From:
Grow Raleigh Great
To:
Raleigh City Council
Attachments:
Dear
Raleigh City Council members,
Recently, local members of the
International Council of Shopping Centers (ICSC) submitted a paper entitled
“Sensible Retail Zoning” to the Raleigh City Council. In their introductory
letter, the ICSC noted concerns with the Grow Raleigh Great initiative founded
by residents from across the city this spring. We appreciate the ICSC’s
interest in Raleigh and trust that the organization shares similar objectives
that align with Raleigh’s commitment to protect and preserve neighborhoods.
Attached is our response to the
ICSC paper. To summarize:
We recognize the ICSC is
renowned as the premier global trade association of the shopping center
industry, representing the interests of shopping center owners, developers,
managers, marketing specialists, investors, retailers and brokers, as well as
academics and public officials. Grow Raleigh Great represents the interests of
neighborhoods, and the residents who call Raleigh home.
Grow Raleigh Great observes
that the ICSC white paper includes misstatements and incorrect assertions. Note
as well that the ICSC presents data that has been modified from its original
source. These changes may be misleading to Council members or other readers, so
our response includes the actual source data as an exhibit – please see the
ICSC document entitled “U.S. Shopping-Center Classification and
Characteristics” from January 2014.
It is important to note that the ICSC source document agrees with Grow Raleigh Great on several points:
It is important to note that the ICSC source document agrees with Grow Raleigh Great on several points:
·
Grocery stores
anchoring neighborhood centers are much smaller than 50,000 square feet. The
average anchor in neighborhood centers ranges from 21,000 to 35,000 square
feet.
·
Larger grocery
stores belong in community centers. The ICSC source documents state that the
average size anchor of community centers is 50,000 square feet.
·
The range of
anchor sizes for neighborhood centers (21,000 to 35,000 square feet) agrees
well with the definition of “superstore” put forward by another industry group,
the Food Marketing Institute. According
to the FMI superstores are greater than 30,000 square feet.
·
Given that
Raleigh’s Comprehensive Plan excludes superstores from Neighborhood Mixed Use
areas, we find that the ICSC and the FMI agree with Raleigh’s Comprehensive
Plan.
There are assertions and
misinformation in the ICSC white paper that we take exception to.
·
Neighborhood
centers defined in the ICSC source document serve a radius of three miles while
convenience or strip centers serve one mile or less. The white paper mentions convenience centers
but fails to mention that their average size is 13,000 square feet. Grow Raleigh Great supports centers with
stores up to 30,000 square feet, the average for a neighborhood center.
·
After opening
their white paper by detailing their own shopping center classifications that
were, in their words, "based on data that underwent years of scrutiny from
industry experts", they abandon that data and begin discussing the average
size of grocery stores in the U.S. At this
point they also misrepresent data from the Comp Plan by asserting that NMU is
intended to serve multiple surrounding neighborhoods while conflating CMU and
RMU together as servicing regional populations.
In reality, the Comp Plan states that NMU "serves the immediately
surrounding neighborhood" (singular), while it is the job of CMU to
"draw from multiple neighborhoods" and only RMU is considered
regional.
·
The ICSC white
paper states that grocers are moving away from the neighborhood concept and
building bigger stores. Although we are not experts in the grocery store
business, we do note the following article in Time, “Your Grocery Store May
Soon Be Cut in Half”, that was published June 2, 2014. According to this article chains such as Aldi
and Trader Joe’s successfully operate stores under 20,000 square feet. The
article also links to additional articles documenting how traditional grocers
such as Walmart, Kroger, and Publix are experimenting with smaller format
stores. Notably, one of those articles dated
May 7, 2014 is entitled, “Publix quietly working on smaller prototype store”
and details its plans for a 20,000 square foot store.
Whatever the trend, Raleigh should not have to increase the size of its neighborhood centers to accommodate large stores. Instead, large stores serving large areas should move into zoning districts designed to accommodate them, be that CX or larger zoning districts.
Whatever the trend, Raleigh should not have to increase the size of its neighborhood centers to accommodate large stores. Instead, large stores serving large areas should move into zoning districts designed to accommodate them, be that CX or larger zoning districts.
·
The ICSC white
paper includes 12 grocery-anchored shopping centers, and states that these
centers “would not have been developed if the City discarded the
industry definitions and practices as outlined herein.” Grow Raleigh Great
disputes this claim. We agree with Raleigh’s Planning Staff, which has remapped
all of these shopping centers, except one, to Commercial Mixed Use (CX).
The one exception is the proposed Shoppes at Bedford Falls. The site is
currently undeveloped, and a rezoning proposal has yet to reach the Planning
Commission. We find it telling that of the examples provided, none of the
existing shopping centers is remapped to Neighborhood Mixed Use. As with the
modified ICSC source document, we do not want the Council to be misinformed on
these important facts.
·
Grow Raleigh
Great recommends the addition of an intermediate zoning district between NX and
CX. The white paper suggests that Grow Raleigh Great’s recommendation will
prevent large stores from being built. Additional gradations in zoning provided
by an additional zoning district will simply clarify and make transparent where
large shopping plazas with large anchors should be built. We suggest that the ICSC fails to understand
our position, and that is understandable. They have not been involved in the
extremely productive discussions that have taken place in the Comprehensive
Planning Committee meetings since June.
As our response paper
concludes, it appears that a multitude of interests, including the ICSC, the
FMI, City staff and Grow Raleigh Great have all separately arrived at a similar
conclusion: Neighborhood Mixed Use centers
are anchored by single retailers around 30,000 square feet. Larger retailers,
or multi-retailer anchored centers should not be zoned for Neighborhood Mixed
Use. They should be zoned to larger districts, such as Grow Raleigh Great’s
proposed CX-Small and CX-Large.
We invite the ICSC to join the
effort to clarify the vagaries of the UDO, its failure to implement the
Comprehensive Plan and to creating a development process that is predictable,
consistent and beneficial. And, that lives up to the City of Raleigh’s mission
statement and its commitment to “…welcome growth and diversity through policies
and programs that will protect, preserve and enhance Raleigh's existing
neighborhoods.” Grow Raleigh Great agrees with this mission, and we will
continue to pursue sensible policies that enable growth and protect
neighborhoods.
Regards,
Grow Raleigh Great
