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8.A. - Page 20 :aff also identified eight intersections having the potential to be impacted by the Project and warranting further evaluation. This report was evaluated as part of the IS checklist and staff review, and staff concluded that In summary, the proposed Project forecasted traffic falls within the magnitude of the traffic increase accounted for in the DTPP EIR. 7. There is no need for additional CEQA analvsis reqardinq "relational heiqht considerations" or "tower wall stepbacks" since the Proiect is not adlacent to a four-story heiqht zone. The Appellant incorrectly states the need for an analysis of"relational heighY' and "tower wall stepback" considerations in the DTPP EIR (Appeal, Items II.0 and II.D). Again, this objection relates to the analysis in the DTPP EIR, and it is too late for Appellant to raise objections to that certified, approved EIR (see Master Response, IV.A.1 above). Nevertheless, Staff assumes that the Appellant is referring to Figure 6.3 in the EIR, not "Figure 7.3" as the Appellant refers to. The Project site is not adjacent to a four-story height zone (see DTPP Height Regulations Map, p. 86, Figure 6.3 in the DTPP EIR, as well as Master Response 1 in this document). The Appellant assumes that references to "tower wall stepbacks", "relational heighY' provisions, and other DTPP descriptive terms (DTPP EIR, Chapter 6, Aesthetics) are mandatory standards that apply to the Project. As discussed in Master Response 1 , they do not apply to the Project as a regulatory standard. V. The Project does not require additional environmental review because of the inclusion of the "unbundled" parking approach. A. The Appeal Should Not Be Granted on the Grounds that impacts from the "unbundlinq" of parkinq have not been analvzed. AppellanYs Position: Additional environmental analysis is needed because the Project proposes to "unbundle" parking (Appeal, Item II.B). City's Response: 1 . The Project meets the City's parking requirements, and as a result, there will be no significant impact due to the Project being "underparked". As discussed in Section 1 , Table 1 — Compliance with Key Standards of this staff report, the Project complies with the minimum parking requirement. In fact, the Project provides for 599 spaces, while the requirement per the DTPP is 526 spaces (for a surplus of 73 spaces). In addition, in the opinion of San Franciscans Upholding the Downtown Plan v. City and County of San Francisco (2002) 102 Cal. App. 4th 656 (1st App. Dist.) (Attachment 11) the court held that even if unbundled parking may lead to less use of on-site parking and more vehicles relying on street parking, a shortfall in the parking is not, in and of itself, a significant environmental effect under CEQA. 2. There is some evidence that unbundled parking results in reduced demand for parking as well as other general benefits. The City Is not Page 20