Additional Public Comments received Thursday, February 18, 2021 – 203 S. Marion Street

Mr. Failor:

My wife and I have lived in the Pleasant Maple Condominium since 1986. We have very much enjoyed

our Building and it’s neighborhood. It suits us in just about every way.

Over time we have watched the neighborhood become very very popular. We’ve enjoyed Philander’s,

Barclay’s, Poor Phil’s, La Bella, Two Brothers, et. al. All these have attracted a lot of visitors. And traffic.

When the Carleton Hotel is busy, especially on weekends, many vehicles travel through on Pleasant

Street to the main entrance of the hotel. There can be a constant stream of guests being dropped off and

picked up. These vehicles also utilize the spaces across the street, which will be dedicated to the 203

Building loading zone. At times, traffic is reduced to one lane. And this is where our alley meets Pleasant

Street - a real choke point.

The alleged traffic analyst glossed over all this activity. I’m aghast that he feels that the logical location

for the 203 garage entrance and exit is the alley behind the building. I understand that garages generally

open onto alleys. But surely a multi - story garage designed to hold 100+ cars is an entirely different

animal. Disgorging these vehicles into an already congested alley and street is surely asking for

trouble. There potentially will be cars, taxis, limousines, delivery vans, moving vans, wedding busses,

etc. , all in this one small section of side street. And don’t forget pedestrians with or without digital

devices. This will be a very big problem. Not all the time, of course. But especially on busy wedding

weekends (which are most weekends), there will be many opportunities for accidents At the very least, it

will make for very tense, careful, slow driving in order to maneuver safely into traffic.

We feel that the only real solution to this problem is for the developer to redesign the parking garage to

enter/exit onto Marion Street. Especially at the south end of the building, there should be an opportunity

to design an entrance that is more open with better sight lines, allowing safer entry into traffic and much

less congestion. Some type of device can be installed to alert pedestrians to exiting vehicles.

John & Christie Sergo 204 S Maple Ave. Apt 15

______________________________

My name is Bob Ebert of 227 S. Marion, Oak Park, Ill

I am the owner of Ebert Studio of the same address .

I agree with the majority of the concerns of the PMCA.

There concerns are well thought out and need to be

addressed. The Density, Parking ratio and logistics and

set-back are particularly disturbing. There is no ‘harmony or

compatibility’ with the neighborhood. Basically to large a project

in every way shape and form.

Having read the PMCA report to the O P Planning Commission in full

I am very concerned about the problems this project would create

for its neighbors and our historical area image. This project should

be restructured with those concerns.

Bob Ebert 708 772 6222 rebes1025@gmail.com

____________________________

Oak Park Plan Commission

In reference to the proposed 203 South Madison building.

This project is a tragedy to the international significance of Oak Park’s architectural Heritage.

Why are we putting up another mediocre box of living units.

This project does not enhance the streetscape, the pedestrian experience, and adds more

parking and traffic to what is already an overburdened issue.

There also appears to be very little benefit to the Oak Park resident. We are already burdened

with high taxes and I wonder if any of these building contributed to reducing our tax burden? I

doubt it.

I offer this quote:

“The good building is not one that hurts the landscape, but is one that makes the landscape

more beautiful than it was before the building was built.”

Frank Lloyd Wright,1957

Frank Lloyd Wright and his contemporaries put this village on the international map. Maybe it is

about time the Village listened to him.

Jack Lesniak, AIA

JOHN R. (Jack) LESNIAK AIA CCCA

ARCHITECT

1101 N. Humphrey Oak Park, Illinois 60302

________________________________

February 17, 2021

Dear Members of the Oak Park Plan Commission:

I am a home owner in the Pleasant-Maple Condominium, aka Decker, building and writing to object to

the granting of Zoning Ordinance allowances to the 203 S Marion Planned Development.

The Focus Acquisition Company, LLC is seeking approval to construct a building that will be 140% of the

height, contain 353% of the dwelling units, and provide only 77% of the required parking spaces currently

allowed.

Additionally the building footprint will effectively utilize the entire property creating a massive block on the

corner of Pleasant and Marion walling in the residents of the Pleasant-Maple Condominiums and

destroying the sight lines and character of the surrounding community.

It has been stated the building must be this size to make this particular project's financials work. This

project is an excellent business opportunity allowing the Focus company to offer an enhanced living

experience to it's potential renters, but it comes at the expense of the adjacent property's home owners

and surrounding community.

My objections are based on the safety and quality of life issues resulting from the construction a massive,

high population density building on this site.

Alley access and safety:

The alley running between Pleasant and Randolph already supports high pedestrian and vehicular traffic

due to the population density of the multiple family homes on Maple Ave, Carleton Hotel parking lot

usage, member participation at the West Cook YMCA, and commuter access to the Metra and CTA

transportation hub.

Driving onto Pleasant street from the alley is difficult with the current sight lines and traffic. The

decreased visibility and increased traffic volume resulting from the proposed building's size and

population density will exacerbate the problem.

The Pleasant-Maple garages on the alley have very narrow door openings. All of the current available

space in the alley is needed to access these garages. Regardless of currently posted no parking signs,

vehicles are parked in the alley making it impossible to access one's garage until the offending vehicle is

moved. There already exists a shortage of parking in our neighborhood. Insufficient indoor parking

allotment will likely result in alley parking. Additionally, the proposed building's garage access location

and potential volume will introduce new safety challenges to accessing our garages.

Quality of life diminishment:

This massive building will wall in the east side of the Decker Building, replacing our views of the morning

sun, sky, historic buildings, and the green space of Mills Park with that of a garage wall.

To the south, enjoying one of Oak Park's most enjoyable and popular al fresco dining experiences at Poor

Phil's also will be overshadowed by the wall.

The ambiance of the Pleasant Maple area has already been harmed by overbearing structure of the

Eleven33 Apartments to the north. The 203 Marion project will extend the damage to the east.

Disruption of the Pleasant District's character:

The Pleasant District is a valuable recreational area for Oak Park's citizens and a significant tourist

attraction. The Historic Preservation Commission has reported that this building is too big, not compatible

with the adjacent properties, and that it definitely will change the character of the district.

The problem is with the proposed building's massive size and style. No amount of facade adjustments

can remedy this flaw.

I urge the Oak Park Plan Commission to support and preserve the safety and well being of the residents

and character of the Pleasant District by denying the application for the 203 S Marion Planned

Development.

Sincerely,

Monica Domagala

224 S. Maple Ave #45

__________________________

Craig Failor Plan Commission of Oak Park I would like to add additional commentary to my original letter sent two weeks ago. I was unaware that there will not be enough parking allocated for the residents of the proposed building. This one factor alone should negate the acceptance of the proposal of this building. Pleasant District is an extremely dense area comprised mostly of residences and multi family housing built prior to the advent of the "vehicle" becoming a necessity to the culture of life. It may seem like we can direct this current "car driven" culture to be reduced or canceled completely, however, this is so speculative and wishful thinking that is "Orwellian". Bottom line: the absolute majority of people moving into this area will have a car or cars and need parking. And they will insist on parking very nearby ( as in - "included parking within the building's lot line"). Let us not forget that there are are going to be multiple occupants in many of the units who will need cars and need multiple parking spaces. Let's not speculate that every person who would rent at 203 S. Marion is either going to work in Chicago and therefore take public transportation or they're going to work from home and thereby not "need" a car. This is very dangerous and naive to make an assumption like this! Parking is a problem in the Pleasant District already that no one seems to want to admit to. If 203 S. Marion does not offer a minimum 1:1 ratio of units: parking space, excess parking is going to spill into the neighborhood and compete with the parking needs of all the other multi family residences, restaurants and businesses. There is not enough on-street parking in this neighborhood as it is. As far as any nay sayer or speculator who thinks contrary to what I have just said, I have stated fact. And I have 21 years of factual evidence as the Leasing Agent of Mills Park Apartments (1033-1045 Pleasant Street) and the Fountainhead (1000-1012 Pleasant Street and 119-121 S. Home Ave. that residents do indeed have cars and want parking ( typically on site and to not have to walk a distance off the boundaries of the property). All age groups - young, middle age, older, elderly, single, couples, partners, roommates, families with children - want parking. There are very few ( in over 21 years of my experience) who don't have a car - ranging from 1% to about 7%. However, unaccounted for are the residents who have 2 or more cars.

With 21 years of experience, I can expertly contest and factually admit - people have cars and need parking to accommodate them. To further my argument, residents over the years have moved out of their apartments at our buildings because of lack of parking and/or the inconvenience of having to walk blocks at all hours to parking. Also, potential residents will purposely choose not to rent at our buildings because of lack of parking. I look forward to a future someday where we will not have cars polluting this earth. What a wonderful aspiration! However, we have to be realistic. We still have to build and design for today's needs. Sincerely, Nancy Nemetz Mills Park Apartments The Fountainhead

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18 February 2021 To: Oak Park Plan Commission Re: PC 21-01 203 South Marion Planned Development Dear Plan Commissioners: On behalf of the Pleasant Maple Condominium Association board (PMCA), I am providing additional information related to our opposition to the Planned Development at 203 South Marion. Our previous letter, dated 4 February, remains in effect. This letter provides more information on our objections based on the presentation by Focus Acquisition Company, LLC (Focus) at the 4 February hearing, questioning by interested parties, and updated information provided by Focus on 16 February. Parking Allowances: Focus is requesting two allowances on parking requirements. Zoning Ordinance Table 10-2 requires one parking space per dwelling unit. Based on the updated unit count of 158 units, only 0.78 spaces will be provided. Zoning Ordinance 10.3-B-4 requires a 9 foot turnaround space at dead-end aisles. No turnaround space is being provided. Notably, at least two other code requirements apply but have not been requested. Zoning Ordinance 10.3-H-5 requires a clear sight set back of 8 feet for parking structure exits (with 8 feet clear sight lines on each side). This is not being provided; on the north garage exit, there is only a 5 foot setback and at the south garage exit, no setback is provided. Municipal Code 8-12-11 limits compact car parking for private multi-family buildings to 20% of the total. The applicant is proposing 123 spaces, 25 of which will be compact. This is just over the 20% limit, requiring a variance. Although arguments have been made by the applicant that this project falls within a Transit Oriented Development (TOD) zone, the reduction of required parking by 35 spaces is troubling. This neighborhood already has a significant shortage of 24-hour parking for the multi-family buildings. This would add another multi-family building with insufficient parking. Furthermore, the plans submitted do not even provide for 123 usable parking spaces. At the second level, northwest corner, two spaces are fully or partially blocked by other parking, making these spaces unusable and out of compliance with the Zoning Ordinance’s parking design standards (10.3). An additional six spaces are impacted by the requested relief on turnaround space at dead end aisles. The attached diagrams show that the lack of sufficient turnaround will render these spaces functionally useless. This results in a total of 115 usable spaces, an effective parking ratio of only 0.73.

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Diagram showing the lack of turn-around will render end-of-aisle spaces unusable (courtesy Foresite Group)

The 20% limit on compact spaces is further worsened by the above reality. The two non-useable spaces are standard, so if these are discounted, the ratio of compact parking increases. Five of the six spaces impacted by the lack of turnaround space are standard. Again, if those standard spaces are discounted, the ratio of compact spaces increases. Alternatively, if those spaces are converted to compact to make them somewhat more functional, that would increase the compact space ratio. During the hearing, Village Planner Craig Failor answered my question about the required setback for a parking structure exit as follows: Village staff has interpreted that section of the Zoning Ordinance [10.3-H-5] as required only for public parking garages. This interpretation defies the plain text of the Ordinance, as confirmed by our attorney. Nowhere in Section 10.3 or, more specifically in 10.3-H-5, is there a reference to “public” parking structures. This section is for general parking design standards. This interpretation is wrong on the facts, and the Plan Commission should require the appropriate interpretation and a request for relief by the applicant. It is our position that this setback is essential to maintain pedestrian and vehicular safety in the alley. Building Height Allowance: Focus is requesting a relief of building height from the limit of 60 feet to a total of 84 feet 10 inches. This is an increase of almost 25 feet. No other neighboring buildings have a height even close to what is requested. The applicant clearly shows in their materials and testimony that the building’s height is twice that of the tallest adjacent buildings. This is not in keeping with the character of the neighborhood or the Planned Development Standards. In 2017, the zoning height for this parcel was increased from 45 feet to 60 feet. That was a 133% increase in allowable height from the previous. The applicant is requesting an additional 142% increase in height from the new standard. If approved, in the matter of four years, the allowable height on this

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parcel would have risen by 40 feet, a 189% increase. Owners who bought their condos years ago should have an expectation that the zoning will protect their property investments, not allow for a development that is nearly twice as tall as allowed when they purchased. Even a modest allowance on height would not result in an extra 25 feet (over two floors). Furthermore, the applicant has made no effort to visually mitigate this massive increase in building height. The top floor is set back only at the east elevation. The full seven stories will be plainly visible from all viewpoints as is clearly shown in the applicant’s renderings. On cross examination, the applicant had no reasonable explanation for why the top floor could not be set back similar to what they propose on the east side. Such set backs would offer the opportunity to provide outdoor living space and to take advantage of what are likely impressive views. Pleasant District: The Pleasant Commercial District is a transitional neighborhood. At the north end along South Boulevard and the rail viaduct, development tends to be more intense in height and density. South Boulevard is a major thoroughfare that allows for higher traffic volumes west-bound. As one moves south towards Pleasant Street, the buildings reduce in height, ranging from two to four stories. This area is typically multi-family and commercial development. South of Pleasant, the character changes again to a mix of multi-family and single family buildings. The taller multi-family buildings are three to four stories, but many of the buildings are only two stories and all have significant setbacks and green space.

Focus and several Plan Commissioners have made comparisons of this application to projects built at 1133 South Boulevard and the Opera Club building at Marion and South Boulevard. Specifically, they cite that because those buildings are taller, it is appropriate for this development to exceed the zoning limit of 60 feet (note that the Opera Club is only six stories). This is the complete opposite of what should be happening on this site. Those two developments are at the north end of the district, along the rail corridor and adjacent to the taller and more dense developments of downtown Oak Park. This project would introduce a similar scaled building in the location where density and height is decreasing. On two sides, the seven-story building would be adjacent to two-story single family homes (since converted to commercial uses). On the other two sides, the building would face four-story buildings half its height. This building will tower over everything that surrounds it and is entirely out of character with this neighborhood. This conclusion is the same as that provided by the Historic Preservation Commission, the village body with the expertise to review the appropriateness of design and character.

Alley Congestion & Pedestrian Safety:

One of the primary concerns by the PMCA is the impact of this development on the alley, specifically our right to access private parking, and the safety of pedestrian and vehicular traffic in and along the alley. During the hearing, the Focus team dismissed concerns about the alley, pedestrian safety and traffic congestion that would result from their development and the additional 123 cars that will utilize the alley for access.

The KLOA traffic consultant testified that the 18 foot wide alley is more than enough for regular traffic flow. He also testified that although the applicant will install a visual warning device at the garage exits, there would be no danger to those walking and driving in the alley from vehicles exiting the garages. He also testified that the 8.3 foot setback of the Decker building (only 4.3 feet at the north end) provides an effective width of approximately 26 feet. This calculation includes private property used as a walkway for PMCA owners to access garbage/storage rooms, our outdoor lawn to the south, and the various garages. It should be noted that this setback complies with the 8 foot setback for sightlines of our

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underground parking garage exit, something not provided in the new construction. He also testified that vehicles exiting the garages would need to turn into oncoming alley traffic due to the lack of required setback. In fact, the KLOA Exhibit A2 shows those exiting the northern garage would turn into oncoming traffic right where southbound traffic would be turning into the alley.

The attached figures clearly show the consultant’s testimony to be in error or misleading. While technically two standard sized vehicles can pass each other in the alley, Figure 3 shows that the clearances are so tight that people routinely use our private apron as a go-around, or will pull off to the side and wait for oncoming traffic to pass. This is a regular occurrence at the south end of the alley where existing buildings are built on the lot lines; cars do not attempt to pass each other. Figure 3 also shows that two vehicles cannot pass each other when pedestrians are present. Figure 4 shows that the lack of the required garage exit setback means that drivers will have already pulled into the alley before they can see any nearby pedestrians or oncoming cars. And that the lack of setback will require those cars to swing widely into the alley, as shown in their own documents and testimony. We also contend that their proposal to add visual warnings at the garage exits is proof that their proposal does not meet minimum safety standards.

Also of concern to PMCA is the lack of visual sightlines at the north end of the alley. Currently, the Decker Building is setback from the west line of the alley by 4.3 feet. It is setback from the public sidewalk by over 7 feet. This provides more than adequate views of pedestrians by north-bound alley drivers. The proposed building will be situated directly on the west and north lot lines, providing zero sightlines of pedestrians by north-bound alley drivers. Figure 1 clearly shows that north-bound cars will already be moving into the pedestrian walkway before a driver can see if someone is walking west along the sidewalk. Pedestrians will not have a view of cars until they are almost directly into the alley crossing. Given the tendency of pedestrians to be distracted by their phones, pets and children, this poses an unnecessary risk to public safety.

On a similar front, the sightlines for north-bound alley drivers pulling onto Pleasant Street is already challenging. The proposed loading zone just east of the alley makes this situation even more difficult. Figure 2 shows a standard sized delivery truck (8.5 feet wide), such as used by parcel delivery services and small moving vans. A car will have to be already into the drive lanes before a driver can adequately determine if the way is clear. The presence of such trucks will also make it difficult for drivers turning eastbound onto Pleasant not to swing into the oncoming traffic lane. The proposal to restrict parking within 12 feet of the alley on the west side will provide a benefit and further shows the negative impact of the lot-line development proposed.

The KLOA traffic study provided in the application also contains some significant errors or omissions. Figure 5 purports to document existing pedestrian traffic volumes. At Pleasant Street and the alley, the north-south traffic is reported as 2 in the AM peak hour, 7 in the PM peak hour and 11 in the Saturday peak hour. These numbers ought to be fairly representative of pedestrian traffic in the alley, since most people are coming and going from the train stations and downtown Oak Park. But per these numbers, the AM peak hour only sees one person every half hour on average; the PM peak hour sees someone only every 8.5 minutes on average; and the Saturday peak hour sees someone only every 5.5 minutes on average. These numbers are just woefully inaccurate. Residents at the Decker Building can easily testify that the alley has regular and significant pedestrian traffic, which is often timed with the trains. A similar error occurs with the reported vehicle traffic in Figure 4. Northbound alley traffic is reported as 5 in the AM peak hour, 12 in the PM peak hour and 4 in the Saturday peak hour. Again, residents can easily testify that cars pass by in the alley once every minute or two in peak times, not every 5-10 minutes as reported. Since these numbers are the basis for KLOA’s conclusions that the project’s additional traffic will not be a burden, or that the safety issues raised will not be significant, such conclusions must be

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called into doubt. The Plan Commission should expect and demand accurate documents and traffic studies, despite the pandemic.

Compensating Benefits:

At the previous hearing on cross examination, the Focus team was forced to admit that most of what they claimed to offer as Compensating Benefits were in fact required by the Planned Development Ordinance or are general community benefits that any similar development would provide (such as tax revenue and customers for local businesses). Initially, the only true Compensating Benefits offered are:

1. A publicly accessible temporary parking space at the southwest corner of the property. 2. A commitment to providing fiberoptic lines to the neighborhood. 3. A commitment to providing short-term leased parking for PMCA owners, as available. 4. The re-construction of the public alley directly adjoining their property. 5. A commitment to burying the utilities in the alley. 6. The extension of the bluestone public sidewalk/streetscape further south along Marion to the

south border of their property (approximately 25-30 feet).

Several commissioners, even those seemingly in favor of the project, noted the lack of Compensating Benefits for a project of this type and scale. We remind the Plan Commission that the allowances requested in a Planned Development are meant to be offset by Compensating Benefits.

On 16 February, Focus amended their application to offer an additional Compensating Benefit: Offering an additional $60k for alley reconstruction (in addition to rebuilding the alley directly adjoining their property).

Although we object to the project as proposed, we respectfully request that the applicant offer reasonable Compensating Benefits comparable to those offered in other Planned Developments. Examples that have been suggested include a setback along the alley and at the northwest corner, long-term parking leases for PMCA owners, a living wall to screen the parking garage, PMCA access to resident amenities, and additional improvements to the alley. We must also point out that several benefits are mere commitments, not guarantees. While we do not doubt the applicant’s commitment, the implementation is largely out of the applicant’s control. It is highly possible that several of the offered benefits would not actually occur, yet the project would have already been approved and constructed.

Comparison to 835 Lake Street:

In 2020, the Plan Commission and Village Board approved a Planned Development at 835 Lake Street. This was the site of an earlier contentious development proposal for a high-rise that would have been significantly out of character with the neighborhood and was dropped under intense public pressure. The approved plan is a six-story apartment building of 84 units and parking for 88 spaces (no parking relief required). The project has green space with trees and landscaping along the front side. It has a setback on the rear side of over fifteen feet (an allowance was approved to reduce the setback from 25 feet).

Notably, the project removed a curb cut on Lake St. in favor of alley access for the new parking garage. However, the parking garage exit has a setback of over 15 feet with more than 8 feet of side view setbacks, thus providing the code required sightlines. It should be noted that this alley is 20 feet wide and handles much less vehicle and pedestrian traffic than at 203 S. Marion, which is only 18 feet wide. During the pre-hearing public meeting, someone expressed concern about traffic in the alley. The applicant responded, “We have set the building away from the alley and our two drives allow for cars to maneuver. Moreover, there are about 73 cars parked there today. So, we don’t believe that the small

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increase in cars will have a significant negative impact on maneuverability in the alley.” Needless to say, the differences on the parking and alley impact with 203 S Marion are considerable.

The development did acquire a variance on the height limit of 45 feet for a building that is 74 feet tall. But this relief was appropriate since the building to the west is nearly the same height, other surrounding buildings are of similar height, and the location is along the major Lake Street corridor. Also, the top floor is setback on all elevations by a considerable distance, making the building appear shorter than it is.

Compensating Benefits for this project included the replacement of public sidewalk/streetscape along the entire length of the development; three new public parking spaces on Lake Street; the addition of 16 public parking spaces for a minimum of five years with a commitment to extending that; an access easement and new walkway for the 815 Lake Street Condominium; a tree restoration payment; and a $100k additional payment to the affordable housing fund (above what was required). These benefits represent both improvements to the community and things that would directly benefit the immediate neighboring condo owners.

The project received a generally favorable advisory review by the Historic Preservation Commission. It was generally well received by neighbors and community citizens. Per news reports, the applicant worked with neighbors to adequately address their concerns and adjusted the plans accordingly.

Additional Information:

During the initial hearing, a number of questions were raised on cross examination that Focus was unable to answer that evening. Additional concerns and comments were raised by commissioners. We expected that these questions and issues would be addressed by the applicant in its 16 February update, but most were not. We hope that they do so in person at the 18 February hearing. Focus did adjust their proposal’s east setback, offering slightly more green space and two trees on the south side. They pledged to boost the sustainability certification from bronze to silver and added some minor brick details to the building. They also offered an additional Compensating Benefit: More funding of the alley reconstruction. But other issues related to the parking garage layout, alley and garage exit setbacks, construction logistics, and overall building height were not addressed. We would also expect that commissioners might have questions of the applicant, something usually addressed early in the hearing process. Because of their failure to fully respond, we urge the Plan Commission not to rush through their review and to require a full response on all of the issues. The applicant has a right to properly respond to questions and concerns, and the neighbors/interested parties also have a right to review these responses and conduct a cross examination and provide comment.

Conclusions:

We once again ask that Focus provide significant changes to the proposed development to address neighbor concerns and to make it a more appropriately scaled development. The current proposal does not meet many of the Planned Development Standards, and should be denied if changes are not made to address them. The case of 835 Lake clearly shows that a similar development can be scaled and designed to fit the neighborhood and respect the concerns of neighbors. Requiring significant changes, or denying the project, will not prevent a development from occurring on this important site. PMCA is not opposed to development here; we only request that our property rights and investments be respected and that our new neighbors not impose a significant burden on our quality of life and on public safety.

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Sincerely, Douglas E. Gilbert

On behalf of the Pleasant Maple Condominium Association Board: Johnnie Allen, President Ruth Huet, Treasurer Pam Deady, Secretary John Sergo, Manager Douglas Varn, Manager CC: Thomas Gardiner, Gardiner Koch Weisberg & Wrona Craig Failor, Village Planner

Feb 18, 2021

To the Members of the Oak Park Plan Commission:

In support of others’ statements of opposition, starting with the HPC, I wish to

highlight several ways in which the building proposed for 203 S Marion is

simply too big for its setting. Here are 3:

Unlike all the other tall buildings cited as “precedents” in the proposal, 203 S

Marion would overshadow buildings directly to its north. The shadow study

images don’t even show the full reach of shadows on the Pleasant/Marion

intersection around the winter equinox. But surely a building almost twice as

tall as the hotel will create a dark, looming presence at the intersection and

undermine its current open character. We’ll lose not only green space but

another equally threatened if less quantifiable community resource in the

downtown area: open space and light, not to mention greenery.

The traffic study claiming only a negligible negative impact from the building

does not account for the high volume of service and delivery vehicles it will

bring. A rental building with 159 units will see frequent moves in and out.

Until drones can deliver Peloton bikes, the online future of retail means truck

and van deliveries—the more so for the affluent residents of this building who

are predicted to own fewer cars. Those busy professionals will not walk

everywhere. Add grocery and restaurant deliveries, plus ride-share and taxi

stops, to the obstruction already generated on the block’s north side by the

hotel, with its two restaurants, events, and of course guests. And on top of the

delivery, service, and refuse vehicles serving 159 households are those

necessitated by a café. With street parking spots occupied as they invariably

are, this narrow street is already barely passable for two-way car traffic. It

cannot sustain the much higher traffic volume brought by the proposed high-

density building. To cite a comparable example, the District House condo

building and Fairgrounds Café at the northwest corner of Lake and Euclid

generates so many stops by delivery vans and trash trucks that the resulting

bottleneck necessitated the elimination of two precious street parking spaces

on the east side of Euclid just north of Lake: even so, when a trash or delivery

truck is pulled up on Euclid, even in the loading zone space, two-way

movement is often obstructed. I observe this several times a day. And District

House is a mere 28 units, a number dwarfed by the 159 proposed here.

Finally, the allowance of parking--.7 spaces per unit--is demonstrably

inadequate even for a transit-oriented development with a high walkability

score. District House is also such a building, yet its far higher allowance of 1.3

vehicles per unit still does not meet demand. Eight District House owners have

installed car lifts, so the 28-unit building now houses 46 cars, for a ratio of 1.6

per household, more than twice the ratio proposed here. Those who live

downtown may want to walk everywhere but we have not given up car

ownership. The new development will undoubtedly put pressure on the severely

strained supply of parking in the neighborhood. It’s one more of many reasons

that shoehorning 159 units into a lot zoned for 45 will not serve at 203 S

Marion.

Thank you.

Wendy Greenhouse

Oak Park

wgreenhouse@gmail.com / 708.404.2789

RE: 203 South Marion redevelopment by Focus Acquisition In response to the request for a waiver of the number of parking spaces required by zoning

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February 18, 2021 To: The Members of the Oak Park Plan Commission From: Masaru Takiguchi, 125 S. Maple Avenue, Oak Park RE: 203 South Marion redevelopment by Focus Acquisition In response to the request for a waiver of the number of parking spaces required by zoning Parking. Perhaps the most subtle proposal with which to take issue is the relief requested related to parking. Parking is an essential element to residency in 203 S Marion. It is essential to the district. Both the current residents of the area, as well as the future residents are entitled to the benefit of the 159 units of parking required under the zoning ordinance. The 1 unit of parking per unit of apartment is manifestly reasonable and important to the area and the unit residents. The request for a waiver of the requirement is misleading and is unjustified. It is misleading because it make the unsubstantiated presumption that these occupants will not or do not need vehicles for employment, education, errands, transportation of children to and from school and other activities. Unjustified because the data submitted states unequivocally that renters in the area on the average have more than one car per unit. The Commissioners must take notice that the inherent presumption made by the Applicant is that residents simply should not need vehicles. It assumes that there is a certain kind of renter that will occupy the apartments, but it provides no current data to support the proposition that vehicles are abandoned by renters in general, or the diverse renters that will be sought after. Applicant submitted a study authored by Kenig Lindgren Ohara Aboona Inc. (KLOA), dated January 29, 2021. A document submitted is a four page Summary Report and a three page Appendix consisting of a 2005-2005 Center for Transit Oriented Development (CTOD) data sheet. This also is referenced in the lengthy Traffic Impact Study submittal. Both rely on 2005-2009 data, raising the issue of how this data is relevant to the 203 Marion project. While the data is submitted in support of the Applicant’s request for relief from the

RE: 203 South Marion redevelopment by Focus Acquisition In response to the request for a waiver of the number of parking spaces required by zoning

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159 parking spaces required by the current zoning, the CTOD data contradicts the assertion that there is a trend toward fewer cars. Although it refers to 43 studies that are 12 years old, predating the commencement of the pandemic by over a decade, the report does not comment on the impact of the pandemic on employment and daily living. There is no relevant discussion or evaluation of data addressing the pandemic or it impact on public transportation, health and safety. In the Tracy Cross Report, there is a cautionary note about the limitations of the housing market presumption and data used. No such caveat is contained relative to parking. The CTOD data is old data and neither the Applicant nor the Memo addresses the current demand for private transportation in 2019, 2020, 2021. The applicant intentionally or unintentionally left the issue of relevancy unaddressed. For these reasons, the Commissioners should deny the request for a 30% reduction in parking. Further, although the KLOA Memo is offered to support a need for less parking, the CTOD data used in the Memo states explicitly that rentals experience a greater than a 1:1 ration of vehicles to residential rental units. The Applicant, Focus, fails to show why this submission supports less parking than is required by law and the Commissioners must require a showing of relevance as part of their duty to the public. The CTOD data contained in the Appendix to the January 29, 2021 Memo from Millan and Werthmann to Brower describes a quarter mile area bounded with areas south of Madison to an area north of Augusta, Ridgeland on the east and parts just west of Harlem. This area is so diverse that an effort to make the data relevant is appropriate and necessary. Again, note that there is no effort to apply data to the current facts and circumstances of the Pleasant District and why development should not be required to adhere to zoning requirements. Note further that the area of Pleasant and Marion is unique and significantly distinguishable from the others included in the quarter mile area of the data sample from 2009. Because the Applicant fails to show with this report how the data of 2009 supports a proposition of a lower parking requirement the presentation fails to support the request and the Commissioners must deny the request as unsupported. So not only is the data historical, it is not made relevant to why a typical residential tenant as is the subject of the study would not have at least one car on average. The CTOD report from 2009 indicates an average number of vehicles per household of 1.91/ household and an average number of vehicles available for renter occupied units as 1.02. It does not support the Applicant’s assertion that demand for parking in the CTOD area is less than 1 space per unit. The CTOD in fact indicates that the Zoning requirement is reasonable. It is inconsistent in the presentation of the Applicant that the CTOD data supports a need for full

RE: 203 South Marion redevelopment by Focus Acquisition In response to the request for a waiver of the number of parking spaces required by zoning

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compliance with the parking requirements while arguing for a lower requirement. The conclusion is that less than the zoning requirements would burden the area. For this reason the request must be denied. There was an anecdotal comment that residents have abandoned vehicles for bicycles, public transportation and ride sharing. No data. The data does reflect however that public transportation systems have been shunned by many for driving. Uber and Lyft drivers are facing tighter regulation. And there is not data supporting the proposition that residents will abandon their vehicles to about 30% of requirement. Further, the fact that many places of employment are not served by public transportation, or are served with service that makes the use incompatible. It is not inexpensive to use ride shares and vehicles continue to be more convenient and generally more reliable to middle income employees with employment in suburban communities. As a direct and proximate result, residents will continue to have vehicles and parking continues to be an unrelenting need in the current circumstances and in the area of 203 Marion and such need and demand will not be reduced to such a degree as to render it unnecessary to the prospective residents of the proposed new residential development. Our collective effort to create all types of diversity in all areas of the community and municipality should encourage us to recognize that those prospective tenants will need vehicles to support their standard of living. It is not an option. It would be dereliction of duty to assume that the Commissioners know best how to force tenants to live. It is unrealistic to make a decision on parking because there is a profile of the kind of jobs or resident that will occupy the rental unit. To make it available to a diverse group of prospective tenants, Commissioners must consider the impact of the burden of forcing a person that seeks to rent to go outside for parking and the attendant cost of that parking in an area of such low availability. Parking is not inexpensive in Oak Park and is not conveniently located to this site. It is reasonable and important that the number of parking spaces required by zoning be applied. The term TOD has been bandied about as directive of to the Commissioners. It is used as a sine qua non with regard to whether anything of any use would be built on the site and as a reason that bicycles and pedestrians would flock to the site. Encouragement of transit oriented development (TOD) is a guide, not a directive. The data submitted demonstrates that in the area of the Green Line and the Metra, renters own on the average more than a single vehicle. Areas are unique and in some ways, such as this one, the unique needs and circumstances direct that a reduction in parking requirements for construction be enforced. In no way does TOD require that the Commissioners approve less than zoning standards for parking for 203

RE: 203 South Marion redevelopment by Focus Acquisition In response to the request for a waiver of the number of parking spaces required by zoning

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Marion when the data provided by the developer is compelling for the foreseeable need of parking in this district. The current zoning requirements are reasonable. Implementation of parking limitations resulting from a reduction of onsite parking constructed by the developer may be an impediment to diversity which is antithetical to the fabric of Oak Park. In this area, vehicles are important to employment. Vehicles create opportunity for employment. Everyone should have an equal opportunity for employment. We cannot legislate away the fact that the zoning is relevant and an important component to attracting a diverse tenant base. Reduction of the zoning requirement based on the submittals results in an arbitrary circumstance favoring the developer but disfavoring diversity. It is an avoidable impairment. We cannot deny the fact that the request for less parking by Focus is short sighted and against the interests of the community. There is no data suggesting that as applied to this development in this area that a reduction is a significant contribution to the quality of life. The Plan Commission as a whole and the Commissioners as individual members have a duty to require that the Applicant fully describe and present evidence. The Applicant has failed to do so. It is the duty of the Commission to evaluate each and every premise for relief presented. The members may require information even absent public comment and absent questions during cross examination. Respectfully submitted, Masaru Takiguchi