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11/18/2013 <br /> For developments where this is nat passible, the payment of in-lieu fees for the development of <br /> an equivalent number of units cauid be an alternative to this requirement. <br /> 4. Eliminate eligibility for targe commercial projects (75,000 square feet ar greater). <br /> Large commercial (aka big box) prajects are highly auto-oriented (even if they are near public transit) <br /> and undermine effarts to preserve or create historic, walkable commercial districts that are waven into <br /> the urban fabric. In the sho►t-term an individual big-box project may reduce lang-distancs driving ta <br /> the nearest similar stare. But there is a long-term impact on smaller, neighborhood-serving business <br /> districts, and retail in particular, that must be accounted far. As small walkable retail choices decline, <br /> VMT will grow and it becames mare difficult to reduce car awnership. In fact a 2011 study in <br /> Southern California by 5 praminent researchers found that the number af businesses per acre is the <br /> single mast robust indicator of whether peaple are likely to walk in their neighborhoad. They found <br /> that people living in neighborhaods with more business establishments per acre conduct more of their <br /> travel within the neighborhaod and are more likely to travel by walking. (Retrof'�tting Suburbs ta <br /> lncrease Walking, in tTS'ACCESS magazine, Fall 2011.) <br /> Beyond the fact thafi big box stores may harm the environment averall,there is little evidence ta <br /> suggest that big-box development is underbuilt in California. With billions in annual profits and <br /> dozens of stores opening each year in California, CEQA analysis does not seem to be an <br /> unaffardable ar unnecessary process for these stores. <br /> Recommendation: Eliminate the provision that allaws commercial or retail projects to be <br /> eligible if they prepare a transportation study. <br /> 5. Commercial/Retail projects in areas above.75% regianal per capita VMT shautd not be <br /> eligible just bas�d on meeting CALGreen criteria. <br /> The prapased guidelines lay out a very strong set af guidelines ta promote cammercial and retail <br /> development that can reduce VMT. Unfartunately, all of those criteria may be undermined in the <br /> same way that the residential gaals may be undermined. As stated above far residential prajects, <br /> CALGreen building cade daes not consider project location or ather criteria that address VMT. VMT <br /> is an appropriate metric far identifying infill development;CALGreen is not. While we support the <br /> inclusion of CALGreen in these guidelines, they shauld nat substitute far VMT as the metric far <br /> determining eligibility. <br /> Recammendation: Prajects in TAZs that are less than 75 percent af regianal VMT and meet <br /> the ather criteria should be able ta receive the SB 226 benefits. But the option of implementing <br /> CALGreen Tier 1 or 2 alone as a way to reach eligibility in the higher VMT TAZs should be <br /> eliminated. Given that the guidelines paint to iwa other criteria that could be met to eligible-- <br /> 1} close proximity tp 1,200 househalds and 2) transit proximity plus low parking -- it may be <br /> feasible ta develop some standards-based form for considering commercial and residential in <br /> yellow and red zone TAZs, but these should not be based on CALGreen and wnuld need to be <br /> explored in much greater depth. We are concerned that travel studies would not be adequate <br /> as the literature and the modeling capabilities for commerciaUretail projects are less robust <br /> than for residential and would be ripe for gaming. <br /> 6. Inctude a maximum parking ratia for two of the propased commercial/retait eligibility <br /> criteri� <br /> 4 RESO.#15305 <br /> MUFF#603 <br />