Mountain View YIMBY

Re: Agenda item 6.1

Dear Chair Nunez and Members of the Environmental Planning Commission,

Mountain View YIMBY supports work on the Citywide TDM Ordinance. A standardized framework with a parking exemption pathway for residential projects is a significant step forward from the current ad hoc approach of imposing TDM requirements project-by-project. We appreciate the exemptions for residential trip caps, travel surveys, and driveway counts, and the decision to keep TMA membership optional given the Prop 218 concerns the staff report identifies. We ask the Commission to consider the following comments.

ADT Reduction Targets / Numerical Requirements

We appreciate the smaller ADT reduction targets for TOD projects, as proximity to transit encourages less single-occupant vehicle (SOV) trips. However, we are concerned that the targets for residential projects, particularly for non-TOD residential projects (30/40/50% for S/M/L), are still high without concrete analysis, just references to Precise Plan targets and peer jurisdiction benchmarking. To incentivize new large residential developments, as new density is inherently critical for reducing SOV trips and city vehicle-miles-traveled (VMT), we would recommend lowering the reduction targets, at least until there is study on the cost to development.

The separate requirement of choosing Auxiliary Strategies in proportion to project size also seems without evidence of effectiveness or cost-benefit, especially since the strategies range in effort. We request evidence, or we request the number to be less/eliminated.

Parking Reduction

Reducing car parking is one of the most important strategies to reduce SOV trips in new projects, and one of the hardest to do post-construction. While the proposed TDM program does encourage reducing parking and allow projects to receive exemptions to parking minima, we recommend further changes to maximize the impact of the TDM program.

For the enhanced TDM parking exemption, its own restrictions undermine it. A residential project seeking the exemption must either exceed its ADT target by 5% or adopt one additional Core Strategy and two additional Auxiliary Strategies beyond the minimum (Section 124(I)). At the same time, the project cannot count Unbundled Parking or Limit Parking Supply toward meeting enhanced TDM criteria, on the theory that this would be “double-counting.” This is not double-counting under any reasonable definition of the term; a project that reduces the parking it provides will reduce the number of SOV trips generated, and it would be inaccurate not to give projects credit for doing so. The research on reduced parking supply as a trip-reduction intervention is extensive. Excluding it entirely from the parking exemption pathway treats parking supply as neutral when it is not.

The lack of scaling in the parking reduction program means projects that reduce their parking to near-zero will receive no more credit than a project that goes slightly under the standards in the ITE Parking Generation Manual. Projects should receive more credit for supplying (near-)zero car parking than a flat 10%; such projects should be able to meet the ordinance without having to implement any other major strategies.