Public Comment: Critical Information Is Missing In Parking Facility Proposal

The following public comment, directed to the Amherst Town Council, was submitted to the town’s web site on December 13, 2021

I am writing to urge you to expand your scope in considering how to improve parking conditions in downtown Amherst by voting down the proposed parking overlay district and stepping back to look at all options and consider more fully the public need and the public good.

Recommendations Of The 2019 Parking Study.
The proposal under consideration assumes both that a parking garage is the only and best solution to achieve an excellent parking system in downtown, and that of all possible locations for a parking garage, the CVS lot is the best and only option. The Town of Amherst Downtown Parking Study; Parking Implementation Strategy Final Report (2019) lists eight goals for parking strategies, each with three sub-goals. Building a new parking facility is only one of 24 steps that are recommended. Goal # 8 is “Add new parking facilities when utilization regularly surpasses 85%”. Among these goals, “Expand the public parking supply through design interventions at existing facilities” is listed first-before “adding new parking facilities.” And 85% utilization has NOT been achieved in the parking system as a whole.

A parking garage is a high-impact, high-cost, irreversible step; something to be considered only after all the other goals have been accomplished. The 2019 report notes that it is only public parking spaces that reach full utilization, while private parking areas (60% of all parking spaces) go underutilized, never exceeding 55%. The cheaper and lower-impact solution is to expand use of private parking areas through public-private contracts. This could have the benefit of expanding parking access throughout the town center. It could also potentially benefit the owners of private lots with increased income. The other 22 recommended actions include better administration and communication of current parking systems, improving permitting systems for consistency, clarity and to avoid leaving permitted spots underused at key times of day; provide better signage and wayfinding. Why has the Council not focused on these less expensive options? How fully has the town implemented the other 23 recommendations? Why are these not the focus of the Council’s discussion?

There are other options to be considered for parking garages: Boltwood and Amity St. The Boltwood garage was intentionally built with the strength to support more floors. Why has this not been discussed?

Risks Of Approval Of The Overlay District
Consistently the discussion on this proposal has disregarded requests for further impact studies on residential neighbors, pedestrians, traffic patterns, and loss of on-street parking to accommodate traffic flow, delaying these till after the overlay district is approved. The Council needs these studies to make a good decision. The public (and the Council) need clear descriptions of what a four story building with a five foot setback on side borders and 15 foot setback on front borders or to other buildings will look like and feel like for residential neighbors and for those using the buildings around the garage or even just walking  down N Pleasant Sreet. There is no way that a four story, 3-D rectangle block of concrete can be landscaped so that it pleases the eye. Yes, it will be visible from North Pleasant and will change the look and feel of the entire area. The impact on the residential neighbors on North Prospect Street seems to have been ignored in the planning process. Passing all future details of design on to the permit approval board takes the whole process out of the public view and access. This has not proven to be an adequate control on designs and permits that prove to have negative consequences.

What’s The Rush?
What does the rush to hold a vote under the outgoing configuration of the Council, in its final meeting before newly elected Councilors are instated, tell us about the strategies being adopted by this Council? This is not a proposal that requires immediate approval. Whose voices in our town might not have been heard or valued in the Council’s consideration?

In fact, the work on this proposal has missed some important analyses. It is important to look at what is the potential net-yield in affordable spaces for this compared to other solutions. The CVS lot is just 0.68 acres; based on the 1990 analysis of a 1-acre site, this site could support a garage of 150 spaces — just twice the current 72 spaces. Supposing that a developer would want to rent a significant portion of that for long-term leases (since each space will cost an estimated $40,000), there could be little or no gain in short-term parking and likely those would be more expensive than current parking. Further, this lot has a poor entrance and exit layout. Use of North Prospect for exit and/or entrance would likely require losing more on-street parking spaces, further reducing the net benefit.

You Are Called To Be Systems Thinkers!
Town Council has a broad mandate and broad powers to influence what happens in this town. You are called upon to fully embrace the discipline of systems thinking. That is, you must seek to understand the full complexity of the problem(s) to be solved, and the interactions among what might appear to be different problems. Ask yourselves, what are we forgetting to look at as we discuss this? Beyond that, you are called up to anticipate and explore the many possible consequences of each decision that you make. How will this decision affect all users of downtown? What are the unintended consequences that could follow? What other solutions have we not considered that could work just as well and achieve other, positive goals? I urge you to ask and answer these questions of yourselves and each other. I believe that the answers provide ample reasons to vote NO on this proposal.

Ruth Hazzard

Ruth Hazzard is a resident of Amherst