code restconflicting or potentially harmful

    (such as liquor stores) with a defi

    radius of schools, the land use c

    should also designate zones of the

    that restrict development of unhea

    food options such as fast

    restaurants.

    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 an

    behaviors that the design and siting of buildings and public works create. Reversing the detrimental effects o

    policies favoring auto-centric and use-separated zoning remains a key goal of WNYEA for the Green Code.

    The Green Code can address public health by facilitating both

    behavioral and environmental changes.

    Public Health

    Healthy Lifestyles

    The Green Code can provide the opportunity for all communities to be healthy now and in the future by lessening hea

    nequity. The acknowledgement of the Green Codes role in public health in the principles section of the land use plan

    40) is welcomed, but the section as written is underdeveloped and does not address the full complement of possi

    nitiatives and regulations that should be codified to improve wellness within the city. The code can address public hea

    by facilitating both behavioral and environmental changes.

    Photo b Michael Clarke

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    Though many of the elements of

    reating a safe public environment will

    be delineated in the zoning code rather

    han the land use code, it is important

    o reinforce the notion that safety is in

    arge measure defined by place. A

    place that feels safe will be a welcoming

    nd therefore active space creating, inffect, a self-fulfilling cycle of

    perception and reality. But the

    orollary is also true. A place that is

    designed poorly will feel unsafe, and

    hus become unwelcoming, unused,

    nd, thereby, unsafe. This applies from

    treets to parks to apartment

    omplexes. It applies in

    neighborhoods, districts and corridors.

    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 crimeprevention through environmental

    design should be included in the land

    use plan: natural surveillance (eyes on

    the street), access control (privacy

    gradients and defined entries), image

    (proper maintenance/ broken windows

    theory), and territoriality (clearly

    defining public/ private space).

    SMART GROWTH... A STARTING POINT...WORK REMAINS TO ENSURE THE RHETORIC OF SMART GROWTH AND THE

    REALITY OF FUTURE DEVELOPMENT ARE INDEED LINKED...

    Behavior change will help contribute to

    ncreased health outcomes, but, when it

    omes to public health, the impact of

    mbient environmental factors cannot

    be overlooked. Pollution from the

    egions industrial legacy, from freight

    nd high volume commuter traffic, and

    rom our persistent combined sewer

    overflow issues disproportionally

    mpacts low-income communities of

    olor. As stressed in the Environmental

    Justice section above, the Green Code

    needs to go farther in identifying and

    liminating environmental burdens on

    communities. Air, water, and soil

    quality should be analyzed throughout

    the city and the presence of raised

    levels of toxicity in or adjacent to

    neighborhoods should add additional

    levels of scrutiny for adjoining land

    uses and place types while providing a

    blueprint for addressing these harmful

    elements.

    The Green Code also needs to consider

    ongoing demographic shifts and what

    kind of accommodations will need to be

    made for an older population. These

    considerations apply not just to the

    burdens placed on or lifted

    individuals, but also to the demand

    our social service sector. For insta

    though accessibility is referenced

    street design and in place

    adjacency, this needs to extend

    buildings as well. Though

    provides regulations for public spa

    it is important, too, to integ

    visitablity as a minimum componen

    accommodation within

    development and retrofitting of pri

    spaces as well.

    Safe Environments

    Places that are designed we

    promote public s

    Places that are poordesigned quickly becom

    unsafe.

    Public Safety

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    5 Draft Land Use Plan Com

    stated in our original letter, Buffalo

    nnot achieve sustainable

    mmunities without sustainable

    mployment. The inclusion of Retail

    stricts as a future place type (see

    mart Growth above) is one suchample where the draft land use plan

    ls to reduce logistical barriers to

    mployment (i.e., time and expense of

    nsportation and childcare) and

    rpetuates reliance on private

    tomobiles for accessing daily needs.

    egrating economic development and

    mmunity development means

    egrating and erasing the lines

    etween where those activities were

    couraged in the previous zoningde.

    e plans goals to enhance connections

    etween the Central Business District

    d adjacent neighborhoods (Section

    ) is a good start, but can be improved

    d broadened. However, inclusion of

    her districts requires establishing

    onnections rather than the mixed-

    e ideal of full integration instead of

    ngle use zones. The language that

    dresses medical and educationalstricts is telling (Section 2.1) in that it

    ely focuses on mitigating conflicts

    her than addressing shared benefit.

    long as these types of us vs. them

    chotomies are allowed (or regulated)

    persist, conflict will be the dominant

    der of the relationship and we will be

    ever relegated to settling for

    acticing mitigation and

    establishing connections. The plan

    needs to go much further in this regard.

    The draft plan furthers this otherness of

    community and economy by placing an

    emphasis on the expansion of office and

    industrial parks (Section 3.1). Yet thesesites tend to yield disappointing

    employment densities even at full

    build-out. They are almost always

    caught in the car-dependent trap that

    plagues Retail Districts and

    disadvantage low-income households

    through their inaccessibility via public

    transit, walking, or cycling from

    neighborhoods.

    The Larkin District revitalization,however, provides a more sustainable

    and urban means of building on

    Buffalos heritage to provide new

    opportunities for commercial and light

    industrial development that

    strengthens existing communities. This

    means of redevelopment should be

    prioritized and the "Belt

    Line" (referenced in Section 3.2 in the

    draft plan), where many of Buffalos

    large scale structures are positioned,provides a framework for linking these

    secondary centers together in the future

    and to neighborhoods today. Reusing

    former industrial structures along the

    Belt Line for environmentally-friendly,

    mixed-use redevelopment is likely to

    yield stronger results than the

    conventional greenfield style economic

    development which has unfortunately

    provided the model for much

    Buffalos Brownfield redevelopme

    strategy. Focusing on the existi

    infrastructure along the Belt Line as

    preservation and reuse strategy is mo

    sustainable and less resource-intensiapproach to growing jobs in Buffalo.

    should be given priority in the pl

    over office and light industrial parks

    The Belt Line provides a speci

    example of how valuable the existi

    rights of way are and can becom

    Preserving rights of way for linkag

    between communities and econo

    opportunity should be a priority. Th

    should not be turned over to privaownership or private development.

    Another plank of the histo

    transportation network on whi

    Buffalo thrived and requir

    revitalization is the Ellicott grid a

    radial network. Though referenced

    the plan (Section 10.3), this reference

    insufficient on its own. The restorati

    of this network including streets li

    Genesee, Busti, the Terrace, and

    should be visible in the future platype maps and reserved for restorati

    in the future zoning code and zoni

    map. A detailed plan for the restorati

    of lost neighborhoods, like the Itali

    Colony referenced in the plan, shou

    be focal points for rebui

    downtown and fostering strong

    connections to adjacent neighborhood

    conomic Integration

    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

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    Board of DirectorsBob 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

    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

    he Citys Planning Day in October underscores the fact that the

    public is, and has a desire to remain, engaged in this process. However,

    here are elements in the plan that are underrepresented and the City

    hould strongly consider formation of targeted issue advisory or focus

    groups such as environmental justice, vacant land reclamation and

    einterpretation, youth and educational facilities, and green energy to

    ugment the ongoing process.

    n addition, the public meetings still to come need to do a better job of

    ccommodating families and children. Successful expanded

    ngagement techniques make it easier for those who want to come to

    raditional meetings by providing childrens activities, and even bus

    are wherever possible. WNYEA member organizations have heard

    rom 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

    ncrease in costs, in relation to the project scope, the benefits of a better

    process are well worth the minimal expense.

    As the plan notes, early in Buffalos

    development the Citys energy

    ourcechanged almost from decade

    o decade horse power, water power,

    oal and steam, hydroelectric(p.4).

    This draft has begun to establishprinciples that do, in fact, anticipate the

    caling up of existing green technology

    while paving the way for Buffalo to

    build on our legacy of energy

    nnovation to become a hub for new

    lean energy in the future. Particularly

    s fresh water becomes more precious,

    Buffalo will be well positioned for

    etaining and attracting residents if it

    an also craft an energy independent

    future as carbon based fuels likewise

    become more rare and expensive.

    In addition to considering energy

    conservation (p.20) the plan is right to

    look to energy production as well. TheGreen Code should employ as many

    tools as possible within zoning

    regulations to incentivize energy

    conservation (energy smart

    mechanicals and increased insulation),

    clean on site production (i.e.

    geothermal, active and passive solar,

    small scale wind) in addition to

    environmentally sensitive building

    methods in new construction, changes

    of use, and substantial renovations. As

    noted in our initial letter, a sepa

    City initiative will need to focus o

    those remedies that heal the exis

    city by creating a suite

    accompanying policies and prac

    that align municipal operations capital investment with the intent o

    new code. A large component of

    companion policy would need

    incentivize existing buildings and

    to comply with the spirit of the c

    Ideally the ongoing planning pro

    for land use and zoning review

    produce recommendations for this

    aspect as well.

    Clean Energy

    Public Engagement

    Photo by TonyDude919 on Flickr

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    Economy

    1Reinforcedowntownasaregionalhub.

    1.1Activatethedowntowncore.

    1.2EnhanceconnectionsbetweentheCBDand

    adjacentneighborhoods.

    1.3Reintroduceahighqualitypublicrealm.

    2Supporttheemergingknowledge

    economy.

    2.1Supportthegrowthofregionaleducational

    andmedicalanchors.

    2.2Embraceartsandcultureaseconomic

    drivers.

    2.3ImprovethevisitorexperienceinBuffalo.

    3Growemploymentcenters.

    3.1Facilitateofficeandindustrialpark

    development.

    3.2Facilitatemixed-useredevelopmentalong

    theBeltLine.

    3.3Supportaworkingwaterfront.

    3.4Devoteresourcestowardbrownfieldand

    greyfieldreclamation.

    3.5Promoteandfacilitateentrepreneurship,

    homebasedbusinessandgreenenergy

    innovation

    4Increaseretailactivity.

    4.31Supportneighborhoodretailersand

    entrepreneurs.

    4.2Reintegrateretailwiththeurban

    environment

    4.1Facilitatedevelopmentofretailcenters.

    4.2Identifyappropriatesitestoclusterretail

    stripdevelopment.

    5Optimizeaccessandcirculation.

    5.1ReinforceMetroRailridership.

    5.2Supportefficientmovementofgoods.

    5.3ConnectwithCanada.

    Neighborhoods

    6Reinforcewalkableneighborhoods.

    6.1Supporteffortstorevitalizeneighborhood

    centers.

    6.2Buildonexistingneighborhoodstrengths.

    6.3Capitalizeonneighborhoodassets.

    6.4Maximizehousingchoiceandaffordability.

    6.5Establishinterimalternativeusesand

    improvemanagementpracticesforvacantland.

    6.6Increasepublicsafetythrougheffective

    urbandesign

    7Improvetransportationoptions.

    7.1Improvestreetdesign.

    7.2Encouragewalkingandcycling.

    7.3Promotetransportationalternatives.

    Environment

    8Enhancenaturalresources.

    8.1Protectandrestoresensitivehabitats.

    8.2Enhanceriparianenvironments.

    9Reinvigoratepublichealth.

    9.1Promotehealthyandsustainable

    environments

    9.21Promoteactiveliving.

    9.32CreateahealthylocalfoodsystemEnable

    healthyfoodproductionanddistribution.

    10Preservenatural,cultural,andhistoric

    resources.

    10.1Protectandenhanceopenspaces.

    10.2Supportwaterfrontaccessandusage.

    10.3Preserveculturalandhistoricresources.

    Implementation

    FuturePlaceTypeMaps-General

    Principles

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    Economy

    Planningforasustainableeconomymeanshelpingensurethatbothcurrentandfuture

    businessesareabletosuccessfullyoperateandgrow.Theplanaimstopromoteplace-

    based economic development by targetingdowntown investments, fortifying employ-

    ment centers, reclaiming brownfields, and improving accessibility, capitalizing on our

    potentialforgreenenergyproduction,andpromotingentrepreneurshipinachanging

    economy.

    The principles support downtown as a regional center by introducing strategies to

    reinforceitsdensity,accessibility,compactform,andrangeofuses.Theplanwillhelp

    diversifythecitysemploymentbasebysupportingemergingindustriesthatneedplaces

    togrow.ItwilldefinetheknowledgecorridorthatstretchesalongMainStreetfrom

    theUniversityofBuffalototheheartofdowntown,andhelpcapturethecitysshareof

    consumerandvisitordollars.

    Convenientshoppingis anamenityforvisitors,a necessityforresidents,ananchorfor

    neighborhoods, and an economic benefit to the citys economy. The recognizedprinciples encourage mixed-use centers in every neighborhood, and protect the

    intimateandpedestrian-orientedcharacter,andallowforthetransitionofconventional

    suburbanarterialsto mixed-usecenterswhereappropriate.Theplanalsoattemptsto

    reintegrate locatesadditional destinationretail whereitispossibletoclusterbigbox

    developmentintothefabricofthecity.

    Theplananditsprincipleswillhelpmaintainthecitysemploymentbase.Itsupports

    developmentofemploymentcenters,suchasthosealongtheBeltLine.Theplanalso

    reinforcesongoingworktoreclaimindustriallandinBrownfieldOpportunityAreasin

    SouthBuffalo,BlackRock,theEastSide,andtheInnerandOuterHarbors.

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    1Reinforcedowntownasaregionalhub.

    1.1Activatethedowntowncore.

    Permitthefullrangeofuses,suchasoffice,residential,hospitality,civic,retail,

    andentertainment,toactivatethestreetsofdowntown.

    AcceleratedevelopmentofemergingneighborhoodclusterswithintheCentralBusinessDistricttocreateamixed-use,24/7downtown.

    Encouragecentralizationofregionallysignificantgovernmentfacilitiesto

    downtownBuffalo.

    SupportthecontinuedgrowthandintensificationoftheBuffaloNiagaraMedical

    CampusandtheUniversityatBuffalosDowntownCampus.

    FocusstructuresofthegreatestheightandintensityneartheMainStreetTransit

    Mall.

    Supportregionaldevelopmentpoliciesthatattractresidentsandemployersback

    totransit-servicedlocationsoftheurbancore. Encouragegreenbuildingtechnologies(includingon-sitestormwater

    management)thatcanbolsterdowntownsimageandattractinnovative

    businesses.

    Re-establishandRestoreJosephEllicottsoriginalstreetgridpatternintheCentralBusinessDistrictandwithinurbanrenewalareas(I.e.TheWaterfrontUrban

    RenewalProject)

    Restoreallone-waystreetstotwo-way1.2EnhanceconnectionsbetweentheCBDandadjacentneighborhoodsandbeyond.

    Enhancelinearconnectionstoadjoiningneighborhoodswithpedestrian-oriented

    frontagesandmulti-modalaccommodationsalongradialssuchasErie,Niagara,

    Delaware,Main,Genesee,Broadway,andSeneca. ReducethenegativeimpactofstreetsthatserveasbarriersbetweentheCBDand

    adjacentneighborhoods,suchastheElm/Oakarterials,SouthElmwood,Tupper

    andGoodell.

    Supportenhancedmulti-modaltransportationconnectionsbetweentheCBD

    andadjacentneighborhoodswhereverpossible.

    Encouragemid-riseredevelopmentwithinthedowntownedgetoprovideap-propriatetransitionsinscalefromtheCBDtoadjoiningneighborhoods.ImproveconnectivitybetweentheInnerHarbor/ErieBasinMarinaandthe

    Downtowncoreunderthe190(short-term);throughahighcapacityBoulevard

    (longterm).1.3Reintroduceahighqualitypublicrealm.

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    Downtownshouldbegreenandwelcomingwithampleprovisionoftrees/

    vegetation,plantedmedians,andnaturalstormwatermanagement.

    EstablishastreetgridwithintheCBDwherepedestrian-orientedfrontageswillbealignedandmulti-modalaccommodationsprovided.

    Prioritizeroaddietinitiativesondowntownstreetstoproperlyallocatespaceformotorvehicles,cyclists,andpedestriansandgreeninfrastructure.

    Reestablishtwo-waytrafficonstreetsthatarecurrentlyone-way.

    AvoidnewsurfaceparkinglotswithintheCBDcore;allowingdevelopmentof

    structuredparkingthatmeetsdesign,mixed-use,andenvironmentalstandards.

    LimitProhibitskywalksandtunnelsthatdivertpedestriantrafficfromsidewalks.

    CompletetheCarsSharingMainStreetProjectwhilepreservingrapid-transit

    prioritization,accessandqualityofservice.

    ContinueimprovingNiagaraSquareandotherpublicsquaresandgreenspaces

    intoamorebeautiful,clean,comfortable,andpedestrian-friendlypublic

    spaceplaces.

    2Supporttheemergingknowledgeeconomy.

    2.1Supportthegrowthofregionaleducationalandmedicalanchors.

    Encouragemulti-buildingeducationalandmedicalinstitutionstoestablishor

    updatecampusplanstofacilitatedevelopmentthatintegrateswith

    neighborhoodswiththebenefitofpublicinput.

    Inconsultationwithsurroundingresidentialneighborhoods,developstrategiesthataddresstownandgownconflictsandprovidejointbenefits.

    2.2Embraceartsandcultureaseconomicdrivers.

    RecognizeculturaltourismusessuchastheMartinHouseComplex,Richardson

    OlmstedCenter,andtheTheatreDistrict,MuseumDistrict,andMichiganStreet

    BaptistChurch.

    Supportpublicartinstallationsinstrategiclocationsincludingstreetscapes.

    2.3ImprovethevisitorexperienceinBuffalo.

    Facilitatethedevelopmentofvisitoraccommodations,includinghotels,inns,hostels,andbed-and-breakfasts,inappropriateplacesacrossthecity.

    DevelopImplementstrategiesforimprovingtheappearanceoffirstimpression

    corridorsandentrypointsintothecity.

    SupportErieCanalHarborDevelopmentCorporationseffortstorReestablishthe

    historicstreetgridandcanalnetworkofdowntownandCanalside.

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    SupportCreateimprovedtransitconnectionstotheBuffaloNiagaraInternational

    Airport.

    WorkwithAmtrakonanimproveddowntowntrainstation.

    SupportNFTAplansforimprovementstotheMetropolitanTransportation

    Center.

    3Growemploymentcenters.

    3.1Facilitateofficecommercialandindustrialparkdevelopment.

    ReserveEnsureavailablelandforeconomicdevelopmentofficecampusesand

    industrialuses,encouragingthataresuchenvironmentstodevelopedinanurban

    characterandintegratedintoneighborhoodswherepossible.

    Accelerateprovisionofreuse-readystructuresandfacilitateexistingvacantland

    forshovel-readylanduseswhereappropriateandreuse-readystructures.

    Capitalizeuponhighway,rail,andPeaceBridgemultimodalaccesspointsfor

    cargo-orienteddevelopment,whileensuringneighborhoodsarenotnegatively

    impactedfromfreightactivity.

    Minimizeconflictbetweenemploymentdistrictsandresidentialneighborhoods

    throughappropriateedgeedgeform,scaleanduse,notthroughsuburban

    treatmentsanddesignssuchasgrassyberms.

    3.2Facilitatemixed-useredevelopmentalongtheBeltLine.

    Continuetoactupontheeconomicpotentialofexistingandemergingemploy-

    mentcenters,suchastheLarkinDistrict,Tri-Main,andNorthland.Permitthewidestrangeofadaptivereuseoptions,includingoffice,residential,

    andlightindustrial,tofacilitatereinvigoration.

    IntegrateadjacentneighborhoodcentersintoBeltLineemploymentareas.

    SupportEstablishongoingserviceimprovementsandthedevelopmentofto

    transitroutesthatconnecttoBeltLineemploymentcenters.

    3.3Supportaworkingwaterfront.

    Protectmarinecommercialandwater-dependentandenhancedindustrialuses

    whichdonotdegradetheenvironmentorimpactneighborhoodsinthezoning

    code.

    Facilitaterepurposingofvacantwaterfrontlandandstructuresforemployment

    usesthroughongoingbrownfieldsplanningandheritagepreservationefforts.

    IncorporategreeninfrastructureintoallstreetscapeprojectstoreduceCSOsandestablishahealthymarineecosystemtosupportwater-dependentuses.

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    3.4Devoteresourcestowardbrownfieldandgreyfieldreclamation.

    IncorporateplanningeffortstoreclaimbrownfieldsacrossthecitythroughNew

    YorkStatesBrownfieldOpportunityAreas(BOA)Program.

    Activelyseekoutdevelopmentsolutionsforunderperformingretailsites,suchas

    CentralParkPlaza.Supportinfrastructureinvestmentsthatreintegratebrownfieldsandgreyfields

    backintotheregionaleconomywhileenhancingandreinforcingurbancharacter.

    Prioritizebrownfieldredevelopmentwithinneighborhoods,bothtoeliminatehealthrisksandprovideaccessibleemploymentopportunitieswithincommunities.

    3.5Promoteandfacilitateentrepreneurship,homebasedbusinessesandgreenenergy

    innovation

    Permitnon-noxious,non-nuisancestartupsandbusinessesinallareasofthecityregardlessofbuildingtype.

    Allowforgrowthofurbanagricultureandfoodrelatedindustriesinavarietyofsettingsandapplications

    Promoteandincentivizesharedcommercialtenanciesaswellasretail/productionspaces,particularlyalongcommercialstripsandurbancenters

    Permitandencouragethedevelopmentofcleanenergyonavarietyofscales,bothforon-siteuseandforcommercialization,includingdistrictandgeothermal

    heating,solar,wind,andagri-fueltechnologywhereappropriate.

    4Increaseretailactivity.4.31Supportneighborhoodretailersandentrepreneurs.

    ActivelyEencourageandincentivizewalkableretaildevelopmentin

    neighborhoodcenters.

    Establishlegalclarityforcornershopsandsmall-scaleretailuses(suchas)in

    residentialareasneighborhoodplacetypesneighborhoodplacetypes.

    Developtransparentandpredictableregulationsformobilefoodvendors,

    includingfoodtrucks,wagons,bikes,andcarts.

    4.12ReintegrateretailwiththeurbanenvironmentFacilitatedevelopmentofretail

    centers.

    Reservesitesforretailcentersinappropriatelocations.

    Establishguidelinesforretailcentersthatprovideforthesafetyandcomfortof

    pedestrians,cyclists,transitusers,andmotoristsalike.

    Establishedgetreatmentguidelinesforretailcentersthatallowforappropriate

    transitionstoadjacentneighborhoods.

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    Mitigatetheenvironmentalimpactsofexistingcar-dominatedretailcentersby

    connectingtomulti-modaltransportationoptionsanddeployinggreen

    infrastructuresolutions;restrictthedevelopmentofauto-orientedretailcentersin

    thefutureers;restrictthedevelopmentofauto-orientedretailcentersinthe

    future..

    4.2Identifyappropriatesitestoclusterretailstripdevelopment.

    Prohibitretailstripdevelopmentthatisoutofcharacterandformwith

    traditionalurbanism.Focusretailstripdevelopmentontheoutskirtsof

    neighborhoods.

    Targetlocationsalonghigh-volumearterials;proximatetohighwayaccess

    points;industrialsitesnolongermarketablefortheiroriginalpurpose;and

    adjacenttoestablishedretailcenters.

    5Optimizeaccessandcirculation.

    5.1ReinforceMetroRailridership.

    CreategreatplacesatMetroRailstationareasbyemphasizingmixed-use,high-

    densityneighborhoodcenters.

    Prioritizetrafficcalmingandwalkabilityimprovementsthatwouldhelphu-

    manizeandactivateMainStreet.

    Pursueeffortstoprovidepublicsafetythroughenvironmentaldesign.StriveforthemaximumpopulationandemploymentdensitiesnearMetroRail

    stations.

    SupportfurtherstudyofMetroRailexpansionalternativesandencouragethe

    developmentoflightrailreadyneighborhoodsalongtheseroutes.

    Thelightrailsystemshouldbeexpandedtoprovidebetteraccesstoresidentswithstopslocatedwithina14mileofallresidentialandcommercialparcels.

    Enhancepedestrianfacilitieswithinaone(1)mileradiusofalltransitstations. Enhancebicyclefacilitieswithinathree(3)mileradiusofalltransitstations.

    5.2Supportefficientmovementofgoods.

    Protectcorridorsforrailandwaterfreighttransportation.

    Supportinfrastructureimprovementsthatincreasefreightmovementefficien-

    ciesandreducecarbonemissions.

    Reviewdesignatedtruckroutestoensureconsistencywithbotheconomic

    development,andneighborhoodstabilityandenvironmentaljusticeobjectives.

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    Protectstrategicexcessroadway,rail,aircargo,andportcapacitytoattract

    economicdevelopment.

    5.3ConnectwithCanada.

    PromotetheInternationalRailwayBridgeasacross-borderfreightconnection.

    Supporteffortstoimprovepassenger-orientedtrafficflowtraveloverthePeaceBridge,tocapitalizeonthegrowingknowledgeandleisureeconomyindowntown

    BuffaloandtheBuffaloNiagaraMedicalCampus.

    ReducetheenvironmentalhealthburdensofinternationalfreightontheWestSidewhileminimizingtheimpactsonrestoringFrontParkandsurrounding

    neighborhoods.

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    GREEN DEVELOPMENT IN DISTRESSED NEIGHB ORHOODS

    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 situat ion i s particularly

    apparent in the Broadway- Fillmore neighborhood.

    Vacant land created by abandonment can become an asset. The pending zon ing ordinance wi ll allow the land to be used for its

    potential to:

    employ local residen ts in activit ies 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 city s stormwater problems.

    Even left as green space, the land ho lds va lue given it s 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 transit ional or temporary spaces and must also protect the traditional development patterns in these

    neighb orhoods for future housi ng 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.

    Neighborhoods

    Planningforsustainableneighborhoodsmeanspreservingthecharacterofneighborhoodswhile

    encouraging redevelopment consistent with the prevailing pattern. The plan identifies five

    majorneighborhoodtypesthathavebeenidentifiedbasedontheircharacter,form,andmixof

    uses.

    The principles encourage integrated mixed-use development at thecenter of neighborhoods.

    Neighborhood centers provide important services to residents and create a greater sense of

    place.Theplanidentifiesamixed-usecenterineveryneighborhoodwhereonealreadyexists

    orwhereonemightbedevelopedtopromotepedestriansafety,comfort,andinterest.

    Highqualitypublicspaceisvitaltocommunitycohesion,yetmanyneighborhoodsofthecityare

    deficientpresentingasituationthatneedstoberemedied.Greeninfrastructurefromstreet

    treestostormwater managinglandscapetreatment isalsoa crucialcomponentofqualityof

    lifeoneveryblockofthecity.

    Theplanwillexpanduseanddevelopmentoptions ,particularlyindistressedneighborhoods.It

    isimportantthatvacant land ismanagedcreatively, keeping itin activeorpassive usesinthe

    short term, and making the most of its development potential over the longer term whereappropriatetopromoteincreaseddensityandregeneration.WhereWherevacancyexistsareas

    arepredominantly vacant, the plan will allow transitionalusessuchas community gardening,

    side and back lot programs, or urban agriculatureagriculture and also acknowledges the

    appropriateness oftheseuses insome ofthe Citysparks. In environmentallysensitiveareas

    andin some heavily distressed communities itmay beappropriate to pursue a naturalization

    program which creates amenities for residents while providing valuable ecological services.,

    whilekeepingopenlonger-termoptionsforredevelopment.

    Instrongneighborhoodsoroneswherevacanciesarelesssevere, communityspaceneedswill

    beaccommodatedandinfillprogramsopportunitieswillbefacilitated.Wheresuperblocksare

    intransitionplaceswherethestreetpatternhasbeendisruptedtocreatedistrictorcampus-

    likeareastheplanwillallowredevelopmentconsistentwithanadjacentneighborhoodto

    reconnectwiththecity-widestreetpatternonceagain.

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    6Reinforcewalkableneighborhoods.

    6.1Supporteffortstorevitalizeneighborhoodcenters.

    Identifythemixed-use,walkableneighborhoodcentersfrommajorcenters

    suchasSeneca/CazenoviaandJefferson/Utica,topedestrianpocketsorfour-

    cornerssuchasClinton/BaitzandFivePointsandtargettheirregenerationasfocalpointsfordailylife.

    Prioritizerevitalizationeffortswithinneighborhoodcenterslocatedontransit

    routeswithstrongmarketpotentialandstakeholdercommitment.

    Coordinatetransitplanningwitheffortstorebuildneighborhoodcenters.

    Rebuildweakmarketneighborhoodcentersthroughfocusedinfillandreha-

    bilitationwithinthepedestrianshed.

    Safeguardtheeconomicpotentialofneighborhoodcenterswithzoningprovi-

    sionsthatprotecttheirintimate,pedestrian-orientedcharacter.

    Removerestrictiveregulatorybarrierswhileencouragingandproviding

    incentivesfornewtosmart,compactdevelopment;Encourageandprovide

    incentivesfornewsmart,compactdevelopment.

    6.2Buildonexistingneighborhoodstrengths.

    Identifyandsupporttheformandcharacterelementsoftraditionalneighbor-

    hoodsaccordingtoBuffalosdistincturbantransect.

    Reinforcethedistinctiverolesofneighborhoodcenters,whereeconomicand

    socialactivityisconcentrated;andneighborhoodedges,intendedasplacesofless

    intenseactivity.

    Recognizetheroleofneighborhoodsinprovidingabalancedmixofshopping,

    work,schooling,recreation,andalltypesofhousing.

    Reinforceandenhancetraditionalnetworksofstraightstreetsandshortblocks

    thatprovideequallyforpedestrians,bicycles,andautomobiles.

    Locateanddesigncivicbuildingstopromotetheirpublicstatusonprominent,

    visible,andaccessiblesites,includingimportantstreetintersectionsandsitesthat

    terminateastreetvieworfaceanimportantnaturalorculturalfeature.

    IntroduceregulatorytoolstoprotectBuffalosexistinganddesiredneighbor-

    hoodcharacter,includingguidelinesonbuildingtype,height,disposition,visual

    andfunctionalpermeability,parking,signs,landscaping,andancillarystructures.

    Supportthecreation,rehabilitationandmaintenanceofgreenwaysandtrails,parks,playgroundsandrecreationfacilitiessothatallresidentialareasintheCity

    ofBuffalohaveaccesswithina1/4miledistanceoftheirhomes.

    6.3Capitalizeonneighborhoodassets.

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    Focusinfilldevelopmentandpromoteproductiveusesnearexistingwalkable

    neighborhoodcentersandcivicspaces,schools,communitycenters,andsenior

    centerstorecognizetheirvalueascommunityhubs.

    Focuspublicrealmimprovementswithinwalkingdistanceofreconstructed

    schools,particularlythosethatincreasethesafetyandcomfortofchildrenwalking

    andcyclingtoschoolfollowingtheSafeRoutestoSchoolModel.

    PermitPursueproductiveneighborhoodsensitivereusesofhistoricschool

    buildingsscheduledtoclose.

    BuilduponneighborhoodplanningeffortssuchastheLarkinDistrictPlan,Al-

    lentownNeighborhoodStrategy,andFruitBeltNeighborhoodStrategy.

    Assessexistingvacant,abandonedandleftoveropenspacesaspotentialassets.6.4Maximizehousingchoiceandaffordability.

    Allowhousingtypesofeveryvarietyintheirappropriatelocations,takinginto

    specialconsiderationtheneedsoftheelderly,children,andthemobility-impaired.

    Removebarrierstohousingaffordability,suchasrestrictionsongrannyflats,

    minimumparkingrequirements,excessivelotareastandards,andlimitson

    multifamilyhousing.

    Focusaffordablehousinginitiativesaroundprioritytransitroutestofoster

    combinedhousingandtransportationsavings.

    Reintegratesuperblockdevelopmentsbackintoneighborhoods.

    Establishlegalclarityforhome-basedbusinessesandworkshops.

    Establishlegalclarityforresidentialrenewableenergysystems,suchassmallwind,solarthermal/photovoltaic,anddistrictgeothermalsystems.

    6.5Establishinterimalternativealternativeusesandimprovemanagementpractices

    forvacantland.

    SupportPrioritizetheuseofvacantlandtoexpandparks,recreation,gardens,

    andhabitatareas,andotherinnovativeuses.

    Developatypologyofinterimreusestrategiesforvacantland,includingcorner

    gateways,cut-throughs,multipleparcelconnections,splitlotgreening,andrain

    gardens,amongothers.Establishcriteriaforwhichusesandwhichspacesare

    transitionalusesandwhicharepermanentlandusechanges.

    Permitandpromoteandpromotethedevelopmentofcommunitygardenson

    publiclands,withlandscapingandbeauticiationbeautificationstandardsthat

    ensurecommunitybenefit.

    WorkwithcommunityorganizationstoAllowdeveloppilotprojectsfor

    aesthetically-pleasingandenvironmentallybeneficialconstructedwetlands,forest

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    reserves,municipalorchards,andurbanagriculturewithinhigh-vacancyblocksto

    reduceCitymaintenanceexpenses.

    Minimizeregulatorybarrierstoadaptivereuseofvacantpropertiestoprevent

    blightandabandonment.

    ContinueintegratingtheCitysdatasystemsintoasinglepointofentryasaprecursortoaBuffaloNiagaraPropertyIntelligenceNetworkforanticipatingandreactingtoneighborhoodtrendsandspecificpropertyinterventions.

    EstablishalandbankunderNewYorkStatesenablinglegislationthatconsolidatesvacantpropertyacquisition,management,anddispositionwithinasingleentity.

    Revampcitypolicysothatallvacantparcelsandpropertiesareacquiredwithinthelandbank.Implementaclearandrigorousclassificationsystemtodetermine

    whichareappropriateforshorttermredevelopmentandwhichareappropriate

    forotheruses.

    Createacleanandgreenstrategywhichemployslocalresidentsthroughnon-profitpartnerstobeautifyandmaintainvacantlots.

    6.6Increasepublicsafetythrougheffectiveurbandesign.

    Incorporatestrategiesfortheinclusionofeyesonthestreetthrough

    mandatoryfenestrationcoverage,regulationsonfenceheightsandtypes,and

    othermeansofvisualsurveillanceofpublicandsemi-publicspace.

    Provideguidanceforthedesignofspacesandbuildingstocreateperceptibleand

    clearlydelineatedgradientsandaccesspointsbetweenpublicandprivaterealms.

    StrictlyenforcemaintenancestandardsandbuildingcodesMandatetheincorporationofsymbolicbarriersindicativeofdefensiblespace,

    particularlyincampusandlargerinstitutionalsettings

    7Improvetransportationoptions

    7.1Improvestreetdesign.

    Codethestreetsidentifyingallcorridorplacetypesbyadoptingthe:TheCompleteStreetsThoroughfareAssemblies,Transit-OrientedDevelopmentandBicycling

    ModulesintheSmartCode,whichcanbeaccessedhere:

    http://www.transect.org/modules.html

    Developacompletestreetsdesignmanualandspecificationsbaseduponthestreetcodestoensurethatinallroadwayfacilityupgrades,includinglane-marking

    contracts,allappropriatebicycleandpedestrianfacilitiesaswellasstormwater

    managementmitigationareincludedasamatterofcourse.

    CodeBuffalosexistingoverbuilthighwayinfrastructuretobeginthediscussionofupgradingourhighwaystopedestrian-friendly,bikeable,high-capacityurban

    boulevardsthatreconnectstotheJosephEllicottradialstreetgridpattern.

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    IncorporatebyreferencetheNationalAssociationofCityTransportationOfficials'UrbanBikewayDesignGuide(2010)astheimplementationguideforthe

    City'sCompleteStreetsPolicy.

    Mapaconceptualframeworkforthefullbuild-outofaBuffalobicyclefacilitynetwork,includingasystemofon-streetbicyclelanesandcycle-tracksaswellas

    off-streetpaths(includingrailstotrails).Establishcitypolicytoincludethe

    developmentandmaintenanceofaminimumoften(10)milesofbicyclefacilities

    annually.

    IncorporatebyreferencetheInstituteforTransportationEngineersDesigningWalkableUrbanThoroughfares:AContextSensitiveApproach(2010)astheguide

    forthedesignofnewandreconstructedstreetsinBuffalosneighborhood

    contexts.

    Mapaconceptualframeworkfortheimplementationofwalkableurbanthoroughfareimprovementsinfocusedareasovertime.Adoptatargeted

    approachforstreetscapebeautificationandright-sizingofBuffalosprioritymixed-useneighborhoodcenters,takingintoaccounttheneedtodeploylimited

    resourcestositesthatwillgeneratehighreturnsoninvestment.Establishcity

    policytoincludethemaintenanceandrepairofaminimumoften(10)milesof

    pedestrianfacilitiesannually.

    Identifycandidatesforroaddietstrategiesacrossthecitythatwouldrationalizetrafficflowandalignroadwaycapacitywithdesireddesignspeeds.

    Maximizeon-streetparkingfacilitiesandchargemarket-ratepricingtoensuretheavailabilityandconvenienceofparkingformotorists,whilecreatingdedicated

    on-streetspacesforcarsharinginitiatives.

    Providesidewalksalongbothsidesofallgeneralaccessstreets,withtheexcep-tionofalleys.

    Maximizeon-streetparkingfacilitiesandchargemarket-ratepricingtoensuretheavailabilityandconvenienceofparkingformotorists,whilecreatingdedicatedon-

    streetspacesforcarsharinginitiatives.

    Maximizeon-streetparkingandconsiderdedicatedspacesforcar-sharing

    initiatives.

    StriveforImplementreasonabledesignspeedsforgeneralaccessstreetsthat

    calmtraffic,reducepedestriancrossingdistances,andpromoteefficientmotor

    vehiclemovement.

    Introducefeaturesthathavebeenshowntoeffectivelyimproveroadwaysafety,

    suchastimedpedestriansignalsandcurbextensions.

    Craftmaximumblocksizestandardstofacilitateaconnectivestreetnetwork,

    andavoidcul-de-sacs.

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    Plantandmaintainnativeshadetreesbetweenthestreetandsidewalkalongall

    neighborhoodstreets.

    Ensurestreetlightingoftheproperscale,aesthetics,andintensity.

    Reducethenegativeeffectsofhighwayshigh-capacityroadwaysonadjacent

    neighborhoods.7.2Encouragewalkingandcycling.

    SupporttheNFTAsgoalstoimplementBikesonBusesonallvehiclesintheAuthoritysbusfleet.

    IncorporatetheCity'sbicycleparkingpolicydirectlyi