AMERICAN FORK CITY COUNCIL MAY 9, 2018 JOINT WORK SESSION AGENDA. 1. Discussion on the TOD (Transit Oriented Development) zone. 3. Adjournment.

Transcription

1 AMERICAN FORK CITY COUNCIL MAY 9, 2018 JOINT WORK SESSION AGENDA WORK SESSION The purpose of City Work Sessions is to prepare the City Council for upcoming agenda items on future City Council Meetings. The Work Session is not an action item meeting. No one attending the meeting should rely on any discussion or any perceived consensus as action or authorization. These come only from the City Council Meeting. The American Fork City Council and the Planning Commission will meet in a joint work session on Wednesday, May 9, 2018, in the American Fork City Hall, located at 31 N. Church Street, commencing at 7:00 p.m. The agenda shall be as follows: 1. Discussion on the TOD (Transit Oriented Development) zone. 3. Adjournment. Dated this 3 day of May, Terilyn Lurker City Recorder In accordance with the Americans with Disabilities Act, American Fork City will make reasonable accommodations to participate in the meeting. Requests for assistance can be made by contacting the City Recorder at at least 48 hours in advance of the meeting. The order of agenda items may change to accommodate the needs of the City Council, the staff, and the public.

2 CITY COUNCIL STUDY ITEM City of American Fork COUNCIL WORK SESSION MAY 9, Department Recorder Department Terilyn Lurker STUDY ITEM Discussion on the TOD (Transit Oriented Development) zone. BACKGROUND Upon adoption of the Station Area Plan a few years ago, Staff worked with planners from UTA to create a form-based code to guide development around the Front Runner station. The Code was prepared to address not only use, but the form development would take to house various uses. A template code for development around transit stations was used, and molded to fit the station area in American Fork. As development pressure has increased, different development groups have come forward and pointed out perceived inconsistencies in our Code, and ways to address those-while benefiting their particular types of development. Rather than address these issues one by one, and have the code amended to fit certain developments, Staff felt that it would be prudent to discuss the code, in its entirety, with an outside expert; well versed in TOD, and how to accomplish the goals that the Code set out to address: compact, walkable, mixed-use, quality development. Mike Hathorne, with Michael Baker International is a leading expert in the creation and modification of TOD code. Mike has worked with numerous cities, and developers, in the creation of TOD codes that allow the objectives of all parties to be met, while ensuring quality, lasting development. Staff asked Mike to review our existing TOD code; give some initial, highlevel feedback while also taking a look at some recent proposals by a development group for changes to the code. Mike reviewed the code and presented a memo to staff addressing some initial observations. The take-away from his initial review is that, in Mike s words, the DNA is good. Our code has a good backbone; there are, however, some short-circuits, if you will. Some of the pieces don t quite fit the way they need to. Regarding recent proposals by a development group, Mike feels that if enacted, they will take away from what a TOD is (compact, walkable, pedestrian oriented), in exchange for standard suburban development (auto oriented, compromised walkability within the TOD area). Mike will lead this joint work session with the Council and Planning Commission to discuss his initial findings as they relate to our TOD code. He will discuss what TOD is, and how our current code supports TOD development; while letting us know of the gaps that exist and what can be done to address those. Staff would like to continue to work with Mike to bring our code up to speed so that American Fork can guide development within the TOD area to achieve the goals of walkability, compact, mixed-use development that compliments the City and allows an array of uses while ensuring quality, lasting development. Packet Pg. 2

3 2.1 SUPPORTING DOCUMENTS JWS - American Fork - TOD Code - Memo Report ( ) (PDF) JWS - UT-American Fork - Patriot Commons - Submittal Response ( ) (PDF) Packet Pg. 3

4 Memo Report Prepared for: Prepared by: Mike Hathorne Senior Planning Manager Packet Pg. 4

5 Introduction Development in the United States is shaped by land use policies (zoning) that govern it. Land use policy has a direct impact on such areas as physical appearance, human behavior, economic development, and environmental sustainability. All of these carry over to the everyday experience in our built environment. The relationship that zoning has to our day-today lives as human beings is directly impactful. Its relationship is directly attributable to the relationship that DNA has in all living things. DNA is genetic code which identifies outcomes (both positive and negative) to the owner of it. Zoning acts in the exact same fashion. Its sequencing delivers results directly tied to the development patterns which are emitted both intentional and unintentional. This must be both understood and accepted in order to make the necessary adjustments to deliver results that are different from today s common practices. From its inception zoning had three intended purposes. First, it would divide a community into zones separating the different areas based on their intended use. The uses have typically been defined as housing (residential), business or retail (commercial), manufacturing (industrial), and farming (agriculture). The zones would keep incompatible uses separated from each other with the intent of protecting the health, safety, and general welfare of the public based on the police power as established by the 5th and 14th amendments of the United States Constitution. Second, zoning would deal with the amount of use that a particular zone would be allowed to experience. Once a particular use was established a limit of that use would need to be determined, mainly to prevent the overcrowding of a given area with the same use. This was a lesson learned through the overcrowding of tenements in New York City during the late 1800 s and early 1900 s. Overcrowding led to many deaths through disease and fire. Intensity is controlled through the use of dwelling units per acre (DUA) for residential zones, and floor area ratios (FAR) for commercial zones. Third, zoning addressed the issue of how much of the land in the zone could be used. To prevent the overbuilding of land parcels, measurements of volume were instituted. These measurements would establish where development could occur on a particular parcel through the use of setback requirements, and how high development could go through height restrictions. Page 1 Packet Pg. 5

6 Source: Peter Katz - Form-Based Code Institute Conventional zoning s primary focus is on regulating USE and DENSITY. While it touches on FORM, it does so at a subordinate level, often only as an afterthought in the overall process. This forces development decisions to be addressed in a subjective and reactionary manner. Because Conventional zoning is proscriptive by nature, it tells the development community what NOT to do, rather than offering a prescriptive vision that invites what can be done. The result is the community is left with uncertainty as to what the end product will be because FORM is not adequately considered. Such uncertainty leaves Planning Commissions and City Councils focusing on what the project is going to look like and how will it fit into the community. The irony in this is that these are FORM related questions because the current system doesn t adequately address those issues. Euclidean zoning separates incompatible land uses for the intended purpose of protecting conjoining land users. What it has become is not what it was intended to be. Current zoning practices now limit market choice and push different, yet compatible uses away from each other creating a physical environment that neither works nor is wanted. Form-based codes offer an alternative to zoning for governing the built environment. It is a regulatory system which places a more direct focus on the urban form that is created through development practices, while emphasizing the physical character of development and deemphasizing the specific regulation of land uses in general. Form-based codes don t ignore USE and DENSITY, but rather place them in a supporting role to FORM. USE and DENSITY become subject to the FORM which is determined by a community s vision of what the desired outcome should be. The end result with form-based codes is a greater degree of predictability for the municipality, the developer, and the community at large. Page 2 Packet Pg. 6

7 Source: Peter Katz - Form-Based Code Institute Form-based codes have shown tremendous promise in promoting placemaking, encouraging infill, and integrating land use and transportation. Form-based codes have also proven effective in shortening plan review times due to their clear and prescriptive nature. General Overview What American Fork City is working to do, in the area of its FrontRunner station, is establish better DNA, thus delivering different built results, and in the process change the dynamics for regulating development through the use of form-based code. This is not an easy process. It requires discipline in learning how to re-direct one s thinking from primarily focusing on use to instead shifting the focal point to form. Many people have invested their entire careers in the present use-based system. Government, developers, financiers, designers, engineers, public safety, etc. The investment in the current system causes discomfort and a misconstrued view that change is a threat to their livelihood. The feelings and perceptions are real the truth says otherwise. These aspects are important to understand in order to know where some of the pushback will be coming from as efforts to implement a new system take place. Pushback may come from inside (adjusting to different and unfamiliar standards in regulating process) or from outside (adjusting to a different application for doing business). Resisting these areas of pushback will be critical to the vast number of opportunities and benefits that will come through implementing sequencing for development that has proven itself more resilient, effective, and beneficial when done right. Page 3 Packet Pg. 7

8 1.0 Description and Intent This section identifies the objective of the code and establishes the code s building blocks: 1) Sub-districts 2) Blocks 3) Street Types 4) Open Space The sections which follow identify the regulatory parameters for each of the identified building blocks. The listing of building blocks in this section is silent on the primary organizing principle of this particular code Building Types. While Building Types aren t the right primary organizing principle for a code of this type, this purpose, and for this size of a regulating area, it is notable that it was not identified in this section. Regulatory Plan This code was created through the use of a template code which was funded by a federal HUD Grant and overseen by a Consortium Organizing Committee. Page 4 Packet Pg. 8

9 Section 1.0 identifies a detailed exhibit which identifies the regulatory area associated with the TOD zone, along with identified sub-districts, and street right of ways. Because this exhibit is an actual part of the zoning code itself it infers a great deal of detail irrespective of the underlying land ownership and associative parcel boundaries. This presents problems because when the time for implementation arrives the identified detail associated with sub-districts, for example, which are generated by identified by street right of ways force subdivision decisions upon the underlying land owners ahead of their direct coordination. These presumed lines are critically important because of the interpretations associated with them in terms of such things as who receives what in the way of development entitlements. Sub-districts overlayed on parcel boundaries In an area of this size general areas should be identified allowing for follow-up decisions to be made based on the information available at the time. For instance, the finalization of sub-district boundaries (and thus, street alignments and their associative right of ways) would be solidified based on who is first in the door. Those decisions could be driven in part by the identification of higher level district boundaries which would identify a capacity allocation of the overall entitlements for the regulatory area. Page 5 Packet Pg. 9

10 There are no general or specific parameters associated with the noted sub-districts in the code. Rather, the objective with the code is that the other organizing principles, and their application to the sub-districts is ultimately how they are defined. This is problematic based on the implied differentiation between sub-district. It is also problematic in application when referring to the Regulatory Plan which combines the General Mixed-Use and Residential Edge sub-districts as opposed to delineating the implied differences between the two. Each has intentions of being utilized for different purposes, yet there are no tools to delineate between the two. 2.0 Street Types Streets are the vascular system of the built environment. Street standards will govern everything from flow to circulation to connectivity to transportation types (i.e. auto, bike, pedestrian). Streets are also a critical area of governance between the public and private realm. Whether the built environment is scaled to the human being is often a direct correlation to its streets. Streets also serve as a primary source of subdividing property which then provides the necessary accessibility for the subdivided parcels. The type of streets that are used for these purposes can often make the difference in determining the conditions between parcels based on their design parameters. Will the defined street type be friendly towards multi-modal transportation opportunities or will it strictly favor one type of transportation over others? The Code, as written, does an adequate job of addressing items such as circulation and connectivity. It begins the process of identifying street types that will be used to set the parameters of a street network. Some of the street types require some slight adjustments in order to better fit the overall objectives of the network that is desired to be created. For instance, the alley cross section should be considered for revision. As presently designed it calls for the inclusion of sidewalks on both sides of the alley way. Doing this infers pedestrians in an otherwise Alley cross section utilitarian space. Secondly, it widens the cross section inadvertently making it possible for higher Page 6 Packet Pg. 10

11 design speeds for the vehicles which will be using the alleys for rear access to their property. This makes for a dangerous combination for pedestrians. Street Plan There is also a need for the creation of neighborhood level streets. Presently, the code doesn t anticipate smaller streets that would be used in more pedestrian environments. Streets that the code currently identifies are intended to set the district and sub-district network only. They are too large and auto-oriented to provide a neighborhood level, pedestrian friendly environment. 3.0 Districts This section is mis-labeled as Districts, which is in direct conflict with the identification as Sub- Districts in Section 1.0 of the TOD Code. The objective in using sub-districts is supposed to regulate intensity rather than density. Intensity governs mix of use, while density primarily governs residential and its separation from other uses. Page 7 Packet Pg. 11

12 Sub-districts help set boundaries for general acceptance of where levels of intensity will reside, which then determines the lines by which transitions of intensity must carefully be planned for. As presently written, Section 3.0 only lightly defines the sub-districts to be used, making it difficult to fully delineate between them in application. There isn t a way to project and measure intensity because the application occurs through a limited palette of Building Types which lack the necessary detail to make scenario calculations of their development impacts when implemented. 4.0 Uses Section 4.0 provides relationship details between sub-district and desired character which comes through the allowed use relationships which are identified. This section can be better utilized through a proposed re-application to Lot Types rather than the current Building Type relationship. 5.0 Building Types Buildings within a use-based system are what house the separate uses. In a form-based system buildings should instead be thought of as a container which has the potential of housing any of a number of uses and/or different uses over the course of its useful life. This way of thinking Building Type examples (from low to high intensity) Page 8 Packet Pg. 12

13 used to be a common practice prior to the institution of use-based zoning. Now we are efforting to re-learn what is the most economically beneficial method for creating our built environment. The TOD code, as presently constituted, identifies six (6) building types that are intended to produce the development fabric for 400+ acres. Those building types are as follows: Storefront Limited Bay General Stoop Civic Row Yard When compared to the depth of building types that exist it doesn t leave much room for opportunity to only be using 6 building types to work from. In comparison, below are listed a far from comprehensive list of existing building types: Residential Accessory Unity Edgeyard Shared Drive Sideyard Court Rowhouse Duplex Multiplex Flats Live/Work Loft Liner Mixed-Use Office Shopfront Live/Work Drive-thru Gas & Pump Canopy Flex Liner Mid-Rise High-Rise Non-Residential Commercial: Dock Height Industrial Shed Civic Due to the overall size of the regulatory area, the recommendation would be to work with Lot Type requirements as opposed to Building Types. The reason being is that the subdivided lots are the means by which building types are better able to be determined based on the context of the lot within its sub-district and within a district. The use of Lot Types will more effectively produce a multitude of building types without narrowing the number of opportunities at the outset. Page 9 Packet Pg. 13

14 6.0 Open Space Types The same problem exists with the number of allowed open space types that are allowed by virtue of the TOD Code. The code identifies the following Open Space Types as allowable: Plaza Square Green Commons Pocket Park Again, there are numerous Open Space Types that are left out of consideration for a Regulatory Area that is intended to go from extremely urban to lower density suburban. Plaza Square Green Entrance Park Pocket Park Linear Park Close Neighborhood Park Community Park Regional Park School Park Sports Complex Special Use Waterfront Green Community Garden Greenway Waterway/Channel Parkway (Boulevard) Tree Lawns Connector Trail Paseo Open Space Types need to be broad in their offerings in order to account for physical environment that it will serve, taking into consideration its potential programming (Formal -vs- Informal / Passive -vs- Active). Open Space Types will differ based on needs and thus a much broader palette should be considered. 7.0 Landscape Section 7.0 works sufficiently as presently written. 8.0 Parking Parking is a delicate issue to be dealt with and determining the right amount can be a difficult equation to answer. Parking standards, as presently constituted, are sufficient for the time being. If other areas of the code are open for revision it would be worth exploring how to implement parking minimums within the code as a means of attempting right sizing the necessary balance between the needs within the market and the desire to regulate for a more pedestrian (and less auto-oriented) environment. Present standards are sufficient further exploration is recommended. Page 10 Packet Pg. 14

15 9.0 Sign Types Sign Type standards, as presently written, limit signage opportunities through its narrow palette. As previously identified with Building Types and Open Space Types there are opportunities for greater choice in Sign Types that can then be directly applicable to their appropriate Sub- Districts. Present standards are sufficient further exploration is recommended Administration Administration of a form-based code is a function of the intent regarding the objectives and intents that are established in the code s vision. This being said, there are aspects for consideration, regarding the code s administration, that have direct impacts back into the other sections. These considerations fall into two particular areas: 1. General Decision-Making Factors 2. Application of Subsidiarity The application of general decision-making factors addresses areas of focus which should draw consideration in how and why aspects of a form-based code are addressed, but typically are either left alone or ignored in the process. These factors include the following: Market The wants and needs of the market in general are subject to fluctuation based upon such things as changing market demands and real estate cycles. Size The size of a given piece of property brings with it factors such as those associated with aspects of scale. Larger pieces of property require scalability factors at the level of a neighborhood/center, where as smaller pieces may only have to account for block and lot scale issues. Time Time will have both direct and indirect aspects of the previous two elements (market and size), but its application also has its own aspects for consideration when viewed in isolation. For instance, when applied to the absorption horizon of a piece of property, time must be addressed relative to both developer and municipal government. Use - The aspects of use need to be reset within a more appropriate set of parameters in order to ensure a more correctly allocated role. Aspects associated with use are too often addressed prematurely. Next, is the application of subsidiarity in the code to assist in governing the aspects of who and when in relation to the administration of the code itself. Subsidiarity is readily defined as an organizing principle of devolving decisions to the lowest practical level. Thus, smaller, more local, or lower, human associations have proper social functions which should not be assumed Page 11 Packet Pg. 15

16 by larger, or higher associations (i.e. performance on a higher/macro level should only be warranted in the pursuit of assisting a lower/micro level to fulfill their functions). Going a step further, one could say that implementing the principle of subsidiarity suggests that decisions are best made when the smallest competent group, at the most local level and at the last practical moment is allowed to occur. When this is able to transpire a delicate balance between flexibility and certainty is able to be applied decisions are able to be made based on the details that are prevalent, which then are bale to better assist future decision making without the need to guess at details that have not materialized yet. These administrative aspects aren t present in the code as presently constituted. However, the ability of revising the code to include these aspects is certainly not out of the question. It is recommended that exploring these opportunities be considered if the TOD Code is determined to be opened for revision. Page 12 Packet Pg. 16

17 2.1.b Memo Report Developer Response Prepared for: Prepared by: Mike Hathorne Senior Planning Manager Attachment: JWS - UT-American Fork - Patriot Commons - Submittal Response ( ) (TOD Discusion - Joint Work Session) Packet Pg. 17

18 2.1.b PATRIOT COMMONS SUBMITTAL RESPONSE INTRODUCTION In response to an informal submittal by Parleys Partners to consider revisions to American Fork s Transit-Oriented Development Code, Mike Hathorne with Michael Baker International was retained to offer potential response recommendations to the proposed revisions. The revision requests came in the form of addressing four (4) issues as defined by Parleys Partners: 1) Text revisions regarding TOD Row Building Setbacks 2) Text Revisions regarding TOD Yard Building Setbacks 3) Additional text regarding TOD Neighborhood Street ROW and text revisions regarding Alleys 4) Text revisions regarding conveyance of water rights The scope of analysis is to address Items 1 through 3 as they are part of the TOD Code analysis work. Item 4 is not part of the scope. 1) TOD Row Building Setbacks The nature of the request being made in Item 1 is in regard to the placement of garages relative to the Row Building. As presently written, garages are required to be accessed from an alley (rear-load) with all Row Buildings. Parleys Partners is requesting that the code language be softened to allow for garages to be accessible from public streets (front-load). They are also requesting a change to the minimum side yard setback (20 feet to 14 feet), and an increase in the number of Rowhouses in a building (6 to 8). As to the request for allowing front-load access for the Rowhomes, this should absolutely not be allowed to take place. From a design perspective, allowing this to occur would mean that the primary feature of Row Building would be garage doors. Secondly, allowing this to occur would destroy the pedestrian environment which is the direct responsibility of the city through its management of the public realm. Curb cuts would occur almost endlessly along the street, and would leave no space for framing streets with park lawns and street trees. While these are cause and effect items which stem to the reasoning as to why the request shouldn t be allowed, the code itself goes further in ensuring the prohibition of what the developer is requesting. In Section 8.5 ( ) front-load Row Buildings are expressly outlawed due to the housing types building width: Driveway Width at Property Line. All driveways shall have a maximum width of 22 feet as measured at the property line Attachment: JWS - UT-American Fork - Patriot Commons - Submittal Response ( ) (TOD Discusion - Joint Work Session) Page 1 Packet Pg. 18

19 2.1.b PATRIOT COMMONS SUBMITTAL RESPONSE Since the Rowhome product itself is 22 feet wide the maximum driveway width generates an indirect prohibition against the existence of a front-load opportunity to exist for this building type. The requests for shrinking the sideyard setbacks (20 feet to 14 feet) and increasing the number of Rowhouses in a building (6 to 8) can easily be answered together. The requests are intended to allow for the density output of the building type to be increased. The cause and effect of the requests will shrink the distance between buildings which minimizes the visual impact of the buildings and reduce open space around the buildings. Increasing the number of units per building will multiply the visual impact of the building s overall size through adding an extra 44 feet (as presently proposed) to an 8-unit building. These are form-based issues that come down to why the original parameters were set as they were to begin with. Both requests have their own impact together their combined impact is quite significant. There are no positive impacts to any of these proposed revisions for the Row Building Type. It is recommended that all ROW Building revision requests be denied at this time. 2) TOD Yard Building Setbacks There are five (5) different code revisions being proposed. Each will be addressed separately with any combined impacts being pointed out to follow. Front Setback The revision being requested is to allow for the encroachment of the front setback (to 12 feet) while allowing for the front-load garage to remain at the 20-foot setback requirement. One of the reasons the developer is making the request is to shorten the amount of driveway needed and thus reduce building costs. Allowing for an encroachment of living space to 12 feet is intended to camouflage the garage and reduce its visual impact. While admirable in its attempt, the 12-foot encroachment plan is not a requirement meaning that the product designs could potentially allow for the 65% of the front façade (front property line coverage) to become dominated by the garage door. Minimum Rear Yard Setback A reduction of the rear yard setback from 25 feet to 15 feet may not seem like a big deal when considered in isolation. However, when combined with other factors this request may become problematic. If for instance all Yard Buildings were on lots with significantly wide lots where all could be front-loaded this may not be an issue. However, the minimum lot width is 30 feet. Any lots narrower than 45 feet should be required to provide alley (rear-load) access in order to protect the pedestrian environment on the street side of the home, and eliminate the visual design conflict of the garage door dominating the front façade of the home. In this instance a 25-foot rear yard setback will allow for a driveway pad that will Attachment: JWS - UT-American Fork - Patriot Commons - Submittal Response ( ) (TOD Discusion - Joint Work Session) Page 2 Packet Pg. 19

20 2.1.b PATRIOT COMMONS SUBMITTAL RESPONSE allow for extra off-street parking putting it in the rear of the property as opposed to the front (on-street parking). Maximum Lot Width An adjustment of the maximum lot width from 70 feet to 80 feet is a realistic request, if a cap on the number of these larger lots and specific designation of their location (only within a Residential Edge Sub-district) can be established. This request just needs some added detail to it to ensure the opportunity for larger lots isn t over used. Parking and Vehicular Access Any attempts to eliminate alley requirements should be denied. The use of alleys is a critical element to ensuring good design which contributes to public safety as well as community aesthetics. Minimum Overall Height It is reasonable to allow for the height standard to be reduced from 1.5 stories to 1 story. Yard Building design doesn t particularly incorporate the use of half stories. The reduction to 1 story does not preclude the design of 1.5 story product if warranted. 3) TOD Neighborhood/Local Streets and Alleys The request for a neighborhood street standard is astute on the part of the developer, because the TOD Code does not address the inclusion of neighborhood/local streets as presently written. A standard (or standards) need to be created to fill this gap in the existing code. The developers request can certainly start the conversation, but more thought needs to be put into the standard(s) that end up being formally adopted. For example, the cross section being proposed by the developer includes a 4 foot parkway which would include street trees. Numerous studies have shown that the minimum width allowed in order to ensure proper health of street trees is 6 feet. Secondly, travel lane width is a direct indicator of travel speeds. In a neighborhood/local setting an 11-foot travel lane (accompanied by a 6-foot shoulder) creates a recipe for higher speeds and a deterioration of the pedestrian environment. 10-foot travel lanes should be considered. Lastly, what is the intent for the shoulder in the design? Is it intended to accommodate and allow for on-street parking? If YES, then this needs to be directly called out and a determination of whether 6 feet is accommodating enough to allow on-street parking should be considered. If NO, then the amount of shoulder should be considered for reduction so as to not generating the perception of wide travel lanes which will lead to an unsafe increase in travel speeds. The proposed alley cross section identifies a flaw in the present alley standard, which is the inclusion of sidewalks within the alley. Informal pedestrian access is to be expected within alleys, but the inclusion of formal pedestrian elements is unnecessary. The removal of the sidewalks is a positive step. However, 13-foot travel lanes are simply too wide. It is presumed that the 13-foot travel lanes are an effort to address fire code requirements for 26-feet of clearance for fire Attachment: JWS - UT-American Fork - Patriot Commons - Submittal Response ( ) (TOD Discusion - Joint Work Session) Page 3 Packet Pg. 20

21 2.1.b PATRIOT COMMONS SUBMITTAL RESPONSE trucks. This is an overly prescriptive standard for alleys since any fire truck access will come from the street side rather than the alley side. This includes access to fire hydrants. As long as the code for hydrant coverage is met there is very little reason for emergency response vehicles to need alley access. This, alleys should be built to driveway standards, since they are in essence a shared driveway. Also, the alley width can be safely reduced to 20 feet (10-foot travel lanes) since the 26 foot clearance shouldn t be an alley requirement. Alley widths of less than 20 feet can also be adequately considered. Attachment: JWS - UT-American Fork - Patriot Commons - Submittal Response ( ) (TOD Discusion - Joint Work Session) Page 4 Packet Pg. 21