REGULATING MOBILE FOOD VENDING IN GREENVILLE, SC

A Terminal Project Presented to the Faculty of The School of Planning, Development, Preservation, and Landscape Architecture, College of Architecture, Arts and Humanities, Clemson University In Partial Fulfillment of the Requirements for the Degree of Master of City and Regional Planning May 2012 Jason Tanenbaum

Approved:

________________________________ Dr. Cliff Ellis Committee Chair

________________________________ Dr. Barry Nocks Committee Member

Table of Contents Introduction ......................................................................................................................... 1 Review of Literature ........................................................................................................... 5 Tactical Urbanism ........................................................................................................... 5 Process Based Benefits of Tactical Urbanism ................................................................ 7 Benefits of Food Trucks ................................................................................................ 11 Social Benefits........................................................................................................... 12 Economic Benefits .................................................................................................... 14 Arguments Against Food Trucks .................................................................................. 16 Social Concerns ......................................................................................................... 16 Economic Concerns................................................................................................... 17 Conclusion .................................................................................................................... 18 Research Questions ........................................................................................................... 19 Research Methods ............................................................................................................. 19 Data Collection ............................................................................................................. 19 Appropriateness of Food Trucks ............................................................................... 20 Laws, Regulations, Programs and Policies ............................................................... 20 Data Analysis ................................................................................................................ 25 Appropriateness of Food Trucks ............................................................................... 25 Laws, Regulations, Programs and Policies ............................................................... 26 Results of GIS Analysis .................................................................................................... 27 Results of Regulatory Analysis ......................................................................................... 36 Regulatory Clarity and Accessibility ............................................................................ 36 Maximizing Vendor Flexibility and Certainty .............................................................. 40 Location Restrictions on Street Vending .................................................................. 40 Location Restrictions on Private Property Vending .................................................. 45 Hours of Operation .................................................................................................... 49 Predictability and Certainty....................................................................................... 51 Balancing Public Good and Private Burdens ................................................................ 54 Advancing Social Goals ................................................................................................ 57
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Recommendations for the City of Greenville ................................................................... 62 Public Process ............................................................................................................... 62 Unified Ordinance ......................................................................................................... 63 Licensing ....................................................................................................................... 63 Street Vending............................................................................................................... 64 Private Property Vending .............................................................................................. 65 Public Health and Social Goals ..................................................................................... 66 Additional Efforts ......................................................................................................... 67 Concluding Thoughts ........................................................................................................ 68 Appendix – Case Study Summaries .................................................................................. 69 Works Cited ...................................................................................................................... 92

List of Tables Table 1 - Population of case study cities .......................................................................... 23 Table 2 - Number of employees in focus areas ................................................................. 35 List of Figures Figure 1 - Map of case study cities ................................................................................... 23 Figure 2 - Food Vendors in Greenville ............................................................................. 30 Figure 3 - Food Vendors and Employers in Greenville .................................................... 31 Figure 4 - Food Vendors and Employer Service Areas .................................................... 32 Figure 5 - Small area focus ............................................................................................... 33 Figure 6 - Small area focus ............................................................................................... 34

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Introduction This project addresses the question of how the city of Greenville, SC should formulate and implement a policy encouraging the operation of food trucks, more generically known as mobile food vending, in the city. The facilitation of food trucks is a form of tactical urbanism that the city can encourage at relatively low cost and low risk. No large scale infrastructure is required since the bulk of the monetary investment will come from private entities, people who want to operate food trucks in the city. However, if successful, the city can realize economic, social and environmental benefits that more than justify any expenditure. Citizens, whether those who own and operate food trucks, those who patronize them, or the general public at large can also derive economic, social and environmental benefits from development of a vibrant food truck culture. This project, therefore, is aimed at helping the city make decisions that encourage productive and beneficial behavior while minimizing potential conflicts and harms. Mobile food vending is by no means a new concept. The chuck wagons that became popular in the 1860s were mobile kitchens that served the cattlemen driving herds overland to support westward expansion (Thompson, 2011). Urban lunch wagons, ice cream   trucks,  fruit  vendors,  and  others  including   a  1940’s  waffle  truck  in  New  Orleans   help fill in the subsequent history (Ottuski, 2011). However, mobile food vending has recently started to experience an evolutionary change and period of growth. The new “culinary  trend”  has  been  traced  back  to  2008  and  the  establishment  of  notable  gourmet   food trucks such as Kogi Korean BBQ in Los Angeles and the Rickshaw Dumpling Bar in New York (Buck, 2011; McCracken, 2011). In the following years, food trucks have become  an  “anthropological  phenomenon”,  at  least  according  to  the  increasing  number  of  

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Google searches (Hancock, 2011). It is this development that highlights the need for Greenville to re-examine its regulatory policies, policies formulated during a time when food trucks were not always viewed as potentially desirable. This evolution in food truck industry is characterized by both quantitative and qualitative changes. Quantitatively, the popularity of food trucks has been increasing dramatically. A report by the National Restaurant Association shows that consumer interest   in   visiting   a   food   truck   has   “increased   significantly,”   with   the   percentage   of   people surveyed who said they would visit a food truck run by their favorite restaurant rising 12% from the prior year to a total of 59% percent (Stensson, 2011). Other research by a private consultancy firm found that experiences of food truck customers were very positive, with 91% of respondents indicating that they would continue to support food trucks over the coming year (Technomic Consulting, 2011). Based on 2010 sales growth, one  financial  information  company  ranked  “Catering  service  or  mobile  food  contracting”   as the top service business to open in 2011 (Bierman, 2011). Even established restaurant chains are beginning to move into the mobile food business, despite the cultural contradictions this raises (Daley, 2011). The fact that chain restaurants might be an uneasy fit in the food truck world highlights the reality that the modern food truck industry is qualitatively different from the pre-existing  model  of  mobile  food  vending.    Whereas  food  trucks  “used  to  be known as  ‘roach  coaches’  with  sub-par  fare”  they  now  increasingly  serve  high quality, gourmet fare and are operated by entrepreneurs with culinary training (MacDonald, 2011). No longer confined to traditional foods such as hot dogs or tacos, food truck customers can find everything from gourmet ice cream to escargot. Also distinguishing the modern

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food truck scene is the use of modern technology to support the businesses.

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effectively reach a broader customer base and overcome the uncertainties of not always having a predictable location, food truck operators typically make use of social media such as Twitter or Facebook to broadcast their location or menu to their customers and the   public,   giving   rise   to   the   tendency   to   refer   to   these   businesses   as   ‘Twitter   Trucks”   (Sayers, 2011). Other innovative uses of technology include being able to take mobile credit card payments, GPS tracking, dedicated mobile phone apps that allow customers to pre-order and pre-pay, and digital menu screens that facilitate creativity (Drell, 2011). The mainstream media has become aware of food trucks, as evidenced by at least two national TV shows dedicated to the phenomenon. It is therefore not a stretch to suggest that these developments make food trucks worthy of a fresh look by city planners and policy makers. This project focuses on formulating a plan for Greenville, South Carolina because of the noticeable lack of a developed food truck community. The city of Greenville has a thriving award-winning downtown that features a wide variety of non-chain restaurants. The city hosts an annual food festival, Euphoria, which attracts top chefs from around the country.    One  of  the  city’s  most  popular  events,   the  annual   Fall  for  Greenville  festival,   centers on what are essentially temporary street food vendors. Yet, articles about food truck cities do not include Greenville, since few trucks are operating in the area. The first truck recognized as one of the new breeds of mobile food vendors has only recently begun operation (Reynolds, 2011). Given the potential benefits of food trucks, discussed herein, and the current undeveloped state of the industry in the city, Greenville represents

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an opportunity to develop and implement a plan that anticipates potential conflicts and facilitates productive business incubation. This report is organized into five sections. The review of literature presents some theoretical and empirical research relevant to the discussion of mobile food vending. This section is offered as support for the underlying assumption that food trucks are potentially beneficial for urban areas. That said, this report should not be seen as

advocating for food trucks in all situations. The discussion includes both potential benefits and concerns that will structure the following analyses. The remainder of the report will present an objective analysis of factors to consider should Greenville or any other city choose to encourage mobile food vending. The section on research questions and methods provides details on data collection and analysis. The following two sections discuss the findings of the study, starting with the question of whether the potential benefits of food trucks in Greenville can be demonstrated and progressing to the discussion of regulatory concerns relevant to formulation of a food truck policy. The final section synthesizes the findings and applies them to the existing conditions in Greenville. The overarching goal is to help inform policy makers who may be

contemplating creation of new regulations or changes to an existing regime so that any resulting mobile food vending policy will be more likely to achieve the city’s goals and serve the needs of the various stakeholders.

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Review of Literature The increasing popularity and presence of food trucks in urban environments raises practical questions of how cities can maximize the benefits of these businesses while minimizing the potential negative factors. Notwithstanding the continuing debates about the benefits of the food truck industry, discussed infra, this project treats the presence of food trucks in a city as generally positive and desirable. Arguments supporting this assumption, applied both to the broad notion of tactical urbanism or the more specific phenomenon of food trucks, will be discussed. However, potentially problematic

concerns regarding urban food trucks will also be considered, particularly those related to public health, safety and welfare. The potential benefits and shortcomings of

encouraging food trucks will be used to evaluate regulatory options when formulating a plan for Greenville. Tactical Urbanism The use of food trucks as a tool for urban development is an example of a broader approach that can be seen as a counterpoint to large scale, top down planning efforts. Such approaches may be categorized as systems urbanism, in that they focus on the role of individual actors operating in the context of a larger system, or alternatively as a form of community urbanism, whereby decision making power is decentralized or explicitly draws upon extensive public input (Barnett, 2011). The San Francisco Planning & Urban Research Association (2010) refers to this phenomenon as D.I.Y or do-it-yourself urbanism,   focusing   on   “ways   in   which   small   or   finite   efforts   can   blossom into largerscale,  ongoing  transformations.”    These  types  of  actions  extend  the  individualist  notion  of   self-sufficiency to the community level (Page, 2008). This has also been called tactical

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urbanism.    Tactical  urbanism  views  “incremental,  small-scale  improvements  …  as  a  way   to stage more substantial investments”   (Lydon, 2011, p. 1). Yet another commentator prefers   to   use   a   more   verbose   description,   “Provisional,   Opportunistic,   Ubiquitous,   and   Odd   Tactics   in   Guerilla   and   DIY   Practice   and   Urbanism”   (Zeiger, 2011). For

simplicity’s  sake,  the  term  tactical  urbanism  will be used here. Regardless of the exact term used to describe these actions, several characteristics recur. Lydon (2011) describes the approach as being deliberate and phased, locally based, involving short-term commitments and realistic expectations. Actions involve taking small risks that have a potential for high rewards and attempt to build social capital between citizens and organizational capital between institutions and their constituents. Better Block projects, for example, use low cost structures, temporary street alterations and pop-up   programming   to   illustrate   “the   potential   to   create   a   great   walkable,   vibrant   neighborhood   center”   in   areas   that   are   currently   lacking   vibrancy  

(www.betterblock.com).

These projects have resulted in the creation of permanent

improvements, new businesses, and commitments by municipal authorities to continue improvement efforts (Lydon, 2011, p. 3). Page (2008) emphasizes the role of the public in such processes; DIY   urbanism   aims   at   “empowering   people   to   implement”   projects   rather  than  simply   “involving”  them   in   consultations.    (PARK)ing  day   celebrations,   for   example, have been spreading globally wherein citizens temporarily transform parking spaces into public parks by installing chairs and other amenities in the space after paying into the parking meter (see http://parkingday.org). Guerrilla gardening is a movement that sees citizens taking the initiative to improve plots of land that are vacant or overgrown by illegally  turning  them  into  “urban  gardens”  (Scott, 2011). These initiatives

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and others like them are likely to continue to be attractive following the economic collapse in 2008. Although supporters of tactical urbanism do not seek to replace top down, formalized planning efforts, but instead supplement and complement them, declining municipal budgets and public opinion shifting away from public spending may result in greater acceptance and reliance on these alternative means of promoting urbanism. Process Based Benefits of Tactical Urbanism While the preceding discussion hinted at some of the benefits of a tactical urbanism approach to urban improvement, various theoretical analyses of urban processes support the notion that these approaches have much to offer. One recurring theme relates to the notion that cities should be understood as a particular type of complex system. Weaver (1948, p. 539), in analyzing the nature of questions in the life sciences, argued that such questions   were   ones   of   organized   complexity,   “problems   which   involve   dealing   simultaneously with a sizable number of factors which are interrelated into an organic whole.”     Jane   Jacobs   famously   used   this   insight   in   describing   “what   kind   of   problems   cities  pose”  (Jacobs, 1961, p. 428). Jacobs argued that in order to formulate solutions to urban problems, it is essential to understand what type of problems they are. Problems of organized complexity are not amenable to narrow solutions that focus only on one element. Instead, solutions must focus on the several processes at work in the cities and consider the ways that they interact to generate the organic whole. Tactical urbanism, then, can be a valuable approach to urban development because it engages the urban processes that are at the root of various deficiencies.

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Tactical urbanism processes, in contrast to traditional rational planning, can engage these processes in various ways. For example, actions that occur at the local and

distributed  level  are  more  likely  to  put  “eyes  on  the  street”,  one  of  Jacobs’  prescriptions   for safer urban spaces (Jacobs, 1961, p. 35). Similarly, increasing the number of grass roots  activities  aimed  at  urban  improvement  can  help  build  trust,  something  “formed  over   time from many, many little public sidewalk contacts. (p. 56). Finally, again relating to the notion of cities as comprised of processes contributing to organized complexity, Jacobs  highlights  the  importance  of  diversity,  such  as  in  the  necessary  “mixtures  of  uses   …  sufficiently  complex  to  sustain  city  safety,  public  contact  and  cross  use”  (p.  144).    In   other words, the intermingling parts that contribute to a great city are the same types of factors on which tactical urbanism focuses. Jacobs was not the only theorist to discuss cities in this manner. As discussed by Mehaffy (2008), Christopher Alexander’s  New Theory of Urban Design also focused on processes of collaboration that result in emergent functionality and wholeness. In

contrast to the top-down forms of urban design, such as master plans, Alexander sought to encourage collaborative processes that create organized complexity and evaluated proposed developments in terms of how well they contribute to the wholeness of a city. These generative methods of development focused on local stakeholders who engage existing conditions and avoid standardization and over planning (p.66-67). The focus on complex processes stems from a recognition that urban systems are in fact organic systems. Hamdi (2004) builds on this insight by highlighting the special nature of human organic systems. Whereas organic systems are characterized by order emerging from the interactions of multiple local forces, not imposed by a single centralized force, human

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systems   do   need   structure   and   rules   to   “provide   continuity   and   stability”   and   promote   “shared   sense   of   purpose   and   justice”   (p.   xvii).     These   rules   and   structures,   however,   should emerge from the collective wisdom of people acting locally; this emergent order is more likely to include social integration, equality, interdependence,   and   be   “flexible,   durable,  and  …  infinitely  resourceful”  (p.xxiv).   For Sennett (1992), embracing anarchistic disorder is necessary in order to counteract individualistic psychological tendencies that are projected into urban development. Sennett sees the human tendency toward puritanism as a psychological response to fears of uncertainty. Just as people will avoid situations that challenge their sense of order, people will also seek to build cities in ways that mitigate their fears, such as through isolated and homogenous communities. Traditional planning supports these tendencies by imposing order over urban areas. Sennett argues, however, that these fears are counterproductive and that people need to be forced to confront each other, in part by prohibiting "preplanned, functional space" that stifles neighborhood diversity (p. 142). Planners thus have the obligation to impose some measure of disorder so as not to allow stifling of the forces that contribute to vitality and flexibility. Viewed in this light, local governments and organizations should use their authority to encourage forms of action such as tactical urbanism in order to create the conditions for organized complexity. McFarlane (2011) emphasizes the adaptive qualities of complex systems in his discussion  of  cities,  describing  “the  city  as  a  machine  for  learning.”    By  bringing  people   together in dense interconnected networks, cities enable problem solving and gains in productivity. These gains play a key role in economic development, whether in

Schumpeter’s   ‘knowledge   economy’   or   Florida’s   ‘smart   cities’   (p.   361).     However,  

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"learning is a political and practical domain through which the city is assembled, lived and contested, and which offers a critical opportunity to develop a progressive urbanism" (p. 360). In other words, urban learning takes place throughout the city, in all contexts and not simply among a particular sector of the economy or class of people. Tactical urbanism, then, enables urban learning in the informal contexts by tapping into "diverse modes of knowing the city" that come from "negotiating the always contingent gap between 'marginal' and 'mainstream'" (p. 365). They can draw upon the otherwise

marginalized people who have gained their knowledge by being immersed in the city and who often have an understanding of urban matters that are unknown to policy makers and formal organizations (p. 366). Including these oft-excluded individuals and groups into the   act   of   urban   planning   may   help   foster   “new,   more socially just forms of urban dwelling”  (p.  373). Harvey (2008) argues for the propriety of local, grassroots efforts from a democratic perspective. Urbanization, for Harvey, has served the interests of capitalists by

stabilizing economies in light of capital surpluses. However, this has had adverse effects on livability and quality of life through the encouragement of placelessness, hyperindividualism, deterioration of collectivity, inequality, political and social fragmentation, and the undermining of ideals of citizenship and belonging (p. 31-32). From Baron Haussman to Robert Moses, he argues, there has been a tradition of dispossessing people in the name of creative destruction in violation of what should be considered a human right – the right to have democratic control of the way urban development proceeds (p.33-37). While Harvey is likely calling for fundamental structural changes in the political-economic framework, tactical urbanism fits within his call for more

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democratization, for taking control of the way cities develop, and undermining the power of established capital. A final aspect of tactical urbanism that makes it a potentially valuable tool in urban improvement is the fact that many of the actions occur in public spaces which are as integral to cities as other elements of the built environment. Mehta (2007) summarizes a number  of  commentators  who  all  conclude  “that  it  is  the  streets,   plazas, squares, parks, and other urban public spaces that have the ability to support, facilitate, and promote public  life,  which  is  an  essential  counterpart  to  our  private,  home  and  work  spaces.”    He   goes further to argue that streets are in fact the primary urban public space, given the sheer amount of public space dedicated to streets, but also the fact that people use streets in so many aspects of their lives (p.165). Oldenburg (1999) has argued for the

importance  of  “third  places,”  gathering  places  outside  of  home  and  work  that  are  essential   for social and political life. While Oldenburg refers mainly to destinations such as bars or restaurants, studies by Mehta (2007) and Mehta and Bosson (2010) examined the role that public spaces and streets can play as third places. Their findings highlight some of the conditions necessary to transform a public street into a place for socialization and vitality, such as the provision of seating, shelter and personalization. These are exactly the types of amenities that tactical urbanism practitioners seek to provide. Benefits of Food Trucks Whereas the preceding discussion highlighted some of the common benefits of a tactical urbanism approach to urban improvement, each specific tactic presents its own particular benefits and drawbacks. The benefits (and critiques) of food trucks tend to fall within two broad categories – social and economic. Examination of the contours of these

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benefits provides guidance for localities who seek to encourage food trucks. Local officials should be able to clearly state the desired outcomes from a well-regulated food truck industry and have solid values underlying and guiding the policies. Crafting a new policy in Greenville will involve questions of balancing these benefits and burdens, ideally with the goal of imposing burdens only to the extent necessary to advance the public interest. Social Benefits Food trucks may play an instrumental role in contributing to the social life of cities. In his study of why some public spaces work better than others, Whyte (1980) identified food as one significant   contributor.     “If   you   want   to   seed   a   place   with   activity,   put   out   food,”   he   writes,   because   "food attracts people who attract more people" (p. 50-52). Food  vendors  often  possess  “a  good  nose  for  spaces  that  work”,  the  type  of  experiential   knowledge of cities that McFarlane discussed (p. 50). Alexander, Ishikawa, and

Silverstein (1977) agreed and included food stands as part of the pattern language for desirable   cities.     Food   stands   are   “natural   public   gathering   places”   that   support   various   social  “habits  and  institutions”  (p.  455).    These  benefits  have  been  observed  in  areas  with   successful food truck cultures such as Los Angeles, where social activity surrounds food carts, helping to create more vibrant urban spaces (Hermosillo, 2010). In Portland, Oregon, one of the more prominent cities for mobile food vending, the social life around food truck pods features informal conversations among customers, people using the areas as public meeting spaces, and ongoing social relationships between customers and vendors (Kapell et al., 2008, p. 26). MacIver (2011) reports on how food trucks can alter the social dynamics in a public space, potentially calming existing tensions. The City of

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Seattle (2010) views street vendors as a way of improving public safety, by putting more ‘eyes   on   the   street’.     From   a   land   use   perspective,   mobile   food   vending   is   one   way   of   activating public spaces and making efficient use of otherwise vacant lots. In contrast to corporate franchises, often located on isolated lots or commercial corridors, food trucks can integrate their services conveniently in the context of daily activities and offer the personalized touch of owner-occupiers (Alexander et al., 1977, p. 456). Food trucks offer the possibility of creating more walkable environments, with a variety of associated benefits. As Glaeser (2010) notes, food trucks are particularly fitting for walkable cities built at a human scale. They provide convenient and affordable food options for pedestrians who might otherwise have limited options (Kapell et al., 2008). People seeking food at times when restaurants are not open, such as late nights, or people with dogs who are not always welcome inside restaurants are also particularly likely to make use of food trucks if available (Chastain, 2010). Recently, several

universities in California have signed agreements with food trucks to allow them to operate on campus (Fry & Luna, 2011). College students are merely one segment of the population that values walkability and can make use of the convenient food options that food trucks offer. For other groups, having access to food trucks addresses more fundamental concerns about the availability of food. Food trucks can help bring food into areas that lack affordable restaurants or even markets (Cameron Hawkins & Associates, 2011). They are also particularly useful to people who lack access to automobiles, a relatively common conditions when dealing with children, the disabled, the poor, or people who are transit dependent by choice or other circumstances (Hermosillo, 2010). Food trucks often

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find success in areas with a high population of workers, people with limited time available for lunch and who therefore value the convenience and speed of food trucks. As Tinker (2003, p. 332) argues, modern economies have made street foods more important since workers are less likely to work near their home and are frequently prevented from travelling to get food because of urban sprawl and road congestion. Increasing access to food is can also be coupled with efforts to encourage provision of healthy and local food options, thereby advancing additional social goals (Cameron Hawkins & Associates, 2011; Kapell et al., 2008). Economic Benefits While food is an important element of social and personal life, food trucks are businesses with implications for local economies. One compelling argument for

encouraging food trucks is that they can be instrumental in creating employment. A key reason for this is that food trucks require less startup capital than brick-and-mortar restaurants, or even other small businesses, and therefore have lower barriers to entry (Chastain, 2010; City of Seattle, 2010; Glaeser, 2010; Kapell et al., 2008). Removing some of the financial barriers may be sufficient to encourage people to start new food truck businesses. This is particularly true since food trucks provide particular kinds of satisfaction for their owners and are therefore attractive to potential small business owners. For example, food truck owners have a degree of flexibility in terms of setting their own hours and goals and maintain high levels of independence, leading to an improved quality of life (Chastain, 2010; Kapell et al., 2008). They also have high levels of community interaction, as discussed in the previous section.

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The economic activity associated with food trucks should be attractive to cities because of their local nature. As small business owners, many food truck owners are rooted in the community and therefore keep profits local (Chastain, 2010; City of Seattle, 2010). As Hermosillo (2010, p. 11) finds, not only profits but taxes, fees, and money spent  on  supplies  serve  as  a  “grassroots  solution  to  disinvestment  and  unemployment  in   many   communities”.     The   communities that receive these benefits are often among the neediest. In Portland, food trucks demonstrate high ownership rates among immigrants and ethnic minorities (Kapell et al., 2008). The City of Seattle (2010), sees food trucks as a way of targeting underemployed groups such as immigrants, minorities and women as well as supporting family run businesses. In fact, Tinker (2003) finds that street food vending is an important means for women to help support their family in countries throughout Africa and Asia. The popularity of food trucks among these groups is likely related to the lower capital requirements of food trucks but may also be a reflection of the lack of restaurants representing the culinary traditions of many immigrants and remaining barriers to the participation of women in business. Some of the economic benefits that flow from food trucks relates to the adaptable nature of the industry, thanks in part to the lowered barriers to entry. Chefs can test out new concepts or recipes somewhat easier than they could in traditional restaurant settings, resulting in innovative offerings (Glaeser, 2010; Huus, 2011). The close contact between operator and customer may lead to better and quicker feedback, enabling vendors to improve their products; close proximity to other food trucks can also lead to healthy competition resulting in more innovative products (Chastain, 2010). As such, cities   can   use   food   trucks   as   a   method   of   displaying   the   city’s   culinary   and   cultural  

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diversity (Cameron Hawkins & Associates, 2011). As Portland indicates, a vibrant food truck scene can be a source of neighborhood and city uniqueness, helping to draw residents and tourists (Chastain, 2010; Kapell et al., 2008). Arguments Against Food Trucks As stated previously, this project assumes the overall desirability of food trucks in a city. The preceding discussion of benefits indicates the reasoning behind this position. That said, there are legitimate concerns of both public and private actors regarding the implementation of food truck policies. They tend to fall in the same two categories as the benefits of food trucks – social and economic. The plan for the city of Greenville will take into account these factors in order to avoid or mitigate the undesirable conditions. Social Concerns Perhaps the most obvious concern with the operation of food trucks is the public health aspect of the business. Attention from public health researchers and officials tend to focus on issues of sanitation and vendor hygiene; given the potential for transmission of food borne illness, this is not an unwarranted concern (Tester, Stevens, Yen, & Laraia, 2010). Yet, these concerns are common for all food vendors, mobile or not.

Increasingly, public health questions also focus on issues of nutrition and freshness of food being served (Hermosillo, 2010; Tester et al., 2010). Whereas potential benefits of food trucks includes increasing access to fresh, local and healthy food, there is a corollary concern that food trucks will emulate corporate fast food restaurants and continue to contribute to problems of obesity and associated diseases (Cameron Hawkins & Associates, 2011). Given the connection between food trucks and underserved

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communities, i.e. poor, immigrant, and minority, the benefits to these populations would be somewhat undermined by delivery of unhealthy foods. Quality of life issues are a frequent complaint of opponents to food trucks. Hermosillo’s  2010  study  of  Los  Angeles  highlighted  a  number  of  concerns,  most  notably   the problem of trash. Studies in Toronto and Portland have indicated a similar worry (Cameron Hawkins & Associates, 2011; Kapell et al., 2008). However, the same studies indicate that food truck owners share this concern and would like more support from local authorities in the form of more public trash bins in the areas around trucks. Related issues involve food odors, particularly in residential areas, as well as general concerns about blight and crime that might be attracted to areas of activity around food trucks (Hermosillo, 2010; Kapell et al., 2008). Some of these issues could be solved through provision of amenities such as seating, shelter, or landscaping; the issue of public safety, as indicated by the discussion of food truck benefits, is debatable as well. The city of Toronto raised question of air pollution from generators or idling trucks, also a potential social or quality of life issue, as well as possible congestion in public spaces or streets (Cameron Hawkins & Associates, 2011). Economic Concerns The most common critique of food trucks, economic in nature, relates to the question of competition with brick-and-mortar restaurants. Essentially, traditional restaurants

claim that food trucks have unfair business advantages because they pay lower rents, do not pay various land development charges, do not have to follow building codes, and do not provide restrooms or seating to customers (Cameron Hawkins & Associates, 2011; Chastain, 2010). Although it is true that food trucks do not generally pay rent, they do

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incur various costs such as the purchase and maintenance of the truck and equipment, plus potential commissary charges in areas where trucks are required to be stored in designated locations (Kapell et al., 2008). In addition, studies have questioned whether food trucks actually compete with sit-down restaurants or whether they serve a different population or compete more with lunch counters, fast food and take out restaurants (Chastain, 2010). Although Glaeser (2010) argues for market forces to sort out which restaurants survive, a reasonable debate can be had as to whether some restrictions on food truck locations is justified in order to protect establish restaurants or prevent congestion. Conclusion The phenomenon of food trucks that is the subject of this project is a recent development and as such does not have a great deal of scholarly literature attached to it. That said, various urban theorists have written about issues related to food trucks in more general terms. These authors highlight some of the topics that a responsible city plan should consider. adaptability. These include issues of participation, equity, efficiency and

In addition, the limited literature specifically concerning food trucks

emphasizes other specific concerns such as the use of public space and streets, availability of food to vulnerable populations, entrepreneurialism and local economic development, and auto dependence. The specific research methodology to follow will draw upon this literature in order to more accurately focus the inquiry on topics most likely to be salient in discussions by policymakers and stakeholders.

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Research Questions The broad question to be answered is: How should the city of Greenville encourage the development of a thriving food truck industry? This question has two subsidiary questions: 1. Are food trucks appropriate for the city of Greenville? 2. If so, what laws, regulations, programs or policies should Greenville enact in order to encourage a thriving food truck industry? Research Methods Answers to the posited research questions will be derived through a mixed-methods approach. The goal is to answer the broad research question by approaching the

subsidiary questions using different methods. These two research questions address key concerns identified in the literature, i.e. the regulatory/policy framework pertaining to food trucks and the issue of finding appropriate locations for food truck operations. Each question, however, is amenable to different analytical techniques. The questions will therefore be treated as analytically separate. This research strategy can be conceptualized as  methodological  triangulation,  “the  use  of  multiple  methods  to  study  a  single  problem   or   program”   (Denzin, 1978). Although the questions will be analyzed separately, the results of the analyses will relate back to the original, broader research question. Data Collection Data for this study fell into two categories, corresponding to the two actionable research questions. All data consisted of archival material taken from public records or proprietary subscription data services and data retrieval was conducted primarily via electronic means. Telephone and email communications were used in some

circumstances to solicit data or to ask for clarification of unclear items. Specific data collection questions pertaining to the separate analyses are as follows:

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Appropriateness of Food Trucks Data for the GIS analysis of food service in Greenville consisted of quantitative and geospatial data obtained from both public and proprietary sources. The information on current businesses in Greenville was downloaded from Reference USA, a proprietary database to which Clemson University maintains a subscription. This data was used to identify and categorize existing food service establishments in the city and also for estimates of how many employees might be available to patronize food trucks. Only employers reporting 5 or more employees were included in the analysis. The list of businesses was examined in order to eliminate obvious errors such as double listing of businesses both as individual locations and an aggregate total. Information provided by the Greenville Area Development Corporation and by the City of Greenville Department of Business Licenses was also used to verify that no food service establishments or large employers were absent from the Reference USA database. GIS data layers used in the analysis were obtained from the City of Greenville. Population data was downloaded from the U.S. Census Bureau. Laws, Regulations, Programs and Policies The goal of the archival research was to identify and collect data that could be used when formulating a plan, amending laws, and implementing policies relevant to food trucks in Greenville. The data was collected by examining the regulations and policies employed by other cities in order to present policy makers in Greenville with a menu of options that illustrate common approaches. These options are not necessarily all

inclusive or appropriate for adoption; particular regulations may certainly be modified to fit particular concerns in Greenville. However, by comparing the approaches from a

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variety of cities, the path ultimately chosen in Greenville can be made in a more informed manner. Data was collected from fifteen cities in order to capture a variety of possible approaches to regulation. Cities were chosen   through   purposeful   sampling,   “selecting   information-rich  cases  for  study  in  depth”  in  order  to  “learn  a  great  deal  about  issues  of   central importance   to   the   purpose   of   the   study”,   i.e.   informing   the   city   of   Greenville’s   decision-making processes (Patton, 2002, p. 46). More specifically, theoretical sampling was used whereby cities were chosen   “on   the   basis   of   the   emerging   concepts,   with   the   aim  being  to  explore  the  dimensional  range”  of  the  regulatory  and  policy  options  (Strauss & Corbin, 1998, p. 73). The key consideration for selection was the presence of a developed food truck scene. In such cities, it was assumed that the regulations and policies are conducive, or at least not hostile, to the development of mobile food vending. Portland, Oregon, for example, is frequently mentioned as being the vanguard of food truck culture. Other cities, such as Asheville, North Carolina and Hoboken, New Jersey, were included because of their recent examination of the issues surrounding food trucks; an ordinance allowing food trucks in the downtown area was recently passed in both cities (Burgess, 2011). Because they are so recent, policies in these cities might have been formed in light of past developments, thereby increasing the likelihood of capturing the full spectrum of possible regulatory schemes. Although the geographic location or population of a city was not a primary criterion for selecting comparables, some efforts were made to ensure that case study cities were geographically diverse and represented a variety of scales. Table 1 lists the cities

examined and illustrates the sizes of those locations as compared to Greenville. The table

21

includes urbanized population in addition to municipal population. This is because municipal populations do not necessarily accurately reflect the number of people who might be in a city on a given day. Greenville in particular has a low municipal population relative to its urbanized population, a fact that is relevant for the GIS analysis as well. Figure 1 below illustrates the geographic spread of the case study cities.

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Table 1 - Population of case study cities

City Greenville Asheville, NC Austin, TX Boston, MA Denver, CO (incl. Aurora) Durham, NC Hoboken, NJ (incl. NY, Newark, NJ, CT) Honolulu, HI Los Angeles, CA (incl. Long Beach, Santa Ana) Madison, WI Miami, FL Minneapolis, MN (incl. St. Paul) Portland, OR (incl. Vancouver, WA) St. Louis, MO San Francisco, CA Seattle, WA
Figure 1 - Map of case study cities

2010 Population (SF1) 58,409 83,393 790,390 617,594 600,158 228,330 50,005 390,738 3,792,621 233,209 399,457 382,578 583,776 319,294 805,235 608,660

Urbanized Area Population (ACS 06-10) 322,048 241,486 1,031,104 4,084,553 2,067,512 310,789 18,083,721 767,117 12,009,536 344,712 5,278,094 2,437,965 1,774,292 2,078,224 3,254,650 2,935,248

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Collected data included laws, regulations and policies related to the following broad topics:          Licensing and permitting of mobile food vendors Public health oversight of food truck operations The operation of food trucks in public right-of-ways The operation of food trucks on private property or publicly owned lots Policy statements pertaining to mobile food vending Protection of neighborhood quality of life and environmental integrity Quality and quantity of information related to mobile food vending available through online sources Economic development programs applicable to food trucks, such as financial incentives, social media/technology tools, or training Programs for encouraging/promoting innovation in food trucks, e.g. competitions, showcases, and inclusion in local events

Sources of data included municipal websites, such as Planning and Economic Development, and online legal codes, such as Municode and American Legal Publishing Corporation. There was no uniform organization of the regulations pertaining to mobile food vending. Applicable regulations were scattered throughout the following sections of the various municipal, county, or state ordinances:       Business licensing and regulation Traffic Zoning and development Public health Taxation and finance Parks and recreation

Data collection was limited to regulations pertinent to full service food trucks, rather than all forms of mobile food vending. While many regulations are relevant to different types of food vendors, treatment of full-service food trucks does differ in some ways from treatment of sidewalk vendors, non-motorized pushcarts, or vendors who sell prepackaged, pre-cooked, or pre-assembled foods. Public health regulations, for example, are typically more stringent for vendors who are transporting and cooking raw foods than
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for those who are merely reheating previously cooked items. Regulating the location of sidewalk vending addresses questions and concerns similar, but not identical to, regulations of food trucks operating on the street or on private lots. Finally, not all details of the mobile food vending are discussed in this report. Although all aspects of the regulations were examined, some elements were so common or exhibited minimal variation such that they were not analyzed in detail. For example, as a general rule, food trucks must obey all motor vehicle laws unless specifically exempted. This includes obligations such as paying parking meters, not vending in intersections, or not interfering with traffic flow. Public health regulations governing food trucks are typically very detailed and include technical specifications such as required water temperature for sanitation, methods of waste storage and disposal, or proper food handling techniques. These commonly overlap regulations of brick and mortar restaurants but may also include details specific to mobile food vendors. Evaluation of these technical matters was beyond the scope of this project. This report, therefore, does not attempt to present a complete list of applicable regulations that may be appropriate for regulation of mobile food vending in a city. Data Analysis Appropriateness of Food Trucks GIS analysis was used to interrogate the question of whether Greenville is an appropriate location for food trucks to operate. The basic process is to compare the location of food service restaurants to the concentration of potential customers, employees at work in this case. The network analyst functions of ArcGIS were used to construct service areas surrounding each food establishment based on spatial travel

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distance to or from those locations. This map was then overlaid onto business data that illustrates the spatial distribution of workers in the city. The end result highlights areas where concentrations of people who can potentially make use of food trucks are most distant from existing restaurants. It is in these areas that the presence of food trucks will have a good chance of finding a customer base. These customers are also likely to benefit from the reduced automotive dependency resulting from the creation of more convenient food services. Laws, Regulations, Programs and Policies The goal of analyzing the data pertaining to food truck laws, regulations, programs and policies was to investigate the approaches taken by other cities and thereby to inform the planning process in the city of Greenville. As the modern food truck phenomenon is a fairly recent development, this project is exploratory in nature. There is, as yet, no explicit empirically based, theoretical framework of how municipal regulations and policies affect the success of local food truck industries. There are, however, isolated surveys and widespread anecdotal evidence, previously discussed in the literature review, which suggest criteria upon which regulatory and policy decisions should be based. These ideas were used to structure an inductive analysis of the archival data, whereby conclusions   “emerge[d] out   of   the   data”   (Patton, 2002, p. 453). Factors upon which analyses were based included:
     Regulatory clarity and accessibility Effect of regulations of vendor flexibility Effect of regulations on predictability and certainty Balancing public goods and private burdens Advancing social goals

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Results of GIS Analysis The GIS analysis of Greenville centers on the question of whether there is a demonstrable potential demand for food trucks in the city that could be the justification for regulatory changes designed to encourage development of the industry. Although there are likely to be multiple potential customer bases for food trucks, this analysis focuses on people at work, long a traditional target for mobile food vendors. These are people who may spend seven or more hours per day in places where it is impossible or impracticable to prepare their own food. Available time for meals is typically limited and convenience in obtaining food is therefore desirable. While some workers will bring food from home, others patronize local food establishments. Food trucks are simply a form of food establishment, albeit one that is more mobile than most. The location of current food establishments in the city can be seen in Figure 2. For purposes of this analysis, food establishments include several different types of businesses that typically offer food that could serve as a meal for someone at work. Full service restaurants are those that involve on premises seating and fully prepared foods. The category covers everything from high end restaurants such as American Grocery to chain restaurants such as the Olive Garden and fast food businesses such as McDonalds. Limited service restaurants are typified by sandwich shops that serve meals which are typically assembled but not cooked to order. Snack and nonalcoholic beverage bars include   businesses   such   as   Starbucks   and   Dunkin’   Donuts   that   focus on beverages but also serve a limited food menu of sandwiches and snacks rather than full meals. Retail bakeries are included because they frequently offer sandwiches and other foods that could sustain a person at work. Supermarkets and grocery stores, while primarily aimed at

27

selling ingredients used for cooking, increasingly feature sections that sell ready-to-eat food. This may be as limited as pre-made sandwiches and as extensive as stores like Whole Foods that offer extensive options. Finally, convenience stores are included as they too offer some ready-to-eat foods in addition to the more traditional convenience items. As the map illustrates, most food establishments are located along commercial corridors, which is perhaps to be expected. The next step is to add places of employment to the map as displayed in Figure 3. This dataset excludes food establishments since even though they also qualify as employers, the employees clearly have access to food and their inclusion on the map does not add to the analysis. Examining the locations of both food establishments and employers shows some degree of overlap but also reveals some separation, employers who are not directly adjacent to options for food purchase. To provide better perspective on the magnitude of this separation, service areas around the food vendors illustrate how much area is within a particular distance of the food establishments. The use of service areas instead of buffers generates areas that follow the contours of roads, more accurately representing the path that most customers would use to get to or from the business. Two service areas are displayed, one-quarter mile and one-half mile, which are commonly discussed as defining pedestrian scale development. In other words, people are more likely to consider walking somewhere if it is no more than a quarter mile (or half-mile) away. Figure 4 suggests the areas where a person is likely to consider walking to a nearby food establishment. There are a quite a few food vendors within a one-quarter mile walk and several more within the additional one-quarter mile area. However, there are also

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numerous places of business that are not within a walkable distance. These are people that might be attracted to food trucks because they eliminate the need to drive to get food. Figure 5 and Figure 6 provide a close up view of two of these areas where food trucks could be particularly welcome. As the maps and Table 2 indicate, each relatively small area has at least several hundred employees working in the vicinity. In addition, the maps highlight the fact that these businesses typically have on-site parking which could be utilized for mobile food vending. This analysis is offered as a proof of concept to illustrate the premise that brick-andmortar food service establishments do not provide optimal access to ready-to-eat meals. Food trucks could be a useful supplement, providing people with a convenient option and expanding their dining choices. Similar analyses could be performed for residential areas, potentially identifying food deserts where people do not have dining options within easily walkable distances, or bars and other places where people gather later in the evening. In addition, data layers showing vacant or undeveloped lots could highlight possible locations for food truck vending, including food truck pods. These have the potential to activate public space, thereby improving the neighborhoods in which they are located. All of these uses, however, require municipal ordinances that permit or facilitate these activities. This is the subject of the next section.

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Figure 2 - Food Vendors in Greenville

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Figure 3 - Food Vendors and Employers in Greenville

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Figure 4 - Food Vendors and Employer Service Areas

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Figure 5 - Small area focus

33

Figure 6 - Small area focus

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Table 2 - Number of employees in focus areas

Area 1 Company Berry Plastics Southeastern Products Inc. League Academy Cha Textiles Summit Drive Elementary School Meyer Center for Special Children Pendleton Manor American Fire Protection A Child's Haven Inc. CASTLE Industries LLC US Tool Inc. Emedia Group Inc. Miracle Hill Renewal Center Crawford Family & Cosmetic Chapman Enterprises Parkersway Foods Stone Lake Community Club Thomas Concrete Action Acrylic Compass Of Carolina Northgate Baptist Church Hardwick Printing Northside United Methodist Church Gary A Hester Interiors Wolf Mortgage & Processing American Exterminating Co Total: Employees 200 150 70 70 54 54 40 33 30 25 20 20 14 12 11 10 10 10 10 10 9 7 5 5 5 5 889

Area 2 Company First Baptist Greenville YMCA Orthodontic Associates PA Cleveland Park Animal Hospital City Kids Child Development Piedmont Oral Surgery PA Adult Upstate Dental Care LLC Greenville Family Practice WCA Inc. Signature Smiles Share Greenville Orthodontics Greenville Associate Church W Carter Brown Pa Crowns Now Family Dentistry Palmetto Family Dentistry Gilbert & Gilbert Pa St Matthew United Methodist Greenville Housing Authority Crossroads Apartments Greenville Endodontic Assoc. Andover Park Total: Employees 100 85 20 18 16 11 10 10 9 9 9 8 8 7 7 7 6 6

6 5 5 5 367

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Results of Regulatory Analysis The variety of regulatory regimes featured in the case studies highlights some of the possible approaches that the city of Greenville can take if it decides to enact a new ordinance designed to encourage and facilitate mobile food vending in the city. In order to capture the potential benefits of food trucks while mitigating the potential negative effects of the industry, the choice of code provisions should be based on an analysis of how well the different options advance the values fundamental to a successful food truck program, values that encompass the interests of private parties and the public. This section evaluates alternative code provisions in terms of how well they contribute to regulatory clarity and accessibility, maximize the flexibility of food truck operators’   efforts to reach customers, regulate in an equitable manner that avoids unnecessary burdens, and contribute to social goals and concerns of the city. Recommendations for the city of Greenville follow, taking into account the specific needs and conditions of that municipality. These recommendations recognize the necessity of balancing sometimes competing interests between the interests of vendors and the need for the city to protect the health, safety and general welfare of the community. Regulatory Clarity and Accessibility The organization, presentation, and availability of regulatory requirements for operating food trucks varied considerably among the case cities. Municipal ordinances and guidelines can be difficult to locate and to understand, particularly by people who are less than proficient in conducting computer searches, are not trained in the law, or have no prior experience operating a business in the jurisdiction. Eliminating unnecessary

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burdens on information gathering should therefore be a consideration for cities looking to encourage food trucks. Such consideration includes a number of factors. Since the research for this project was conducted primarily via Internet, no observations were made of how easy it is to get information on food truck regulations through personal visits to relevant offices. Presumably, at least some municipal offices would either have materials in printed format or could explain the processes to a prospective vendor. Nevertheless, relying solely on in-person visits imposes unnecessary costs on the vendors. Visits to multiple departments will likely be necessary, including business licensing, health, planning, public works, and traffic. While these various

departments may be located in the same general area, this is not guaranteed. In addition, visits to county and/or state offices will also be necessary and such offices are more likely to be located in different buildings or parts of the city. Given the increasingly widespread use of the Internet as a means of research and communication, a welldesigned, Internet based source of information can help reduce the burdens on vendors and increase the likelihood of compliance. The most basic aspect of creating a useful web presence is to maintain web pages dedicated to mobile food vending. The cities of Boston, Denver, Madison, Minneapolis, Portland, San Francisco, Seattle, and St. Louis each provide examples of what a positive web presence can entail. Each of these cities makes available information that is useful for prospective or current vendors. There are, however, variations on the type and amount of information that is provided and the way such information is organized. Boston,1 Denver,2 Portland,3 and Seattle4 are notable for hosting specific web pages that

1

http://www.cityofboston.gov/business/mobile/

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offer an overview of the regulatory process.     Seattle’s   page,   hosted   by   the   Office   of   Economic Development, is one of the most comprehensive. It addresses all aspects of licensing and permitting pertaining to street food vending with links to each city department responsible for overseeing that aspect of the process. The   city   of   Boston’s page was created to support the recently created food truck pilot program and is very comprehensive as well. In addition to providing a central online information page, some cities are better than others at providing useful resources about vending for download. Austin, for example, has created a detailed Frequently Asked Questions document5 that provides an overview of  the  regulations  and  answers  many  questions  that  might  arise.    Denver’s  downloadable   Food Truck Guide6 is a very comprehensive listing of regulations and contact information. Checklists are a particularly useful tool, such as those available in  Austin’s   application packet,7 from the  city  of  St.  Louis’  Food  Trucks  page,8 or  Seattle’s  economic   development site9. The city of San Francisco makes available a graphical flowchart10 that guides vendors through the various regulatory pathways, depending on the desired vending locations. For cities that limit the locations where vendors can do business, making maps available is an effective supplement to text based guidelines. Austin11

2

http://www.denvergov.org/businesslicensing/DenverBusinessLicensingCenter/BusinessLicenses/ RetailFoodMobileLicense/tabid/441702/Default.aspx 3 http://www.portlandonline.com/bps/index.cfm?c=52798 4 http://www.seattle.gov/economicdevelopment/mobilefood/ 5 http://www.austintexas.gov/sites/default/files/files/Planning/mobile_food_faq.pdf 6 http://www.denverstreetfood.com/wp-content/uploads/2011/02/Food_Truck_Guide_2011.pdf 7 http://www.austintexas.gov/sites/default/files/files/Planning/mfv_app_2012.pdf 8 http://stlouis-mo.gov/government/departments/street/documents/mobile-vending-permitchecklist.cfm 9 http://www.seattle.gov/economicdevelopment/pdf_files/Street_Food_Checklist.pdf# 10 http://www.sfdph.org/dph/files/EHSdocs/ehsFood/Mobile/FlowchartProcess.pdf 11 ftp://ftp.ci.austin.tx.us/npzd/Austingo/mfv_map.pdf

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provides an overview of permitted vending locations while web sites from Madison12, Minneapolis,13 and San Francisco14 link to detailed vending maps of specific areas where vending is regulated. Downloadable forms, such as vending permits or public health certification, comprise another popular category of forms that are provided by cities that are more proactive in educating vendors on relevant policies. Cities that provide readily accessible information can be contrasted with municipalities such as Asheville, Durham, Honolulu, Los Angeles, and Miami that provide little to no information dedicated to mobile food vending on their web site. Some cities, such as Asheville and Hoboken, have only recently passed food truck ordinances and therefore may have an expanded web presence forthcoming. Similarly, other cities, such as Honolulu, are contemplating new food truck ordinances and may make new regulations available when they are passed. In any case, obtaining guidance on vending in these locations is likely to be particularly burdensome to prospective vendors. For those people, the most reliable online sources of information are the online municipal codes themselves. This, however, presents certain challenges. Not everyone is aware of services such as Municode or the American Legal Publishing Corporation that host the codes. Even if someone does know to look there, they are then faced with the task of navigating the entire city code to find the relevant sections. Typically, relevant

provisions are scattered throughout different sections, such as business licensing, traffic, zoning, and public health. Requiring people to search through these codes raises the risk that important provisions will be overlooked. Once code sections are identified, vendors

12 13

http://www.cityofmadison.com/business/streetvending/maps.cfm www.minneapolismn.gov/www/groups/public/@regservices/documents/webcontent/ convert_272074.pdf 14 www.sfdpw.org/Modules/ShowDocument.aspx?documentid=1011

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must be able to read and comprehend the legal terminology which can be somewhat complex. All of this places unnecessary burdens on people who wish to start new vending businesses and can operate as a deterrent. Maximizing Vendor Flexibility and Certainty The characteristic that most defines food trucks is mobility. Because trucks have the ability to move from place to place, vendors can potentially go to where customers are located and thereby meet unmet demand for food. This flexibility may be limited by factors such as a scarcity of parking, lack of private property from which to vend, or customers located in areas impracticable to reach. More relevant to this study, vendor flexibility is limited by a variety of governmental regulations. To the extent that these regulations advance important public interests, they should be preserved. However, a well-designed food truck regulatory regime will balance the competing interests, maximizing vendor flexibility in ways that do not compromise the public health, safety or welfare. Maximizing flexibility, however, necessarily embraces some degree of

uncertainty. Unlike brick and mortar restaurants, food trucks have the ability to easily move to new locations that may or may not generate more business. City food truck ordinances have the power to alter this balance between flexibility and predictability. Examination of the case studies highlights some of the more common regulations which should be carefully considered. Location Restrictions on Street Vending The most common restriction on the flexibility of mobile food vendors relates to limitations on the locations where vending is permitted. Restrictions fall within two basic categories – those that list specific geographies and those that impose more generic city-

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wide restrictions. Within the first category, the most severe restrictions on permitted street vending locations were found in Asheville which categorically prohibited vending in public streets or right of way.15 This was the only one of the case studies which included such an extreme provision. While many of the other cities had designated zones where street vending was prohibited, presumably because of concerns for traffic or congestion, they did not prohibit it outright. Instead, restrictions on street vending

locations are based on a few different approaches, some more permissive than others. One slightly less restrictive approach is to allow street vending only in assigned locations. Even within this category is some variation as to the level of restriction placed on vending. In San Francisco, the Department of Public Works issues location specific permits based on spots proposed by the applicants.16 In contrast, Boston, Durham,

Madison, and Minneapolis maintain a list of locations from which applicants can apply. In Boston, the city has proposed changes to the relatively new food truck program which would expand permitted sites to 17, separated into tiers based on desirability of the location.17 These locations are in high traffic and high profile areas such as City Hall Plaza and Boston University. Madison operates a somewhat more expansive and

complex program whereby vending in certain high density locations is restricted to assigned site licenses but vending in other permitted areas are not assigned.18 As with Boston, vending in the busiest and most desirable locations in Madison, such as the State Street Mall and Capitol Concourse, are among those that are assigned by permit.19

15 16

Asheville Code of Ordinances §7-16-1(c)(40.1) San Francisco Municipal Code §184.84(i) 17 http://www.cityofboston.gov/Images_Documents/Proposed Changes_tcm3-20987.pdf 18 Madison Code of Ordinances Chapter 9 19 Madison Code of Ordinances §9.13(6)

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Minneapolis maintains a list of locations from which vendors may apply.20 Currently available choices include designated neighborhoods, streets, or specific corners. The use of detailed location restrictions raises the question of what process should be used to assign locations. This topic will be discussed infra. Increasingly permissive are cities that designate specific areas of the city where street vending is permitted without specifying the exact location where food trucks must reside. This allows for more flexibility than the assigned location approach since it allows vendors to move in response to perceived demand for their services. Austin’s  restrictions   are based on the zoning code, whereby mobile food vending is allowed only in commercial and industrial zones, but not in office zones.21 St. Louis designates eight specific vending districts that allow street vending.22 Seattle’s   approach   was   unique   among the cases studied in that street vending was allowed only in designated FoodVehicle Zones, but the location of the zones are designated based on vendor applications. These can be anywhere in the city with the exception of residential zones.23 The second category of location-based regulation of street vending involves restrictions that are less tied to specific geographies that the previously discussed provisions. For example, one recurrent type of regulation focuses on the portions of the street where vending is allowed. These are restrictions that are in addition to the more generalized traffic restrictions, such as the common prohibition against blocking driveways, crosswalks, or bike racks. The degree to which vendor flexibility is impeded depends on the specifics of the regulation and therefore do not neatly fall into the

20 21

Minneapolis Code of Ordinances §188.485(c) Austin City Code §25-2-812(c)(2) 22 St. Louis Code of Ordinances §8.108A 23 Seattle Municipal Code §15.17.120

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categorization previously discussed. For example, the most common restriction was to impose a mandatory distance between the food truck and existing brick and mortar restaurants. These buffers varied in length, as short as 20 feet, such as in Austin24 and Miami,25 or as long as 150 feet in St. Louis.26 The St. Louis buffer, although the largest observed, only applies to other street vendors or businesses selling comparable goods; this is more specific and less restrictive than other cities which mandate the buffer between the street vendor and all other restaurants, cafes, or food businesses. This type of restriction does not on its face appear to address any public health or safety concern, but instead is a likely result of political opposition to food vendors from restaurant owners. As such, the entire category is suspect and could be considered an unnecessary burden on vendors, an issue to be discussed further in this analysis. Also common are required buffers between food vendors and schools in session with some provisions being more restrictive than others. Madison’s  restriction  is  perhaps  the   least restrictive, prohibiting vending on certain streets directly adjacent to or across the street from a school property.27 Honolulu prohibits vending within a designated school zone while school is in session28 while other cities opt for a defined distance ranging from 500 feet in Los Angeles29 to 1,500 feet in San Francisco.30 Although municipal ordinances do not provide explicit reasons for this restriction, two possibilities come to mind. One relates to the concern that students will leave school in order to buy food from the trucks. In areas that do not allow students to leave the campus during the school day,
24 25

Austin City Code §25-2-812(C)(5) Miami Code of Ordinances §39-32(10) 26 St. Louis Code of Ordinances §8.108A.150(F) 27 Madison Code of Ordinances §9.13(1)(b)2 28 Revised Ordinances of Honolulu §29-6.2 29 Los Angeles Municipal Code §80.73 30 San Francisco Municipal Code §184.85(b)(3)(D)

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this may be a legitimate concern. In such circumstances, cities would be justified in limiting other types of commercial businesses that could be a draw for kids. In areas that do allow students to leave the premises, there may be concern that students are foregoing healthy food options in the school in favor of less healthy options from the food truck. This is problematic in that it assumes the school food options are in fact healthier than what is offered by the food trucks. This may not in fact be the case and the unintended consequence may be that students rely on vending machines or unhealthy food brought from home instead of freshly prepared options. In addition, prohibiting food trucks near schools deprives employees of access to those trucks. Whether this type of regulation is a justified restriction on the flexibility of vendors is therefore unclear and cities should carefully consider the issue before enacting such provisions. Other policies aimed at ensuring vendors serve healthy food might also be an option instead of this type of prohibition. A final aspect of this category that can constitute a significant restriction on vendor flexibility involves time based regulations. Honolulu has perhaps the most severe

provision, allowing street vendors to remain in one location for only 15 minutes.31 After this time, they must move at least 300 feet and not return to the same location for another 3 hours, regardless of how many customers are waiting to be served. Portland has a similar restriction, allowing vendors to remain in the same block only for 10 minutes; this provision, however, is limited to residential areas.32 Miami allows vendors to make a street sale only if approached or stopped for that purpose by a customer and they can

31 32

Revised Ordinances of Honolulu §15-13.6 Portland Municipal Code §16.70.550

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remain in that location only as long as it takes to make the sale.33 These ordinances can severely restrict the ability of vendors to conduct their businesses. Unlike ice cream trucks or vendors selling pre-packaged goods, full-service food trucks can benefit from stationary time to prepare foods in anticipation of customers. In addition, 10 or 15 minutes of idle time in between customers, while not ideal for the vendors, is not a particularly long time. To force a vendor to move to a new location after such a short time makes coordination between vendor and customer a difficult proposition, increasing the likelihood of lost sales and unmet customer needs. Location Restrictions on Private Property Vending Regulations defining where vending on private property is permitted invoke some of the same basic concerns as with street vending. Vendors will likely desire the most flexibility in choosing which locations are most advantageous while public health, safety, and welfare concerns underlie city efforts that restrict that flexibility. Maximizing

flexibility while addressing those public interest goals remains the challenge for a good ordinance. Unlike street vending regulations, which are typically found in either the business licensing or traffic sections of the municipal code, private property regulations are typically found in the zoning code, which adds some additional complexities to the regulatory landscape. One notable feature is that zoning regulations differentiate between principal uses, accessory uses, and temporary uses. This means that vendors will face potentially different regulations based on whether the activity is the only use of the land, such as with many food truck pods, or whether it is secondary to a principal use, such as a food truck serving businesses in an office park. Within given zoning areas, uses may be permitted by right, forbidden, or allowed as conditional uses, subject to additional
33

Miami Code of Ordinances §39-38(13)(d)

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regulations.

Temporary use permits add an additional wrinkle, whereby food truck

vending not permitted as a principal or accessory use might be allowed in a limited fashion under a temporary use permit. San Francisco, for example, has a provision for Temporary Use Authorizations which allows short-term uses, including food trucks, without going through the full planning process.34 Understanding the effect of these zoning regulations on vendors therefore requires a holistic view that encompasses each of the possible regulatory provisions. Given the idiosyncratic nature of zoning classifications among cities and the sheer number of different zoning districts within each city, a detailed examination of city zoning ordinances is beyond the scope of this project. Nevertheless, some broad trends can be observed. Subject to a qualification to be discussed infra, these regulations tend to permit or deny vending based on the type of zoning district where the vending would occur. As a general rule, mobile food vending in most cities is permitted, whether conditional use or not, in commercial, office, and industrial districts but is typically prohibited or highly restricted in residential areas. One exception is Asheville, which allows vending in urban village, neighborhood corridor, and urban place districts, which do include residential uses.35 Miami, the only case that employs a form based code, also allows vending in the more intense T4, T5, and T6 districts which typically include mixed uses including residential developments.36 Other cities such as Portland and San Francisco permit vending in designated multifamily or higher density residential zones. Austin adopts an interesting approach for both street and private property vending whereby neighborhood associations can vote to allow vendors in their districts, subject to
34 35

San Francisco Municipal Code §205.4 See Asheville Code of Ordinances Chapter 7 36 Miami Zoning Code Article 4, Table 3

46

certain buffer requirements.37 Similarly, in certain residential and commercial districts, San Francisco requires a neighborhood notification process whereby public notice of the proposed use is required and affected stakeholders are giving the opportunity to voice concerns or request a public hearing.38 Some municipalities allow vending only as an accessory use which narrows the flexibility of food truck operators to find locations. While Minneapolis might allow accessory use vending on approved lots in most districts if  “primarily  for  the  convenience   of the employers, clients, or visitors of the principle use,”39 Madison guidelines more narrowly  define  accessory  use.    For  example,  “it  would  not  be  legal  for  a  food  vendor  to   sell  food  on  the  private  property  of  a  key  shop  because  food  is  ‘not  an  accessory  to  the   principle business.”40 The complexity and uncertainty of private property regulations thus stands in contrast to the relative clarity of street vending regulations. This factor will be discussed further below. As with street regulations, private property vending can be subject to nongeographically based location restrictions. Imposing buffers between competing food establishments was fairly common, but also varied in terms of severity. Asheville, for example, requires food trucks to be at least 20 feet from each other for fire prevention reasons41 while Minneapolis imposes 100 foot buffers between trucks and restaurants or cafes on the same block face.42 Denver was the most restrictive in this regard, requiring

37 38

Austin City Code §25-2-812(M) San Francisco Municipal Code §§311-312 39 Minneapolis Code of Ordinances §537.110 40 http://www.cityofmadison.com/business/streetvending/streetVendorLicenseBasic.cfm 41 Asheville Code of Ordinances §7-16-1(c)(40.1)(d)(12) 42 http://www.minneapolismn.gov/licensing/business-licensing_docs_blip_mobile_food

47

200 feet of separation from another food truck or restaurant.43 Denver also adds an addition restriction that prohibits vending on undeveloped, uninhabited, or unpaved lots. This is a particularly onerous regulation given the potential for food trucks to activate such spaces. It is unclear why the city would prefer an uninhabited lot over one that is being used in economically and socially productive ways. Seattle, in contrast, operates a vacant and underused lots pilot program whereby up to 20 properties are made eligible for active use permits that would not otherwise be available for those sites or those zones.44 This type of program illustrates the positive role that legislation can play in maximizing vendor flexibility rather than burdening it. The wholesale exclusion of mobile food vending from residential areas raises a policy question that is not reflected in the final legislative codes. It would appear that food trucks are seen as unwelcome or potentially detrimental to those areas, thereby justifying their exile. Whether this is true or not is an empirical question – do food trucks bring undesirable externalities that residents are happy to avoid? This is a question worth interrogating by cities, given the potential for food trucks to bring potential benefits to those areas. One of the common criticisms of Euclidian zoning is that the strict

separation of uses makes traditional neighborhoods, with fine grained mixing of uses, illegal. The predominant method of regulating food trucks appears to support this claim. Even assuming that there are legitimate concerns about noise, pollution, or congestion, other potential benefits make the case for prohibition much less clear. There is no reason to assume that only people in commercial, office, industrial, or downtown districts need food. In fact, these districts are more likely to have food establishments available nearby.

43 44

http://www.denverstreetfood.com/wp-content/uploads/2011/02/Food_Truck_Guide_2011.pdf Seattle Department of Planning and Development Client Assistance Memo 246

48

People in residential communities may also desire or need, in the case of people with limited mobility, the kind of food service offered by mobile vendors. As such, this type of regulation is potentially an unjustifiably burdensome and counterproductive part of a wise food truck policy. Hours of Operation Along with laws regulating food vending locations, provisions defining the applicable hours within which food trucks may operate are present in almost every code studied. In some cases, situations, such as residential areas, restrictions may be justified by public health, safety, and welfare concerns. In others, these rules appear more like arbitrary limits on the flexibility of vendors to determine which hours are sufficiently profitable to justify their operation. Market mechanisms are likely to impose natural limits on vending hours, based on the availability of customers. If parts of cities are sufficiently populated during early or late hours, those people deserve to have the options to eat at food trucks as much as people during more traditional business hours. As such, the decision to limit operating hours is one that should be considered in light of both positive and negative aspects of mobile food vending in a community. The case study cities illustrate the range of options available for time-based regulation of food trucks. Potentially the most permissive are those that do not have any explicit limitation on operating hours. Honolulu, Los Angeles, Miami, Portland fall into this category. However, the caveat is that use regulations in the zoning code likely do impose some limits, at least in certain districts. Madison’s   code   does   discuss   operating   hours   specifically, but essentially allows 24 hour vending in the high density areas, albeit broken into a 5:00 a.m. to 1:00 a.m. segment for ordinary vending permits and a 9:00

49

p.m. to 6:00 a.m. segment for late night permits.45 A majority of the remaining cities examined utilize specific time frames within which mobile vending is permitted. The most permissive regulations impose a small time window where no vending is allowed. Asheville, for example, allows vending from 6:00 a.m. to 2:00 a.m. downtown and until 3:00 a.m. outside of downtown; vending near residential areas must cease by midnight 46 and Austin employs a similar 6:00 a.m. to 3:00 a.m. window.47 Cities such as

Minneapolis and St. Louis allow vending from 6:00 a.m. to midnight48 or 11:00 p.m.49 respectively. Denver is among the most restrictive, allowing vending only between 8:00 a.m. and 9:00 p.m.50 Some cities forego this type of definitive time regulations, instead reviewing proposed operating hours on a permit-by-permit basis. Durham is one such city; the Fixed Location Vending permit specifies limitations on vending days and hours as appropriate to  “promote  the  public  safety  and  convenience  of  pedestrians.”51 Seattle also permits   curb   space   vending   based   on   designated   “4-hour weekly increments. (For example, every Monday, Wednesday, and Friday from 10 AM – 2   PM.)”52 Boston utilizes a shift-based system as well, although it is particularly intricate. Vendors are assigned specific site and shifts, such as breakfast/lunch at City Hall Plaza or lunch at a Tier 2 site.53 This is part of an assignment process to be discussed further. Finally, San Francisco provides a large window for vending with the exception that vending after 8:00
45 46

Madison Code of Ordinances §9.16(6)(L) Asheville Code of Ordinances §7-14-2d(3)e 47 Austin City Code §25-2-812(C)(4) 48 Minneapolis Code of Ordinances §188.485(f)(4) 49 St. Louis Code of Ordinances §8.108A.150(A) 50 Denver Zoning Code §11.11.14 51 Durham Code of Ordinances §54-107(4) 52 Seattle Department of Planning and Development Client Assistance Memo 2507 53 http://www.cityofboston.gov/Images_Documents/Proposed Changes_tcm3-20987.pdf

50

p.m. requires vendors to file a notice of intent and submit to public review of their proposed hours.54 These types of approaches potentially maximize vendor flexibility, but raise an additional concern about predictability and certainty. Predictability and Certainty Much of the previous discussion has been concerned with maximizing the ability of food truck operators to make use of their mobility to find the best locations and times for their business. Gains in flexibility, however, can sometimes be accompanied by a loss of predictability and certainty to the detriment of individual food trucks. This is particularly relevant when it comes to the question of whether vending locations and times should be assigned along with the vending permit or whether trucks should be allowed to make those decisions on a more ad hoc basis. There is no simple answer to this question. For vendors who are assigned a particularly advantageous location, such as City Hall Plaza in Boston or on the State Street Mall in Madison, are guaranteed a steady supply of customers. For them, the likelihood of certain profits probably outweighs the loss of flexibility they suffer. On the other hand, those vendors who are not as fortunate with their assignments might not feel as blessed. To some degree this problem can be

mitigated by ensuring that all locations chosen for assignment are chosen because of their proximity to a sufficiently large potential customer base. Even lower tier sites in Boston might therefore still be more advantageous than not having such a designated spot. In these cases, certainty is a tradeoff that many vendors would be willing to make. Furthermore, given the fact that traffic and safety concerns probably justify the need to limit the number and location of vendors in these areas, the larger policy question

54

San Francisco Municipal Code §184.88

51

becomes moot.

However, absent demonstrable necessity to assign locations, the

argument for allowing market forces to operate becomes more persuasive. In at least one area, however, loss of certainty offers no benefits and is not based on concerns for the public health, safety, or welfare. This relates to a problem observed in some zoning code regulations of food trucks. Whereas the preceding discussion of where food trucks can operate on private property makes reference to city zoning codes, it made certain assumptions in light of uncertainties in those code provisions. The problem is that most of the zoning ordinances did not specifically identify mobile food vending as a regulated use. The four cities that did so were Asheville, Austin, Denver, and Seattle. A fifth city, San Francisco, does not do so but addresses the issue in Planning Department regulations   which   state   that   “[l]ong   standing   Planning   Code   provisions   allow   a   MFF   [Mobile Food Franchise] to be treated as if it were a bricks-and-mortar restaurant subject to conventional Planning Code provisions.”55 Similarly, Madison’s  Street  Vending  web   page explains that vending can occur on “private property zoned for commercial use”   despite the lack of specific mobile food vending terminology in the zoning code.56 In other cities, mobile food vending is not listed and therefore other comparable use regulations must be found. Some comparable uses are more easily identified with food trucks than others. Perhaps the most obvious comparable use would be restaurants. Durham’s   description   of   restaurants   as   “[e]stablishments   that   prepare and sell food for on- or off-premise   consumption”   would   certainly   seem   to   accommodate   food   trucks.57 Miami’s   definition   of   Food   Service   similarly   appears   to   accommodate   food   trucks.58

55 56

http://www.sf-planning.org/Modules/ShowDocument.aspx?documentid=8370 http://www.cityofmadison.com/business/streetvending/streetVendorLicenseBasic.cfm 57 Durham Unified Development Ordinance §5.2(D) 58 Miami Zoning Code §1.1

52

Another candidate for categorizing food trucks is the more general retail business use classification.    Boston’s  zoning  code  includes  a  retail  catering  use,  which  is  the “sale  over   the counter .. of on-premises prepared food or drink for off-premises consumption.”59 Honolulu defines retail establishments as including “establishments  where  food  or  drink   is sold on the premises for immediate consumption, but which lack appropriate accommodations for on-premise eating or drinking.”60 Portland, known for its food truck pods that operate on private property, clarifies that retail sales and service includes food sales.61 Not   all   cities   are   so   thorough   with   their   definitions.     Hoboken’s   definition   of   retail   business or service lists a number of examples, including food stores, but omits any language that would clearly cover food trucks.62 Los Angeles, while including

restaurants in specified uses, does not actually define the term. Consider that Hoboken specifies   that   restaurants   sell   food   “for   consumption   on   the   premises,” 63 thereby excluding food trucks and raising the question of what exactly constitutes a restaurant. Minneapolis   differentiates   delicatessen   restaurants,   defined   as   “an establishment which sells ready-to-eat foods, in bulk or individual servings, primarily for consumption off the premises, and is not a fast food restaurant.”64 Food trucks, while not delicatessens in the common usage of the word, might fall within this code section. St. Louis specifies carryout  restaurants,  “A  restaurant  where  food,  frozen  dessert,  or  beverages  are  primarily  sold   in a packaged, ready-to-consume state, intended for ready consumption by the customer

59 60

Boston Zoning Code §8-3 (36A) Revised Ordinances of Honolulu §21-10.1 61 Portland Municipal Code §33.920.250 62 Hoboken City Code §196-6 63 Hoboken City Code §196-6 64 Minneapolis Code of Ordinances §520.160

53

on or off the premises.”65 Food trucks might qualify as carry-out restaurants, depending on   how   “packaged”   is   construed.     As these examples illustrate, the applicability of this common term to food trucks remains uncertain. The uncertainty regarding classification of food trucks may be related to the fact that the zoning code was enacted prior to the growth of the food truck industry and the drafters simply did not anticipate the need for a specific mention of this use. This, apparently, is the case in Greenville, as was explained by the zoning coordinator. In other cities with recent food truck ordinances, such as Boston and Hoboken, the omission is likely just an oversight. In any case, the uncertainty means that planning department staff or planning board members must interpret the ordinance to determine how the regulations apply to food trucks. While this may be satisfactory in most situations, this uncertainty means that there remains the possibility of conflict and even litigation. As such, it is a situation to be avoided if possible. Balancing Public Good and Private Burdens A common theme throughout this analysis has been that cities have some degree of latitude when it comes to drafting regulations on mobile food vending. While the

ultimate goal of regulations should be the protection of public health, safety, and welfare, overzealous laws can impose burdens on vendors that are avoidable and not justified by these concerns. It is not the intent of this report to pass judgment on the wisdom of particular city ordinances. There is no objectively correct manner of regulating food trucks, particularly in light of the unique conditions present in each city. Rather, the goal is to discuss the variety of observed regulations in terms of burdens on vendors so that the

65

St. Louis Code of Ordinances §26.08.377

54

city of Greenville will be sensitized to the potential for overregulation. A few key examples were notable. Public health ordinances are particularly important for mobile food vendor given the potentially volatile conditions under which food is stored, transported, and prepared. Preventing food borne illness is clearly a legitimate basis for regulation and one that justifies a conservative approach to those aspects of the industry with the highest potential risk of problems. Deference is hereby given to the majority of the public health regulations which address technical specifications related to food safety. One less

technical matter that is more germane to mobile food vending is the widely enacted requirement that food trucks operate in connection with a commissary. Commissaries are licensed commercial kitchens, whether in restaurants or other facilities, which food trucks use for functions such as food storage, equipment cleaning, wastewater disposal, freshwater replenishment, recharging of batteries and in some cases, overnight storage of the vehicle. Most commonly, vendors are required to visit the commissary at least once per day. Cities such as Madison and Portland are less specific, either requiring only that a food truck operate out of a base or waiving the requirement as long as all required functions can be performed.66 Boston, on the other hand, requires commissary visits twice per day.67 These variations raise the question of how stringent the commissary requirement needs to be. Given that traveling to and using a commissary might be a lengthy  operation,  Boston’s  provision  might  impose  a  burden  on vendors not justified by any   public   health   benefit.     Portland’s   flexibility,   on   the   other   hand,   addresses   public  

66 67

Oregon Revised Statutes §333-162-1005 Boston City Code §17-10.1

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health concerns but allows vendors to seek methods of compliance other than patronizing one commercial base. Regulations regarding access to restrooms raise a similar dilemma. While food trucks must be certified to have appropriate hand washing facilities, employees of food trucks will still need occasional use of a toilet. Several cities impose requirements that vendors have plans in place for meeting this need. The predominant approach is to mandate that vending can only take place within a specified distance from accessible toilets. Seattle, Los Angeles and San Francisco all require vendors to have permission to use a toilet within 200 feet of the unit if parked for more than one hour 68 while  Boston’s  area  is  500   feet.69 Austin requires written permission to use a restroom within 150 feet if the unit is stationary for two hours or more.70 The dilemma here is how to balance the competing interests. Employees certainly need toilets, but requiring advanced written permission may not realistic in light of how food trucks operate, particularly in the case of street vending. Whereas vending on private property must be done with the permission of the property owner, use of restrooms can be negotiated along with the basic authorization. For street vending, however, an analogous situation might be one where a city contemplated required delivery truck drivers to have designated and scheduled toilet stops. Such a regulation seems more likely to be considered unnecessarily burdensome. Other potential burdens include the prohibition on tables, chairs or other amenities for patrons of food trucks. These may be justified, particularly in the case of street vendors, by concerns about traffic distractions, the need to maintain clear sidewalks for pedestrian
68

See e.g. http://www.kingcounty.gov/healthservices/health/ehs/foodsafety/foodbusiness/%7e/media/health/ publichealth/documents/foodsafety/2010RestroomUseAgreement.ashx 69 Boston City Code §17-10.5 70 Austin City Code §10-3-93(D)(6)

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flow, or to encourage food trucks not to become to sedentary. Even on private property, such prohibitions may be legitimate, given the fact that many such uses are permitted under temporary use authorizations which require fewer inspections or approvals than permanent uses. Structures such as tables and tents blur the line between temporary, mobile food vending and permanent vending out of a stationary food truck. That said, allowing food trucks to set up some amenities for the convenience and comfort of their customers does not necessarily violate any public concern. As such, regulations such as these should be carefully evaluated in terms of the likely benefits and burdens they impose. Advancing Social Goals A final criterion for evaluating a food truck regulatory regime is to look at the affirmative efforts made at advancing social goals. This is the difference between simply allowing food trucks to operate in a city and taking an active role in encouraging them and ensuring that they are positive forces in the community. In accordance with

principles of tactical urbanism, such efforts do not require large scale investments into infrastructure. Rather, they can be a result of policy changes that create an environment conducive to a successful industry. The protective regulations previously discussed are certainly a part of this. However, there are other aspects to this process that go beyond narrow conceptions of public safety, such as putting forth meaningful policy statements to shape public opinion and including regulatory elements that further social goals. Policy statements and legislative findings are a simple way to shape the discourse around a subject, introducing ideas and clarifying intents and desired outcomes. Although non-binding statements do not have the force of law, they can be useful for city

57

officials or judges when it comes to interpreting code provisions and to citizens who operate within those laws. A well-designed food truck policy should therefore include affirmative declarations that communicate core values to be encouraged. Approximately half of the case study cities provide such guidance. The range of ideas represented in these policy statements echo the criteria used throughout this report for evaluating sound food truck regimes. As such, they provide yet another reminder to cities looking to update their food truck plans. The policy statements fall within three basic themes: contribution to economic development, improvements to food systems, and quality of life improvements. The   ability   of   food   trucks   to   contribute   to   a   city’s   economic   vitality is the most recognized trope in the policy statements observed. Asheville’s  ordinance  states  it  most   simply,  asserting  that  their  food  truck  ordinance  “provides  opportunity  for  new  business   activity.”71 Other  cities  are  more  nuanced,  such  as  Boston’s  recognition  that  “The  mobile   food industry has the unique potential to create new employment opportunities, small business growth and favorable conditions for culinary entrepreneurs in Boston and its neighborhoods.”72 Portland and Seattle focus on the small business aspect of mobile food vending,   noting   that   “food   carts   offer a unique and flexible opportunity for microentrepreneurs”73 that   can   help   them   “develop   a   business   track   record   and   build   a   loyal   clientele.”74 These  opportunities  are  a  particularly  “valuable  economic  point  of  entry  for   immigrant and refugee communities.”75 The cities that recognize this potential also recognize the role that a well drafted ordinance can play in creating these opportunities.
71 72

Preamble to Asheville Ordinance No. 4007.Adopted September 13, 2011. Boston Mobile Food Truck Ordinance.http://www.cityofboston.gov/business/mobile/ordinance.asp 73 http://www.portlandonline.com/bps/index.cfm?c=52798 74 Seattle Ordinance No. 123659, Adopted July 21, 2011 75 Ibid

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Their   policy   statements   specify   the   need   to   “clarify   the   regulations   for   mobile   food   vending,”76 “codify   rules and regulations,”77 and streamline “rules   and   regulations,   making it easier and cheaper to become a legal street-food vendor.”78 Policy statements relating to the food aspect of mobile vending compromise a separate popular theme. For example, the small business nature of many food trucks is recognized  as  possibly  leading  to  “food  diversity,”79 thanks in part to the ability of people to  “test  family  recipes  [and]  incubate  their  business  idea.”80 In  addition  to  what  “in  many   cases represents novel or innovative  cuisine,”  the  type  of  food  offered  by  mobile  vendors   is  recognized  as  “typically  offered  at  low  or  moderate  prices”81 and  meets  the  “increasing   demand, particularly among people 18 to 44, for freshly prepared, restaurant quality food that can be had quick and cheap.”82 If fresh produce is part of the offering, food trucks can  help  “promote  community  health,”83 thereby providing an additional benefit. Each of these benefits goes beyond simply contributing to economic development and serve related, but independent policy goals. The final theme relates to the role of food trucks in improving the character and quality of life in the cities where they operate. Broadly  speaking,  food  trucks  “contribute   to  the  vibrancy”  of  the  areas  where  they  operate.84 This occurs at the street level, where food  trucks  “attract  foot  traffic  to  commercial  districts, creat[ing] a more vibrant business retail  climate”  and  “safe,  active,  and  enjoyable  streets  and  public  spaces  [that]  advance  [a  
76 77

Preamble to Asheville Ordinance No. 4007.Adopted September 13, 2011. Hoboken City Code §147-1.1 78 San Francisco Department of Public Works. http://www.sfdpw.org/index.aspx?page=1376 79 Preamble to Asheville Ordinance No. 4007.Adopted September 13, 2011. 80 http://www.portlandonline.com/bps/index.cfm?c=52798 81 San Francisco Ordinance No. 297-10. Effective January 2, 2011. 82 Boston Mobile Food Truck Ordinance. http://www.cityofboston.gov/business/mobile/ordinance.asp 83 Seattle Ordinance No. 123659, Adopted July 21, 2011 84 Preamble to Asheville Ordinance No. 4007.Adopted September 13, 2011.

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city’s]  character  and  quality  of  life.”85 City  streets  become  safer,  thanks  in  part  to  “eyeson-the   street”   and   “pedestrian   activity.”86 By highlighting these desirable qualities of food trucks to activate public spaces, enhance public safety, an contribute to a vibrant urban character, these policy statements become part of the dialogue about mobile food vending, helping to create an optimistic attitude about the industry. Statements of values and intents are a good start, but cities can adopt additional policies to make these commitments more concrete. One concern about having an active food truck scene is apparently the potential for trash to accumulate in areas where they operate. One of the more common code provisions is to require food trucks to provide trash receptacles for their patrons. Some progressively minded cities, such as Durham, Hoboken, San Francisco, and Seattle also require food trucks to provide bins for recycling and/or compost material. Several cities go further with their efforts to have food trucks contribute to the cleanliness of the city. Hoboken requires vendors to pick up litter within 5 feet of the vending area, apparently regardless of whether it is related to the food truck itself.87 Miami88 and St. Louis89 extend this obligation to 15 feet while San Francisco’s  “Good  Neighbor  Policies”  include  picking  up  beverage containers and other trash left by patrons within a 100 foot radius of the food truck within 30 minutes of closing.90 Some of these policies include encouragements to use recyclable or

compostable   utensils,   with   San   Francisco’s   Food   Service   Waste   Reduction   Ordinance   going the furthest in prohibiting polystyrene foam service ware and mandating

85 86

Seattle Ordinance No. 123659, Adopted July 21, 2011 Ibid 87 Hoboken City Code §147-2.4 88 Miami Code of Ordinances §39-38(5) 89 St. Louis Code of Ordinances §8.108A.150(H) 90 San Francisco Municipal Ordinance §184.94

60

biodegradable, compostable, or recyclable utensils unless there is no affordable alternative to traditional materials.91 These   policies,   particularly   San   Francisco’s,   raise   questions about what constitutes an unreasonable burden on vendors. It would be

interesting to see whether comparable policies could be imposed on other businesses such as fast food restaurants or coffee shops that generate significant amounts of consumer disposable materials. In any case, these policies serve as examples of the type of options that cities have when crafting mobile food ordinances.

91

San Francisco Environment Code §1601 et seq.

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Recommendations for the City of Greenville The preceding discussions have set out the reasons why a supportive food truck policy is desirable, demonstrated that demand for such trucks is likely to exist in Greenville, and analyzed food truck policies in fifteen other cities in order to identify important areas of regulation and possibilities for code provisions within those areas. Currently, Greenville has a regime that was enacted prior to the evolution of the modern food truck industry. It contains provisions that are overly restrictive and others that are unnecessarily vague. Perhaps coincidentally, there is no substantial food truck industry operating in the city. Accordingly, the following recommendations are presented for policy makers and municipal staff in Greenville to help guide the policy making process toward a more productive outcome. Public Process An important preliminary matter is that the citizens of Greenville should have the opportunity to provide input on the subject of potential food truck legislation. Not only can this help identify potential concerns that shape the eventual ordinance, but it may also serve to generate interest in food trucks that will encourage people to support to even start businesses. Of particular importance is the question of whether vending in

residential areas should be permitted and if so, under what limitations. It may be that customer demand exists in certain neighborhoods and not others. This information can be used to shape restrictions on permitted vending locations, possibly allowing for individual neighborhoods to formulate their own restrictions on locations and/or hours. Public input may also provide useful regarding questions of vending on public lots, such as  whether  food  truck  ‘pods’  would  be  seen  as  welcome  or  invasive.

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The city should employ multiple means of engaging the public. In addition to public meetings and hearings, the city should engage social media or consider an online survey such as the one employed by the city of Boston. Depending on the level of support or opposition, a limited pilot program might be a useful technique for introducing food trucks to people while reserving space for future changes. This is an increasingly popular approach, utilized in Boston but also currently occurring in numerous other locations as the food truck phenomena spreads. Unified Ordinance The basic objective should be to draft a unified ordinance that addresses all aspects of mobile food vending in a consistent manner. This would begin with clear policy

statements that set forth the key values that the city desires to encourage, including contributing to economic development, improving the food system in Greenville, and improving the quality of life for residents and workers. The ordinance should update all relevant sections of the municipal code, including but not limited to business licensing (§8-261 et seq.) and land management (§19-1.1 et seq.), so as to avoid uncertainties for prospective or actual food vendors. Licensing Current   licensing   regulations   in   Greenville   require   a   peddler’s   license   for   each   salesperson.92 This places burdens the food truck operator, who must obtain a license for any potential employees, a process that includes fingerprinting, background investigation, and payment of fees. The city, which must evaluate and approve these applications, bears some burdens as well. This type of regulation, while possibly appropriate for more traditional single-person vending operations, is less appropriate for modern, larger-scale
92

Greenville Code of Ordinances §8-301

63

businesses. A more moderate, but still restrictive, approach would allow a vendor to apply for a license that allows for a certain amount of employees, as is the case in Madison. More desirable still would be a single license for the vendor that does not require   individual   employee   licenses.     These   employees   may   still   need   food   handler’s   certificates from the South Carolina Department of Health and Environmental Control, which should address public health concerns of the city. Street Vending Current Greenville regulations prohibit mobile vehicle vending within the Central Business District and within 300 feet of it.93 Given that street and sidewalk vending in those   areas   is   seen   as   “promot[ing]   the   public   interest   by   contributing   to   an   active   and   attractive   pedestrian   environment,”94 the exclusion of vehicle vending from this area is presumably related to concerns about traffic, parking, and congestion. Parking in

downtown Greenville can in fact be difficult to come by and large food trucks would likely not fit well with the narrowness of Main Street. That said, the city should consider allowing mobile food vending in the CBD during late night hours. This would entail changing the very restrictive provision that vendors must cease operation a half hour before sunset.95 This would enable vendors to serve people who are leaving the bars and nightclubs. The streets would become livelier places, food would help ensure that people do not drive while intoxicated, and vendors would have a source of customers. Even the usual objections from brick-and-mortar restaurants could be avoided by requiring vendors to wait until other restaurants have closed before moving into the area. Restricting trucks to streets other than Main Street would likely still be justifiable. Should the city consider
93 94

Greenville Code of Ordinances §8-264 Greenville Code of Ordinances §8-261 95 Greenville Code of Ordinances §8-306

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assigning vending locations, they should consider a method designed to avoid the inequalities of seniority or pure lottery systems. A shift-system like that used in Boston would be preferable in that it would allow multiple vendors to have the opportunity to operate from the most desirable locations and would offer customers with variety in food options. Street vending outside the CBD is currently highly restricted by the rule that vendors must remain mobile, not remaining in one location for more than 30 minutes.96 After this time period, they must move at least one block or 500 feet and cannot return to the same location for six hours. As discussed previously, it is not clear what public health, safety, or welfare concerns this provision addresses. The city should discuss this matter during public outreach efforts in order to find the level of regulation that maximizes vendor flexibility and business options while addressing any legitimate public concerns. Limited street vending in residential areas should also be considered. Private Property Vending Current zoning regulations appear to prohibit many food truck activities from occurring on private property. The operation of a food truck on a vacant lot, singly or in pods, would be prohibited by the provision that the “use  of  a  motor  vehicle  …  in  which, out of which, or from which any goods are sold, stored, services performed, or other business  conducted”  is   a  prohibited  use.97 Although this code section has an exception for temporary use permits, the same activities are prohibited as temporary uses in most circumstances.98 This leaves accessory uses, whereby a food truck might be able to vend in the parking lot of an existing business. Although the zoning code utilizes the common
96 97

Greenville Code of Ordinances §8-307(b)(1) Greenville Code of Ordinances §19-4.1.1(h) 98 Greenville Code of Ordinances §19-4.5.3(f)

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and   somewhat   vague   limitation   that   accessory   uses   must   be   “incidental;;   customarily associated   with;;   and   subordinate   to   principal   uses,”   the   code   also   expresses   the   city’s   intent to construe this provision broadly.99 In any case, further clarification would be useful and would entail listing mobile food vending as a specific permitted use, even if only as an accessory. The city should also consider relaxing the principal and temporary use provisions to allow more vending possibilities for food truck operators. Public Health and Social Goals Greenville’s   regulations   on   public   health, as supplemented by the state of South Carolina, are fairly common in their coverage. A daily visit to a commissary is

required,100 the vendor must maintain a trash receptacle for customer use,101 and there are basic   prohibitions   against   “offensive   or   loud   noises.”102 None of these provisions are overly burdensome and the more restrictive provisions of some other cities are not present. Space does exist for additional efforts to advance social goals. Assuming the city amends the laws to allow increased vending on private property, related amendments could be proactive in crafting rules on how tables, chairs or other accessories can be used in a safe and inoffensive manner. Regulations aimed at limiting environmental

degradation, such as the use of recyclable or compostable plates, cups and utensils, could be part of a new comprehensive ordinance. Encouraging the use of healthy and/or locally grown foods by vendors would not only be beneficial to consumers but also to other local businesses.

99

Greenville Code of Ordinances §19-4.4.1 South Carolina DHEC Regulation 61-25, Ch. X(B) 101 Greenville Code of Ordinances §8-307(2) 102 Greenville Code of Ordinances §8-307(4)
100

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Additional Efforts Currently, the city maintains web pages dedicated to vending in the central business district. The page offers relevant information, guidelines and maps of available vending locations. Once a new ordinance is passed, this page can be expanded or subsumed within a broader page that provides information on all of the aspects of vending within the city. The goal should be to present applicable regulations in an easy-to-access format along with supplementary materials such as maps, forms, checklists, or links to other resources. This is a way for the city to actively engage the community so that people will be more likely to want to start a food truck and be able to find out how to go about doing it. Finally, the city is encouraged to be open to other actions or innovative policies that might further encourage development of the industry. Small business assistance

programs could be made available to prospective food truck entrepreneurs along with any other resources geared toward helping people start their own businesses. The city’s   economic development department could offer assistance similar to the GIS analysis offered in this report that would help food trucks identify underserved areas of the city. If the industry does take root and begin to grow, the city can take an active role in helping interested vendors make a transition to a brick-and-mortar restaurant. This might involve identifying vacant properties or working with banks to secure financing for these ventures. In many other cities, private individuals and groups have begun to take an active role in organizing food truck vendors for events, providing consultancy or other services, or advocating for legislative changes. The city should strive to maintain good relations with these groups so that they contribute to the development of the industry

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rather than hinder it. Given the dynamic and rapidly evolving nature of the food truck industry and municipal responses to it, further study of other cities may reveal additional innovative policies which Greenville could consider. Concluding Thoughts The modern food truck phenomenon is expanding rapidly across the country with little sign of slowing. This growth is an indication that people desire high quality, moderately priced, and innovatively prepared foods that are available at convenient locations and times. Although Greenville does not currently have a developed food truck industry, the creation of a regulatory architecture that supports and encourages such businesses could be an important first step toward its creation. Food trucks have the potential to activate public space, reduce auto-dependency, improve street vitality, feed underserved populations, and generate economic activity. Greenville should take this opportunity to formulate a new mobile food vending policy that maximizes these potentials while addressing potential public health, safety and welfare concerns.

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Appendix – Case Study Summaries

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Greenville, SC Policy statements:  Vending on the public streets and sidewalks within the central business district and within 300 feet of the central business district promotes the public interest by contributing to an active and attractive pedestrian environment. Licensing:  Peddlers license required for each salesperson  No vending between half-hour before sunset and 9AM or on Sundays ("except by specific appointment with or invitation from the prospective customer")  No vending from vehicles within the central business district and within 300 feet of the central business district [8-264]  Fingerprinting & investigation required Public Health, Safety, Environment, Quality of Life:  Vendors must maintain a litter receptacle available for patrons' use  No "offensive or loud noise" to attract customers, no PA system, bell or music for up to 5 minutes to announce arrival at a location  Single service articles only  Must report to permitted base of operations at least daily Street vending: (outside of CBD)  must remain mobile and not violate the intent of the zoning regulations by remaining for extended periods of time at one location or in one neighborhood  Cannot remain stationary on a public street or right-of-way more than 30 minutes in any one location conducting business, after which time such vendor must move at least one block or 500 feet, whichever is greater, and shall not return to the same block or location within the next six-hour period. No location shall be used more than twice in any one day. Private property vending:  The use of a motor vehicle, trailer, or shipping container in which, out of which, or from which any goods are sold, stored, services performed, or other business conducted is prohibited  Temporary Use permits may be granted for the sale of food products at a cityapproved event Ease of acquiring information:  Webpage for CBD vendors w/map (food trucks excluded)

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Asheville, NC Policy Statements:  "The regulations for mobile food vending" are reasonable and in the public interest: o Provide opportunity for new business activity o Offers food diversity and expanded options in commercial districts and contributes to the vibrancy of these districts o Ordinance clarifies and expands regulations governing a use that is growing in popularity Licensing:  City business privilege license  Development permit for private property vending (site specific) o Site plan review (access, landscaping, setbacks, etc.) o Preference for permanent electric power infrastructure (outside of CBD)  Temporary vendor permit (site and vendor specific) Public Health, Safety, Environment, Quality of Life:  Vendors encouraged to use recyclable and/or compostable containers, cups and utensils  Vendor must provide trash receptacle and is responsible for maintaining the cleanliness of the vending site  Noise limit on electric generators  Must report to commissary at least daily Street vending:  No vending permitted in public street or right of way Private property vending:  Mobile Food Vending as a specified use in the zoning code  Permitted by right in various office, business (including central business), commercial, industrial, urban village, neighborhood corridor, urban place  Hours: o Downtown CBD - 6:00 a.m. to 2:00 a.m. o Outside of CBD - 6:00 AM to 3:00 a.m. or 6:00 a.m. to midnight if within 200 feet of a residential use  Maximum of 10 permits in the downtown CBD  Vendors must maintain a set schedule of locations and hours  No tables, chairs, tents, shade structures, steps, etc.  Food trucks must be at least 20 feet apart from each other Ease of acquiring information/process:  No information on web site  Ordinance consolidates all regulations in a detailed manner

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Austin, TX Policy Statements:  N/A Licensing:  General business license  Health Department license Public Health, Safety, Environment, Quality of Life:  Must visit commissary once every 24 hours  Written agreement to use business restrooms within 150 feet if at a location for more than 2 hours  Permit limited to approved menu  Must provide trash receptacle Street vending:  Allowed in commercial and industrial zones, not office  Cannot be located within 50 feet of a building with both commercial and residential uses  No vending between 3:00 a.m. and 6:00 a.m.  Cannot be within 20 feet of a restaurant (in a building)  Neighborhood Associations can vote to allow vendors. Optional regulations: o Must be 50 feet or more from SF zoned properties or from SF houses, duplexes or townhouses o Can operate between 6:00 a.m. - 10:00 p.m. if between 50 and 300 feet from SF zoned properties, SF houses, duplexes or townhouses o Can operate between 6:00 a.m. - 3:00 a.m. if more than 300 feet from SF zoned properties or locations of SF houses, duplexes, or townhouses Private property vending:  See street vending rules (not distinguished) Ease of acquiring information/process:  Planning Department webpage with links to supporting documents  Clear FAQ describing the permitting process and regulations  Map of neighborhoods that have adopted additional regulations Other policies/initiatives:  Farmers Market vending permits

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Boston, MA Policy Statements:  The mobile food industry has the unique potential to create new employment opportunities, small business growth and favorable conditions for culinary entrepreneurs in Boston and its neighborhoods  There is an increasing demand, particularly among people 18 to 44, for freshly prepared, restaurant quality food that can be had quick and cheap  Whereas vendors in the mobile industry have faced complex rules and regulations in other communities, [this ordinance] is being set forth to streamline administrative processes, effectively work with the industry and secure the highest quality of life for all Bostonians  Mobile Food Truck Committee seeks to "ensure mobile vending in Boston remains creative, flexible, and most importantly mobile." Licensing:  Department of Public Works coordinates permitting process  Additional requirements depending on location  Vendors must purchase and install GPS tracking devices so that their location can be tracked  Must have property lease or letter of agreement from landlord (private property vending)  Landowner must have Use of Premise Permit (from Inspectional Services Department) (private property vending) Public Health, Safety, Environment, Quality of Life:  Report to fixed licensed food establishment (commissary) two times a day  Must be a certified food manager Street vending:  Establishment of site licenses for locations in the public right of way  For 2012: 17 sites, categorized into City Hall Plaza, Prime, Tier 1, Tier 2, Tier 3  Each site further separated into breakfast, lunch and dinner shifts  Site licenses will be issued according to a two tier process: o Lottery system for City Hall Plaza, Prime, and Tier 1 locations for vendors who apply for them. Vendors separated into 3 groups based on good standing criteria. At public meeting, vendors are randomly selected (within each group, starting with 1) whereby they select a site and shift. Process continues until all shifts are filled. o Schedule requests then submitted for Tier 2 and 3 locations (and any remaining Tier 1). Mobile Food Truck Committee issues site approvals. o Committee can exercise discretion "to ensure that trucks are not in competition with each other or surrounding food retail." o Vendors are limited to a maximum number of shifts at a given location (e.g. no more than 3 lunches/week at Prime sites)

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Boston (continued) Private property vending:  Food trucks not specifically defined in zoning code  Retail Catering: "Sale over the counter .. of on-premises prepared food or drink for off-premises consumption or for on-premises consumption if, as so sold, such food or drink is ready for take-out." o Principal use: Conditional or Allowed in business and industrial districts, Forbidden in residential districts o Accessory use: business uses forbidden in residential districts §10-2 Ease of acquiring information/process:  Dedicated web page to food trucks  Single, integrated application process for permits Other policies/initiatives:  Mayor's Food Truck Challenge - invited local entrepreneurs to present their food truck menus and concepts for a chance to receive permits to operate on City Hall Plaza as well as financial support from the City of Boston  The City has also launched an online survey for food truck vendors and for the general public, asking them to let us know where they are interested in seeing food trucks in the city. The City is looking at locations where food trucks can thrive, with consideration toward factors such as existing 'bricks & mortar' restaurants, pedestrian and vehicular traffic, and emergency vehicle access. The BRA is also looking at the city landscape and coming up with a list of recommendations – places where food trucks would work well and help to activate an area.  City list/map of food trucks and schedules  City Office of Food Initiatives, Food Truck Coordinator

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Denver, CO Policy Statements:  N/A Licensing:  Retail Food Mobile License issued by Denver Business Licensing Center. Requires: o Zone Use Permit for storage or operation of unit on private property o Environmental Health and Fire inspection certification o Commissary agreement Public Health, Safety, Environment, Quality of Life:  Must report to a commissary at least once daily  Health Department review of proposed menu Street vending:  No vending within 20 feet of an intersection  No vending within specified central business district  Vending within 300 feet of a public park or parkway requires Parks Department permit  No chairs, tables, or exterior signs Private property vending:  Allowed in specified zoning districts (no residential districts, certain downtown districts excluded)  Use is regulated as Retail Food Establishment, Mobile  Hours: o Between 8:00 a.m. and 9:00 p.m. only o Limited to 4 hours each day per zone lot  Location restrictions: o Prohibited in lots that are undeveloped, have uninhabited structures, or are unpaved o Must be 200 feet from any eating and drinking establishment or other food truck o Must be 50 feet from a residential zone district  1 vendor per lot (except for special event permit)  Can vend without permit for less than 30 minutes at a location (temporary use, all zone districts)  No structures, tables or seating Ease of acquiring information/process:  City-County multi-departmental food truck guide  Retail Food Mobile License page on Business Licensing web site  Public Health Department web site for mobile retail food establishments with links and detailed guide
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Durham, NC Policy Statements:  N/A Licensing:  County health certification  Fixed location vending (FLV) permit for street vending Public Health, Safety, Environment, Quality of Life:  Street vending o Must provide trash receptacles o Must collect litter within 10 feet area at least once every hour Street vending:  Çity manager maintains a list of locations certified by chief of police as suitable for vending  Permits are site specific and contain permitted operating days/hours, determined by the manager  Tents, tables, chairs, etc. can only be present during the hours specified in the permit Private property vending:  Zoning code does not list mobile vending as a specific use  Restaurants are permitted in several commercial, industrial and downtown design districts Ease of acquiring information/process:  Minimal information on city, county or state web pages  Not all codes are available in public databases Other policies/initiatives:

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Hoboken, NJ Policy Statements:  "[T]here is a need for codification of rules and regulations relating to mobile retail food vendors within the City."  "The City of Hoboken encourages the growth of Mobile Retail Food Vendors within the City of Hoboken while regulating the side effects of this growing industry, such as parking, traffic and waste disposal."  The law "limits the proximity of Mobile Retail Food Trucks to brick and mortar restaurants to secure safe and adequately spaced sidewalks in case of a fire, flood, and other natural or manmade disaster."  "While serving similar purposes, selling food to residents, mobile food trucks and brick and mortar restaurants function separately and are not complimentary in nature."  "The City seeks to locate Mobile Food Trucks in areas to better serve mobile populations. Licensing:  Health inspection  For vending on public property: o City license o Health Certificate from Department of Health o Parking permit from Department of Transportation o Must have on-vehicle GPS unit for tracking of vehicle o Health Department may limit the number of total licenses issued or renewed o Maximum of 25 licenses for Mobile Retail Motorized Food Vendors issued per year Public Health, Safety, Environment, Quality of Life:  Public property vendors: o Must provide trash and recycling receptacles o Responsible for litter within 5 feet of vehicle o Parking only in designated permit zones or metered parking spaces Street vending:  35 foot maximum length for trucks  Operating hours: Sunday-Thursday 6:00AM - 9:00PM, Friday and Saturday 6:00AM - 11:00PM  No provision of dining area  Permit must be used continuously (revoked after 14 days of non use)  Vending at least 75 feet from the business entrance of any menu-serving restaurant  No more than 4 continuous hours in a permit parking space or 2 hours in a metered zone (up to 6 hours with extended parking endorsement)  Must pay for first 2 hours of metered parking  Maximum of 2 vendors on a block  Cannot park for "longer than the time it takes to make a sale to a customer"
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Hoboken (continued) Private property vending:  No specific regulations for mobile food vendors  Retail businesses o Permitted in some residential areas if block currently has two other retail businesses (restaurants are conditional use) o Accessory use in some industrial districts (restaurants are conditional) o Permitted in special Review districts Ease of acquiring information/process:  No specific web pages or information for food trucks Other policies/initiatives:

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Honolulu, HI Policy Statements:  N/A Licensing:  City peddlers license  State food establishment permit Public Health, Safety, Environment, Quality of Life:  Must provide trash receptacle  Must visit commissary at the end of each day Street vending:  No peddling in a school zone while school is in session  Limit of 15 minutes in any one location on a public street or highway. Must move at least 300 feet away for at least 3 hours Private property vending:  Zoning code does not mention mobile food vending specifically  Retail establishments include "establishments where food or drink is sold on the premises for immediate consumption, but which lack appropriate accommodations for on-premise eating or drinking."  Retail establishments permissible in resort/business districts only Ease of acquiring information/process:  No dedicated web sites to vending (very sparse web presence overall)  Relatively short and simple ordinances Other policies/initiatives:  New food truck bill (Bill 59) proposes to increase time limit for street vending to 2 hours

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Los Angeles, CA Policy Statements:  N/A Licensing:  City business tax registration  L.A. County plan review and health certification

Public Health, Safety, Environment, Quality of Life:  Must provide litter receptacle and dispose of any trash related to the vending operation  Must report to a commissary at least daily  Must have access to a restroom within 200 feet if in one location for more than one hour Street vending:  "Catering trucks" prohibited from dispensing victuals: o Within 100 feet from an intersection o Within 200 feet of designated parks or portions of parks o Within 500 feet of the nearest property line of any school Private property vending:  No specific provisions for mobile food facilities. Restaurants permitted in most commercial districts. Ease of acquiring information/process:  No web sites dedicated to mobile food vending Other policies/initiatives:

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Madison, WI Policy Statements:  Restrictions on vending areas justified by "circumstances present within [this] geographic location, including but not limited to the proximity of businesses, university, and residential uses, buildings situated primarily with zero setbacks, high volume of pedestrian traffic, varying sidewalk space, and the volume of vehicle traffic, making this area appropriate to limit street vending to assigned sites only with regulations in addition to the city-wide vending requirements." Licensing:  Basic street vending license from Planning Department o Allows Up to 5 supplemental employees under single license o Special permits needed for:  State Street Mall/Capital Concourse  Late night vending  High density areas, e.g. SE Campus  Mall/Concourse or High Density vending license (if desired)  Late Night Vending area license (if desired)  Mobile Food Establishment license - Issued by Madison and Dane County Public Health Department  Peddler's license (for vending on private property) Public Health, Safety, Environment, Quality of Life:  Vendors are encouraged to use recyclable packaging  Must operate out of a base  Regulation of vending site cleanliness and safety Street vending:  Vending licenses are granted for specific locations for Mall/Concourse, high density, and late night vending  Need special approval from oversight committee for vending on "arterial" or "collector" streets with speed limit greater than 25 MPH located directly adjacent to or across the street from a school property  Hours: o Vending permitted between 5:00 a.m. and 1:00 a.m. in Mall/Concourse area o 9:00 p.m. to 6:00 a.m. in Late Night Vending areas o No vending between 9:00 p.m. and 6:00 a.m. in any residentially zoned district

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Madison (continued) Private property vending:  Mobile vending not specified in zoning code o Zoning code requires business to be conducted in completely enclosed buildings  According to city web site, vending on private property only permitted: o On property zoned for commercial use o If direct connection between the products normally sold on the commercial private property and the products sold by the vendor (must be accessory to existing business) o No vending on private property zoned for residential use Ease of acquiring information/process:  County Mobile Food Establishment web site with guidelines, checklists, forms  Dedicated Street Vending web site with forms and maps  Web site erroneously states that vending is only allowed at special events or in City parks (contradicts code and later portion of the web site) Other policies/initiatives:  Vending Oversight Committee made up of representatives from different parts of the city, current vendors as non-voting technical advisors  Office of Business Resources - provides "start-up, retention, expansion and attraction information and guidance" including local, federal and state financial assistance programs

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Miami, FL Policy Statements:  N/A Licensing:  Business Tax Receipt for Vehicle Peddlers from Department of Finance  Dade County Public Health license Public Health, Safety, Environment, Quality of Life:  Responsible for maintaining a 15 foot radius trash and refuse clear area  County health plan review Street vending:  Prohibited vending locations: o Public parking spaces (metered or otherwise) o Within 500 feet of schools between 7:00 a.m. and 4:30 p.m. on school days o Within 20 feet of a licensed sidewalk café  Prohibited in specified special vending districts  Cannot remain in any one location longer than necessary to make a sale Private property vending:  Mobile food vendors are not specifically listed in zoning code. Food service establishments are allowed by right, warrant, or special exception in various T4, T5, T6, Civic, and special districts  Temporary Use/Special Event permit o Can be issued two times per year per property, for maximum of two weeks each  Temporary Use of Vacant Land permit o Parking lots and abandoned properties are not considered vacant land o Available for 6 months, renewable up to 2 years  Temporary Use permits require informal notice be given to: o Adjacent property owners o Registered neighborhood and/or homeowner associations Ease of acquiring information/process:  No specific web sites about mobile food vending  2011 Media Advisory, "Information on Food Truck City Zoning Ordinance," provides a brief overview of relevant codes Other policies/initiatives:

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Minneapolis, MN Policy Statements: Licensing:  Mobile Food Vendor license from Department of Public Works  State Department of Health plan review Public Health, Safety, Environment, Quality of Life:  Commissary within city required  No seating allowed  No broadcasts of sound or visuals  Self-contained generator  Must pick up all trash Street vending:  Allowed only in designated locations. Maps highlight specific streets, neighborhoods, or corners  Must be at least 100 feet from a restaurant, food manufacturer, coffee shop, or public market unless written waiver  Spots are not assigned or reserved  Hours - 6:00AM to midnight or 6:00AM to 10:00PM if within 300 feet of a residential building  Specific requirements for certain sites o Vending times less than general provision o One vendor per block Private property vending:  Only allowed at approved parking lot locations  Must be at least 100 feet from a restaurant, food manufacturer, coffee shop, or public market unless written consent granted  Hours - 6:00AM to midnight or 6:00AM to 10:00PM if within 300 feet of a residential building  Only one vendor per lot  Zoning code does not list mobile food vending as a use. Restaurants are permitted or conditional use in most districts. Cafeteria and similar food services can be accessory to nonresidential uses if "primarily for the convenience of the employers, clients, or visitors of the principle use." Ease of acquiring information/process:  Business Licenses department web page with links to Business License Information Program brochure, regulations, maps, site specific guidelines, application forms  Detailed application checklist Other policies/initiatives:  State guide - "Starting a Food Business in Minnesota"
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Portland, OR Policy Statements:  Food carts offer a unique and flexible opportunity for the micro-entrepreneur looking to test their family recipes, incubate their business idea, or just to provide for the needs of their family. Licensing:  No permit requirements for vending on private property or street, only sidewalk (not food trucks). Public Health, Safety, Environment, Quality of Life:  County health: plan review and inspection  Must notify of menu, location or route changes  Food handler cards  Commissary not required if unit has all appropriate water and sewer capabilities Street vending:  Cannot "conduct business in a roadway adjacent to or directly across from residential property for a period longer than 10 minutes within any block face. Such vendor must vacate said block face for a period of 2 hours upon expiration of the 10-minute limit." Private property vending:  Restrictions for vehicles over 16'  No specific coverage for mobile food vendors  Retail Sales and Service includes food sales - allowed in commercial, employment/industrial, and some multi-dwelling zones  Parking lot sales allowed as temporary use in certain commercial, employment, industrial and central residential districts Ease of acquiring information/process:  Minimal regulations/applications  Central web site with links to publications, other department webpages, private sources of information  Clear & concise instructions Other policies/initiatives:  Food Policy Council - Established to study and advise the city on "local food issues including hunger relief; nutrition; food business and industrial practices; local farming; community education and institutional food purchasing and practices."

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San Francisco, CA Policy Statements:  "The wide range of fare provided by Mobile Food Facilities is typically offered at low or moderate prices and in many cases represents novel or innovative cuisine. When located appropriately, Mobile Food Facilities add vitality to the street, contribute to the richness of San Francisco's culinary and cultural offerings, and provide economic opportunities especially for small business persons.  Recognize that mobile food facilities have become an increasingly significant feature of the streetscape in the city, like in many major cities  Address the growing trend by streamlining rules and regulations, making it easier and cheaper to become a legal street-food vendor Licensing:  Department of Public Health issues Mobile Food Franchise permit. Completed application includes: o Department of Health approval certificate o Planning Department approval (when required for Temporary Use or Conditional Use permit) o Fire Department certification  Permits are site/route specific Public Health, Safety, Environment, Quality of Life:  Unit must return to commissary at end of the day  Must have permission to use restroom facilities within 200 feet of unit if parked for more than 1 hour  Review of menu and operational procedures, vehicle and cooking/food storage facilities  Good neighbor policies o Maintain quiet, safety and cleanliness of premises o Provide storage of trash o Contain noise and odors o Display notice urging patrons to leave the area in a quiet and orderly manner and to not litter o Vendor responsible for picking up trash in a 100 foot radius within 30 minutes of closing  Must provide containers for source separation of recyclables, compostables, and trash [recycling]  Food Service Waste Reduction Ordinance o No use of polystyrene foam in disposable service ware o Must use biodegradable, compostable, or recyclable food service ware unless no affordable alternative

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San Francisco (continued) Street vending:  No vending between 3:00 a.m. and 6:00 a.m.  Permits can allow more than one vendor at a particular location  Public review of new applications, location changes, hours after 8:00 p.m. o Notice of Intent mailed to all businesses within 300 feet of proposed location o For vendors operating after 8:00 p.m., Notice of Intent also sent to all property owners and residential tenants within the 300 feet area  Permits limited to map designated zones (not purely residential zones)  Cannot operate within 1500 feet of a public school (M-F 7:00 a.m. to 5:00 p.m.) Private property vending:  Permanent use o Mobile Food Facility treated the same as a brick and mortar restaurant for zoning purposes o Must complete Neighborhood Notification process in specified residential and commercial districts (30 day period within which a discretionary review hearing can be requested)  Restaurant retail allowed in commercial, some special districts, select residential districts  Temporary Use Authorization (TUA) o Does not require building permit o Does not require building permit o Not applicable for residential districts o Vendor presence on property limited to 3 days/week or 6 days/week with maximum of 12 hours per day Ease of acquiring information/process:  Department of Public Works dedicated web page with links to ordinance, permit application packet, frequently asked questions, permit maps, guidelines for new applicants, sample drawings, forms, public records pertaining to food trucks  Flowchart of licensing process  Department of Health forms and checklists available online  Department of Planning dedicated web page with links to forms, guidelines, maps, etc.  Interdepartmental links  Private web sites for consumers and prospective vendors Other policies/initiatives:  Small Business Assistance center  Executive Directive on Healthy and Sustainable Food (2010)

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Seattle, WA Policy Statements: Food vending can help:  Improve public safety  Enhance quality of life  Attract foot traffic to commercial districts, create more vibrant retail business climate (Low-cost, culturally-diverse food options)  Promote community health (access to fresh produce)  Be a low-cost, entry-level business opportunity to help entrepreneurs develop a business track record and build a loyal clientele; valuable economic point of entry for immigrant and refugee communities Goals:  Well-managed street-food vending with appropriate oversight and enforcement  Ensure compatibility with existing businesses  Attract and preserve businesses in the Historic District Licensing:  State business license  City business license  SDOT vending permit for street vending Public Health, Safety, Environment, Quality of Life:  Seattle and King County Public Health Department plan review: o design of mobile food unit o commissary agreement o Details of menu and food preparation processes o restroom agreement o site or route information  Street vendors must provide trash, recycling and composting receptacles Street vending:  Vending is allowed only in specifically designated Food-Vehicle Zones  Zones are designated based on vendor application o Only in non-residential zoned areas o Must have clear pedestrian zone area o Setbacks: 50 feet from food-service business, 15 feet from any business entrance or exit, 1000 feet from any school with a 9th-12th grade class o Only one Food-Vehicle Zone per block face - can accommodate up to 2 vehicles  Permit assigns 4 hour blocks of time, tied to that assigned zone. Can apply for multiple zones.

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Seattle (continued) Private property vending:  Vending in legal commercially zoned parking lots is permitted with the approval of the property owner  Intermittent temporary use permits - allow vending for two days a week. Can allow multiple vendors.  Permanent use permits - requires trailer to meet building code standards  Vacant and Underused Lot Pilot Program - designates up to 20 vacant/underused lots which can be used for vending, subject to temporary use permitting. Ease of acquiring information/process:  Econ Development webpage on Street-Food Vending  Street-Food Vending checklist  SDOT webpage and (Street use Vending Permits) and Client Assistance Memos (CAMs)  Planning and Development web page (private prop)  Seattle and King County Health Department dedicated page with associated forms Other policies/initiatives:

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St. Louis, MO Policy Statements:  N/A Licensing:  City business license for establishment  Health Department permit  Identification certificate for each employee  Special permit for Downtown Vending District o Maximum two permits per vendor o Permit review can consider vendor's contribution to diversity of products and appearance of facilities in the district o Partnership for Downtown St. Louis must be included in the permit review process o Maximum of 10 vendor permits for City Parks Area of Downtown district Public Health, Safety, Environment, Quality of Life:  Must provide trash containers and not use public trash bins  Vendors are responsible for collecting and disposing of all trash within 15 feet  Only single-service or single-use articles  Must report to a licensed commissary at least daily  Must submit trash disposal plan (Downtown district) Street vending:  Only permitted in designated vending districts  Vending from 6AM to 11PM  No vending within 150 feet of another licensed vendor or existing business that sells comparable goods  No vending within 300 feet of a fair or festival  Vehicles must have flashing signals indicating that sales are being conducted  Downtown district: o Can only vend from map designated locations (not within 200 feet of a restaurant, assigned vendor space, or other identified areas) o No outdoor seating allowed Private property vending:  No specific mention of Food trucks. Possibly considered a carry-out restaurant - "A restaurant where food, frozen dessert, or beverages are primarily sold in a packaged, ready-to-consume state, intended for ready consumption by the customer on or off the premises."  Prohibited in Central Business District Ease of acquiring information/process:  Department of Streets web site with checklist, regulations, forms, maps

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St. Louis (continued) Other policies/initiatives:  Downtown Motorized Food Truck Vending District Pilot 2011 program  Downtown Vending District Parks Fund to be used for improvement of parks in the Downtown Vending District

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