The Environmental Planning Commission met on April 15 to consider two items we’d written to them about earlier in the week: AB 130 streamlined approval and the citywide TDM ordinance. Our letters were the only public comment submitted on either item.
Item 5.1: AB 130 Administrative Approval
EPC voted 6-0 to recommend adoption, with a minor cleanup to strike a duplicate “small animal keeping” listing from the residential use table. The administrative approval process in the ordinance is what we asked for.
Our specific ask, a target date for completing the transition to a fully ministerial framework (we suggested Q4 2026), did not make it into the motion. Chair Nuñez and Commissioner Subramanian both pressed staff on timelines. Director Murdock committed only to “sometime beyond 2026,” citing completion of the R3 update as a prerequisite. Council is tentatively scheduled to take this up on May 26.
Item 6.1: TDM Ordinance
This was a study session. EPC offered feedback for staff to carry to the City Transportation Commission on May 5 and to Council later this fiscal year.
Three of our concerns came up:
- Tiered parking credit. Commissioner Subramanian proposed tiered credit for reduced parking as an auxiliary strategy, which overlaps with our ask to scale parking-reduction credit and stop excluding unbundled parking and limited parking supply from the enhanced TDM pathway. Majority straw-poll support. Staff called the fix a toolkit change requiring roughly a year of consultant work, so it will not be in place before Council adopts the ordinance.
- TMA membership as a Core strategy. Subramanian raised this directly. Staff rejected it on constitutional grounds, citing Koontz, Nollan, and Dolan. Core strategies are mandatory, and mandating membership in a private nonprofit with non-transparent fee-setting is legally fraught. The compromise is an outsized ADT-reduction credit attached to TMA membership as an Auxiliary strategy.
- Cost trajectory and concession risk. Commissioner Cranston flagged the cost of TDM compliance on larger residential projects and warned that steeper requirements create an incentive for density-bonus concessions to waive the ordinance entirely. Staff agreed to assess the concession history.
Vice Chair Donahue questioned the non-linear 30/40/50% ADT reduction targets. Assistant Community Development Director Blezinski answered that CTC and Council had already approved those thresholds at the framework stage and staff is sticking with them for this round of the ordinance.
Several items from our letter did not come up in discussion: the 10-year residential monitoring window, state-law compatibility language, the mutual exclusivity of unbundled parking and limit parking supply, the street-parking metering precondition in Limit Parking Supply, and our list of site-design auxiliary strategies (paseos, shade, sidewalk-facing entrances, new bike facilities).
Our Take
AB 130 streamlining is a good outcome. The ministerial transition is still a live question, but today’s ordinance solves the immediate problem: qualifying projects were at risk of being deemed approved because the city couldn’t act within the statutory clock.
The TDM item is where the work remains. The ordinance requires new housing to cut vehicle trips by 30 to 50 percent, but it caps or excludes the most effective strategies for doing so: reduced parking counts, unbundled parking, and limited parking supply. The targets themselves are locked. Blezinski confirmed CTC and Council approved them at the framework stage, and EPC is not going to reopen that fight.
That leaves the toolkit as the only place to close the gap, and the commission flagged the same issue our letter did. Subramanian’s tiered-parking-credit proposal overlaps with what we asked for, and a majority of commissioners supported it in a straw poll. Staff said the toolkit revision is roughly a year of consultant work. Most of our parking-related asks sit inside that work: scaling credit, dropping the double-counting exclusion, and fixing the unbundled/limit-parking exclusivity. None of those will be resolved before Council adopts. We’re disappointed: the commission agrees the parking credits are too stingy, and the fix is a year away.
We’ll be at the Council hearing.