SR-8-A (23)
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JUN 4 1991
LU'IM:CPD:SF
wjtmp2
COGNCIL MEETING: June 4, 1991
Santa Monica, California
TO:
Mayor and city Council
FROM:
City staff
SUBJECT:
staff Responses to Council Questions
Commerce Comments on the Proposed
Management Ordinance (TMP).
and Chamber of
Transportation
INTRODUCTION
At the May 28, 1991 City Council meeting, after the public
testimony, council asked staff to prepare responses to questions
by the Council and comments submitted by the Chamber of Commerce.
The attached report provides staff responses to the Council
questions and the Chamber comments.
BUDGET/FINANCIAL IMPACT
The recommendation presented in this report does not have a
budget or fiscal impact.
RECOMMENDATION
It is recommended that the City council provide staff with
recommended changes to the Ordinance and direct staff to return
with a revised Ordinance for first reading.
Prepared By: Paul Berlant, Director of LUTM
Suzanne Frick, Planning Manager
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JUN 4 ;99J
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Karen Pickett, Transportation Coordinator
Paul Casey, Transportation Planner
Land Use and Transportation Management Department
Program and Policy Development Division
B:
City council Comments and Staff Responses
Proposed Budget with Revenues and Expenditures
Chamber of Commerce Comments and Staff
Responses
Attachments: A:
C:
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RESPONSES TO CITY COUNCIL'S QUESTIONS ON THE TMP ORDINANCE FROM
THE MAY 28, 1991 MEETING
1) "Define 'demonstrates' as in how employers demonstrate that
they have attained a L 5 AVR.II
Response:
Demonstrating a l.5 AVR is accomplished through the
employer's filing of an annual plan that calculates
the AVR and provides the backup data used in the
calculation. The City will verify employers' AVR
and plan implementation through random audits at
worksites. (Ref. Sec. 9231, Transportation
Mitigation Monitoring, specifically part (a) on
page 24 and part (b) on page 27.)
2) nnefine violations of the Ordinance and the sanctions which
may be imposed."
Response:
Violations of the Ordinance are failure to submit
an initial plan or annual report and plan update,
failure to implement mandatory plan revisions, or
failure to implement provisions of an approved
plan. Enforcement actions include non-renewal of
the employer's business license, fees, transfer of
enforcement to the AQMD, or any other remedy
provided for by law. (Ref. Sec. 9232,
Enforcement. )
3) "What is staffs authority to approve/disapprove plans?"
Response:
Authority is given to the City'S Transportation
Management Coordinator to approve or disapprove
plans by Sec. 9228 (b) of the Ordinance.
4) If What forms are we going to use and will they be compatible
with AQMD's Regulation XV forms?"
Response:
The forms the City uses will be exactly like AQMD's
except for the additional information we will
require for measurement and reporting of the p.m.
peak period AVR. The forms will be included in an
Employer/Developer Handbook which will be
distributed to each affected employer and
developer. The handbook will also explain the
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purpose of the Ordinance, provide examples of how
to complete and file a plan, and outline expected
results of implementing various types of commute
plan elements.
5) "What is the cost of implementation?"
Response:
Please see the attached budget section outlining
projected costs and revenues.
6) "Will there be a reduction in fees to publie employers?"
Response:
Public employers are required to pay a fee under
AQMD's Regulation XV and the City's proposed
Ordinance requires the same, unless council directs
staff otherwise.
7) "Is the county exempt?tI
Response:
The County is not exempt under Regulation XV, and
the City's Ordinance treats them the same.
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PROPOSED BUDGET FOR THE IMPLEMENTATION
OF THE TRANSPORTATION MANAGEMENT ORDINANCE
The following outlines the anticipated expenditures and revenues
for implementation of the Transportation Management Ordinance.
Due to the potential shortfall of revenues after the forth year
(due to the proposed incentive fee reductions), staff is
recommending that the ordinance be changed to limit the maximum
reduction of fees to 90% of the total fees required. This will
help ensure the program generates sufficient revenues to operate
the program.
The following outlines the proposed budget:
Proposed Budget
1 TMP Manager
2 Transp. Coord.
1 Clerical
consultants
supplies
$70,000*
91,000*
33,000*
20,000
35,000
Total:
$249,000
* This figure includes benefits
Projected Revenues
1st Year
2nd Year
3rd Year
4th Year
4th Year (90% Cap)
$ 75,000
172,079
3l5,468
287,992
291,742
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YEAR 1 REVENUE ESTIMATES
100+ EMPLOYERS
TOTAL NUMBER OF EMPLOYEES: 25,000
ASSUME 50% PARTICIPATION DUE TO AQMD PLAN OPTION
FEE IS $6 PER EMPLOYEE
NO TMA PARTICIPATION IN FIRST YEAR
# OF EMPLOYEES
FEE
REVENUES
50% PARTICIPATION
TOTAL
25,000
$6
$150,000
$75,000
$75,000
TOTAL REVENUE FOR YEAR 1 = $75,000
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YEAR 2 REVENUE ESTIMATES
100+ EMPLOYERS
NUMBER OF EMPLOYEES: 25,000
ASSUME 100% PARTICIPATION
25% WILL BE IN A TMA AND RECEIVE 25% FEE REDUCTION
TMA RECEIVES 50% FEE REDUCTION FOR AVR 1.5
THUS A TOTAL DISCOUNT OF 75%
75% NO TMA
25% TMA
# OF EMPLOYEES
FEE
REVENUES
75% DISCOUNT
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18,750
$6
$112,500
6,250
$6
$37,500
$9,375
TOTAL
$121,875
50 -99 EMPLOYERS
NUMBER OF EMPLOYEES: 8,925
ASSUME 100% PARTICIPATION
25% WILL BE IN A TMA WITH NO AVR DISCOUNT FIRST YEAR
75% NO TMA
25% TMA
II OF EMPLOYEES
FEE
REVENUES
25% DISCOUNT
6,694
$6
$40,164
2,231
$6
$13,386
$10,040
TOTAL $50,204
TOTAL REVENUE FOR YEAR 2: $172,079
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100+ EMPLcvERS
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YEAR 3 REVENUE ESTIMATES
NUMBER OF EMPLOYEES: 25,000
ASSUME 100% PARTICIPATION
25% WILL BE IN A TMA AND RECEIVE 25% FEE REDUCTION
TMA RECEIVES 60% FEE REDUCTION FOR AVR 1.5 FOR 2 YEARS
TOTAL REDUCTION OF 85% FOR TMA MEMBERS
# OF EMPLOYEES
FEE
REVENUES
85% DISCOUNT
TOTAL
50 -99 EMPLOYERS
75% NO TMA
25% TMA
18,750
$6
$112,500
6,250
$6
$37,500
$5,625
$118,125
NUMBER OF EMPLOYEES: 8,925
ASSUME 100% PARTICIPATION
25% WILL BE IN A TMA AND RECEIVE 25% FEE REDUCTION
TMA RECEIVES 50% FEE REDUCTION FOR AVR 1.5 FIRST YEAR
TOTAL REDUCTION OF 75% FOR TMA MEMBERS
# OF EMPLOYEES
FEE
REVENUES
75% DISCOUNT
TOTAL
10 - 49 EMPLOYERS
75% NO TMA
25% TMA
6,694
$6
$40,164
2,231
$6
$13,386
$3,347
$43,511
NUMBER OF EMPLOYEES: 20,5l0
ASSUME 100% PARTICIPATION
25% WILL BE IN A TMA WITH NO AVR DISCOUNT FIRST YEAR
$8 FEE FOR EMPLOYERS WITH LESS THAN 50 EMPLOYEES
(I OF EMPLOYEES
FEE
REVENUES
25% DISCOUNT
75% NO TMA
25% TMA
15,383
$8
$123,064
5,128
$8
$41,024
$30,768
TOTAL $153,832
TOTAL REVENUE FOR YEAR 3: $315,468
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YEAR 4 REVENUE ESTIMATES
100+ EMPLOYERS
NL~BER OF EMPLOYEES: 25,000
ASSUME 100% PARTICIPATION
25% WILL BE IN A TMA AND RECEIVE 25% FEE REDUCTION
TMA RECEIVES 80% FEE REDUCTION FOR AVR 1.5 FOR 3 YEARS
TOTAL REDUCTION OF 105% FOR TMA MEMBERS (NO REBATE)
75% NO TMA 25% TMA
# OF EMPLOYEES
FEE
REVENUES
100% DISCOUNT
18,750
$6
$112,500
6,250
$6
$37,500
$0
TOTAL
$112!500
50 -99 EMPLOYERS
NUMBER OF EMPLOYEES: 8,925
ASSUME 100% PARTICIPATION
25% WILL BE IN A TMA AND RECEIVE 25% FEE REDUCTION
TMA RECEIVES 60% FEE REDUCTION FOR AVR 1.5 FOR 2 YEARS
TOTAL REDUCTION OF 85% FOR TMA MEMBERS
75% NO TMA
25% TMA
# OF EMPLOYEES
FEE
REVENUES
85% DISCOUNT
6,694
$6
$40,164
2,231
$6
$l3,386
$2,008
TOTAL
$42,172
10 - 49 EMPLOYERS
NUMBER OF EMPLOYEES: 20,510
ASSUME 100% PARTICIPATION
25% WILL BE IN A TMA AND RECEIVE A 25% DISCOUNT
TMA RECEIVES 50% FEE REDUCTION FOR AVR 1.5 FIRST YEAR
TOTAL DISCOUNT OF 75% FOR TMA MEMBERS
$8 FEE
75% NO TMA 25% TMA
# OF EMPLOYEES 15,383 5,128
FEE $8 $8
REVENUES $123,064 $41,024
75% DISCOUNT $10,256
TOTAL $133,320
TOTAL REVENUE FOR YEAR 4: $287,992
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YEAR 4 REVEN~ESTIMATES - WITH 90% RED~ION CAP
100+ EMPLOYERS
NUMBER OF EMPLOYEES: 25,000
ASSUME 100% PARTICIPATION
25% WILL BE IN A TMA AND RECEIVE 25% FEE REDUCTION
TMA RECEIVES 80% FEE REDUCTION FOR AVR 1.5 FOR 3 YEARS
TOTAL REDUCTION OF 90% FOR TMA MEMBERS DUE TO CAP
# OF EMPLOYEES
FEE
REVENUES
90% DISCOUNT
TOTAL
50 -99 EMPLOYERS
75% NO TMA
25% TMA
18,750
$6
$112,500
6,250
$6
$37,500
$3,750
$116,250
NUMBER OF EMPLOYEES: 8,925
ASSUME 100% PARTICIPATION
25% WILL BE IN A TMA AND RECEIVE 25% FEE REDUCTION
TMA RECEIVES 60% FEE REDUCTION FOR AVR 1.5 FOR 2 YEARS
TOTAL REDUCTION OF 85% FOR TMA MEMBERS
# OF EMPLOYEES
FEE
REVENUES
85% DISCOUNT
TOTAL
10 - 49 EMPLOYERS
75% NO TMA
25% TMA
6,694
$6
$40,164
2,231
$6
$13,386
$2,008
$42,172
NUMBER OF EMPLOYEES: 20,510
ASSUME 100% PARTICIPATION
25% WILL BE IN A TMA AND RECEIVE A 25% DISCOUNT
TMA RECEIVES 50% FEE REDUCTION FOR AVR 1.5 FIRST YEAR
TOTAL DISCOUNT OF 75% FOR TMA MEMBERS
$8 FEE
# OF EMPLOYEES
FEE
REVENUES
75% DISCOUNT
75% NO TMA
25% TMA
15,383
$8
$123,064
5,128
$8
$41,024
$10,256
TOTAL $133,320
TOTAL REVENUE FOR YEAR 4: $291,742
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RESPONSE TO COMMENTS ON TRANSPORTATION MANAGEMENT PLAN FROM SANTA
MONICA CHAMBER OF COMMERCE
1) lilt is possible for a TMA to operate as an 'employer' for the
purpose of preparing and implementing a plan...Alternative1y,
the TMA can be nothing more than a source of information for
its employer members"
A) "If the City is to encourage the use of THA'S, a
reduction should be made available to employers joining
either type of TMA. The amount of the reduction should
depend upon whether the TMA is an employer TMA or an
information TMA."
Response: Staff agrees that a TMA may serve as a source of
information. However, the 25% discount on the
employer impact fee will only be provided to
employer TMA's since they will be preparing and
implementing plans for a number of employers. An
information TMA will be providing assistance to
employers but not reducing the amount of work
required by the city TMP office to review the
plans.
B) "section 9227(d) recognizes the two different types of
TMAs but the concept is not fully adhered to throughout
the ordinance".
Response: Staff agrees and will modify the Ordinance for
consistency.
C) Section 9227(d) requires the execution of covenants,
conditions and restrictions or similar legal instruments
which set forth the obligations of each member employer.
First, any requirement of this type should apply only to
employer TMAs....Second, it is not clear what type of
document is contemplated."
Response: Staff agrees that the requirement for CC&Rs only
apply to employer TMAs. The City will work with
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employers to develop an appropriate document to
guarantee that all employers are equally
responsible for implementing the plans. CC&Rs are
one alternative.
D) "The concept of joint and several liability established
in section 9227(d) is a disincentive sUfficiently strong
to discourage any employer from participating in a TMA.1I
Response: Staff believes that formation of TMAs will be
attractive to employers for both the reduction in
the impact fee and the ability to achieve the 1.5
AVR requirement at an earlier point through
cooperation and coordination. The formation of a
TMA would be similar to that of a partnership, with
all employers who join being equally responsible
for implementing the approved Plan. Should an
employer decide not to comply with the approved
Plan, the TMA would have the ability of removing
the employer from the TMA.
E) "Section 9227(d) on page 19 gives the City the right to
require the formation of a TMA. This provision is
inappropriate_If
Response: The requirement to form a TMA will only occur when
staff believes that synergism of a large number of
small employers will greatly enhance their chances
of achieving an AVR of 1.5.
2) "Before the amount of the fee is established, a budget should
be presented which takes into account the $1,000,000
available from the Water Garden and Arboretum projects and
shows how the money will be spent.n
Response:
A budget will be presented to the City Council
outlining the expected revenues from the fee and
the costs of staffing the City TMP office. It is
expected that the revenues raised by the fee will
not be sufficient to fund the initial start of the
program for the first two years. Money from the
Water Garden and Arboretum projects are available
to fund a portion of the TMP program, but those
monies may also be used for other mitigation
measures and therefore should only be used to
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implement the TMP ordinance as necessary. See
attachment for more information.
3) "The Ordinance should contemplate an annual review of the
amount of the fee in light of actual revenue and costs."
Response:
The fees will be reviewed each year as part of the
budgetary process to determine if there is a
surplus or shortfall occurring.
4) "The Ordinance should exempt the Santa Monica Malibu Unified
School District from payment of the fee.1I
Response:
There are no fee or plan exemptions for any
employers, as all employer sites will be
responsible for preparing a plan which the City
must review.
5) "The definition of this term (Average Vehicle Ridership)
works well enough when the methods used to increase AVR are
ridesharing in nature. However, if the employer, like the
City itself, ehooses to reduce peak period traffic through
flexible work hours or alternative schedules, AVR, as
defined, will be affected even though the purpose of the
Ordinance has been implemented.1I
Response:
The definition of AVR in the Ordinance is very
general. We agree that it needs to be amended to
account for compressed work weeks.
6) "Why should small employers with fewer than SO employees be
required to prepare and file plans when there is no
requirement to achieve any particular AVR level?1I
Response:
A) Small employers are required to file plans
because it is expected that they will eventually be
required to achieve a 1.5 AVR level through
Regulation XV. Therefore we include them in the
Ordinance now and will amend their requirements as
Regulation XV is modified.
7) "section 9227(f) requires that employer plans be consistent
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with developer plans previously approved by the city. There
seems to be no reason for this requirement and it violates
the principle of flexibility."
Response:
Developer plans focus on facility improvements,
therefore, employer plans will be expected to take
advantage of those improvements. Employers will
not be mandated to use the facilities, but it will
be one of their options.
8) Ifsection 9228(a) permits an employer with a plan which has
been approved by the AQMD within the previous six months to
submit that plan to the City in satisfaction of the first
year's requirement. Although this is a positive change from
the previous draft of the Ordinance, there seems to be no
reason not to expand this provision to include plans approved
within the previous twelve months.1I
Response:
staff believes that it is important to only allow
plans approved by AQMD in the previous six months
to guarantee that the Plans accepted by the City
are up to date. If the Ordinance allows plans that
are older than six months, it could be as long as
two years before an employer submits an annual
update plan.
9) If The AQMD echoed one of our concerns which relates to the
forms on which the reports are required. The staff states in
its response that 'changes will be made' but we do not yet
know what they will be~1I
Response:
The machine readable form will be struck. City
staff will work with AQMD to make sure that City
forms are compatible with AQMD forms.
10) "section 9231 sets forth an extensive list of information
which employers are required to submit to the City each year.
The list appears to be far lODger than necessary."
Response:
The information required is similar to what is
required by AQMD under Regulation XV, and provides
valuable information regarding mode choices and
other TOM related issues.
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11) "We strongly urge the Council to include a provision which
states that the Ordinance will not apply to any employer
covered by Regulation XV until the AQMD has provided a letter
to the City stating that the exemption will available and
that the AQMD will accept the City1s annual monitoring
reports under Regulation XV.II
Response:
staff agrees and the Ordinance will be changed.
12) "If developers are required to perform traffic improvements
identified in the EIR as being necessary to mitigate the
project1s impact and pay the fee, the aggregate will
necessarily require the developer to more than mitigate the
impact. II
Response:
Any improvements required of a developer to
mitigate significant traffic impacts under the
City'S environmental review process will still be
required and should not be allowed as credit
against the developer's Impact fee because those
are typically local impacts and not citywide or
regional impacts which is what the Impact fee will
address. However, if the developer funds
improvements not required to mitigate significant
impacts, a dollar-far-dollar credit will be given
against the Impact Fee, subject to mutual agreement
by the developer and the City.
13) liThe Ordinance purports to apply t.he fee retroact.ively t.o
projects which do not yet have a certificate of occupancy
even though these projects were approved through an EIR
process which required them to adequately mitigate their
traffic impacts; how can the City now attempt to come back
and require additional mitigation measures?1I
Response:
since the building has yet to be occupied, it is
still appropriate to assess the developer impact
fee to help fund traffic improvements. In
addition, all new development has a condition of
approval requiring payment of a traffic impact fee
prior to the issuance of a certificate of
occupancy. The impact fee is to mitigate
region-wide impacts, not necessarily the local
impacts which is what the ErR process analyzes.
14) tiThe Ordinance requires developers to prepare 'worksite
transportation plans. similar to those prepared by employers.
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In our view, these plans are of limited value and should be
deleted. II
Response:
See answer to #7
l5) "If, however, these plans are to be retained, then we have
the following comments: A) Although staff has streamlined
the requirements somewhat from the prior draft, the Ordinance
is still vague as to the content of these points1 (and) B)
Section 9231 requires the developer to monitor annual
compliance with its plan and submit reports. This seems
unnecessary and probably unrealistic."
Response:
City staff will revise section 9230 to include more
specific language on teh content of developer
plans. In section 9231 all references to
developers will be deleted.
16) "Like other City boards and commissions, we believe this
Board (The Worksite Transportation Plan Appeals Board) should
be made up of members of the public . . .and that at least
some of the Board members have experience in the area, such
as employment transportation coordinators for local
companies. II
Response:
One member of the Appeals Board will be appointed
by the City Council and Council will have the
opportunity to choose a member of the business
community or a transportation coordinator.
17) "section 9220(d) contains a specific number of additional
trips expected to be added to the City by the year 2010. If
the source for this number was the crain City-wide traffic
study, it is probably unreliable because of the reduction in
permitted levels of development in most areas of the city.
In this section, specificity is not necessary in any event."
Response:
staff will examine the number to make sure it
accurately reflects expected trips in the future.
la) "This definition (employee) should be clarified by adding the
following concepts: A) No employee should be counted who
does not work in Santa Monica..... (and) B) No person should
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be counted as an employee unless he or she regularly reports
to work during one of the peak period.1t
Response:
The definition is consistent with AQMD's definition
and will only affect employees in Santa Monica.
19) liThe AQMD comments raised a question regarding these two
definitions (Multi-tenant worksite and worksite) and while
the thrust or their comment is not particularly clear, there
is an inconsistency between the two terms.1t
Response:
City staff will change the definitions so they are
consistent with one another.
20) liThe Ordinance defines the afternoon peak period to begin at
3:00 and end at 7:00. This is quite an expansive definition
of the afternoon peak period which is generally stated to be
between 4:00 and 6:00 or 4:00 and 7:00.
Response:
The peak period between 3:00 p.m. and 7:00 p.m. was
chosen due to ever expanding congestion in the
afternoon. However, with the expanded peak period,
this will likely capture employees with compressed
work weeks or flex-time schedules and help
employers achieve the 1.5 AVR goal.
21) liThe term 'peak hour' is probably unnecessary as the
ordinance typically uses the phrase 'peak period'.1t
Response:
staff agrees and will make the necessary changes.
22) "A peak period trip includes one which 'begins or ends'
within the peak period. This seems inconsistent with the
remainder of the Ordinance which focuses upon when the
employee reports to work and, as the AQMD notes, creates
operational questions.
Response:
Staff agrees and will make the necessary changes.
23) "In determining the number of employees, this Section (9224)
is inconsistent with the definition of 'employee' which
requires reporting for work for at least six months."
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Response:
The definition in Section 9224 relates to the fee
calculation and has a different meaning than the
definition for employee for AVR purposes.
24) "In paragraph (5), it is not clear that the 50%, 60% and 80%
discounts are to be applicable to the annual fee as reduced
by 25%; this should be made more explicit...
Response:
staff agrees and will clarify this issue.
25) "Paragraph (6) exempts from the fee only those employers with
an approved AQMD plan which is less than six months old.
Why are these provisions limited to six months?"
Response: See response to question #8
26)
"In paragraph
25% discount?
it should be.
may be higher
members of an
(7), is the THA fee to be calculated using the
In order to provide an incentive, we believe
Otherwise, the fee paid by an 'employer THA'
than the aggregate of the fees paid by all
'informational THA'.
Response:
For employer TMAs, only one fee will be collected
thru the TMA, and the TMA fee will be eligible for
a 25% fee reduction.
27) "Section 9225(a) contains a new prov1s1on permitting the use
of fees for 'development and operation of TMAs.' What is
contemplated here?"
Response:
As requested by the Chamber, staff has included the
possible use of fees for development and operation
of TMAs. The City will, working with large
employers, provide mapping of potential areas for
TMAs and will work cooperatively with the Chamber
in establishing new TMA areas.
28) "Section 9225(b) (1) contemplates the use of developer impact
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fees for TDM measures. Such a use seems inconsistent with
the nature of the developer fee, particularly when the
operations of the TMP office are to be funded through the
employer fees."
Response:
Some TDM measures require capital or facility type
improvements, like bike facilities, bus turnouts
and preferential parking. These TDM measures are
appropriate for the developer impact fees.
29) nIt is unclear how a reduction in the length of trips would
directly affect AVR and, it the provision was intended to
relate to jObS-housing balance, as the statt suggests, how
can it be implemented by an employer?"
Response:
Employees living closer to a worksite provides more
opportunities for employees to use carpools,
vanpools, transit, bicycles or walking as an
alternative commute mode.
liThe word I employee' in the first line of the first
paragraph on page 20 should probably be 'employer.'
why is the one-halt mile limit imposed in paragraph
page 21?"
30)
Response:
full
Also,
Ce) on
staff agrees that the word 'employee' should be
'employer'. The one-half mile limit was imposed in
order to remain consistent with AQMD.
31) nThe timing of approval (for sUbmission of developer plans)
is odd because it is to come after the project itself is
approved. II
Response:
As part of the development review process, the
application will require developers to submit
proposals regarding the development. However,
final approval is not until all city permits are
secured and the issuance of a building permit
occurs.
32) "Paragraph Cd) on page 24 refers to a 'subsequent owner' of
the building. This requirement appears inconsistent with
staff's statement to the AQMD that building owners are not
subject to the Ordinance. In any event, of what relevance is
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the developer's plan after the building is complete and
occupied?"
Response:
This is to apply to developers in the event they
sell a building before it is occupied.
33) nparagraph (1) on page 25 seems to duplicate a part of
paragraph (10) on page 26. If paragraph (1) is to be
reworded to require calculation of the AVR, as suggested by
AQMD, perhaps paragraph (10) should be deleted. Also, there
is no need to 'determine' peak periods since these are
defined. There is also no need to determine 'vehicle trips
to and from the site' since only the AVR is important."
Response:
Staff agrees there is no need to determine peak
period and will modify the Ordinance accordingly.
However, staff does feel there is a need to know
the vehicle trips generated by each site in order
to verify plan calculations.
34) "Paragraph (4) on Page 25 refers to unspecified 'goals'."
Response:
staff agrees and will make the necessary changes to
the Ordinance.
35) liAs stated earlier, several paragraphs may require a
calculation or explanation which is not part of the
employer's plan. Therefore, some phrase should be included
in the lead-in language which states that the report may be
limited to the applicable items."
Response:
Everything listed as required information on the
plan is information that the city will require of
all employers to determine annual monitoring.
36) "Paragraph (13) on page 26 requires a 75% response rate for
the employee survey. This rate strikes us as quite high; if
it cannot be achieved, is the entire report invalid?"
Response:
This is an AQMD requirement, and surveys that do
not achieve a 75% response rate will not be valid.
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.
A new survey will have to be conducted until a 75%
response rate is achieved.
37) liThe reference to section 9230C in paragraph (5) on page 29
should be to section 9232C."
Response:
staff agrees and will make the necessary changes.
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