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11/18/2013 directly counter to the explicidy stated goals of SB 375, which is attempting ta reduce not increase VMT, as well as SB 226's goals. The CALGreen building code is a useful tool for promating energy efficiency and green construction; however this code does not consider praject location or other criteria that address VMT. While we support the inclusion of CALGreen in same way in these guidelines,they should not substitute far VMT as the metric for determining eligibility. As a reference far what is possibls, TransForm's GreenTRIP certification uses 25 -35 VMT/household/day �depending an Iocation} as the maximum daily driving as a cut off for GreenTRIP eligibility. This represents 50%- 70%of the Bay Area's regional hausehald driving average, which is 50 VMTIHH/Day. Projects must also meet a maxlmum parking criteria and provide at least ona of three eligible traffic demand management measures.TransForm's first five GreenTRIP certified projects would produce just 30%-59%of the regional average VMT, measured using URBEMIS as the sketch madel. Same examples of strategies that can be used to reduce VMT in higher VMT zones include: � Unbundled parking • Affardable housing generatian � • Providing transit passes • Providing CarShare pads and patentially free memberships Unbundled parking —In this strategy, the cost of parking is separated from tha cast of purchasing or renting a home. This strategy because can reduce the amount af parking needed and thus the costs of development. It is proven to be effective because it incentivizes and rewards those who decide to reduce vehicle awnership. Depending on th�price, and demand and convenience of parking work environments, unbundled parking produces parking demand reductions of 10-15%: MTC Smart Growth Parking Taolbax, 2007. According to CAPCOA's 201 Q report, Quantifyinq Greenhouse Gas � Mirigation Measures, unbundling could reduce bath VMT and GHG emissians by 2.6'�-13� (depending on tha tocation and etasticftfes}. Unbundling can also be used far retail, affica, industrial and mixed-use prnjects. Affordable housing generation: URBEMIS and CalEEmod cap the reduction credit for affordable housing at 4°!o irrespective of the depth of affordability.The recerrt City of San Diego affordable hnusing parking survey shawed how this is significantly undercaunting the driving reduction credit of dedicated affordable housing, especially for low and very-low income units in urban areas. We believe that by callecting and combining existing data, and conducting new empirical research that is being considered far funding by Galtrans, dedicated affordable hausing could ultimately count for even greater reductions. Transit passes and carshare memberships: �n-site transportation demand management strategies, such as fres transit passes ar on-site carsharing with free memberships, can reduce the amount of parking that must be pravided. In many areas, especially where the transit agencies provide bulk discounts, these amenities may be able ta "pay far themselves" if parking is reduced enaugh. More transit agencies are now praviding bulk monthly transit passes for an entire residential building. By providing it to each resident they can charge the building managers just$10 to $20 per manth, low enough that it can be covered through the saving of reduced parking. Recommendatian: For residential prajects to benefit from the SB 226 CEQA streamllning we recommend a "cap"on VMT equal to 75°!0 of the regional average VMT. This would ensure that 2 RESO.#15305 MUFF#603