Re: Agenda item 6.1
Dear Chair Nunez and Members of the Environmental Planning Commission,
Mountain View YIMBY supports work on the Citywide TDM Ordinance. A standardized framework with a parking exemption pathway for residential projects is a significant step forward from the current ad hoc approach of imposing TDM requirements project-by-project. We appreciate the exemptions for residential trip caps, travel surveys, and driveway counts, and the decision to keep TMA membership optional given the Prop 218 concerns the staff report identifies. We ask the Commission to consider the following comments.
ADT Reduction Targets / Numerical Requirements
We appreciate the smaller ADT reduction targets for TOD projects, as proximity to transit encourages less single-occupant vehicle (SOV) trips. However, we are concerned that the targets for residential projects, particularly for non-TOD residential projects (30/40/50% for S/M/L), are still high without concrete analysis, just references to Precise Plan targets and peer jurisdiction benchmarking. To incentivize new large residential developments, as new density is inherently critical for reducing SOV trips and city vehicle-miles-traveled (VMT), we would recommend lowering the reduction targets, at least until there is study on the cost to development.
The separate requirement of choosing Auxiliary Strategies in proportion to project size also seems without evidence of effectiveness or cost-benefit, especially since the strategies range in effort. We request evidence, or we request the number to be less/eliminated.
Parking Reduction
Reducing car parking is one of the most important strategies to reduce SOV trips in new projects, and one of the hardest to do post-construction. While the proposed TDM program does encourage reducing parking and allow projects to receive exemptions to parking minima, we recommend further changes to maximize the impact of the TDM program.
For the enhanced TDM parking exemption, its own restrictions undermine it. A residential project seeking the exemption must either exceed its ADT target by 5% or adopt one additional Core Strategy and two additional Auxiliary Strategies beyond the minimum (Section 124(I)). At the same time, the project cannot count Unbundled Parking or Limit Parking Supply toward meeting enhanced TDM criteria, on the theory that this would be “double-counting.” This is not double-counting under any reasonable definition of the term; a project that reduces the parking it provides will reduce the number of SOV trips generated, and it would be inaccurate not to give projects credit for doing so. The research on reduced parking supply as a trip-reduction intervention is extensive. Excluding it entirely from the parking exemption pathway treats parking supply as neutral when it is not.
The lack of scaling in the parking reduction program means projects that reduce their parking to near-zero will receive no more credit than a project that goes slightly under the standards in the ITE Parking Generation Manual. Projects should receive more credit for supplying (near-)zero car parking than a flat 10%; such projects should be able to meet the ordinance without having to implement any other major strategies.
For the “Limit Parking Supply” item, we are concerned about the requirement for adjacent street parking to be metered/permitted. While it is true that limiting parking supply is less effective when there is free street parking nearby, that does not mean that it is ineffective. It is also the case that a new development does not have control over whether street parking is free or not. While we would urge the City to properly regulate the availability of street parking adjacent to new developments, we do not believe that a developer’s ability to use this program should be contingent on the City taking action first.
The applicability of some of the parking-related strategies is a bit confusing. It is not clear why unbundled parking should be mutually exclusive with restrictive parking supply—even a project that has reduced parking may still benefit from unbundling parking, and vice-versa. Note AB1317 already requires most multifamily projects to unbundle parking.
Core Strategies for Residential
Given that various Core Strategies are inherently unavailable to Residential projects (e.g. Telecommuting) and that the Auxiliary Strategies are not equal in effort or cost, we do recommend that some of the Auxiliary Strategies, such as Car-Share or TMA membership, be made available as core strategies with reasonable ADT estimates.
Additional Auxiliary Strategies
We would also encourage the City to explicitly list as Auxiliary Strategies site-related design changes that can encourage active transportation, particularly in light of some of the proposed R3 design standards. For instance:
- Projects providing public paths through their property for paseos.
- Projects which provide shade, whether via arcades or tree canopy, on public sidewalks.
- Projects which fund new bicycle facilities or wider sidewalks on the public right-of-way.
- Projects which place primary entrances on the sidewalk rather behind a parking lot.
Monitoring
Residential projects are exempt from travel surveys and traffic counts, which is a meaningful distinction from nonresidential. However, medium and large residential projects are required to submit annual TDM Reports for at least a decade, which is quite a long compliance period for a housing project. We ask that residential monitoring be capped at 5 years for all project sizes in order to see TDM strategies to maturity. Continued reporting may produce excessive administrative burden without proportionate benefit to the city or community.
Compatibility with State Law
Many new housing projects will qualify for state laws that require review only against objective standards. The ordinance should include explicit language confirming that TDM compliance is satisfied by adopting a qualifying TDM Plan from the Toolkit without additional discretion.
Thank you for your consideration.
James Kuszmaul, on behalf of Mountain View YIMBY