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The proposed project does not integrate affordable and below market rate housing (Measure T-4). <br />Instead of including affordable housing in the project, the "applicant has selected the option to pay in - <br />lieu fees." (Staff Letter, p. 4-6) <br />The parking VMT-reduction measures documented in the Handbook include: <br />• T-15 Limit Residential Parking Supply, and <br />• T-16 Unbundle Residential Parking Costs from Property Cost, and <br />Both parking measures encourage residents to shift trips from autos to walking, biking, and transit. The <br />Handbook states: <br />Limiting the amount of parking available creates scarcity and adds additional time and <br />inconvenience to trips made by private auto, thus disincentivizing driving as a mode of <br />travel. (Measure T-15) <br />On the assumption that parking costs are passed through to the vehicle owners/drivers <br />utilizing the parking spaces, this measure results in decreased vehicle ownership and, <br />therefore, a reduction in VMT and GHG emissions. (Measure T-16) <br />The Handbook cautions that these measures may not work well in auto -oriented areas like the area <br />where the proposed project is sited. The Handbook states: <br />When limiting parking supply, a best practice is to do so at sites that are located near <br />high quality alternative modes of travel (such as a rail station, frequent bus line, or in a <br />higher density area with multiple walkable locations nearby). (Measure T-15) <br />Measure T-16, unbundling residential parking costs, is explicitly prohibited by the City of Santa <br />Ana. Its document, Off -Street Parking Requirements, states: <br />No owner or agent of any owner of multiple -family residential property shall impose any <br />charge on any resident for the privilege of parking in the off street parking spaces on <br />such property which is separate and distinct from the rent charged to such resident for <br />such resident's dwelling unit.' <br />The proposed project is in an auto -oriented, VMT-inefficient part of the City of Santa Ana, and <br />the project's location also will largely preclude significant mitigation of its VMT impacts. <br />Sincerely, <br />Norman L. Marshall <br />' https:��stora�e,00leapis,corn�proudcity�santaanaca�uploads�2f�22�f�3�®ff-StreetParkinll-17,pdf, p. 5 of 17. <br />P <br />