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0 <br />Parking <br />L <br />As explained in the Initial Statement of Reasons, the Natural Resources Agency <br />concluded that the question related to parking adequacy should be deleted from the <br />Appendix G checklist in part as a result of the decision in San Franciscans Upholding <br />the Downtown Plan v. City and County of San Francisco (2002) 102 Cal.AppAth 656. <br />The court in that case distinguished the social impact of inadequate parking from actual <br />adverse environmental impacts. In particular, that court explained: <br />[Tjhere is no statutory or case authority requiring an EIR to identify <br />specific measures to provide additional parking spaces in order to meet an <br />anticipated shortfall in parking availability. The social inconvenience of <br />having to hunt for scarce parking spaces is not an environmental impact; <br />the secondary effect of scarce parking on traffic and air quality is. Under <br />CEQA, a project's social impacts need not be treated as significant <br />impacts on the environment. An EIR need only address the secondary <br />physical impacts that could be triggered by a social impact. <br />(ld. at p. 698 (emphasis in original).) The Natural Resources Agency is aware of no <br />authority requiring an analysis of parking adequacy as part of a project's environmental <br />review. Rather, the Agency concurs with the court in the San Franciscans case that <br />inadequate parking is a social impact that may, depending on the project and its setting, <br />result in secondary effects. Consistent with exiting CEQA Guidelines section <br />15131(a), deletion of the parking adequacy question from Appendix G checklist will <br />ensure that the "focus of the analysis shall be on the physical changes." Specifically, <br />the Appendix G checklist contains questions asking about possible project impacts to air <br />quality and traffic. <br />Some comments pointed to examples of potential adverse impacts that could <br />result from parking shortages, such as double- parking and slower circulation speeds, <br />and referred specifically to a study of "cruising" behavior by Donald Shoup that noted <br />that cruising could result in emissions of carbon dioxide. The relationship between <br />parking adequacy and air quality is not as clear or direct as some comments imply. Mr. <br />Shoup, for example, submitted comments to the Natural Resources Agency supporting <br />the deletion of the parking question. (See, Letter from Donald Shoup, Professor of <br />Urban Planning, University of California, Los Angeles, October 26, 2009.) In those <br />comments, Mr. Shoup opines that cruising results not from the number of parking <br />spaces associated with a project, but rather from the price associated with those <br />parking spaces. (ibid.) The Natural Resources Agency also has evidence before it <br />demonstrating that providing parking actually causes greater emissions due to induced <br />demand. The California Air Pollution Control Officers Association CEQA White Paper, <br />for example, suggests reducing available parking as a way to reduce greenhouse gas <br />emissions. (Greg Tholen, et al. (January, 2008). CEQA & Climate Change: Evaluating <br />and Addressing Greenhouse Gas Emissions from Projects Subject to the California <br />Environmental Quality Act. California Air Pollution Control Officers Association, at <br />Appendix B, pp. 8 -9.) <br />96 <br />55A -235 <br />