Re: Agenda item 6.1
Dear Mayor Ramos and Members of the City Council,
Mountain View YIMBY supports work on a Citywide TDM Ordinance. A standardized framework with a parking exemption pathway for residential projects is a significant step forward from the current ad hoc, project-by-project approach. We appreciate the exemptions for residential trip caps, travel surveys, and driveway counts, and the decision to keep TMA membership optional given Prop 218 concerns identified.
We appreciate some of the changes made since the EPC & CTC meetings, including allowing projects to receive credit for limiting parking supply when they also unbundle parking costs and introducing additional core strategies.
ADT Reduction Targets / Numerical Requirements
We appreciate recent changes that lowered the ADT reduction targets for all residential projects, though we would still like to see more concrete analysis on the cost and feasibility for expected projects.
The separate requirement of choosing Auxiliary Strategies in proportion to project size lacks evidence of effectiveness, especially since the strategies range in effort. We request that staff either provide evidence or reduce/eliminate the number.
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.
The lack of scaling in the parking reduction program, as called out by EPC, 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 meet the ordinance without having to implement any other major strategies. While staff does mention that this detail can be administratively modified, we would still like amendments to be made as soon as possible.
For the “Limit Parking Supply” strategy, we thank staff that the requirement for adjacent street parking to be metered/permitted has been lifted, allowing projects to use this program regardless of city action.
Parking Reduction for Small Projects
We would encourage the city to provide some pathway such that small residential projects (under 200 ADT) can receive a parking exemption if they meet some enhanced TDM criteria, even though they would not be required to participate in the TDM program at all normally.
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 enough 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, including AB 130 ministerial review (toward which the City is already working). The ordinance should include explicit language confirming that TDM compliance is satisfied by adopting a qualifying TDM Plan from the Toolkit without additional discretion. Some of the strategies, such as “Active Transportation Gap Closure Improvements”, may be a bit too vague to meet the state definition of objective.
Thank you for your consideration.
James Kuszmaul, on behalf of Mountain View YIMBY