ARMBRUSTER GOLDSMITH & DEL V AC LLP

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1 ARMBRUSTER GOLDSMITH & DEL V AC LLP LAND USE ENTITLEMENTS 0 LITIGATION 0 MUNICIPAL ADVOCACY DALE GOLDSMITH DIRECT DIAL: (310) SAN VICENTE BOULEVARD, SUITE 900 LOS ANGELES, CA Tel: (310) Fax: (310) Dale@AGD-LandUse.com WEB: VIA and U.S. MAIL The Planning and Land Use Management May 10,2011 Committee of the Los Angeles City Council 200 North Spring Street, Room 350 Los Angeles, California Attention: Michael Espinosa, Legislative Assistant Re: Appeal of CPC ZC-HD-ZAA-SPR, VTTM No CN and ENV EIR (State Clearinghouse No ) (Item No.6 on the Committee's May 10,2011 Agenda) Dear Chairman Reyes and Hon. Committee Members: We represent 6104 Hollywood LLC, the applicant in the above cases. Our client is seeking to develop the property located at the southwest comer of Hollywood Boulevard and Gower Street with is an iconic mixed-use development with 176 residential units and approximately 7,200 square feet of neighborhood-serving ground-floor commercial/retail space (the "Project"). This letter and the attached memorandum respond to the arguments and assertions made by Appellant Doug Haines, La Mirada Neighborhood Association of Hollywood ("Appellant") challenging the City Planning Commission's ("CPC") approval of the abovereferenced cases and its certification of the Hollywood & Gower Project Environmental Report (the "EIR"). As discussed more fully in the attached memorandum and the attachments thereto, Appellant's arguments are without merit or supporting evidence and are entirely based on opinion, speculation, and misstatements of fact and law. Contrary to Appellants unfounded assertions: Impact The Project is compatible and consistent with surrounding uses, including the Columbia Square Project (28 stories), Hollywood & Vine (180 feet), Sunset Vine Tower (22 stories), Sunset & Gordon (23 Stories), Sunset Media Tower (22 Stories) and Yucca & Argyle (16 stories).

2 The Planning and Land Use Management of the Los Angeles City Council May 10,2011 Page 2 Committee The Project will not adversely impact The Music Box, the owners of which strongly support the The City has granted similar adjustments for reduced yards to many other projects in the vicinity, including Boulevard 6200, Hollywood & Vine, Broadway Building, Jefferson at Highland, and Sunset & Gordon projects. e The Project and the yard adjustment conform to the General Plan, including Objectives 1 to 6. The Project parking exceeds City's Zoning Code requirements and, as shown by the parking demand study, is adequate to meet demand. The removal of the existing surface parking spaces will not create a parking shortage since that site has never been used as a public parking lot. The CPC properly rejected the Reduced Density Alternative as infeasible because it fails to meet the basic project objective of maximizing housing. The comprehensive EIR fully complies with the requirements of CEQA. In short, Appellant simply does not want a tall building on the Project site. However, Appellant has failed to show any way the City has erred or abused its discretion in granting the Project approvals. Appellant has also failed to show any inadequacy in either the EIR or the City's environmental findings. Consequently, the City should uphold the CPC's determination, deny the appeal, certify the EIR, and approve the Project. cc: Jim Tokunaga, City Planning Department Katherine Hennigan, CD 13 City Attorney Rick Stinson RJ. Comer Ira Handelman Craig Lawson Jessica Pakdaman Enclosures

3 ARMBRUSTER GOLDSMITH &DELVACLLP DATE: May 10,2011 TO: The Honorable Planning & Land Use Management Committee of the City Council FROM: CC SUBJECT: Dale Goldsmith RJ. Comer Jim Tokunaga, City Planning Department AppealofCPC-200S-30S7-ZC-HD-ZAA-SPR, VTTM No CN and ENV EIR (State Clearinghouse No. 200S011113) INTRODUCTION This memorandum responds to the arguments and assertions made by Appellant Doug Haines, La Mirada Neighborhood Association of Hollywood ("Appellant") challenging the City Planning Commission's approval ofthe above-referenced cases and its certification of the Hanover Hollywood & Gower Project Environmental Impact Report (the "EIR"). This memorandum also responds to Bradley Torgan's April 12,2011 letter incorrectly asserting that the hearing Notice is deficient. The Hanover Hollywood & Gower Project (the "Project") is an iconic mixed-use development with 176 residential units and approximately 7,200 square feet of neighborhood-serving ground-floor commercial/retail space. As discussed more fully below, Appellant's arguments are without merit or supporting evidence. Appellant offers opinion, speculation, and arguments that advocate for policies different than the City'S established policies. Appellant attempts to substitute his own interpretations of the City's codes and plans. Most importantly, Appellant fails to provide any substantial evidence that the City Planning Commission erred or abused its discretion in approving the Project and certifying the EIR I 16 [ [ San Vicente Blvd. I Suite 900 I Los Angeles I CA I fel: I Fax: I

4 ARMBRUSTER GOLDSMITH & DEL VAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10, 2011 Page 2 THE HEARING NOTICE IS PROPER Mr. Torgan is incorrect in his April 12, 2011 letter regarding his alleged "Deficiency in Notice for City Council File No " He erroneously asserts that the 500' radius notification and 24-day notice period set forth in LAMC Section C.4(b) applies to the appeal hearings scheduled for the Hollywood & Gower Project It does not. Section C.4(b) establishes hearing notice requirements for actions on the initiation or application for proposed land use ordinances and refers to the public hearing held by the Hearing Officer in order to make a recommendation for action to the Planning Commission (LAMC Section C.3). LAMC Section C.4(b) requires that a written notice be mailed to the owners and occupants within 500 feet of the subject property at least 24 days prior to the date of the hearing by the Hearing Oflicer~not the Planning & Land Use Management Committee of the City Council. The City Planning Department fully complied with LAMC Section C.4(b). The Project hearing governed by LAMC Section C.4(b) was the August 25, 2010 Hearing Officer Hearing. The notice for that hearing was mailed 24 days prior to the date ofthat hearing in full compliance with LAMC Section CA(b). No language in LAMC Section (or any other LAMC section) requires a hearing notice for the City Council action on the land use ordinance. Only in the case of an appeal to City Council of the Planning Commission's initial decision is a l C-day hearing notice required, and then only if the appeal is initiated by the applicant appeal after the Planning Commission's recommended disapproval of the land use application. In the case of this Project, the City Planning Commission recommended approval of the subject Zone and Height District Change. Therefore, the appeal procedures under LAMC Section C. are not applicable. The Appellant filed appeals to the Vesting Tentative Tract Map, Zoning Administrator's Adjustment, and Site Plan Review approvals by the City Planning Commission (the only actions in this case that are appealable by the Appellant). LAMC Section AA (Appeals to Council for Tentative Maps) requires that notice ofthe City Council hearing be given to the subdivider, the appellant, the Appeal Board and the Advisory Agency, but does not specify any notification period for the hearing notice. On the other hand, LAMC Sections 16.0S.H.3. and 16.0S.G.3.b (Appeal Hearing Notice Procedures for Site Plan Reviews) require a IS-day hearing notice to the appellant, and to all other parties specified in Subsection G3.b, which include the applicant, owners and tenants of property within 100 feet of the boundary of the subject site, and other interested parties that request to be notified. Thus, the hearing notification procedures specified under LAMC Section require direct notice to Appellant and other interested parties and govern this hearing.

5 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 3 On or about April 22, 2011, the City Clerk sent the required notice of the May 10,2011 PLUM Committee Hearing. Thus, the City has complied with the applicable notice requirements. In any event, the Appellant has actual noticed and would not have been prejudiced even if the City had not provided such notice. RESPONSES TO APPEAL Substantial Evidence Supports the Zoning Administrator's Adjustment Findings. The Zoning Administrator's Adjustment (the "Adjustment") allows a zero-foot westerly side yard including the south and west side yards. Appellant challenges the Adjustment findings based on specious arguments that misstate the facts, applicable law or both. The Project is compatible and consistent with surrounding uses. Appellant attempts to limit any analysis of the Project's compatibility and consistency to only those existing uses adjacent to the Project site - particularly uses west of the Project site. Although this nan-ow analytical scope may serve Appellant's perspective, it is not the appropriate analytical scope for an urban, in-fill Project in a dense, urban environment and is not what the finding requires. The appropriate analytical scope is to consider compatibility and consistency with regard to "surrounding uses" - which includes adjacent uses, but also includes the surrounding area taking into consideration the urban context and functional compatibility of the proposed use with surrounding uses. The Project EIR and the City's findings acknowledge that the proposed Project is much taller than the existing Henry Fonda Theater adjacent to the Project's western boundary. However, the City has concluded, based on substantial evidence, that this difference in height is not a de facto incompatibility as Appellant suggest. While The Music Box Theater may be a 2-story historic building, it is not a zone of quiet requiring that the theater be set back from other uses. As its own website states, "... The Music Box, conveniently located in the heart of Hollywood, is the venue of choice for concerts, premieres, wrap parties, award shows, RBO specials, fundraisers, and a wide range of special events and celebrations... Averaging 20 concerts, clubs, and special events each month, the venue entertains thousands of concert fans, dance enthusiasts and special event guests every week... The Music Box's multi-level facilities can accommodate events of nearly any size, from intimate rooftop gatherings to elaborate large-scale productions...:' The theater itself is built across the entire site, and given its use, having 1 The Music Box's website,

6 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 4 the proposed Project set back from the theater would do nothing to preserve the theater's character. The immediate and general surrounding area is characterized by an eclectic mix of styles and heights. While the term "compatible" is not defined in the LAMC, Merriam- Webster's Dictionary defines "compatible" as "capable of existing together in harmony." The Project, although it will be taller in height than the adjacent uses, has been designed to ensure compatibility with the adjacent uses, particularly the adjacent Music Box Theater to the west, in order to minimize potential impact on the closest nearby uses. Only the five-story parking podium is located within the otherwise applicable yard area. The residential tower proposed to be located on top of the parking podium will be oriented towards to northeastern corner of the Project site and has intentionally been designed to be located well beyond the otherwise applicable yard areas and away from the adjacent commercial properties to the west and to the south. In addition, a 10-foot landscaped rear yard will be provided at the southern end of the property for an added buffer. Thus, the proposed development and the placement of the residential tower will be harmonious with adjacent uses. Furthermore, the Project is compatible with several other existing and entitled developments in the general vicinity of the Project site, all of which are on sites that are located within several blocks from the Project site, are similarly zoned C4-2, and are similarly designated Regional Center Commercial: The Columbia Square Project has been entitled just two blocks to the south of the Project site, at 6101 Sunset Boulevard at Gower, for a 28-story mixed use project, including multi-family units, office, hotel, and commercial/retail, on property zoned (T)(Q)C4-2-SN and designated Regional Center Commercial. Maximum permitted FAR is 6:1 (Case Nos. CPC GPA-VZC-HD- CUB-CUX-VCU-SPR-DA and VTT CN); Just two blocks to the west of the Project site is the Hollywood & Vine development ("W" Hotel site), located at 6252 Hollywood Boulevard, which includes 15 stories (180 feet in height) on a site zoned [Q]C4-2-SN and designated Regional Center Commercial. This existing development includes 300 hotel rooms, 150 residential condominiums, 375 apartment units, and 61,500 square feet of commercial retail floor area, with a maximum FAR of 5.26:1 (Ordinance No. 177,528; Case Nos. CPC ZC-ZAA and VTT-63297); Sunset Vine Tower, located at 6290 Sunset Boulevard at Vine Street, is 22 stories on a site zoned (Q)C4-2D-SN and C4-2D-SN and designated Regional Center Commercial. The development includes 63 apartment units, 8,300 square

7 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 5 feet of retail space, and a maximum 2.3:1 FAR (Case No. APCC ZC- SPE-SPP); Sunset & Gordon, located at 5935 Sunset Boulevard at the site of the Old Spaghetti Factory, has been entitled for 23 stories (260 feet in height) on a site zoned (T)(Q)C2-2D-SN and (T)(Q)R4-1 VL and designated Regional Center Commercial. This project will provide 311 condominium units, 13,500 square feet of ground floor retail, an 8,500-square foot restaurant, 40,000 square feet of office floor area, and maximum FAR of 5.15: 1 on the C2 portion and 3: 1 on the R4 portion (Ordinance No. 180,094; Case No. CPC GPA-ZC-HD-CU- PAB-ZV -ZAA-SPR-SPE-SPP); Camden Project/Whole Foods Market, located at 1540 N. Vine Street, was approved with a maximum height of 145 feet on a site zoned C4-2 and designated Regional Center Commercial, and will include a maximum FAR of 4.5: 1, 306 apartment units, and 69,000 square feet of retail/grocery space (Ordinance No , Case Nos. CPC ZC-CUB-SPR and VTT-67101); McCadden Place, located at 1714 McCadden Place at Hollywood Boulevard, was approved to be 120 feet tall on a site zoned (Q)C4-2-SN and designated Regional Center Commercial. This project includes 218 residential units and a maximum FARof4.17:1 (Ordinance No. 178,181; Case Nos. CPC ZC- ZAA-SPR and TT-61838); Sunset Media Tower (also known as House of Blues), located at 6255 Sunset Boulevard at Argyle, is an existing 22-story office tower on a site zoned C4-2D- SN and designated Regional Center Commercial; and Yucca & Argyle, located at 6230 Yucca Street, was entitled for a 16-story mixed-use project on a site zoned (T)(Q)C4-2D-SN and designated Regional Center Commercial, This project was approved with a maximum FAR of 4.5:1, 13,790 square feet of commercial space, 10 live/work units, and 85 residential condominium units (Ordinance No. 180,082; Case No. CPC ZC-HD- ZAA-SPR). In addition, the proposed Project will be compatible with the following projects in the Hollywood Area, which are also mixed-use and larger-scale in nature: Boulevard 6200, located at 6200 Hollywood Boulevard, between Argyle and El Centro on both sides of Hollywood, is just one block west of the Project site and was approved for 1,014 apartment units, 28 joint live/work condominiums, 175,000 square feet of retail, and total FAR of 4.5: 1, on properties zoned

8 ARMBRUSTER GOLDSMITH & DEL V AC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 6 [TJ[Q]C4-2D & [TJ[Q]C4-2D-SN (Ordinance No. 179,026; Case Nos. CPC ZC-ZV-YV-SPR and VTT-67429); and Jefferson at Highland, located at 1724 Highland Avenue, has been approved and developed with a mixed-use project containing 270 residential apartment units and 8,500 square feet of retail on property zoned C4-2D-SN and designated Regional Center Commercial (Case No. ZA ZV-ZAA-SPR-SPP). Reduced side yard setbacks have been granted for similar project in the same zone and vicinity: III The Boulevard 6200 Project is one block to the west along Hollywood Boulevard (between Argyle and El Centro) and is zoned [T][Q]C4-2D and [T][Q]C4-2D-SN. It was granted a Zoning Administrator's Adjustment to permit O-foot side yard setbacks in lieu of the 9-foot side yard setback required. The Hollywood & VinelW Hotel Project, located at 6252 Hollywood Boulevard and zoned C4-2-SN, received approval for an Adjustment to allow variable 5- to 8-foot side yards for the interior lot lines of the project due to it being adjacent to the existing Taft Building located at the southeast corner of Hollywood Boulevard and Vine Street. The Taft Building is the only part of the entire City block that is not a part of the Hollywood & Vine Project, and if the project were to be built across the entire block, it could observe a O-setback on all of its sides pursuant to LAMC Section A.18.c(3). However, because ofthe Taft Building's adjacency, the residential portions of the project are technically required to maintain a 16-foot side yard next to the Taft. The Broadway Building, located at 1645 N. Vine Street (southwestern corner of Hollywood and Vine, 3 blocks to the west ofthe Hollywood & Gower Project) is zoned C4-2D and has been granted approval for an Adjustment to permit a O-foot rear yard and a O-foot westerly side yard for the additional floors/floor area added to the upper portion of the existing building in lieu of the required 20-foot rear yard and II-foot side yard. This will allow the new addition to observe the same zero yards for the existing building along the side and rear. It should also be noted that the Cultural Heritage Commission, responsible for reviewing project conformity with the Secretary of the Interior standards for historic renovation, has indicated that the zero yard setback helps create an architecturally integrated design consistent with the Secretary of Interior standards.

9 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 7 III The Jefferson at Highland Project, located at the southeast corner of Highland and Yucca (1 block north and 10 blocks west of the Hollywood & Gower Project) and zoned C4-2D-SN, received approval for an Adjustment to provide 0- and 2- foot side yards and a 2-foot rear yard in lieu ofthe required 9-foot side yards and 18-foot rear yard in the C4-2D Zone. III Finally, the Sunset & Gordon Project, entitled for the property located at 5935 Sunset Boulevard (1 block south and 1 block east of Hollywood & Gower) and zoned (T)(Q)C2-2D-SN (southern half) and to (T)(Q)R4-1 VL (northern half), received approval for Adjustments to permit a O-foot easterly side, westerly side, and rear yard in lieu of the required 16-foot side yards and 20-foot rear yard. As one can determine from the numerous recently entitled and/or built mixed-use Projects in Hollywood, urban renewal has taken root in Hollywood's historic core, west of Gower. The area east of Gower, however, still has a concentration of older, relatively low-rise commercial buildings. These buildings were not required to provide setbacks and consequently are built out to their lot lines. Thus, the proposed Project is in keeping with the prevailing setbacks, and moreover is consistent with the Draft Land Use and Zone Change Map ofthe Hollywood Community Plan Update, dated September 30, 2009, which shows the recommendation for much of the area east of Gower Street, along Hollywood, as also containing Regional Center Commercial uses. As evidenced above, the Project has been designed to be not only compatible with adjacent uses (in terms of design sensitivity), but also compatible with other mixed-use developments in the Project vicinity. Any analysis of an in-fill project's compatibility with an urban environment should take into accountfimctional compatibility of the proposed Project with its surrounding land uses. Functional compatibility is defined as the capacity for adjacent, yet dissimilar, land uses to maintain and provide services, amenities, and/or environmental quality associated with such uses. Functional incompatibility arises when a proposed Project hinders the functional patterns of use and relationships associated with existing land uses. Patterns of use relate to the interaction and movement of people, goods, and/or information. The proposed Project is functionally compatible in that a housing and retail project provides the much-needed housing in Hollywood, while further activating Hollywood Boulevard with retail. The development of a 20-story, landmark building at the "gateway" into the easternmost section ofthe historic Hollywood Walk of Fame will be in conformance with the intent and purpose of the Community Plan and will also address the significance of the Hollywood Walk of Fame in the context of the urban Hollywood community. Additionally, the Project would improve the physical condition of the area by replacing the existing asphalt surface parking lot on an under-utilized site with an aesthetically

10 ARMBRUSTER GOLDSMITH & DEL VAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 8 appealing mixed-use building. The Project includes several features that will enhance pedestrian access and experience. The Project is located on a planned streetscape corridor consistent with Hollywood Community Plan Policy LU The Project will promote pedestrian-friendly land uses along streets with high pedestrian activity by including streetscape features and by its convenient location nearby to mass transit. In any event, Appellant's argument that the City cannot make the requisite compatibility finding due to the Project's height is a red herring. The site's C4-2D zoning allows for unlimited height by right; the Adjustment is for reduced yard') and in no way affects the Project's height. The Adjustment is in Conformance with the General Plan. Appellant attempts to change the required finding from "The Adjustment is in conformance with the intent and purpose of the General Plan" to "the project is in conformance..." Appellant then abandons all discussion of the side yard setback adjustment and instead argues that the Project itself is not consistent with the General Plan. On its face, therefore, Appellant's argument fails to show how the CPC erred or abused its discretion in upholding the Adjustment. Nevertheless, the Project is conformance with the intent and purpose of the General Plan. The City has included detailed findings supported by substantial evidence of consistency with the General Plan. Appellant attempts to substitute his own, novel interpretation of a few Community Plan policies for the proper interpretation made by the City of its own Community Plan. The Plan designates the subject property as Regional Center Commercial, which corresponds to the C2, C4, P and PB Zones. The Project site is currently zoned C4-2D- SN on the northern portion and C4-2D on the southern portion. Although the existing "D" Development Limitation restricts the maximum floor area ratio (FAR) to 2: I, the Hollywood Community Plan Map (Footnote 9) permits development intensity on the project site to Height District No.2, with a maximum FAR of 4.5: 1. The proposed Zone/Height District Change would amend the "D" Development Limitation to allow a maximum FAR of 4.5: 1, consistent with the Hollywood Community Plan. The Community Plan does not limit the height of projects within Regional Centers. The General Plan Framework provides that, in general, projects within Regional Centers should contain structures between 6- and 20- stories or higher." The Appellant asserts 2 General Plan Framework, Chapter 3 - Land Use Goals, Objectives and Policies

11 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee ofthe City Council May 10,2011 Page 9 that the Project is not located within a Regional Center because, allegedly, Figure 3-1 of the Framework shows that Vine Street is the eastern boundary ofthe Regional Center designation. In fact, Figure 3-1 clearly shows that the eastern boundary extends eastward beyond Vine Street to Gower along Hollywood Boulevard. In any event, the introduction to the General Plan Framework clearly states that the Framework is intended to serve as a guideline for subsequent amendments to the City's community plans, and that the specific land use designations in the community plans control. In this case, the Hollywood Community Plan land use map clearly designates the subject property as Regional Center Commercial. The granting of the Adjustment will not be in direct conflict with the goals and objectives of the Hollywood Community Plan, in that the Plan encourages the development of commercial uses along major transportation corridors and promotes distinctive commercial districts. Consistent with the Community Plan, the ground floor of this Project will serve as a commercial frontage for the Project, while the above-ground residential uses will efficiently utilize space that would not otherwise be used as retail commercial space. The Project helps accommodate the City's housing shortage and satisfies the objective of the Community Plan to create more housing for Hollywood. The Project adequately addresses Hollywood Community Plan Objective 4(a) by allocating retail commercial uses on the ground floor of the Project. Thus, the retail component ofthe Project will continue commercial uses in the area. The Project site is located at the major intersection of Hollywood Boulevard and Gower Street, where other commercial uses already exist. The granting of the Adjustment permits the creation of an integrated mixed-use development compatible and consistent with the surrounding uses. Providing the Code-required westerly side yard setback creates an inconsistent layout and building footprint compared to other commercial building footprints in this area. Like many of the surrounding uses in the area, this Project includes ground floor commercial retail with high-density residential units above. The Hollywood Community Plan Land Use Plan Policies and Programs include Objectives and Policies for both residential and commercial land uses. The proposed Project is consistent with the following residential Objectives and Policies: Objective 1: To coordinate the development oj Hollywood with other parts oj the City oj Los Angeles and the metropolitan area. Tofurther the development oj Hollywood as a major center oj population, employment, retail services, and entertainment. The Project is coordinated with the development of Hollywood and other parts of the City of Los Angeles, while developing Hollywood as a major center of population, employment, and retail services. The Project reflects orderly development ofthe urban area, with housing to accommodate residents and

12 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 10 employees, proximate to transit and retail services.. The Project will provide construction jobs and retail commercial jobs, as wen as additional housing for residents. Objective 2: To make provision for the housing required to satisfy the varying needs and desires of all economic segments ofthe Community, maximizing the opportunity for individual choice. The Project will further this objective by providing much-needed housing to the City of Los Angeles. While the housing included as part of the Project is market rate housing, it is important to recognize the role of market-rate housing in providing adequate housing for everyone and driving down housing prices overall by increasing supply, Whichever housing projection is used, it is clear that a housing shortage exists within the Hollywood area. The Draft Hollywood Community Plan Update provides several different analyses of the housing shortage.. Depending on the data used.', the estimates of the unmet housing demand in excess of the existing housing stock range from 2,822 units, to 12,120 units, and even as high as 14,175 units. While it is undeniable that there must be more affordable housing built, there also is a need for market rate units that draw professionals and entrepreneurs to the area. The Project proposes to provide 176 new residential units to help respond to the need for housing in the Hollywood Community Plan area. According to Edward Glaeser, Fred and Eleanor Glimp Professor of Economics at Harvard University, one ofthe factors that predict urban success is an attractive location with "big city" amenities. His research indicates that our cities are becoming consumer cities as people are increasingly choosing areas on the basis of quality of life. It is these skilled people who come to attractive areas that provide the new ideas that fuel the local economy. This, in tum, generates a need for market-rate luxury residential units so that these people will want to live and stay in a given area of a city (see Attachment A).4 Glaeser's work demonstrates that creating affordable housing comes from increasing supply and, in cities, that means building up. As Professor Glaeser states, "the basic economics of housing prices are pretty simple - supply and demand... Building enough homes eases the impact of rising demand on prices and makes cities more affordable.,,5 In a city, there is typically little land for 3 Draft Hollywood Community Plan Population, Employment, and Housing Section Population Employment Housing.pdf 4 Glaeser, Edward. Triumph of the City, New YOlk The Penguin Press, Pages S Glaeser, Edward. Triumph of the City. New York: The Penguin Press, Pages

13 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 11 development, so in order to produce more housing units, one must build up rather than out. Not only does more housing help lower housing costs, but building vertically is better for the environment since one does not have to build in green areas." As Hollywood is highly urbanized and seeks to continue the revitalization eastward, building market-rate housing will not only help maintain housing costs but will also attract the types of individuals that help make Hollywood a vibrant, interesting place, open to all Objective 3: To encourage the preservation and enhancement of the varied and distinctive residential character of the community, and to protect lower density housingfrom the scattered intrusion of apartments. The Project encourages the preservation and enhancement of the varied and distinctive residential character ofthe community and protects lower density housing from the scattered intrusion of apartments by concentrating higherdensity housing along a regional commercial corridor. In addition, the Project would not displace any existing residents or residential communities, as the Project site is not zoned residential and currently is developed with an asphalt parking lot. Objective 4: To promote economic well being and public convenience through: a) Allocating and distributing commercial lands for retail, service, and office facilities in quantities and patterns based on accepted planning principles and standards. The Project will effectively and adequately allocate and distribute commercial lands for retail uses on the ground floor and residential uses above. While the Hollywood Community Plan did not, in 1988, anticipate mixed-uses, such as the Project, generally known and accepted today, the Project still provides the retail commercial uses anticipated in the Community Plan while also providing much needed housing in a Regional Center located on a commercial corridor. Objective 6: To make provision for a circulation system coordinated with land uses and densities and adequate to accommodate traffic; and to encourage the expansion and improvement of public transportation service. The Project is located within a short walk to the Metro Red Line station, and on a major Metro bus line, and will encourage an environment where residents can move without the use of a private vehicle, thereby coordinating transit with land uses and encouraging the expansion and improvement of public transportation 6 Glaeser, Edward. Triumph of the City. New York: The Penguin Press, Pages

14 ARMBRUSTER GOLDSMITH & DEL VAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10, 2011 Page 12 service. The EIR for the Project also analyzed potential traffic impacts caused by the Project and reduced all impacts to the extent feasible. Appellant quotes the existing conditions description from the Draft EIR as evidence that the Project is not consistent with Objective 6. But Appellant is attempting to ascribe to the Project an existing condition of traffic congestion that is not attributable to the Project. Hollywood Community Plan, p. HO-2 states: "The focal point of the Community is the Hollywood Center, located generally on both sides of Hollywood and Sunset Boulevards between La Brea and Gower Street." The development of a 20-story, landmark building at the "gateway" into the easternmost section of the historic Hollywood Walk of Fame will be in conformance with the intent and purpose of the Community Plan and addresses the significance of the Hollywood Walk of Fame in the context of the urban Hollywood community. Additionally, the Project would improve the physical condition of the area by replacing an under-utilized asphalt parking lot with an aesthetically appealing mixed-use building. In addition, although the draft update to the Hollywood Community Plan is not yet applicable to the Project site, it is important to note that the Project is also consistent with the City's future vision for the City of Los Angeles and not simply consistent with the current Community Plan. The Project is located at the gateway of the "most intensely developed commercial area" of Hollywood. Draft Hollywood Community Plan, p. 13. The Project will meet many of the goals of the Draft Hollywood Community Plan, including: 411 Goal LU.I-Conserve viable neighborhoods, industrial districts, historic/cultural resources, and public right-of-way. The Project will conserve and make more viable the commercial neighborhood along Hollywood Boulevard and Gower Street at the gateway to Hollywood and the Hollywood Walk of Fame. The Project will create an active commercial and pedestrian environment for pedestrians to enjoy the Walk of Fame and will maintain the resource consistent with Police LU.l Goal LU.2-Provide a range of employment and housing opportunities. The Project includes a commercial and residential component that will provide construction jobs, retail commercial jobs, and housing opportunities for people in Hollywood. The Project effectively uses planning tools to encourage jobs to

15 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 13 incentivize commercial and residential growth in the Regional Center, consistent with Policy LU.2.1. The Project is also consistent with the Floor Area Ratio of 4.5: 1 for mixed use in the Proposed Floor Area Ratio Map 24. The Project effectively limits stand-alone residential development by including a retail commercial component consistent with Policy LU.2.1 O. The Project also incentivizes job and housing growth around transit nodes and along transit corridors due to its location proximate to the Metro Red Line and bus lines, consistent with Policy LU The Project will also supply adequate housing consistent with Policy LU Goal LU.3-Make Streets Walkable. The Project includes several features that will enhance pedestrian access and experience. The Project is located on a planned streetscape corridor consistent with Policy LU The Project will promote pedestrian-friendly land uses along streets with high pedestrian activity by including streetscape features, creating an urban and active landscape, and embracing its location along the Hollywood Walk of Fame, consistent with Policy LU , Goal M.1.55-Implement transportation demand strategies to minimize vehicle trips. The Project includes a Transportation this Goal. Demand Management Plan consistent with The Adjustment is in conformance with the Spirit and Intent of the Zoning Code. Again, Appellant attempts to substitute his own interpretation of the Zoning Code for the City'S, by restating his opinion (previously-refuted) that the height of the building does not constitute compatible and orderly development. To support this idea, Appellant alleges that the Project is incompatible with the old draft Hollywood Boulevard District Urban Design Plan and the proposed Urban Design Plan. The original draft Urban Design Plan was never approved by the Planning Commission and has no force or effect. The controversial proposed Urban Design Plan has not yet been adopted and has no force or effect, and in any event contains a provision that exempts the Project. Appellant then offers his opinion that there is nothing unique about the Project site to justify deviation from the applicable R4 setbacks. The C4 Zone requires R4 Zone yard setbacks for the residential parking structure of mixed-use buildings. The R4 Zone yard setbacks are required citywide and do not take into account the unique location ofthe proposed project in a dense urban commercial area or the fact that the ground floor of the

16 ARMBRUSTER GOLDSMITH & DEL V AC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 14 Project is a retail commercial use in a largely commercial area. The purpose of imposing R4 setbacks on residential parking in the C4 zone is to assure a separation of residential uses from commercial uses. 7 No such separation is needed here, because the western and southem boundaries of the Project site are adjacent to commercial uses. No Adverse Impacts Will Result from the Adjustment. Appellant asserts that certain Project environmental impacts identified in the Project ElR as evidence that the Adfustment will result in adverse impacts. This argument fails, because Appellant's approach would prohibit the City from ever granting an adjustment to any project that had significant environmental impacts, regardless of whether those significant environmental impacts related in any way to the adjustment requested. The Project's requested Adjustments to the westerly and southern side yards do not result in any adverse impacts, and Appellant has offered no substantial evidence to the contrary. The Appellant's assertion that the vehicles in the Project's parking podium will result in a significant noise impact on the Music Box (which, as a music venue that holds loud concerts, is not a sensitive receptor in any event) is refuted by the expert analysis in the ElK Moreover, the owners of the Music Box do not believe that the Project will adversely impact their business and have testified at a number of public meetings that they strongly support development ofthe Project. The Appellant also asserts that the fact that the Project does not include subterranean parking somehow prevents that City from making the required findings for the Adjustment. This is another red herring - whether or not the project includes subterranean parking has nothing to do with whether the yard Adjustment is appropriate. Substantial Evidence Supports the Site Plan Review Findings. As the Site Plan Review findings are in many respects similar to the Adjustment findings, Appellant restates many of his failed arguments in an attempt to show that the Cl'C erred or abused its discretion in adopting the Site Plan Review findings. With regard to consistency with the General Plan and consistency with Zoning Code, the same refutations set forth above apply. 7 No yards would be required at all if the subject site were to be developed exclusively with commercial uses. LAMe Section C.

17 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10, 2011 Page 15 The Project is Consistent with the Redevelopment Plan. Appellant makes a personal policy argument that a market rate residential project cannot be consistent with the Hollywood Redevelopment Plan. If that was correct, the City could never have approved the numerous recently developed market rate housing projects in Hollywood. Certainly it is not an error or an abuse of discretion for the City to conclude that a market-rate residential project in an area desperately in need of housing is inconsistent with Redevelopment Plan. Certainly, it is not an error or an abuse of discretion for the City to conclude that the Project, that redevelops an asphalt surface parking with a new mixed-use retail and residential building, is inconsistent with the taxincrement needs of a local redevelopment agency. Appellant asserts his opinion that market-rate housing does not serve the needs of all economic segments of society. Appellant offers only his opinion on this without any evidence that he has any expertise to render this opinion and without any reference to any expert evidence that might support his opinion. In contrast to Appellant's unsubstantiated opinion, Edward Glaeser, the Fred and Eleanor Glimp Professor of Economics at Harvard University, has concluded that high-rise, market-rate housing does benefit all economic segments of society. As Professor Glaeser states, "the basic economics of housing prices are pretty simple ~ supply and demand... Building enough homes eases the impact of rising demand on prices and makes cities more affordable.,,8 In a city, there is typically little land for development, so in order to produce more housing units, one must build up rather than out. Not only does more housing help lower housing costs, but building vertically is better for the environment since one does not have to build in green areas." The Project is Compatible with Existing and Future Development on Neighboring Properties. Appellant then offers his opinion that the Project does not consist of an arrangement of buildings that will be compatible with existing and future development on neighboring properties. Again, Appellant merely points out the obvious height difference between the proposed Project and some significantly shorter buildings adjacent to the Project site - as if this fact alone proves incompatibility. It does not. Appellant merely disagrees with the City's findings, but offers no evidence that the City has erred or abused its discretion adopting the Site Plan Review findings. Ample and substantial evidence (summarized above and set forth in the City'S findings) demonstrates that the Project is compatible with its surroundings, despite the singular fact that the Project will be considerably taller than some of its adjacent uses. 8 Glaeser, Edward. Triumph a/the City. New York: The Penguin Press, Pages Glaeser, Edward. Triumph a/the City. New York: The Penguin Press, Pages

18 ARMBRUSTER GOLDSMITH & DEL VAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 16 The Project Fully Complies with the Requirements of CEQA. One of the Site Plan Review findings requires compliance with specific provisions of CEQA. Responses to Appellant's CEQA challenges are discussed below. The Project Provides Adequate Recreational Facilities. Appellant has failed to show that the City erred or abused its discretion in finding that the Project provides its residents adequate recreational facilities. As evidence, Appellant merely states that there are no parks within walking distance of the subject site. No law or City policy requires that recreational facilities be located within walking distance of dwelling units. Such proximate recreational facilities are simply a preference of Appellant. Contrary to Appellant's unfounded assertions, the Project will include ample indoor and outdoor onsite recreational facilities for the benefit of its residents, including a fitness center, club room with bar and kitchen, screening room, pool and spa, and BBQ area. The Environmental Impact Report is Adequate, and Appellant's Challenges to the EIR are Without Merit. In his appeal, Appellant restates previous arguments regarding the adequacy of the environmental analysis in the EIR. All of these arguments were fully addressed in the Final EIR Responses to Comments and elsewhere in the administrative record. Mr. Haines simply disagrees with the conclusions in the EIR and refuses to accept the evidence supporting those conclusions. He offers no evidence that the EIR analysis is inadequate or that it failed to comply with CEQA in any way. His allegations are mere speculation, opinion, and argument. In his appeal letter, Appellant lists nine environmental issues, but only attempts to discuss five of them: parking; aesthetics; land use; cumulative impacts; and alternatives. This memorandum addresses the five alleged environmental issues discussed in the appeal. The Project Parking Supply Complies with the City's Zoning Code and is Adequate to Meet Demand. Appellant claims (without any evidence) that the Project's reduction in parking from the advisory parking policy for condominium developments will result in insufficient parking and significant impacts. Appellant's argument is mere speculation unsupported by any evidence, and reveals a fundamental misunderstanding of applicable parking regulations.

19 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee ofthe City Council May 10,2011 Page] 7 The Project meets or exceeds every applicable Zoning Code requirement for parking. For the residential use, the Project is providing 1.5 on-site parking spaces per dwelling unit plus 0.25 on-site guest spaces lo per dwelling unit. This requirement is consistent with other high-rise residential buildings in dense areas, and meets and exceeds the applicable multi-family housing and commercial/retail requirements of the Los Angeles Municipal Code. An un-codified Advisory Agency policy typically seeks 2.0 parking spaces per unit for condominium uses and up to 12space guest parking in certain areas of the City with parking congestion, but this policy does not apply to every condominium project developed in the City. Substantial evidence shows that the parking provided in the Project is sufficient to meet demand. Hirsch/Green Transportation Consulting, Inc. prepared a March 28, 2011 report compiling parking utilization data (Attachment B). Based on the empirical data for actual parking utilizations at a total of 18 residential developments in the Southern California region, and supplemented by the nationally recognized parking recommendations provided by both the Urban Land Institute and the Institute of Transportation Engineers, the peak parking demands for residential units within a typical urban environment can be expected to be approximately 1.59 spaces per dwelling unit, including both resident-only and residential guest parking. However, ULI recommends the greatest number of residential parking spaces - approximately 1.65 spaces per unit, including approximately 1.50 resident-only spaces and 0.15 guest parking spaces per unit. The proposed Hollywood & Gower Project will provide a total residential parking supply of 1.75 spaces per dwelling unit, including 1.50 resident-only and 0.25 guest parking spaces per unit. Thus, the Project parking supply will match the ULI's resident-only parking space recommendations, and the Project parking supply (at 0.25 guest spaces per unit) will exceed (by approximately 67%) the ULI recommendation for residential guest spaces. The Advisory Agency and City Planning Commission allowed the Project to deviate from the Advisory Agency's Residential Parking Policy No. AA , issued May 24, 2000, which is a Policy, rather than a Code requirement, for new residential condominiums to provide 2 parking spaces per dwelling unit plus 0.5 guest spaces per dwelling unit in parking congested areas. The Residential Parking Policy is a one-size-fits-all policy used on a citywide basis and designed for suburban areas and not for urban infill projects near transit. This Residential Parking Policy does not take into account the specific location of a project. The Advisory Agency (and City Planning Commission and City Council on appeal) has the discretion to allow deviations from the Policy, when appropriate, and has granted such deviations in several other cases within Hollywood and elsewhere in the City of Los Angeles. IQ The Zoning Code does not require guest parking for residential uses.

20 ARMBRUSTER GOLDSMITH & DEL VAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10, 2011 Page 18 In this case, the Project site is located just two blocks from the Metro Red Line Hollywood/Vine Station and is proximate to other bus lines, thereby justifying relief for the Project from the most strict application of the Residential Parking Policy. Accordingly, it would be inappropriate to apply strictly the Residential Parking Policy and thus require unnecessary parking spaces in the Project, because this would diminish the incentives of residents to use public transit and undermine the City'S long-term transit goals. The Los Angeles City Planning Commission's Do Real Planning Principles also must inform the City's decision regarding parking needs in the Project. The applicable Principles are: 3. "Require density around transit... "[the] need [for] more jobs and housing, for our current residents and for those whose arrival is imminent. At the same time, we must foster our fledgling rail system and its bus partner, to untangle our worsening traffic. The planning solution is elementary: congregate additional density at train and rapid bus stops, and discourage new density where we anticipate no mass transit relief valve." 12. "Identify smart parking requirements. Our long-standing love affair with the automobile has led us to mandate acres of parking spaces and parking lots that often occupy prime street frontage. We must revisit our 'one size fits all' suburban parking standards, and replace them with project and location-specific tools such as parking maximums, pooled parking, automated stacked parking, and other emerging techniques." The Applicant has real experience with parking utilization in projects similar to the proposed Project. In the other projects developed by Applicant with higher per-unit parking ratios than that proposed for this Project, parking spaces have been significantly underutilized. Attached to this memorandum as Attachment C is a spreadsheet showing that this Project proposes a higher parking ratio than the actual, measured parking utilization rates for the Applicant's other projects (which utilization rates for fully occupied projects range from 1.40 to 1.65 spaces-per-unit), This Project's higher parking ratio will apply, even though this Project has much smaller average unit sizes than the other projects and even though this Project includes 13.6% studio units (while no studio units were provided at any ofthe other projects). Additionally, this Project has more convenient access to mass transit than any ofthe Applicant's other projects (especially Westwood and Viridian), which should further lessen parking demand at the Project. Requiring excess parking to be constructed is extremely wasteful of both financial and material resources. Tenants of the Project would have to pay higher rents to offset the wasted costs for construction and maintenance of unused parking. All of the concrete, water, steel, piping, lumber, paint, fuel, etc. used in the construction of the excess spaces

21 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 19 would be a waste of natural resources, not to mention the energy required to ventilate and light the excess space during the lifetime of the building. 11 Finally, and contrary to Appellant's claims that there is no evidence showing that project parking reductions have been included in other projects, the parking provided for the Project is consistent with nearby approvals in Hollywood. The Project is providing 1.75 spaces per unit, while the following projects have received approvals of similar parking ratios (and sometimes lesser parking ratios), as follows: III Sunset & Gordon, May 13,2008: 1 space per bedroom ill The Jefferson at Hollywood, June 14, 2007: 1.6 spaces per unit Camden, April 9, 2007: 1.8 spaces per unit ill Boulevard 6200, April 9, 2007: 1.6 spaces per unit III 1714 McCadden, September 26,2006: 1.9 spaces per unit ill Hollywood & Vine, March 8, 2006: spaces per unit ill Cole and Wilcox, February 22, 2006: spaces per unit \!II Broadway Building, July 15, 2005: 1.05 spaces per unit ill Sunset Vine Tower, May 1,2008: 1.5 spaces per unit II Sunset + Vine, November 1,2000: 2 spaces per unit. II For this reason, the LEED certification checklist provides points for reduced parking in urbanized areas.

22 "1 ARMBRUSTER GOLDSMITH &DELVAC LLP The Honorable Planning & Land Use Management Committee ofthe City Council May 10,2011 Page 20 Elimination Impacts. of the Existing Surface Parking Lot will not Result in Significant Appellant claims, without any supporting evidence, that the elimination of the existing surface parking will result in significant impacts. It will not. As a preliminary matter, the subject site has never been used as a public parking lot. Rather, it has been historically used for an automobile repair facility (that the applicant demolished after acquiring the site in 2007) and for storage of oversized movie vehicles and film equipment. As an accommodation the Music Box (whose owners strongly support the Project), the applicant entered into a short term lease to allow Music Box patrons to park on site on a temporary basis during the City approval process. The Music Box has already located alternate parking for its patrons for use when the lease for the site terminates. According to Navigate Hollywood, several surface parking lots exist nearby the Project site that provide additional parking, including 6201 Hollywood Blvd., 6121 Sunset Boulevard, 6215 Sunset Blvd., 1634 Argyle, and 1751 Argyle. Furthermore, as Hollywood is now served conveniently by the Red Line Metro, parking demand in Hollywood is slowly reducing as more visitors arrive in Hollywood by transit. Furthermore, courts have found that even if eliminating parking requires drivers to seek alternate parking, CEQA does not require an ErR to identify measures to mitigate an anticipated shortfall in available parking. "Contrary to appellants' apparent assumption, there is no statutory or case authority requiring an ErR to identify specific measures to provide additional parking spaces in order to meet an anticipated shortfall in parking availability. The social inconvenience of having to hunt for scarce parking spaces is not an environmental impact; the secondary effect of scarce parking on traffic and air quality is. Under CEQA, a project's social impacts need not be treated as significant impacts on the environment. An EIR need only address the secondary physical impacts that could be triggered by a social impact. (Citation omitted.)... Parking deficits are an inconvenience to drivers, but not a significant physical impact on the environment." San Franciscans Upholding the Downtown Plan v. City & County of San Francisco (2002) 102 Cal. App. 4th 656. (Emphasis added.) The Related Projects List Need Not Include the Hollywood Cap Park. Appellant restates a previous argument that the Draft EIR should have included the Hollywood Freeway Central Park Project ("Cap Park") in the related projects list for purposes of calculating cumulative impacts because, he asserts, the Cap Park is

23 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 21 undergoing environmental review. The Draft and Final EIR correctly omitted the Cap Park from the list of related projects for purposes of cumulative impact analysis. Response to Comment 2-16 in the Final EIR thoroughly addressed this issue. The Cap Park is proposed for development above the 101 Freeway at Fountain Avenue and St. Andrews Place. This conceptual future park is located approximately 0.8 miles from the Project site. Environmental review for the Cap Park was supposed to commence in 2010, but it has not. The CRA has commissioned a feasibility study for the Cap Park and conducted some preliminary public outreach, and various stakeholders have made sporadic efforts to raise money for the Cap Park, but no CEQA review of the Cap Park has commenced, No applications to the California Department of Transportation or other agencies have been filed requesting permits and approvals for the Cap Parle Further, the Cap Park is estimated to cost a staggering $950 million, yet not a single dollar of City, State or Federal funding has been secured. Given the severe fiscal constraints at all levels of government, securing such financing is highly speculative.. Moreover, the CRA, which is the lead project proponent and would provide funding and eminent domain powers, 12 is likely to be legislated out of existence by pending State legislation. Consequently, under the CEQA precedents cited by Appellant, the Cap Park is not a reasonably foreseeable Project. Accordingly, the Cap Park should not be one of the projects in the related projects list for purposes of calculating cumulative impacts. Furthermore, neither the July 15, 2009 CRA staff report nor the November 2008 Cap Park Feasibility Study existed at the time the Notice of Preparation was published for the proposed Project. The NOP for the Project Draft EIR was circulated for a 3D-day review period starting on January 28, 2008 and ending on February 27, The NOP was delivered to the CRA, and the CRA did not comment that the Cap Park should be included as a reasonably foreseeable project for inclusion in the related projects list. At the time the NOP was circulated for the proposed Project, only a Memorandum of Understanding to explore the feasibility of the Cap Park existed. CEQA Guideline 15125(a) establishes the environmental baseline as: "[T]he physical environmental conditions in the vicinity of the Project, as they exist at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a lead agency determines whether an impact is significant." [Emphasis added.] 12 accessed April 9,2011

24 ARMBRUSTER GOLDSMITH &DELVAC LLP The Honorable Planning & Land Use Management Committee ofthe City Council May 10,2011 Page 22 However, Final EIR Response to Comment 3-2 mischaracterized Cap Park when it stated: the likelihood of the Furthermore, the City's Redevelopment Agency ("CRA") has moved forward with plans to build a Cap Park above the 101 Freeway at the corner of St. Andrews Place and Fountain Avenue. A Memorandum of Understanding was approved by the CRA in January 2007, a feasibility study was made public in November of2008, and a July 15,2009 CRA Staff Report states that the Cap Park would include a baseball field, playgrounds, plaza spaces, open fields, and picnic areas, if it were built. Although this park is currently in the speculative planning stages, significant steps have been taken toward its implementation. The statement in the Response to Comment 3-2 that "significant steps have been taken" is not correct. Significant steps have not been made in implementing the Cap Park. Rather, environmental review for the Cap Park has not commenced (even though the CRA anticipated doing so in 2010). Mere early planning for the Cap Park and some attempts to raise private funds for the Cap Park do not constitute significant steps toward development ofthe Cap Park and certainly do not make the Cap Park a reasonably foreseeable future project in the vicinity of the Project. This reference to the Cap Park in response to Comment 3-2, though incorrect, does not change the conclusion of the response or any environmental conclusion in the ErR. The reference to the Cap Park was merely an aside, and the Cap Park was not included in the park-to-population ratio discussed in the response. Finally, it is mere speculation to conclude that the Cap Park will be developed when it is not funded and no environmental review has commenced. It is also speculative to assume that both the proposed Project and the Cap Park could be under construction at the same time, especially when one considers that the proposed Project is much further along in the approval process than is the Cap Park. As recently as April 23, 2010, noting progress on the Downtown LA 101 Freeway Cap Park, Adrian Glick Kudler in Curbed LA commented "We haven't heard much from that other 101 freeway cap park lately (meaning the Hollywood one)." That is because nothing is happening with the Cap Park. Consequently, the Cap Park is correctly excluded from the related Projects list for purposes of cumulative impacts analysis.

25 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 23 Substantial Evidence Supports the City's Conclusion that the Reduced Density Alternative (Alternative 2) is Infeasible and Fails to meet the Basic Objectives of the Project. Appellant claims that the City must either choose to approve the Reduced Density Alternative, Alternative 2, or deny the Project. Appellant mistakenly asserts that because Alternative 2 is environmentally superior to the proposed Project that only Alternative 2 may be approved. Appellant also incorrectly claims that no substantial evidence supports the City'S conclusion that Alternative 2 is infeasible and that it fails to meet the basic objectives of the project. Most importantly, what Appellant fails to grasp or appreciate is that Alternative 2 does not substantially reduce or avoid the significant impacts of the proposed Project. Although operational traffic impacts would be reduced, they would not be eliminated. Construction-related impacts would not be substantially reduced, because the demolition, excavation, grading, and foundation work for Alternative 2 is identical to that same work for the Project. Although construction and interior finishing of the superstructure of Alternative 2 would take less time that the proposed Project, these construction activities do not generate the most noise and air quality impacts. Rather, the construction activities that would be identical between Alternative 2 and the proposed Project would generate the most noise and air quality impacts. Moreover, as construction noise and air quality impacts are generally measured on a daily or hourly basis, the peak impacts in all phases will be the same even if the overall construction time frame is incrementally shorter, The Reduced Density Alternative was appropriately rejected by the City, because it would not meet the basic project objectives. In particular, it would not meet the housing, retail, and viability objectives of the project. Specifically, the Reduced Density Alternative would fail to maximize the amount of housing provided on the Project site to address housing needs in the community and would thus not meet this important Project Objective. The EIR stated that the Reduced Density Alternative would meet the following Project Objectives to a lesser extent than the Project:., Maximize the amount of housing provided on the project site to address housing needs in the community.., Reuse and redevelop the currently underutilized project site to provide housing and retail space to serve the local community.

26 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 24 This statement is incorrect. A careful study of the housing and economic needs of Hollywood shows that Alternative 2 does not "maximize the amount of housing" on the Project site and does not address the housing needs of the community. Whatever housing projection is used, it is clear that a housing shortage exists within the Hollywood area. The Draft Hollywood Community Plan Update provides several different analyses ofthe housing shortage. Depending on the data used, the estimates of the unmet housing demand in excess of the existing housing stock range from 2,822 units, to 12,120 units, and even as high as 14,175 units. The Reduced Density Alternative fails to maximize housing on the project site to meet this demand and fulfill this key project objective. As stated above in this memorandum, while undeniably there needs to be more affordable housing built, there also is a need for market rate units that draw middle-class income earners, professionals and entrepreneurs to the area. The Project proposes to provide 176 new residential units to help respond to the need for housing in the Hollywood Community Plan area. According to Edward Glaeser, one of the factors that predict urban success is an attractive location with "big city" amenities. His research indicates that our cities are becoming consumer cities as people are increasingly choosing areas on the basis of quality of life. It is these skilled people who come to attractive areas that provide the new ideas that fuel the local economy. This, in tum, generates a need for market-rate luxury residential units so that these people will want to live and stay in a given area of a city. Glaeser's work demonstrates that creating affordable housing comes from increasing supply and, in cities, that means building up. As Professor Glaeser states, "the basic economics of housing prices are pretty simple - supply and demand... Building enough homes eases the impact of rising demand on prices and makes cities more affordable." In a city, there is typically little land for development, so in order to produce more housing units, one must build up rather than out. Not only does more housing help lower housing costs, but building vertically is better for the environment since one does not have to build in green areas. The TDM Plan Requirement does not Constitute Deferral of Mitigation. Appellant alleges that the mitigation measure that requires the applicant to develop a traffic demand management ("TDM") plan constitutes a deferral of mitigation in violation of CEQA In fact, implementation of a TDM Plan is already a legal requirement under City Ordinance 168,700. Moreover, the traffic analysis did not take credit for any trip reductions that may be result from the TDM Plan. Therefore, the EIR did not impermissibly rely on deferred mitigation reaching its conclusions regarding the Project's traffic impacts.

27 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 25 The EIR Did Not Need to Analyze the Helipad. Appellant asserts that the EIR is deficient in that it did not analyze impacts ofthe rooftop helipad. However, this helipad is included in the Project to meet Fire Code requirements. It would only be used in emergency situations. Therefore, no analysis is necessary. Appellant Fails to Provide Any Evidence of Undisclosed Significant Impacts or Adverse Public Health Impacts. Appellant states that the Project is likely to cause substantial environmental damage or cause serious public health problems. Yet, he never identifies the public health risk. First, Appellant asserts that the Project will result in significant permanent adverse environmental effects due to construction noise and vibration and traffic. The EIR properly disclose these significant impacts, and the City Planning Commission adopted a statement of overriding considerations in compliance with CEQA. However, the construction impacts are only temporary, and none of these impacts would cause substantial environmental damage or cause serious public health problems. Appellant's primary argument is that a dense urban in-fill project will create public health impacts. He offers no evidence to support this argument, and, in fact, there is substantial evidence to the contrary. Evidence shows that America's Century dense urban environments such as New York, Los Angeles, Boston, Minneapolis, and San Francisco enj oy lower death rates than the national average. "The average life expectancy in counties with more than five hundred people per square mile is nine months longer than in counties with fewer than a hundred people per square mile.,,]3 Appellant also states his opinion that the Project would result in serious public health problems with respect to shade/shadows and parks and recreation. In fact, the EIR shows that the Project's impacts with respect to shade/shadows and parks and recreation will be less than significant. Appellant offers no substantial evidence to the contrary. In any event, neither a significant shade and shadow impact nor a significant parks and recreation impact would "affect public health." Appellant further argues that the Project will result in a significant aesthetic impact because of its 20-story height and contemporary architectural style. As set f011habove, there are a number of existing and approved high-rise buildings in close proximity to the Project site. The surrounding development is characterized by a mix of architectural styles, including contemporary designs such as the Hollywood and Vine Project. Appellant states his own subjective opinion that contemporary buildings are incompatible with older buildings. This does not constitute substantial evidence that would undermine 13 Glaeser, Edward. Triumph of the City. New York: The Penguin Press, Page 114.

28 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10, 2011 Page 26 the conclusions ofthe EIR. Neither the City's CEQA Thresholds Guide nor relevant case law provides that differing architectural styles between adjacent buildings create a significant environmental impact under CEQA. In fact, differing styles can improve the aesthetics of an area by providing visual variety. Appellant also asserts that the Project will result in a significant cumulative aesthetic impact due to the "canyonization" of Hollywood and Sunset Boulevards. Presumably, Appellant is arguing that contiguous high-rise developments will create a wall of tall buildings on both sides of the streets that will resemble canyons. While there are a number of high-rise developments in the general area, none are contiguous to the subject property. The Project is abutted on the north by Hollywood Boulevard, on the east by Gower, on the south by a low-rise building and surface parking lot, on the west by The Music Box. There are no existing or proposed high-rises in the immediate vicinity that together with the project could create a canyon. Moreover, as the Project is not located on Sunset Boulevard, it could not contribute to a canyon effect on that street. In any event, neither the City'S CEQA Thresholds Guide nor relevant case law recognizes "canyonization" as a significant environmental impact under CEQA Appellant also alleges, without any support, that the Project would result in a significant impact to an historic resource, The Music Box Theater. As set forth in Final EIR Response to Comment No.2-II, the Project would not cause any physical change to The Music Box or involve demolition, destruction, relocation or alteration of the theater. Nor would the Project create a significant impact by altering the historic setting of The Music Box. This setting is already compromised as the original structures were demolished long ago and were replaced with the current surface parking lot. Moreover, preservationists generally decry the mimicking of existing historic buildings by utilizing a faux historical style on new development. Finally, Appellant argues that the Project would result in significant blockage of views of the Hollywood Hills. As set forth in Final ErR Response to Comment No. 2-10, the views of the Hollywood Hills are afforded from many locations around the City. The Project and the related projects would not materially obstruct public views'" of the mountains. In fact, the Project's tall and nan-ow design has less potential to block views than a shorter, squat design advocated by Appellant. As the Project will not result in a significant impact on view blockage, it would not make a considerable contribution to potential cumulative view impacts. 14 Under the L.A. CEQA Thresholds Guide, impacts to private views are not considered to be significant.

29 ARMBRUSTER GOLDSMITH & DELVAC LLP The Honorable Planning & Land Use Management Committee of the City Council May 10,2011 Page 27 The Findings Made by the Advisory Agency, and the City Planning Commission on Appeal, in Approving the Vesting Tentative Tract Map are all Supported by Substantial Evidence in the Record. Appellant asserts that approval of the Vesting Tentative Tract Map is legally and substantively defective. We have previously refuted all of Appellant's assertions in our letter to the City Planning Commission dated November 15, CONCLUSION Appellant's arguments lack any evidentiary basis and instead are merely disagreements. Appellant has asserted strong opinions that a compatibility analysis should be limited to adjacent buildings only, but the City properly analysis compatibility with reference to the surrounding area. Appellant has expressed a strong personal opinion that public policy should discourage market-rate housing and high-rise construction, but the City acknowledges that market-rate housing in an area desperately in need of housing meets housing needs. Furthermore, expert analysis supports the City'S approach that marketrate housing contributes to economic growth of all sectors and affordable housing. Appellant has asked the City to abandon the City's own interpretation of its own plans and regulations and instead adopt Appellant's novel interpretation of the Hollywood Community Plan, the Hollywood Redevelopment Plan, General Plan Framework and City Zoning Code. But the City is afforded great discretion in interpreting its own plans and regulations, and the City has not abused that discretion or erred in any way. Appellant merely disagrees with the City. Appellant seeks to convince that City that a reduced density alternative is feasible when a primary objective of the project is to maximize housing units on the site - not minimize them. In short, Appellant simply does not want a tall building on the Project site. However, Appellant has failed to show any way the City has erred or abused its discretion in granting the Project approvals. Appellant has also failed to show any inadequacy in either the ErR or the City's environmental findings. Consequently, the City should deny the appeal, certify the EIR, and approve the Project.

30

31 How Our Greatest Invention Makes Us Richer, Smarter, Greener, Healthier, and Happier i-~ Edward Glaeser THE PENGUIN PRESS New York 20H

32 U.S. $29.!l5 CANADA $37.5il «onlim,.d/rom/rontjrap) A pioneering urban ecennmlst reveals a trove of surprising insights Of! how cities work and offers inspiring proof that the city is humanity's greatest Inventlerrand our hast hope for the future AMERICA IS AN URBAN NATION. More than twothirds of us live on the 3percent of land that contains our cities. Yet cities get a bad rap: They're dirty, poor, unhealthy, crime ridden, expensive, environmentally unfriendly... Or are they? In this myth-shattering book, Edward Glaeser proves that cities are actually the healthiest, greenest, and richest (in both cultural and economic terms) places to live. New Yorkers, for instance, live longer than other Americans; heart disease and cancer rates are lowerin Gotham than inthe nation as a whole. City dwellers use, on average, 40 percent less energy than suburbanites. And more than half of America's income is earned in twenty-two metropolitan areas. Glaeser travels through history and around the globe to reveal the hidden workings of cities and how they bring out the best in humankind. Even the worst cities-kinshasa, surprising Kolkata, Lagos"':"'confer benefits on the people who flock to them, including better health and more jobs than the rural areas that surround them. Glaeser visits Bangalore and Silicon Valley, whose strangely similar histories prove how essential education is to urban success and how new technology actually encourages people to gather together physically. He discovers why Detroit is dying while other old industrial cities-chicago, Boston, New York-thrive. He pinpoints the single factor that most influences urban growth-january temperatures-and explains how certain chilly cities manage to defy that link. He explains how West Coast environmentalists have harmed the environment and how struggling Orleans cities from Youngstown to New can "shrink to greatness." And he exposes the dangerous antiurban political bias that is harming both cities and the entire country. Glaeser argues that our success as a country and as a species utterly depends on the health and we alth of cities. This book teems with counterintuitive yat convincing connections-how seventeenth-century wool begat the Renaissance, how Dutchmen helped Japan defeat Russia in 1905, how religious competition in colonial Boston setthe stage for that city's current accomplishments. But Glaeser also highlights the unnerving truth that America's poor treatment of'its own cities over the past half century helped spawn many of our most dire problems, from increased inequality to environmental damage to the recent economic collapse. Using intrepid reportage, keen analysis, and cogent argument, Glaeser makes an urgent, eloquent case for the city's import and splendor. He reminds us forcefully why we should nurture our cities or suffer consequences that will hurt us all, no matter where we live. he directs the Taubman EDWARD GLAESER is the Fred and Eleanor Glimp Professor of Economics at Harvard University, where Center for State and Local Government and the Rappaport Institute for Greater Boston. He is also a senior fellow at the Manhattan Institute and a contributing editor to City Journal. He studies the economics of cities, housing, segregation, obesity, crime, innovation, and writes and other subjects, about many of these issues for the New York Times blogeconomix. (ce:lii.tinuedon bc:.ckjlap) 0211 The Pengt,;" Pre.. A MEMBER OF PENGUIN GROUP (USA) INC. 375 HUDSON STRBET, NEW YORK, N.Y IN U.S.A.

33 ._ l 114 I TRIUNPH Of THE CITY city's population growth seems to have declined as a result. Cities have powerful resources-large police forces, observant citizens, strong infrastructurethat have so far enabled them to protect themselves against even the most terrifying threats. Health Benefits A mass of people living on a small amount of land creates enormous health risks, but as of 2007, a child born in New York City could, if current death rates continue, expect to live one-and-a- half years longer than a child born in the United States as a whole. Los Angeles, Boston, Minneapolis, and many other cities can also boast age-adjusted San Francisco, death rates lower than the national average. The average life expectancy in counties with more than five hundred people per square mile is nine months longer than in counties with fewer than a hundred people per square mile. Between 1980 and 2000, life expectancies increased six months more in counties with more than five hun-, -, dred people per square mile than in counties with less than that density. New Yorkers' good h~~lth didn't just happen. It took massive public invest- ;' ment to bring in potable water. It took a tough, quasi-military leader who /. drastically increased his department's expenses to make Manhattan's streets clean. Lots of cops and higher rates of imprisonment safe. Every battle was won by accountable made New York City and empowered public leaders who spent huge amounts of money and enlarged the public sector. The troubled cities of the developing world must go through they are to become safe and clean. But these investments a similarly difficult process if can only explain why large cities are no longer killing fields. The decline in urban infectious diseases and homicides can't explain why many cities like New York are healthier than the nation as a whole. It is easiest to understand why the death rate for Manhattanites between the ages of twenty-five and thirty-four is 60 percent lower than the comparable rate for the country. Accidents and suicides are the two leading causes of death for these younger people, and these are both rarer in big cities. New Yorkers in this age group are more than 75 percent less likely to die in a motor vehicle accident than their counterparts than taking the bus while intoxicated. nationwide. Driving drunk is far more deadly

34 HOW WERE THE TENEMENTS TAMED? 115! I I l The suicide rate for younger New Yorkers is about 56 percent of the national average, which reflects the fact that suicides are more common in rural areas. The death rates from suicide in Alaska, Montana, and Wyoming are more than 2.5 times higher than those in Massachusetts, New Jersey, and New York. While some of this effect may reflect the loneliness that can come from geographical isolation, my work with David Cutler and Karen Norberg on youth suicide also points to the fact that gun ownership is about four times as high in small towns as in big cities. The majority of suicides among younger people involve firearms, and many studies find that suicides are more common when firearms are more common, a fact that is a little odd because guns are hardly the onlymeans of killing oneself. Hunting is the strongest predictor of gun ownership in the United States, which explains why youth suicides rise significantly with the number of hunting licenses in a county. While the low mortality rates of younger urbanites reflect a surfeit of buses and a dearth of firearms, lower mortality rates among older people are more of a puzzle. Death rates are 5.5 percent higher nationwide than in New York for people fifty-five to sixty-four years old, 17fpercent higher for those sixtyfive toseventy-four, and more than 24 percent higher fotthose seventy-five to eighty-four. Differences in education, employment, or income don't seem able to explain the disparity. Mayor Bloomberg waged war against smoking by dramatically increasing cigarette taxes and limiting where one could smoke legally, but New York had become healthier than the nation as a whole before he took office. Perhaps all that walking makes New Yorkers healthier, but can that explain why they die less often from cancer? Los Angeles is also significantly healthier than the nation, and walking is far less common there. I'd like to think that the health of older New Yorkers reflects the vigorous nature of city life, but J can't rule out the possibility that selection may also be playing a role. Poor health increases the likelihood of retirement, and retirement increases the likelihood of leaving the city and moving someplace warmer. The health of cities like New York, Los Angeles, and San Francisco represents an astonishing turnaround from the past, when density too often meant death. Throughout most of human history, proximity enabled the spread of infectious diseases that struck d.own those humans who had the temerity to

35 116 TRIUMPH OF THE CITY risk living near one another. Huge investments in massive waterworks were needed to curb the spread of cholera and yellow fever, just as huge investments inpolicing were needed to reduce crime in the 1990s. The massing of millions in small land areas requires a vigorous public sector to combat crime and illness, which perhaps explains why people in New York are so much fonder of big government than people in rural Kansas. Epidemics will continue. Long after the Croton Aqueduct brought clean water to Manhattan, the 1918 influenza pandemic and AIDS both managed to kill millions. But today the spread of disease in cities is limited by investments in public health, and self-protecting urban innovation is as important as ever. The AIDS virus was discovered because a Parisian clinician who was treating sick patients connected with retrovirus researchers at Paris's Pasteur Institute. The health of cities depends on the health-creating aspects of urban Iife-c-good hospitals, faster information flows, fewer cars and gunsf dominating the disease-spreading consequence of density. Calhoun's warning remains relevant: Urban density IDay create marvels, but it also comes-with costs. The world lost much when plague ravaged Athens 2,400 years ago/and when AIDS struck New York in,the 1980s. Crime and congestion ar~.'still with us; their costs are most terrible in the growing cities of the developing world. But these problems are not insurmountable obstacles to urban success. Cities create their own champions, like Dr. John Snow or Colonel Waring or William Vickrey, who fight to make cities livable. They have often succeeded, and when they do, urban areas become not only habitable but delightful, for concentrated talent doesn't just make cities productive, it also makes them fun.

36 IS LOIlDON A LUXURY RESORT? 129 The novel begins with Carrie taking the train from rural Wisconsin to industrial Chicago. Chicago gives Carrie economic opportunity, significant, an escape from the stultifying boredom of enjoying the pleasures and temptations but even more of rural life. In the process of a big city, she manages to "ruin" a few city slickers, but Dreiser leaves us in no doubt that her life was a whole lot more interesting farm and married the earnest plowman Sister Carrie's somewhat sordid life reflects the availability of urban pleasures, but also the fact that traditional and fun than it would have been if she had stayed on the big cities. If Carrie had carried on with married five miles down the road. social mores tend to break down in men so freely in rural Wisconsin, she would have been ostracized. In Chicago, she may have been disreputable and banned from polite society, but she still had plenty of other disreputable types to play with. The same thing was true of Frank Cowperth-. waite, a Dreiser antihero based on a real-life streetcar magnate, Charles Yerkes, who found plenty of urban associates despite his scandalous behavior. For good,and ill, cities have long freed people from social convention. Villages find it easy to impose rules because people who break those rules can be cut off } from social connection I" and suffer, like the wearer of Hawthorne's scarlet letter, J. th,e pain of solitude. In a big city, however, there's always some new network to try, so no nongovernmental group can enforce harsh rules on behavior without resorting to extralegal violence. Some cities, such as Puritan Boston or Calvinist Geneva, managed to maintain social discipline for a while, but these strictures always eventually break down. The more natural outcome for a city is the less restricted world of Paris or Chicago. When Are High Wages Bad? An increasingly wealthy and well-educated population, eager to sample new delights, is naturally drawn to big cities, which specialize in innovative pleasure. Novelty itself is a luxury good. Only the rich have enough resources to get bored with having excellent, ordinary food every day. As the world has gotten richer and more unequal, more people are willing to pay for the constant stream of new, high -end experiences that are most easily had in big cities.

37 1! 130 I TRIUMPH Of THE CITY A vast array of publications and Web sites strive-and inevitably fail-to keep up with all the art openings, restaurant debuts, concerts, and other events that unfold every week in cities like Barcelona or Los Angeles or Tokyo. These experiences are so numerous and so evanescent that it might seem impossible to evaluate their effect on a city's overall quality of life. How do we sort through all of them and determine whether cities are becoming more or less pleasant places to live? One of the bedrock principles of economics is that free hmches are rare and markets require trade-offs. Investors can choose assets with higher returns only if they also take on more risk; suburbanites can get a bigger lot at the cost of a longer commute. In comparing metropolitan areas, there is a three-way trade-off among wages, prices, and quality of life. Most of the time, high wages. and high prices go together; high housing costs are the price of accessing highwage cities. But even correcting for prices and an individual's skills, real wages vary from place to place. Some cities, like San Diego and Honolulu, have unusually low real incomes, while others, like Dallas, Texas, and Rochester, Minnesota, have unusually high real incomes.,. Should everyone in Honolulu be n.tkhing to Dallas? Of course not. High i real wages are compensating for frigid winters in Rochester and broiling summers in Dallas. Low real wages are the cost of experiencing San Diego and Honolulu. the pleasures of The market works, more or less, and when a city has really high housing prices relative to incomes, you can bet that there is something nice about the place. If an extremely attractive area had high wages and low prices, it would attract thousands up the cost of living. I once estiniated which American metropolitan of new residents who would quickly bid areas were the most expensive,holding wages constant, and found that nine out of the top ten cities were in coastal California. Honolulu was the tenth city. When you look at which places have particularly too cold, like Anchorage, Texas. Other places in that bottom-ten low prices relative to incomes, you find spots that are Alaska, and spots that are too hot, like Midland, list, like Detroit or Trenton, have other problems, like crime and unemployment. Real wages-incomes corrected for local prices-are an effective tool for assessing urban amenities. If places have unusually low real wages, then quality of life must be high. If places have unusually high real wages, then some-

38 "!I I IS londofi A LUXURY RESORT? 131 thing is wrong with those places. Somewhat paradoxically, the decline in real wages in places like New York provides us with the best evidence that, all in all, big-city amenities have become more valuable. In 1970, there Was a strong positive relationship between city size and real wages. Real wages increased by 3 percent as area population doubled. The same relationship also held in In the 1970s, when New York was a battleground, workers had to be given combat pay to put up with the city's problems. Those high real wages were a sign of urban failure-the painful crime rate and disintegration of urban amenities-not urban success. Since 1980, the relationship between area population and real wages first leveled off and is now negative. In the year 2000, people were willing to accept lower real wages to live in New York, which means that they were coming to New York despite the fact that higher prices more than erased higher wages. It's not that New York had become less productive; the city's nominal wages, which reflect productivity, were higher than ever. But housing prices, fueled by the robust ~emand to live and play in the city, had risen even more than nominal earnings. If housing prices rise enough relative to nominal incomes, as they do whe~ cities become far more 'pleasant, then real incomes can actuallyfall during a period of great urban success. Manhattan had changed from a battlefield'~o an urban playground, and people were willing to pay, in the form of lower real wages, for the privilege of living there. Because economic logic suggests that places with high housing prices relative to income must be pleasant, I've tried to capture the pleasures of a place by ranking America's counties based on how unusually high their housing prices were in 1980 relative to their median incomes. On average, counties with high levels of amenities, meaning that they were in the top quarter of areas based on this index, saw their populations grow by 40 percent. Counties in the bottom quarter of areas based on this index had no population growth, on average. The high-amenity counties also saw real median incomes grow by 28 percent, as opposed to 14 percent in the low-amenity counties. The consumer city is on the rise., ' The increased demand for city living has also driven the rise in reverse commuting. People who live in one place and work somewhere else are showing their appreciation of the amenities, or low housing costs, of their hometown. We know that New York doesn't have low housing costs, but there is "I.1! ~ " ;[

39 132 I TRIUMPH OF THE CITV an increasingly large number of people who live in the city and work outside it. Nationwide, the share of the population that commutes from central city to suburb has increased from 2.4 percent in 1960 to 6.8 percent today. The fact that more people will pay high urban prices and work somewhere else is further evidence that big-city amenities have become increasingly valuable. Other variables that indicate an attractive location, like an abundance of tourists, also predict urban success. The correlation seems to hold in England and France, as well as in the United States. People are increasingly choosing areas on the basis of quality of life, and the skilled people who come to attractive areas then provide the new ideas that fuel the local economy. Smart, entrepreneurial people are the ultimate source of a city's economic power, and as those people become more prosperous, they care more about quality of life. What publicly provided amenities matter most for attracting the skilled? People, especially those with more education, and good schools for their children. The growing importance will pay plenty for safe streets of the consumer :city should serve mainly to keep civic leaders focused on doing the basic jobs,of local government: policing the streets and improving public schools. Res-..taurants and theaters are' also artractions, but they are neither as critical as r safely and schools nor as amenable to governmental intervention. Those arne-! nities come naturally in a thriving city, at least as long as the city hasn't overregulated its pleasures. The importance of consumer pleasures also offers a lesson for downturns. City governments must not react to fiscal distress by cutting municipal services, like policing. The easiest way to ensure that a city won't survive an economic crisis is to turn it into a dangerous no-man's-land. Unsafe streets will repel the skilled workers that are so vital for urban rebirth. New York, London, and Paris may be the world's most elite consumer cities, but there are plenty of other places that succeed by being playgrounds. Universitytowns, like Charlottesville, Virginia, have attracted many retirees. LasVegas leveraged its casinos into becoming the fastest-growing large city in America. Indeed, the city's boosters got so excited about all those restaurants that it experienced pain of the overbuilding and casinos one of the most dramatic of all housing bubbles. Once the normal, midsize place that s~cceecls by promoting has subsided, Las Vegas can go back to being a more a certain kind of fun. The problem that New York and London and Paris face is somewhat dif-

40 IS LONDON A LUXURY RESORT? 133 ferent. Robust economies and abundant pleasures have made these places highly desirable. People want to live there, and when there isn't enough housingto satisfy demand, prices can soar. If the most attractive metropolises don't build more homes, they risk becoming boutique cities, depriving all but the wealthiest of their pleasures and their practical advantages. The barriers that prevent construction in these successful areas are the topic of the next chapter. /! l

41 148 I TRIUMPH OF THE CITY space with the cost of real estate. Simply put, the places that are expensive don't build a lot, and the places that build a lot aren't expensive. Several papers have shown that new <:onstruction is lower and prices are higher in places that restrict building. One of the cleverest papers in this genre uses natural barriers to building, such as the hilliness of an area, and shows that places with tough topography have less new mnstruction and higher prices. Perhaps a new forty-story building won't itself house any quirky, less profitable firms, but by providing new space, the building will ease pressure on the rest of the city's real estate. Price increases in gentrifying older areas will be muted because of new construction. Growth, not height restrktions and a fixed building stock, keeps space affordable and ensures that poorer people and less profitable firms can stay, which helps thriving cities remain successful and diverse. Height restrictions do increase light, and preservation does protect history, but we shouldn't pretend that these benefits come without a price. I, ;:: The Perils of Preservation f ' I~1961, the same year that Jane Iacobs published her great book, the Penns,ylvania Railroad was preparing to raze its old New York statim}. That railroad I " bad built the station on Thirty-third Street as a temple to trains ill 1908, the height of the rail era. The old Penn Station was a stunning structure, complete with Doric columns and a waiting room based on the Baths of Caracalla. The building's architect, like Jane Jacobs, saw height as inimical to urban life, so he insisted that the building be short. The decision to go low would prove to be the station's undoing. While the structure was an acknowledged architectural masterpiece, it also made less sense as rail travel declined in the twentieth century. By the end of the 1950s, the Pennsylvania Railroad was determined to get more value out of their wellplaced, central Manhattan property. They tore down the Beaux Arts structure and replaced it with today's far less loved station and a thirty-fom-story office tower. The rents from the tower could make up for some of their declining rail revenues. Everything the Pennsylvania Railroad did was entirely legal, but the old station had been loved by both cognos<:enti and ordinary commuters. The demolition of the beautiful station became a rallying cry for a growing pres-

42 WHAT'S SO GREAT ABOUT SKYS(RA~ERS? 149 ervationist movement that aimed to protect New York's most beautiful older buildings from Penn Station's fate. In 1962, Mayor Robert Wagner established a Landmarks Preservation Commission. Just in case there was any confusion about the mayor's motivation, the subtitle of the New York Times article announcing the formation of that new agency was "Wagner Names 12 to New Agency~Architects Decry Razing of Penn Station." In 1965, despite vigorous opposition from the real estate industry, the Landmarks Preservation Commission became permanent. It initially seemed like a small sop to the preservationists. The number of landmarked buildings, seven hundred, was modest, and the commission's power was checked by the mayor, who could and can veto anyone of their decisions. Yet, like entropy, the reach of governmental agencies often increases over time, so that a mild, almost symbolic, group can come to hold sway over vast swaths of a city. By the spring of 20 10, the New York Landmarks Commission had jurisdiction over twenty-five thousand landmarked buildings a~d one hundred historic districts. More than 15 percent of Manhattan's nonpark land south of Ninety-sixth Street is now in a historic district, where every external change must be approved by the Landmarks Co.tpl~ission. In 2 96; the developer Aby Rosen proposed putting a twenty-twa-story glass tower atop the old Sotheby-Parke- Bernet Building at 980 Madison Avenue, in the heart of the massive Upper East Side Historic District. The building itself was not landmarked, but Rosen and his Pritzker Prize-winning architect, Lord Norman Foster, proposed keeping the original huilding's facade intact. The tower would have risen above the old structure, much as the former Pan Am Building rises above Grand Central Terminal. Wellconnected neighbors didn't like the idea of more height, and they took their complaints to the Landmarks Preservation Commission. Tom Wolfe, who has written brilliantly about both the foibles of New York and the real estate industry, penned a 1,500-word piece in the New York Times insinuating that if the Landmarks Commission gave approval to the project, it would hetray its mission, Wolfe & Co. won. In response to his critics in the 980 Madison Avenue case, of which I was one, Mr. Wolfe replied in the Village Voice that "10 take their theory to its logical conclusion would be to develop Central Park... When you consider the thousands and thousands of people who could be housed in Central Park

43 '11 :,-';!\ 150 TRIUMPH OF THE CITY if they would only allow them to build it up, boy, the problem is on the way to being solved!" But one of the advantages of building up in already dense neighborhoods is that you don't have to build in green areas, whether in Central Park or somewhere far from an urban center. From the preservationist perspective, building up in one area reduces the pressure to take down other older buildings. One could quite plausibly argue that if the Landmarks Commission has decided that a building that its replacement be as tall as possible. can be razed, then they should demand The cost of restricting development is that protected areas become more expensive and more exclusive. On average, people who live in historic districts in Manhattan are almost 74 percent wealthier than people who live outside such areas. Almost three quarters of the adults living in historic districts have college degrees, as opposed to 54 percent outside them. People living in historic districts are 20 percent more likclyto be white. The well-heeled denizens of historic districts convincing the Landmarks Preservation Commission to stop taller structures have become the urban equivalent of those restrictive suburbanites who want to mandate five-acre lot sizes in order to keep out the riffraff. It's not that poorer people could ever afford 980 Madison Avenue, but restti~ting new supply anywhere makes it more difficult for the city to accom- I. modate demand, and that pushes up prices everywhere. / The basic economics of housing prices arc pretty simple-supply and demand. New York and Mumbai and London all face increasing demand for their housing, but how that demand affects prices depends on supply. Building enough homes eases the impact of rising demand on prices and makes cities more affordable. That's the lesson of New York in the 1920s, when New York built hundreds of thousands of homes and the city stayed affordable, and of affordable pro-growth cities, like Chicago and Houston, today. In the postwar boom years between 1955 and 1964, Manhattan permitted more than 11,000 units each year. Between 1980 and 1999, when the city's prices were soaring, Manhattan permitted an average of 3,120 units per year. fewer new homes meant higher prices, and between 1970 and 2000, the median price of a Manhattan housing unit increased by 284 percent in constant dollars. In New York City, the price of building an additional square foot of living space on the top of a tall building is less than $400. Prices do rise substantially in ultratall buildings, say over fifty stories, but for ordinary skyscrapers, it

44 cc c, _ "i WHAT'S SO GREAT ABOUT SKYSCRAPERS? 151 doesn't cost more than $500,000 to put up a nice, new 1,200-square-foot apartment. The land costs something, but in a forty-story building, a 1,200-squarefoot unit is only using 30 square feet of Manhattan, less than a thousandth of an acre. At those heights, the land costs become pretty small. If there were no rules restricting new construction, then prices would eventually come down to somewhere near construction costs, about a half million dollars for a new apartment. That's a lot more than the $200,000 that it costs to put up a nice 2,500-square-foothouse in Houston but a lot less than the $1 million or more that such an apartment now costs in New York. Land is also pretty limited in Chicago's Gold Coast, on the shores of Lake Michigan. Demand may not be the sanle as in Manhattan, but it's still pretty high. Yet you can buy a beautiful condominium with a lake view for roughly half the cost of a similar unit in Manhattan. The cost of building in Chicago is cheaper than in New York, but not half as cheap. The big difference is that Chicago's leadership has always encouraged new construction more than New York's, at least before the Bloomberg administration. The forest of cranes along Lake Michigan keeps Chicago affordable. Most people who fight to stop a new development think of themselves as heroes, not-villains. After all, putting J up a new building on Madison Avenue clearly bugs a lot of famous people, and one building isn't going to make much difference to the city as a whole. The problem is that all those independent decisions to prevent construction add up. Zoning rules, air rights, height restrictions, and landmarks boards together form a web of regulation that has made it more and more difficult to build. The increasing wave of regulations was, until the Bloomberg administration, making New York shorter. In a sample of condominium building's, Ifound that more than 80 percent of structures erected in the 1970s had more than twenty stories, while fewer than 40 percent of the buildings erected in the 1990s were that tall. The elevator and the steel-frame skyscraper made it possible to get vast amounts ofliving space out of tiny amounts ofland, but New York's building rules were stopping that process. The growth in housing supply determines not only prices but the number of people in a city. The statistical relationship between new building and population growth across areas is almost perfect, so that when an area increases its housing stock by 1 percent, its population rises by almost exactly that " I.!

45 rl 152 I TRIUMPH OF THE mv amount. As a result, when New York or Boston or Paris restricts new construction, those places' populations will be smaller. If the restrictions become strong enough, then places can even lose population, as wealthier, smaller families replace poorer, larger ones. despite rising demand, Jane Jacobs's insights into the pleasures and strengths of older, lower urban neighborhoods were certainly correct, but she had too little faith in the strengths of higher density levels. I was born a year before Jacobs left New York for Toronto, and I lived in Manhattan for the next seventeen years. My neighborhood looked nothing like low-rise Greenwich Village. I grew up surrounded by white, glazed towers built after World War II to provide affordable housing for middle-income people like my parents. The neighborhood may not have been as charming as Greenwich Village, but it had plenty of reasonably fun restaurants and quirky stores and even quirkier pedestrians. The streets were reasonably safe. It was certainly a functioning, vibrant urban space, albeit one with plenty of skyscrapers. Hong Kong, which has embraced verticality and change, is an even more extreme case, where exciting street life is perfectly compatible with soaring structures.,i Not-everyone :. should live in a high-rise. Plenty of urbanites, like Jane Jacobs,jJIefer older, shorter neighborhoods. However, plenty of others enjoy t, li~?g in urban aeries, and government shouldn't stop skyscrapers from fulfilling their dreams either. Limiting high-rise development doesn't guarantee interesting, heterogeneous neighborhoods. It just guarantees high prices. People in an affluent society want and expect comfortable, spacious homes. Today America builds those homes in the suburbs of the Sunbelt, which pulls people out of cities and toward Texas. But spacious, affordable homes can also be built in our older cities. There can be an urban future where more people live in central cities, but to do that, the most desirable of those cities must reduce the regulatory barriers that limit the construction of taller buildings. Rethinking Paris. ' A century ago, Paris and New York offered completely different visions of urban development. vision, and his bureaucrat-baron Paris was built from the top down. The emperor had his made it so. New York's skyline was made by thousands of relatively unregulated builders putting up whatever the market

46 -_._--_ _..._ _.._ _ CHAPTER 8 Is There Anvthing Greener Than Blacktop? :'\n a pleasant April day in 1844, two yolli1g men went out for a walk in i.~ the woods along the Concord River. Sin<~ethere hadn't been much rain OD \- ~.- lately, the water was low, and they could fitly procure our food from the stream, Indian-like:' Using a match they had gotten from a shoemaker, they built a fire in a pine stump near Fair Haven Pond. The two intrepid were hungry and looking to cook some chowder. explorers The same dearth at rain that made for easy fishing madejthe grass around their cooking area qty'and flammable. Wind spread their fire to the grass and "as every thing around them was as combustible almost as a fireship, the flames spread with rapidity, and hours elapsed before it could be subdued;' One of the men rushed to town to raise the alarm, but the fire could not be stopped, Over three hundred fire lit by these two young pleasure seekers. acres of prime woodland were razed by a careless Smokey the Bear could use this story to teach children the dangers of forest fires, but at least one of the culprits steadfastly denied any guilt. He wrote: "I have set fire to the forest, but I have done no wrong therein, and now it is as if the lightning had done it:' The other residents of Concord were less forgiving, taking an understandably dim view of even inadvertent arson. They called the young incendiary a "dammed rascal" and a "flibbertigibbet," The Concord Freeman's text sounds like a stuffy nineteenth-century Smokey: "It is to be hoped that this unfortunate New Englander channeling result of sheer carelessness, will be borne in mind by those who may visit the woods for recreation:' The unrepentant forest burner was Henry David Thoreau, a somewhat underemployed Harvard graduate who has since become the secular saint of en-

47 200 TRIUMPH OF THE CITY vironmentalisrn. Thoreau's Walden is one of those rare books whose influence 'seems only to grow over time. During his lifetime, his journal, describing two years of isolated living, received little attention. But in the twentieth century, it became a global bestseller, read by millions and taught by environmentally conscious high school teachers around the world. Thoreau loved the woods, but he was also part of an urban chain of intellectuals. He had been educated in the intellectual hothouse of early nineteenthcentury Harvard, More important, he was one of a remarkable concentration of minds brought together by Ralph Waldo Emerson in Concord, a town filled with creative thinkers. Emerson assembled, and occasionally funded, brilliant minds, including Herman Melville, Nathanial Hawthorne, Margaret Fuller, Bronson Alcott, Louisa May Alcott, and Thoreau. Thoreau was part of Emerson's Transcendentalist salon, but he extolled the virtues of rural isolation rather than urban interaction. In his introduction to Walden, Emerson described Thoreau thus: "An iconoclast in literature, he seldom,thanked colleagues for their services to him, holding them in small esteem; whilst yet his debt to them was important;' Would Thoreau have been able ~o write so well about living alone if he hadn't also connected with so m,,4y smart people in towns? Yet the eloquent cadences of Walden preach the t. virtues of sylvan solitude. Just as Thoreau and his disciples have rarely seen the virtues of cities, they have also had little empathy for the Concord Freeman's warnings against rural recreation. Thoreau's walk in the woods did much more for his soul than for the woods themselves, and my move into the countryside has done nothing but harm the.environment. I've gone from being a relatively parsimonious urban energy user to emitting massive amounts of carbon. While my compact urban living space could be easily warmed, it takes hundreds of gallons of fuel oil to heat my drafty home over a New England winter. My modest attempts to reduce energy use have led my mother to accuse me of trying to freeze my children. I call it building character. What with lights and air conditioning and appliances, my electricity bill has tripled. Of course, like most of non urban America, I've also become dependent on the car, burning roughly a gallon of gas every time I go to a 'full-size grocery store. It all seems pretty absurd to someone city-born, didn't learn how to drive until he was in graduate school. who, My story, like Thoreau's, makes a fundamental point: Cities are much bet-

48 ~-, IS THERE ANYTHING GREENER THAN BLHKTOP? 201 ter for the environment than leafy living. Residing in a forest might seem to be a good way of showing one's love of nature, but living in a concrete jungle is actually far more ecologically friendly. We humans are a destructive species, even when, like Thoreau, we're not trying to be. We burn forests and oil and inevitably hurt the landscape that surrounds us. If you love nature, stay away from it. In the 19708, Jane Jacobs argued that we could minimize our damage to the environment by clustering together in high-rises and walking to work, and this point has been eloquently argued by David Owen in his book Green Metropolis. We maximize OUr damage when we insist on living surrounded by greensward. Lower densities inevitably mean more travel, and that requires energy. While larger living spaces certainly do have their advantages, large suburban homes also consume much more energy. There is still much debate about the relationship between greenhouse gases and global warming, and there is plenty of uncertainty about the effects global warming will ha~e on the planet. I am no climatologist, and I have little to add to these contentious discussions. However, even those who doubt that humans are responsible fbr much of the recent risein global tejnperature should still recognize that!th~~eare environmentil risks associated ~ith massively increasing the arnouht of carbon we emit. Anyone 0ho believes that global warming is a real danger should see dense urban living as part of the solution. Over the next fifty years, China and India will cease to be poor rural nations, and that's a good thing. 'Ihey-s-like the United States and Europe before them-s-will move from farms to urban living. If billions of Chinese and Indians insist on leafy suburbs and the large homes and cars those suburbs entail, then the world's carbon emissions will soar. Some environmentalists seem to wish that these countries would just stay rural Thank goodness that isn't a real option. Remaining rural means poverty and its attendant curses. The critical question is whether, as Asia develops, it will become a continent of suburban drivers or urban public-transit users. Environmentalists can make the case for greener living in dense cities, but to do this they must give up their antipathy to concrete. Today ecofriendly households raise their children on Dr. Seuss's fable The Lotax, which depicts a callous city destroying a once beautiful landscape. True environmentalists should toss their copies of this book into the recycling bin and denounce the

49 202 TR III MPH 0 F THE (I TY Lorax fallacy-that cities are bad for the environment. High-rise pioneers like William Le Baron Jenney and A, E. Lefcourt are better guides to a greener future than Henry David Thoreau, The Dream of Garden living Itis, of course, unfair to single Thoreau out for touting low-density living. For millennia, writers have praised the virtues of going back to nature, which actually made some sense before cities got clean water. The classical poet Horace, who left his father's farm to be educated in Athens and Rome, wrote, "The chorus of writers, one and entire, detests the town and yearns for the sacred grove," At the start of the nineteenth century, the age-old pleasures of English country living acquired one of the greatest public relations teams ever. Wordsworth, Coleridge, Keats, Shelley, and their fellow Romantic poets all extolled the magnificence of the countryside. T~ese poets were reacting to the first explosion of industrial urbanization. They understandably saw more poetry in autumn or the west wind than in a textile mill. Byron was one of the Luddites' few defenders in the House of Lof~i~:In a sense, Thoreau's years in Walden were just a more extreme version o/wordsworth's life in the Lake District. Indeed, neither one was crazy to flee 'the disease and disorder of nineteenth-century cities, where life was too often nasty, brutish, and short. The Romantics' love of nature spread to the more practical arts of architecture and urban planning. John Ruskin was raised in early nineteenth-century London, but as an art critic, he urged painters to "go to nature in all singleness of heart,.. rejecting nothing and selecting nothing:' He loathed the standardization that marked both industrialization and classical art forms. He favored the vagaries of nature and Gothic structures. Ruskin was also an early advocate of town planning. He urged that "from any part of the city perfectly fresh air and grass and the sight of far horizon might be reachable in a few minutes walk:' He had in mind a compact, walled town, girded by a "belt of beautiful garden and orchard round the walls:' Ruskin's message underwent a slight metamorphosis when it crossed the Atlantic, for Peter B. Wight, who helped make urban skyscrapers possible in the United States, started off as one of Ruskin's most fervent American apostles,

50 206 TRIUMPH OF THE CITY temperatures through the greenhouse effect, whereby gases in the atmosphere absorb infrared radiation and warm the land below. The basic intuition of the mainstream hypothesis on climate change is that more greenhouse gases mean more infrared absorption and higher surface temperatures. For those of us who endure New England or Midwestern winters, a few extra degrees in February sounds swell, but unfortunately the side effects from rising global temperatures are potentially terrible for almost everybody. TIle poorest people in the world tend to live near the equator, and more heat is particularly problematic for them. The polar ice caps appear to be melting quickly and threatening seaside cities [rom New York to Hong Kong with the prospect of severe flooding. And higher ocean temperatures may create more volatile, stormier weather worldwide. Temperatures do fluctuate for many reasons, butthat doesn't change the fact that a colossal increase in carbon emissions could still radically affect the wea ther. Humani ty has spent millennia adjusting to our current environment. If our carbon emissions radically alter that environment, the costs may well be enormous. The potential risks from a different climate make it reasonable for the world to take significant action" to reduce the growth of carbon dioxide emissions. Among other things, that means favoring construction in areas that are greener and reducing building in areas that are more brown. Dirtv Footprints: Comparing Carbon Emissions Matthew Kahn and I have put together a carbon inventory of new housing throughout America. We wanted to determine the amount of carbon emissions that come from building a typical new home in different parts of the country, so we based our estimates primarily on homes built over the last two decades. In 2006, the United States produced about 6 billion metric tons of carbon dioxide, which doesn't include the emissions related to the goods we import from elsewhere on the planet. That figure represents about one fifth of total world carbon dioxide emissions, more than any other country except China and more than the amount emitted by Europe and Latin America. Together, homes and cars account for about 40 percent of an average household's output and also about 40 percent' of America's and 8 percent of the world's carbon footprint. About 20 percent of America's carbon dioxide emissions are related

51 IS THERE ANYTHING GREENER THAN BLACKTOP? 207 to residential energy use, and almost another 20 percent is associated with our motor vehicles. Using a gallon of gas produces about twenty-two pounds of carbon dioxide, ifyou factor in the carbon used in refining and distributing gasoline. An average family in the United States buys about a thousand gallons of gas a year, which is associated with about ten tons of carbon dioxide. It may be easier to imagine American families buying more fuel-efficient cars than giving up on car-based living altogether, but historically the bulk of variation in gas usage among various people over various periods of time comes from total miles traveled, not from fuel efficiency. Cars now get, on average, about 22 miles per gallon, and the big difference is whether you drive three hundred miles per year or thirty thousand, which depends on whether you live in a city or a suburb. Kahn and I found that area density and distance to the city center are both strongly associated with gasoline usage. The average household living in a census tract with more than ten thousand people per square mile uses 687 gallons of gas per year, while the average household living in an area with fewer than one thousand people per square mile (about one household per acre) uses 1,164 gallons of gas per year. The density of ones home neighborhood matters becausemost car trips aren't commutes downtown. People drive millions of mile to buy groceries, to go out to eat, and to pick their children up at school. The density of stores and schools in an area determines the average distance of those trips. In a city, you often walk to a restaurant. In a low-density area, eating out might entail a twenty-five-minute drive each way. Holding family income and size constant, gas consumption per family per year declines by 106 gallons as the number of residents per square mile doubles. These estimates suggest that if the average Northeastern household moved from living at one family per acre to five families per acre, then that family would consume 350 fewer gallons. These facts remind us that mass transit isn't the only way to lower gas consumption. If people lived in denser areas, they'd travel far fewer miles and burn much less gas, even if they still drove to work. Public transportation emits carbon too, but most forms of public transit are,a lot more energy efficient than driving vast distances in our own personal gas burners. For example, the New York City Transit system uses 42 million gallons of diesel fuel and 14.8 billion megawatts of electricity each year to deliver 2.6 billion trips to its riders. That works out to an average of 0.9 pounds

52 208! TRIUMPH OF THE CITY of carbon dioxide per trip-a tenth as much as the nine pounds of carbon dioxide emitted in an average car trip. Kahn and I predicted the amount of gas that an average family with about $60,000 of income would consume in every census tract and every metropolitan area in the country. While every other area in our sample was associated with more than 1,000 gallons of gas per year, the average household the New York metropolitan area was connected with fewer than 850 gallons of gas per year. While people in the United States as a whole are more than fifteen times as likely to drive themselves to work as to use public transportation, New York City residents are more than twice as likely to take mass transit as to drive to work. Throughout the country, big cities mean less driving. On average, when population doubles, per-household carbon dioxide emissions due to driving decline by almost a ton per year. Southern cities have particularly high driving levels, and over 75 percent more gasoline usage than New York. Sunbelt cities like Greenville, South Carolina, Nashville, Tennessee, and Oklahoma City were built at low densities and have widely dispersed employment, and their residents use the'rnost gas. J in -I. In almostevery, ' metropolitan area, city dwellers consume a lot less gas than suburbanites. Predictably, some of the biggest city-suburb gaps are in older areas, lih: New York, where the average urban family consumes more than three hundred fewer gallons of gas per year than its suburban counterpart. But some of the largest gaps between cities and suburbs also occur in places like Atlanta and Nashville. It isn't that central Nashville or Atlanta has so little driving, but that people drive so much in their suburbs. These facts suggest that city density reduces carbon emissions in the older areas of the Northeast, but also in the newer areas that are growing fastest. Cities are also greener than suburbs because urbanites use less electricity. Electrical appliances acco unt for two thi rds of residential energy Use.The main factor that explains the difference in energy use among various metropolitan areas is summer heat. Everybody runs refrigerators and appliances, but air, conditioning really drives the differences from place to place. The rise of the American Sunbelt in the postwar period owes much to the availability of cheap, cool air. Who would want to put up with Houston's ninety-nine 90-degree days a year without air conditioning?

53 IS THERE ANYTHING GREENER THAN BLArKTOP? 209 America's lowest electricity-using metropolitan areas are in coastal California and the Northeast. in our sample of metropolitan San Francisco and San Jose have the coolest summers areas, and they're two of the places that use the least electricity. By contrast, the hot, humid cities of Houston, New Orleans, and Memphis lead the pack in electricity consumption. In these places, the summer months are almost unbearable without an artificial climate. Warm Julys aren't the only force driving up electricity usage. Bigger, denser cities, where people own smaller homes, use less electricity. The average singlefamily detached horne consumes 88 percent more electricity than the average apartment in a five-or-more-unit building. The average suburban household consumes 27 percent more electricity than the average urban household. When we standardize for income and family size, we find that central-city residents use less electricity in forty-four out of the forty-eight metropolitan areas that we analyzed. More centralized metropolitan areas, such as New York, Boston, and even Las Vegas, use less electricity than more sprawling places, like Dallas or Phoenix. In warmer areas of the country, electricity is sometimes used for heating, but natural gas is America's primary source of warmth, and it is responsible.."' for almost a fifth 0rresidential carbon emissions. Home heating has actually gotten a lot greener over time. We started off burning wood, which emits plenty of carbon, and then moved on to coal, which darkened the skies of American cities until after World War n. Gradually cities started forcing people to switch away from coal, and luckily, just as coal was being phased out, natural gas from the American West became far more available (and George Mitchell made his fortune). Fuel oil, an older source of heat, still accounts for almost a tenth of residential carbon emissions, despite the fact that it is rarely used, because fuel oil emits much more carbon than natural gas. Home heating emissions make the Snow Belt look less green than tern perate California. Detroit and Grand Rapids, Michigan, lead our sample of metropolitan areas in natural gas consumption. Buffalo, Chicago, and Minneapolis are close behind. By contrast, Florida consumes hardly any natural gas. Miami.is still pretty warm in January, even at night. To form a total estimate of household carbon emissions, we just add together the emissions from driving, electricity, andheating, and add public transit. By now, it should be no surprise that cities are greener than suburbs.

54 210 1 TRIUMPH OF THE CITY But the differences between metropolitan areas are even larger than the differ, ences between individual cities and their suburbs. Coastal California is by far the greenest part of the country. The Deep South is by far the brownest. The five greenest metropolitan areas in the country are San Diego, San Francisco, Los Angeles, Sari.Jose, and Sacramento. The five places with the highest carbon emissions per home are Houston, Birmingham, Nashville, Memphis, and Oklahoma City. The gap between these two extremes is dramatic. A household in San Francisco emits 60 percent less carbon than its equivalent in Memphis. Older places in the Northeast and Midwest lie at various points between these extremes. They use more electricity than California but less than Houston, and they use plenty of energy for heating. New York is one of the greener cities, because of its density. Detroit, being the Motor City, has much higher emissions. The Unintended Consequences of Environmentalism So how should we interpret / emissions by changing our land-developm~nt all this data? Simply put, if we wanted to reduce policies, more Americans should li~e in denser, more urban environments. More Americans should move to, coastal California and fewer should live in Texas. California is blessed with a splendid natural climate that doesn't require much cooling in the summer or heat in the winter. Living in Houston or Atlanta requires a lot more energy for habitability, so then why aren't more Americans living in California? The answer certainly isn't overcrowding. California's coastal areas are remarkably open. The drive along Route 280 through the heart of Silicon Valley is like a drive through an open Eden. There are about 2 people living on each acre in Santa Clara County. Marin County, just north of the bay, has more than one-and-a-quarter acres per person. By contrast, Montgomery County in Maryland has about 3 people per acre. Cook County, Illinois, has almost 9 people per acre. Manhattan has 111 people per acre, and that isn't counting the vast crowd of workers that comes and goes each day. Coastal California could house many millions more than it already does, but the growth in these coastal regions has fallen dramatically heyday. Between 1950 and 1970, the population from its postwar of Santa Clara County more

55 IS THERE ANYTHING GREENER THAN BLACKTOI'? 21l than tripled, from fewer than three hundred thousand to more than one million. But between 1990 and 2008, Santa Clara County grew by only 17.8 percent, less than the national average, from 1.5 million to 1.76 million. Over the last seventeen years, Silicon Valley has been one of the most productive places on the planet, but its population growth has lagged behind the rest of the nation's. Coastal California hasn't grown because it hasn't built much housing. Any area that doesn't build much won't grow much. Coastal California's construction declines don't reflect a lack of demand. In 2007, the National Association of Realtors median sales price passed $800,000 in both San Francisco and San Jose. Even after the crash, these places remain the two most expensive areas in the continental United States, with average housing prices around $600,000 in the second quarter of Prices in California are kept high by draconian limits on new construction, like the sixty-acre minimum lot sizes that can be found in Marin County. These rules are joined with a policy of pulling more and more land off the market as protected parks and wildlife areas. By 2000, one quarter of the land in the Bay Area has become permanently protected, that is, off limits to building. Many environmentalists see the reduction of development in the San Francisco Bay region as a great triumph. The pioneers of the Save the Bay movement, which formed to block development around the water, have become iconic figures in American environmentalism. The Friends of Mammoth case, which imposed environmental reviews on all new California projects, is seen as a watershed victory. The advocates of California's growth limitations are often put forward as ecological heroes. But they're not. The enemies of development in California are quick to point out that restricting construction is necessary because of the state's sparse water supplies. Yet California would have more than enough water for its citizens if it didn't usc so much of it irrigating naturally dry farmland. California's cities and suburbs use about 8.7 million acre-feet of water each year. California agriculture gets subsidized water and uses 34 million acre-feet of water each year for irrigation. America is filled with wet regions that can raise crops. By redirecting water from farm areas to cities, California could easily provide enough water to sustain much higher density levels, which would reduce America's carbon footprint.

56 ~~ ~~-~---~"-" I TRIUMPH Of THE CITY I' I, '. I ",,! While limits on California's growth may make that state seem greener, they're making the country as a whole browner and increasing carbon emissions worldwide. Houston's developers should thank California's antigrowlh movement If they hadn't stopped building in coastal California, where incomes are high and the climate is sublime, then there wouldn't have been nearly as much demand for living in the less pleasant parts of the Sunbelt. People who fight development don't get to choose the amount of new coustruction throughout the country; they only get to make sure it doesn't OCCUr in their backyard. At the national level, a principle that could be called the law of conservation of construction appears to hold. When environmentalists stop development in green places, it will occur in brown places. By using ecological arguments to oppose growth, California environmentalists arc actuallyensur_ ing that America's carbon footprint will rise, by pushing new housing to less temperate climates. The 1970 California Environmental Quality Act was a pioneering piece of.legislation, which mandated that any local government project have an environmental impact review before it went forward, In 1973, an environmentally.activist California Supreme Court interpreted this act to mean not only proj- / ects undertaken by local governments, but also projects permitted by local government, which means pretty much any large construction in the state. In 2008, California's regulations generated 583 environmental impact reviews, considerably more than the 522 impact reviews that occurred nationwide in response to federal guidelines, These impact reviews add costs and delays to new construction, which ultimately make it even more expensive. The great flaw of environmental impact reviews is their incompleteness. Each review only evaluates the impact of the project if it's approved, not the impact if it's denied and construction begins somewhere else, outside tile jurisdiction of the California Supreme Court. The incompleteness of these reviews stacks the environmental deck against California construction and makes it seem as though it's always greener to stop new building. The full impact would note that permitting building in California would reduce construction somewhere else, such as the once pristine desert outside of Las Vegas. Assessing the full environmental cost of preventing construction in California would make that state's environmental policies look more brown than green.

57 r CONClUSION: Flat World, Tall City T '"here is little that you own or use or know that wasn't created by someone. else. Humans are an intensely social species that excels, like ants or gibc bans, in producing things together. Just as ant colonies do things that are far beyond the abilities of isolated insects, cities achieve much more than isolated humans. Cities enable collaboration, especially the joint production of knowledge that is mankind's most important creation. Ideas flow readily from person to person in the dense corridors of Bnngalore and London, and people arf\~lling to put up with high urban prices just to be around talented people, some of whose knowledge will rub off. Rousseau famously wrote, "Cities are the abyss of the human species," but he had things completely backward. Cities enable the collaboration that makes humanity shine most brightly. Because humans learn so much from other humans, we learn more when there are more people around us. Urban density creates a constant flow of new information that comes from observing others' successes and failures. In a big city, people can choose peers who share their interests, just as Monet and Cezanne found each other in nineteenth-century Paris, or Belushi and Aykroyd found each other intwentieth-century Chicago. Cities make it easier to watch and listen and learn. Because the essential characteristic of humanity is our ability to learn from each other, cities make us more human. No matter how mundane a city's origins, urban concentrations can have magical consequences. Roman soldiers settled on an island in the Seine because it was a good spot to defend themselves against unfriendly Gauls. From that humble start, over the past two thousand years, Parisians have produced r ; i

58 248 TRIUMPH OF THE CITY vast amounts of cultural, economic, and political innovation. The Nether_ lands' medieval cities were built on the wool trade, but urban density enabled their burghers to foment the modern world's first successful republican revolution. Chicago's location made it the ideal place for Midwestern hogs to be slaughtered on their journey east, but the city attracted a remarkable cluster of architects=-ienney, Burnham, Sullivan, Wright-c-who collectively invented the skyscraper. Shanghai began as a cotton town, but in the 1920s, its density helped create a wave of innovation in music, movies, and animation. Artistic movements tend to develop in one place-like fifteenth-century Florence or nineteenth-century Paris. In eighteenth-century Vienna, Haydn passed his symphonic ideas to his friend Mozart and his student Beethoven. The great chains of artistic innovation forged by painters or composers who live together in dense cities bear a striking resemblance to the far more prosaic chain of urban innovations that gave us junk bonds, leveraged buyouts, and mortgage-backed securities. Pundits and critics have long argued that improvements in information technology will make urban advantages obsolete. Once you can learn from ~ikipedia inanchorage, why pay New York prices? But a few decades of high ~echnology can't trump millions of years of evolution. Connecting in cyberspace will never be the same as sharing a meal or a smile or a kiss. Our species learns primarily from the aural, visual, and olfactory clues given off by our fellow humans. The Internet is a wonderful tool, but it works best when combined with knowledge gained face-to-face, as the concentrations of Internet entrepreneurs in Bangalore and Silicon Valley would attest. Everyone of Harvard's economics students uses technology constantly, but they also get plenty out of face-to-face meetings with their peers and professors. The most important communications still take place in person, and electronic access is no substitute for being at the geographic center of an intellectual movement. The declining cost of connecting over long distances has only increased the returns to clustering close together. Fifty years ago, most innovators played on a local stage. High transport costs limited one's ability to make money quickly from selling a good idea worldwide. Today, traders in London or New York or Tokyo can instantly exploit a mispriced asset halfway around the world. The death of distance may have been hell on the goods producers in Detroit, who lost out to Japanese competitors, but it has been heaven for the idea producers

59 flat WORLD, TAll CITY 249 of New York and San Francisco and Los Angeles, who have made billions on innovations in technology and entertainment and finance. Even when the financial world flails in one of its recurring downturns, we should be confident that its collective intelligence will eventually produce another boom. Countries still make wars, and governments slaughter their own citizens. Much of the world is still poor, while many in richer countries are less happy than they could be, and everyone's environment is at risk. To face these challenges, humanity needs all the strength it can muster, and that strength resides in the connecting corridors of dense urban areas. The fact that we need our cities so much makes me optimistic about their future. The world recognizes the value of new ideas. People still flock to cities to get the skills they need to succeed. As those skills are acquired, new ideas multiply, and innovations emerge. Ahead of us lies a new emerald-green wisely. Car-based living on the urban age of cities, if we choose our policies edge will surely continue, but it will be accompanied by denser development close to the urban core. We can build taller towers that give people plenty of space in the heart of downtown,. - build them in a way that guarantee» environmental sustajnability and good sight lines and plenty of street life. We can make sure that everybody, not just I the privileged few, can enjoy the pleasures of Manhattan or Paris or Hong Kong. But to achieve all this, we must encourage but cities instead of sprawl. We must embrace the changes that drive great cities forward, instead of clinging to a stultifying status quo, No matter what we do, some people will never want an urban lifestyle. They will want, like Thoreau, to be surrounded by open space and green trees. No one who can afford such a bucolic life should be forced to live in a city. But far too many people live outside cities because of mistakes that our societies have made. We should not force urban growth, but we must eliminate the barriers that artificially constrain the blossoming of city life. Give Cities a Level Playing Field The central theme of this book is that cities magnify humanity's strengths. Our social species' greatest talent is the ability to Iearn from each other, and we learn more deeply and thoroughly when we're face-to-face. I have also tried

60 260 TRIUMPH OF THE CITY value on the innovative enjoyments that cities can provide. The bottom-up nature of urban innovation suggests that the best economic development strar, egy may be to attract smart people and get out of their way. But how can places become consumer cities and attract skilled residents? One vision, espoused by urbanist Richard Florida, emphasizes the arts, tolera_ tion for alternative lifestyles, and a fun, happening downtown. A second vision focuses on better providing the core public services that have always been the province of cities: safe streets, fast commutes, good schools. City leaders typically have scarce resources; they can't do everything for everybody. Even if one believes, as I do, that evely city should subscribe to a bit of each vision, there will always be the question of where to invest the revenues of city govenunent and the energy of its leaders. In a sense, the relative appeal of the two visions depends on whom you think of when you imagine an ideal citizen. The first vision, with its fondness for coffeehouses and public sculpture, seems aimed at a twenty-eight-year-old wearing a black turtleneck and reading Proust. The second vision, with its focus on core urban services, seems to address the needs of a forty-twa-year. old biotech researcher concerned aboatwhether her familywill be as comfortable in Boston as it is in Charlotte. There are roughly three times as many people in their thirties, forties, and fifties as there are in their twenties, so it would be a mistake for cities to think that they can survive solely as magnets for the young and hip. As much as I appreciate urban culture, aesthetic interventions can never substitute for the urban basics. A sexier public space won't bring many jobs if it isn't safe. AU the cafes in Paris won't entice parents to put their kids in a bad public school system. If commuting into a city is a lengthy torment, then companies will head for the suburbs, no matter how many cool museums the city has. The Curse of NIMBYism In cities and suburban enclaves alike, opposition to change means blocking new development and stopping new infrastructure projects. Residents are in effect saying "not in my backyard." In older cities like New York, NIMBYism hides under the cover of preservationism, perverting the worthy cause of pre-

61 rr. f! I HAT WORLfI, TAll CITY serving the most beautiful reminders of our past into an attempt to freeze vast neighborhoods filled with undistinguished architecture. In highly attractive cities, the worst aspects of this opposition to change are that it ensures that building heights will be low, new homes will be few, prices will be high, and the city will be off-limits to a11but rich people. Unfortunately, it is all too easy to understand why people oppose change: You've bought a house in a leafy suburb. Right now, there aren't a lot of homes there, and you like that. After all, that's why you bought. A neighboring landowner wants to put up twenty townhouses on her five acres efland. You're furious. That's not why you came to this town. You don't want the bother of the nearby construction or the extra traffic once the new neighbors move in. You want things as they were. You've bought an apartment on Manhattan's Upper East Side with lovely views. A developer wants to put up a high-rise across the street. You'd be able to see it from your apartment, and you don't want to lose your views. Also, you're not sure you'd like the new people who'd move into that building. You want the neighborhood to stayi1he way it was when you moved in. You want things as they were. You've lived in a Boston triple-decker for twenty years. A university wants to build a contemporary art museum on its land a few blocks away.you'll be able to see it from your apartment. You expect that the museum will attract many outsiders into your area. You don't much like contemporary art anyhow. You want things as they were. These are real-world examples of NIMBYism. Case by case, they couldn't be more comprehensible. Someone else is changing your neighborhood. You don't want to live in a denser, or tauer, or artsier place. You just want the status quo. What could be more reasonable than that? But N1MBYism that seems reasonable can often have terrible consequences. Stopping new construction may seem like a good idea to you, but it imposes costs on'everyone who would have liked to live in a new subdivision or apartment building. Stopping a new, privately funded museum deprives the city of an amenity that would have appealed to many residents and brought in tourists who would have contributed to the local economy. The interests of people

62 262 I TRIUMPH OF THE my who oppose change are certainly comprehensible, but their interests usually don't match the public interest. Moreover, in each of these cases, the angry neighbor doesn't even own the property that he wants to control The property owner with five acres Owns her land, as does the urban developer and the university. The enemies of change essentially want to control somebody else's property. From that vantage point, stopping growth isn't so much maintaining the status quo as it is taking someone else's rights and reducing the value of someone else's property. There are two powerful, interlocking psychological biases that lie behind the popularity of NIMBYism. The first is called status quo bias, which is an overly strong attachment to the current state of affairs. One set of famous experiments illustrating this bias shows that people wiil forgo far more money to keep a mug that they have been given than they will pay to buy the exact same mug. The second bias is impact bias, which causes people to significantly overestimate the impact that a negative shock will have on their happiness. The enemies of a new high -rise may think that the tower will make them miserable, but in reality, they will quickly adapt to the new situation. Over the -past forty years, we've experienced a Iittle-remarked revolution in property,lights in America. We have gone from a system wherein people could essentially do what they wanted with their own property to a system wherein neighbors have enormous powers to restrict growth and change. Some of this revolution in rights is for the better, but much of it is for the worse. Not all change is good, but much change is necessary if the world is to become more productive, affordable, exciting, innovative, and environmentally friendly. At the national level, we mistakenly oppose change when federal policies try to preserve older places at the expense of growing regions. At a local level, activists oppose change by fighting growth in their own communities. Their actions are understandable, but their local focus equips them poorly to consider the global consequences of their actions. Stopping new development in attractive areas makes housing more expensive for people who don't currently live in those areas. Those higher housing costs in turn make it more expensive for camp ames to open businesses. In naturally low-carbon-emissions areas, like California, preventing development means pushing it to less environmentally friendly places, like noncoastal California and suburban Phoenix. Local environmentalism is often bad environmentalism. "

63 ri! flat WORLD, TAll CITY 263 In older cities, preservationists can be the great enemies of change. They couch their arguments in terms of beauty and history. I respect their values enormously, but also believe their power must be checked. Many buildings must be protected, but cities also must grow to thrive. Striking the right bal~ ance between protecting architectural treasures and allowing change will never be easy. It's hard enough in San Francisco and New York, and it becomes even more complicated in places like Paris and Rome, where humanity's history is written in stone. The key is to make the most use of the space that is allowed to change. In no way do I favor running roughshod over the most important and beautiful structures in older cities, but in those areas where rebuilding is permitted, it makes sense to allow as much new development as possible. Smarter preservationisrn would push new buildings to be taller, not shorter. Building taller, newer structures would reduce the pressure to tear down other, older monuments. The importance of allowing change becomes particularly clear when America or anyplace else considers building new infrastructure. The same forces that have slowed private development of homes and apartment buildings have also made it far'.more difficult to construct urban megaprojects that could benefit cities ind society as a whole. In France, Germany, and Japan, highspeed rail service has connected major cities for decades. In 1994, Amtrak tried to bring such rail service to the United States with its Acela line. The Acela can reach speeds of 150 miles per hour, which would bring New York-to-Boston train service down to less than ninety minutes, making trains a speedy, ceofriendly alternative to plane service, However, NIMBYist politics keeps Amtrak from laying the straight track that would enable the Acela to reach those speeds. Its current, circuitous route keeps speeds down to an average of 86 miles per hour, and travel times between New York and Boston exceed three hours. In today's political climate, community opposition makes it impossible to straighten a route, even if the economic and environmental advantages of faster rail service outweigh the costs. I return every once in a while to the neighborhood where I grew up, on Sixty-ninth Street between First and Second avenues. Brownstones still line the street across from my old apartment building, as does a Magyar church that recalls the area's erstwhile ethnic identity. Would I be sad if those brownstones and that church were replaced by high-rise apartment buildings? Per-

64 264 TRIUMPH Of THE CITY haps. But those buildings would make it possible for many other chhdren to experience, as I did, the wonders of growing up in New York City. I'll take the side of people over buildings any day. In developing countries, the case against overregulation is even stronger. In rapidly growing places like Mumbai, height restrictions cause enormous damage by forcing people to spread themselves horizontally rather than vertically, which helps to create massive congestion. The last thing that Mumbai or any developing megacity needs is regulation that prevents the construction of good, usable real estate. Cities are the path out of poverty, and preventing urban growth makes developing countries artificially poor. The Bias Toward Sprawl Over the past century, tens of millions of people have left cities for suburbs.. As much as I love cities, I can't fault their choice. I suburbanized too. But I can fault a system that stacks the deck against cities and creates artificial inducements to leave urban areas. I've already discussed the problems that come from expecting cities' richer residents to pay (or the needs of the poorer ones. An antiurban bias is even more obvious in housing and transportation policy, which seems almost intentionally designed to hurt the cities that enrich their countries and the entire world. The centerpiece of federal housing policy is the home mortgage interest deduction, which allows home owners to deduct from their taxes the interest on up to a million dollars of mortgage debt. Because more than 60 percent of Americans are home owners, this policy has become politically inviolate, but it is deeply flawed. The home mortgage interest deduction is a sacred cow in need of a good stockyard. It encourages Americans to leverage themselves to the hilt to bet on housing, which looks particularly foolish in the wake of the great housing bust of s. Subsidizing home ownership actually pushes up housing prices by encouraging people to spend more. And the deduction's benefits accrue overwhelmingly to the richest Americans. The average deduction for American families earning more than $250,000 is more than ten times higher than the average deduction for American families earning between $40,000 and $70,000. Environmental concerns should push toward a tax policy that encourages

65 flat WORLD, TALL my 265 thrifty living in modest residences. The home mortgage interest deduction pushes us in the opposite direction, encouraging people to buy bigger homes, which are often suburban. The post-world War II move to enclaves like Levittown and The Woodlands was fueled by pro-horne-ownership tax policies. I'm happy for people to enjoy the pleasures oflarge houses on large lots, but there is little reason why federal tax policy should subsidize those who buy big. A simple way to ease this problem without harming middle-class Americans would be lowering the upper limit on the home mortgage interest deduction to some more modest figure, like $300,000. The home mortgage interest deduction is part of a seventy-year-old federal push toward home ownership. Government-sponsored enterprises like Fannie Mae and Freddie Mac long received implicit and now receive overt federal funding to encourage the mortgage market. The Federal Housing Administration and the Veterans Administration have long encouraged Americans to buy their own homes. While there are some social benefits of home ownership, subsidizing ownership hurts cities. Home owners do vote more and get involved solving local problems-and they own more guns. Maybe these things are worth. subsidizing, but surely it makes moresense to subsidize any desirable activities directly rather than encouraging people to borrow as much as possible to bet on housing markets. The great housing crash of well illustrates the folly of pushing people to wager all they have and more on the vicissitudes of property markets. The high price of urban land leads naturally toward multiunit dwellings, and 85 percent of such dwellings are renter-occupied. It is possible to have owner-occupied cooperatives and condominiums, but those complex ownership structures create their own difficulties, which is why they remain relatively rare. As long as owner-occupied housing remains disproportionately nonurban, then subsidizing ownership will hurt cities. President Obama is the first urban president since Teddy Roosevelt, but the infrastructure component of the 2009 stimulus bill was as stacked against urban America as most of America's previous infrastructure spending. Per capita stimulus spending from March to December 2009 was twice as high in America's five least densely populated states as in the rest of the country. Perhaps this fact shouldn't surprise us, for those five states control 10 percent of the Senate with only 1.2 percent of the population. But that doesn't make the

66 .~.--~ 266 I TRIUMPH OF THE CITY disproportionate flow of resources to less dense areas any more sensible, especially as this was supposed to be antirecessionary spending and the fiveleast dense states managed to sit out the recession with an average unemployment rate of 6.4 percent, as of December Over the last twenty years, transportation funding for the ten most densely populated states has been half as much, on a per capita basis, as funding for the ten least dense states. In the stimulus package, which uses the old formula, the ratio is the same. We're using our infrastructure money more to make rural America accessible than to speed the flows of people within dense urban areas. Yet slow commutes are far more likely in big crowded cities than in lowdensity areas. The average commute in the ten largest metropolitan areas takes 20 percent longer than in the country as a whole. As the White House Office of Management and Budget writes of the federal highway program, "funding is not based on need or performance and the program has been heavily earmarked:' In the 19505, the interstate highway program made it much easier for people to flee cities. By continuing to subsidize low-density areas, transportation spending continues to entice people away from urban America. ft) Granted, transportation spending in urban areas is difficult. Large urban projects are extremely expensive. As the famed battle over the Lower Manhattan Expressway between Jane Jacobs and master builder Robert Moses reminds us, building where people already live invariably involves far more community opposition than building in green fields. Moreover, far too many urban transportation projects have gone into declining cities that don't need more infrastructure. After all, the defining feature of such cities is that they have lots of structure relative to people. We need to build in ways that make increasingly crowded cities more functional. The difference between good projects and follies like Detroit's People Mover is that good projects create tangible benefits for large numbers of users. Bad projects just create patronage opportunities and rewards for developers. People who support the disproportionate flow of transportation money into less dense areas argue that these areas deserve the largesse because they're paying more in gas taxes, the chief source of federal funds for transportation. If that's the case, then more dense areas should be better compensated for paying more income taxes. Over half of American income is earned in twenty-

67 flat WORLD, TALL mv two metropolitan areas. If the federal government apportioned money based on tax revenues, big cities would be getting a lot more federal money. But unlike the argument for giving cities back more of the money they pay in income taxes, the argument for giving gas-guzzling states more transportation dollars is faulty on its face. One of the primary reasons for the gas tax is to make drivers bear some of the social costs of their road use. Basic economics tells us that if drivers increase pollution and congestion, they should be charged for those costs. But if the gas taxes they pay are then plowed back into highways, thereby subsidizing more driving, then the benefits of the gas tax largely vanish. To give cities a level playing field, drivers should be charged for the pollution their gas usage causes, and they shouldn't form of more roads. To create the right externality-relieving get that money back in the gas tax, we need to know exactly how much damage drivers inflict on other people through pollution, traffic fatalities, and congestion. One recent article added together all of these costs and came up with a figure of $2.30 a gallon, which suggests that current u.s. gas taxes are too low, but European gas taxes may be too high. If America moved toward the European model, certainly more of sprawl's denizens would start thinking that compact living made more sens/ Ending the antiurban bias of federal policies also means charging suburban drivers for the environmental costs of their actions. Even the income 'tax can be seen as a tax on big-city life. Earnings are higher inbig cities because people are more productive there. By taxing higher earnings, we make the simple life of nonmetropolitan areas more attractive. Income taxes essentially make it less attractive to earn more, and people earn more in cities, I am not suggesting that we should do away with the income tax, but it does make sense to limit the antiurban effects of the tax. More tax revenues should flow back to the areas that paid those taxes. Taxing cities to build up rural America is a foolish policy that hurts our urban engines of prosperity. Green Cities One of the costs of subsidizing sprawl is that America's carbon emissions are higher than they should be. Cities are green. Living at high densities and walk-

68 268 TRIUMPH OF THE {lty ing is a lot more envirorunentally friendly than living in a low-density suburb and driving everywhere, America's failure to have a sensible environmental policy that charges people for the environmental costs of their actions also creates a dangerous antiurban bias, People who like suburbs should be able to live there, but their choice should be based on the true costs and benefits of suburbanization. Suburbanites USe much more energy and emit much more carbon than urbanites. The need to price carbon emissions appropriately is particularly important in places li1ce India and China, whose lifestyle decisions will determine the world's future carbon emissions. The most straightforward way to address climate change is a simple carbon tax, If energy users are taxed for the social costs of their actions, then they'll use more fuel-efficient cars and live in more energy-efficient houses. They'll also find energy-conserving big-city life more appealing. By not taxing energy use properly, we are implicitly subsidizing energy-intensive suburban lifestyles and pushing people out of cities. Over the next forty years, India and China will continue to urbanize rapidly. Their decisions about land use will ~ave a huge impact on energy consumption and carbon emissions, If they live at high densities and use public transit, then the whole world will benefit. If they sprawl, then we will all suffer from higher energy costs and higher carbon emissions. One important reason the West must shrink its own carbon footprint is to reduce the hypocrisy of telling India and China to be greener while driving our SUVs to the mall. Gifts of the City Our cities' gleaming spires point to the greatness that mankind can achieve, but also to our hubris. The recent recession reminds us painfully that urban innovation can destroy value as well as create it, Any downturn challenges the world and its cities. As trade and financial marketscontract, urban areas suffer. As tax revenues decline, cities must struggle to provide basic services. Rising unemployment levels burden those services further, especially in the cities that are already poor. Yet our urban future remains bright. Even the Great Depression failed to

69 flat WORLD, TAll CITY 269 dim big-city lights. The enduring strength of cities reflects the profoundly social nature of humanity. Our ability to connect with one another is the defining characteristic of our species. We grew as a species because we hunted in packs and shared our kills. Psychologist Steven Pinker argues that group living, the primitive version of city life, "set the stage for the evolution of humanlike intelligence:' We built civilizations and culture together, constantly learning from one another and from the past. New technologies from the book to Google have failed to change our fundamentally social nature. They've made it easier to learn some things without meeting face-to-face, but that hasn't eliminated the extra edge that comes from interacting in person. Indeed, since new technologies have increased the returns from new ideas, they have also increased the returns from face-to-face collaboration. During the late twentieth century, declining transportation costs eliminated the former production advantages of the great industrial cities. The car moved Americans to suburbs and to car-based cities in the Sunbelt, These events traumatized many older urban areas, yet they did not sound the city's death knell The advantages of being close to other humans are just too great. China's leadersseem to understand that high densities'will enable their once poor country to "become rich. They seem to getthe fact that tall towers enhance productivity and reduce environmental costs, If China embraces height rather than sprawl, the world's carbon emissions will be lower, the planet will be safer from global warming, and China will be less dependent on the oil-producing nations of the Middle East. India's future will also be urban, but the shape of its urban areas is harder to predict. Indian cities have so far embraced the worst aspects of English land-use planning, leading to short buildings and dispersed populations. The costs that this model imposes on India are so enormous that the subcontinent may well be forced to abandon its antipathy toward high -density construction. If India and China both become highly urban civilizations, then American suburbs will begin to look like an exception rather than a prognosis of the world's future. I suspect that in the long run, the twentieth-century fling with suburban living will look, just like the brief age of the industrial city, more like an aberration than a trend. Building cities is difficult, and density creates costs as well

70 270 I TRIUMPH OF THE CITY as benefits. But those costs are well worth bearing, because whether in London's ornate arcades or Rio's fractious favelas, whether in the high-rises of Hong Kong or the dusty workspaces of Dharavi, our culture, our prosperity, and our freedom are all ultimately gifts of people living, working, and thinking together-the ultimate triumph of the city.

71

72 l.!jirs.ch IGIREEN Hirsch/Green Transportation Consulting, Inc. March 28, 2011 Mr. R. J. Comer Armbruster, Coldsmith & Delvac San Vicente Boulevard, Suite 900 Los Angeles, California RE: Recommended Parking Supplies for Residential Developments in Southern California Dear R J., Per your request, we have researched the available data regarding parking utilization and/or parking demands for residential developments located within the Southern California region, in order to identify the likely parking needs of the proposed mixed-use residential/commercial project proposed for the southwest corner of the intersection of Hollywood Boulevard and Gower Street, in the Hollywood community of the City of Los Angeles. As you know, that project will contain a total of approximately 176 residential apartment units and a total of approximately 7,200 square feet of ground floor retai'l area. The project proposes to provide a total of approximately 345 on-site parking spaces, including 264 resident-only spaces, an additional 44 residential guest parking spaces, and 36 commercial (retail) parking spaces. Based on these parking supplies, the project will result in an average parking provision of approximately 1.75 spaces per residential unit (1.50 resident-only spaces per unit plus an additional 0.25 residential guest parking spaces per unit), and approximately 5..0 spaces per 1,000 square feet for the proposed commercial areas. The parking provi.ded will meet the City's current requirements for residential apartment parking as identified in Section of the City of Los Angeles Municipal Code ("LAMC"), and will exceed the 4.0 spaces per 1,000 square feet required for the proposed retail component of the site. As a result, the project is not expected to result in any parking deficiencies, and no parking-related impacts or "overflow" into adjacent commercial or residential areas is anticipated. However, in order to provide some assurance to the City and surrounding community that the amount of parking provided, particularly for the proposed residential component of the project, is adequate to meet the actual parking demands of the project, we have prepared the following brief assessment of both recommend residential parking ratios, as identified by the Urban Land Institute ("ULI'') and the Institute of Transportation Engineers "ITE"), and of actual residential development parking demands, based on surveys of existing and operating residential projects in the region; these surveys were performed by Fehr& Peers, and by Darnell and Associates, and are documented in a study prepared in 2001 by Kaku Associates for the California Coastal Commission. The referenced data and reports are contained in attachments to this letter Ventura Boulevard, Suite 204 Sherman Oaks, California Phone Fax 81 B

73 Letter to Mr. R. J. Comer March 28, 2011 Page 2 of 3 A summary of the attached information indicates that, in general, residential for-rent units exhibit total parking demands, including both resident-only and residential guest usage, of between about 1.15 and 1.65 spaces per unit. The Kaku Associates study prepared for the California Coastal Commission features empirical parking utilization counts performed at a number of sites within the Cities of San Diego (3 sites), Long Beach (4 sites), Marina del Rey (2 sites), and Santa Monica (2 sites) in 2001 and 2008, and references additional data collected by Darnell & Associates at seven additional sites in San Diego in The Fehr & Peers data shows parking demands ranging from approximately 0.66 to 1.59 utilized parking spaces per occupied unit, although the lower end of the range of data is considered to somewhat anomalous, since it consists primarily of studio and t-bedroorn units; the remaining surveyed sites contain a more typical ratio 1, 2, and 3-bedroom units; breakdowns of the unit mix for the seven apartment complexes surveyed as part of the supplemental Darnell & Associates information is not provided, although the data summarized in that document identifies a range of between 1.15 to 1.52 utilized spaces per occupied dwelling unit. The ULI parking demand information referenced is provided in the 2 nd Edition of Shared Parking (2005), which identifies a typical parking demand for for-rent residential units of approximately 1.65 spaces per unit, including approximately 1.50 spaces per unit for resident-only use and an additional 0.15 spaces per unit provided for guests. The ULI data described above is, in turn, based on research conducted by ITE, and published in the 3 rd Edition of Parking Generation (2004). The ITE parking recommendations are based on data collected at seven "high-rise" (five or more floors) apartment developments (Land Use 222) within a "central city" environment (not downtown) that provides conditions similar to the densely developed Hollywood area surrounding the proposed Hollywood & Gower project. The ITE data identifies an average peak parking utilization of 1.37 spaces per unit within a range between 1.15 and 1.52 occupied spaces per dwelling unit; the 85 th percentile data parking demand is 1.52 spaces per unit. Therefore, based on the empirical data for actual parking utilizations at a total of 18 residential developments in the Southern California region, and supplemented by the nationally recognized parking recommendations provided by both the Urban Land Institute and the Institute of Transportation Engineers, the peak parking demands for residential units within a typical urban environment can be expected to be approximately 1.59 spaces per dwelling unit, including both resident-only and residential guest parking. However, the highest parking recommendation is identified by ULI, which recommends a total of approximately 1.65 spaces per unit, including approximately 1.50 resident-only spaces and 0.15 guest parking spaces per unit The proposed Hollywood & Gower project will provide a total residential parking supply of 1.75 spaces per dwelling unit, including 1.50 resident-only and 0.25 guest parking spaces per unit, matching the ULI's resident-only parking space recommendations, and at 0.25 guest spaces per unit, provides approximately 67 percent more residential guest spaces than noted by UU.

74 Letter to Mr. R. J. Comer March 28, Page 3 of 3 It should also be noted that the parking ratios and recommendations noted in the attached empirical and theoretical recommendations do not reflect a high degree of public transit utilization. Although some transit opportunities are available for many of the surveyed sites, it does not appear that this factor significantly influences the number of vehicles owned or utilized by residents of the subject residential devel.opments. Therefore, although the Hollywood & Gower project is located within a transit-rich environment, and is expected to exhibit reduced vehicle ownership and utilization as a result, the attached data indicates that even if such reduced vehicle ownership does not occur, the project will still provide adequate on-site residential parking to meet even the highest anticipated parking demands, Further, as noted earlier, the project will provide parking for the commercial components of the site (approximately 7,200 square feet of ground floor retail space) at a ration of 5.0 spaces per 1,000 square feet of floor area, or approximately 25 percent more parking than is required by the LAMC. As a result, the project will provide more than adequate on-site parking, and no residential or commercial parking shortages or "overflow" into any nearby parking areas is anticipated. Please review the above and attached information, and as always, feel free to call me if you have any questions or comments. Attachments Sincerely, ~~~---2/' ~----=, ~/~~ Ron Hirsch, P.E. Principal

75 ATTACHMENTS

76 Kaku Assoclates/Darnell & Associates Study

77 RESIDENTIAL PARKING DEMAND STUDY SOUTHERN CALIFORNIA COASTAL ZONE JUNE 2001 PREPARED FOR CALIFORNIA COASTAL COMMISSION PREPARED BY A CorporationKUASSOCI/\TES

78 RESIDENTIAL PARKING DEMAND STUDY SOUTHERN CALIFORNIA COASTAL ZONE June 2001 Prepared for: CALIFORNIA COASTAL COMMISSiON Prepared by: KAKU ASSOCIATES, INC Third Street, Suite 400 Santa Monica, California (310) Ref: 1338

79 TABLE OF CONTENTS Executive Summary I. Introduction 1 Study Purpose... 4 Methodology... 4 II. Parking Survey Results 6 Survey Results... 6 Dwelling Unit Size 12 III. Background Data 13 Demographics 13 Parking Zoning Codes 14 Recent Project Approvals Parking Counts in San Diego 17 IV. Summary. 20

80 LIST OF FIGURES 1 Parking Supply and Demand Survey... ii 2 Site Location 2 3 Proposed Site Plan... 3 LIST OF TABLES NO. 1 Southern California Coastal Zone Residential Parking Survey Parking Zoning Code Requirements - California Cities 15 3 Parking Occupancy Count Results - Residential Developments in San Diego, California 19

81 EXECUTIVE SUMMARY The Genesis Real Estate Group is proposing to build a residential development at 350 East Ocean Boulevard in downtown Long Beach, California. The project proposes to serve this development with 1,008 parking spaces - a ratio of 1.81 spaces per dwelling unit The City of Long Beach's Local Coastal Plan LCP) calls for a parking ratio requirement of 2.16 spaces per dwelling unit The LCP parking standard was adopted almost 20 years ago - prior to the introduction of significant job growth and transit improvements in downtown. The City granted a parking variance and approved the project in March The California Coastal Commission has asked for additional backup regarding the parking demand patterns in dense residential developments. Detailed parking counts were conducted at midnight on a weekday (the peak parking time of the day) at 11 apartment and condominium complexes in the Coastal Zone. The sites were located in San Diego (3 sites), Long Beach (4), Marina del Rey (2) and Santa Monica (2). The peak parking demand at these 11 sites ranged from 0.66 to 1.59 spaces per occupied dwelling unit (sp/du). Figure 1 compares the parking supply and peak parking demand at the 11 study sites to the proposed parking supply at the proposed 350 East Ocean project. As can be seen, the 1.81 sp/du parking supply at the project would be more than sufficient to meet the parking demand at any of the 11 test sites. Seven additional high-density apartment complexes in San Diego were the subject of detailed parking occupancy surveys by Darnell & Associates in These surveys showed peak parking demands of 1.15 to 1.52 sp/du. Again, the parking supply proposed for the 350 East Ocean project would be more than sufficient to meet the demand at any of these sites.

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83 The projects that had the highest proportion of small units (Le., studio or one-bedroom units) had the lowest parking demands among the sites studied. With 64% of its units configured as one-bedroom apartments, the proposed 350 East Ocean project would be expected to experience parking demand rates in the lower end of the 0.66 to 1.59 range measured in the 18 study sites. The parking requirement for the Long Beach Local Coastal Plan was adopted over 20 years ago. Since the adoption of the required 2.16 sp/du standard, downtown Long Beach has added transit service (Metro Blue Line light rail transit, free Passport shuttle service and the Downtown Transit Mall) and thousands of downtown jobs. In the 20 years since the adoption of the LCP parking standard, the trends toward later marriages, fewer children and increased preference for living without roommates all combine to reduce on-site population density. In fact, 26% of all households in the United States are now single-person households - the highest proportion in the history of the country.' These factors result in reduced on-site parking demand, as seen in all 18 sites surveyed. Detailed parking surveys at 18 high-density residential sites in Southern California showed peak parking demand patterns significantly less than the supplies required by the Local Coastal Plan. The proposed project at 350 East Ocean in downtown Long Beach would provide a parking supply of 1.81 spaces per dwelling unit. This parking supply would more than adequately serve the parking demand found at any of the 18 sites studied. No spillover parking onto the adjacent streets would be expected. The results of this study show that the proposed parking supply at the 350 East Ocean residential project would provide more than enough parking to meet its peak parking demand. Adding more parking to the proposed supply would not increase the parking supply available to the general public visiting the California coastal resources because additional spaces would be private, reserved (but empty) spaces allocated to the residential apartments in the development. 1 The Old Neighborhood: What We Lost in the Great Suburban Migration: , Ray Suarez, Senior Correspondent, The NewsHour with Jim Lehrer, 2000 iii

84 I. INTRODUCTION The Genesis Real Estate Group is proposing to build a residential development at 350 East Ocean Boulevard in downtown Long Beach, California. Figure 2 shows the location of the project and Figure 3 provides a schematic of the site plan. The project would consist of two i8-story apartment buildings providing 556 dwelling units (du) according to the following unit types: 1 Bedroom 1 Bedroom w Study 2 Bedrooms 3 Bedrooms 297 du 60 du 189 du 10 du TOTAL 556 du The project proposes to serve this development with 1,008 parking spaces - a ratio of 1.81 spaces per dwelling unit. The City of Long Beach's Local Coastal Plan LCP) calls for a parking ratio requirement of 2.16 spaces per dwelling unit. The LCP requires 2.0 spaces per dwelling unit plus one guest space per every 6 dwelling units. Under this calculation, the project would be required to provide a total of 1,205 spaces to be consistent with Code requirements. It should be emphasized that the LCP parking standard was adopted almost 20 years ago. It was adopted prior to the development of the Downtown Transit Mall, prior to the operation of the Passport (Long Beach Transit's free downtown shuttle), prior to the opening of the Metro Blue Une light rail line connecting downtown Long Beach with downtown Los Angeles and prior to the creation of literally thousands of jobs in downtown Long Beach. Given the number of significant changes that have taken place in downtown Long Beach over the past 20 years, the code itself is outdated and needs to be updated. 1

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87 The project sought a parking variance based on actual parking demand experience at other Long Beach Coastal Zone residential developments and based on the changed conditions in downtown as described above. The City granted the parking variance and approved the project in March The California Coastal Commission, however, has asked for additional backup regarding the parking demand patterns in dense residential developments. Specifically, the Commission asked that other urban residential developments in Southern California be studied to measure 1) the parking supply and 2) the actual parking demand. STUDY PURPOSE This report summarizes the results of parking studies conducted at dense residential developments in or immediately adjacent to the Coastal area in Southern California. Each residential development was visited late at night on a weekday to count the total number of spaces and the number of occupied spaces. Based on previous residential studies in Long Beach, the highest overall parking demand occurs on a weekday night. METHODOLOGY Residential developments in downtown San Diego, Long Beach, Santa Monica and Marina del Rey were surveyed to determine appropriate properties for study. These urban areas were selected because of their similarity to downtown Long Beach. San Diego has light rail transit similar to the proposed project site in Long Beach while Santa Monica and Marina del Rey are served by extensive bus systems. City Planning/Redevelopment Departments were contacted for suggestions of candidate locations and field surveys were conducted in all four locations to identify prospective study locations. Over 40 developments were contacted to seek their cooperation and participation in the study. Of the locations contacted, 11 sites agreed to allow field crew late-night access to their parking garages for the purpose of collecting parking inventory and occupancy data. Each of these projects also agreed to divulge their dwelling unit breakdown and their lease/sale occupancy levels. Each project asked to remain anonymous. 4

88 The sites for the detailed parking counts were located in the following areas: San Diego 3 Long Beach 4 Marina del Rey 2 Santa Monica 2 TOTAL 11 These locations were selected because they are urban areas with transit service and urban amenities similar to those available to the proposed project in Downtown long Beach. All of the sites were located in the Coastal Zone except for one San Diego site and one Long Beach site. These two sites were located in the downtown areas of these two cities, but in both cases the projects were located within two blocks of the Coastal Zone. Thus, the sites selected should represent the parking demands of the proposed project. While the Urban Land Institute studies showed that there is no seasonal variation in residential parking demand, the parking counts summarized in this report cover three different months of the year - May, November and December. 5

89 II. PARKING SURVEY RESULTS The eleven sites selected for detailed study are summarized in Table 1. The sites range in size from 88 dwelling units to 532 units, with both the largest and the smallest site located in Santa Monica. All but one of the sites were virtually fully occupied with occupancy rates over 94%. partially occupied site in San Diego is a new development that is still being leased. The SURVEY RESUL TS Table 1 summarizes the results of the parking surveys. The parking inventory and occupancy counts are shown for each of the sites. San Diego ~~Sites A. Band C Sites A and B are located along the waterfront on Pacific Highway or Harbor Drive. Site A is a relatively new apartment development primarily made up of studio and t-bedroorn units. It provides 1 parking space per unit in a secured parking garage under the residential units. In terms of peak parking demand, the nighttime count showed a parking demand of 0.66 spaces per occupied dwelling unit. Site B is a condominium site with a higher proportion of 2- and 3-bedroom units. It experiences one of the highest parking demand rates of 1.43 spaces per occupied dwelling unit. This site in only 60% occupied as it is a new site with condo sales underway. The first units in the building are actually generating parking demand at a rate higher than the overall parking supply for the project (1.43 sp/du demand for the first 193 units VS. an overall supply of 1.35 sp/du for the entire 321 units). The management of the building expects the parking demand to fall within the provided supply as the building fills. For the moment, however, the parking demand measured represents an 6

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91 unconstrained demand because there were 198 empty parking spaces during the peak occupancy count. Site C is an apartment development located in the Gaslamp District of Downtown San Diego. It has a high proportion of studios and t-bedroom rental apartments and it provides 1.26 spaces per dwelling unit in a self-contained, secure garage on the site. Its peak parking demand represents a ratio of 0.77 spaces per occupied dwelling unit. Long Beach - Sites D, E, F and G The Long Beach counts included both weekday late night counts and Saturday evening counts in order to identify the peak parking patterns for residential developments. It was thought that the peak demand might occur on Saturday evening when guest parking at the development was at its peak. However, the peak parking demand for all three sites surveyed occurred during the late weeknight night count when the highest amount of residential parking demand occurred on site. Site 0, a 160-unit condominium located approximately one-half mile outside of downtown Long Beach along Ocean Boulevard, is fully occupied. Located on the south side of Ocean Boulevard, the site has a 248-space parking garage with 244 of the spaces located in a parking garage under the building. Access to the garage is restricted to residents. Guests are permitted into the garage only after checking in with the Concierge. The project provides a supply of 1.55 spaces per dwelling unit The late Friday night count showed a peak parking occupancy of 148 spaces spaces per dwelling unit. The Saturday evening count showed virtually the same guest parking demand, but the resident demand was lower at 7pm than it was at 1am (114 vs. 136 resident spaces occupied). Thus, the Saturday evening count showed an actual demand of 0.78 spaces per occupied dwelling unit. 8

92 The largest of the Long Beach sites, Site E is a 220-unit condominium development on the ocean side of Ocean Boulevard in downtown. The site provides a parking supply of 529 spaces - a parking ratio of 2.40 spaces per dwelling unit. The project has 52% of its condos in two-bedroom units as compared to only 36% large units in the proposed 350 East Ocean project. This project has a large guest parking area that is accessible without passing through a control point. The guest area is monitored by closed circuit television to the security guard desk in order to prevent unauthorized use of these spaces. All residential spaces are located behind a control gate. The parking occupancy surveys showed a peak parking demand of 294 spaces (1.36 spaces per occupied du) during the late Friday night count. The Saturday evening count showed an increased demand of 11 guest spaces, but the resident parking demand was lower than during the late Friday night count. The parking supply for Site F is a 397-space parking garage shared by the residential units and by general visitors to the restaurants and retail shops in the Pine Street area. There are 212 spaces reserved for the residents of the project - a parking ratio of 1.49 spaces per dwelling unit. These spaces are either located behind gates or on the midlevel of the garage (prior to the gates) but marked by "Reserved for Resident Parking" signs. The remaining spaces in the garage serve residential guests or serve general visitors to downtown Long Beach. This garage participates in the downtown visitor parking validation program. The Friday late night count showed 114 occupied residential spaces (0.83 spaces per occupied du). During this same time period, there were 60 parking spaces occupied in the shared parking visitor area. Assuming that all 60 of these vehicles were associated 9

93 with the residential units and that none of the spaces was used by visitors to the retail/restaurants in downtown (a very conservative assumption), the peak parking demand would be 1.26 spaces per occupied dwelling unit. There were 33 fewer resident spaces filled during the 7pm Saturday count. The public area of the garage (Le. the visitor area) was more active during the 7pm count with 76 spaces filled. Even if the highest public parking demand was added to the highest resident parking count, the parking demand would be 1.38 spaces per occupied du - well below the parking supply ratio proposed for the 350 East Ocean project. This calculation assumes that ill! of the vehicles parked on the upper levels of the garage are visitors to the residential units and none of the occupied general parking spaces are serving the visitors to downtown Long Beach - a situation not likely to be the case. Site G is a 266-unit apartment building located a few blocks east of downtown on the south side of Ocean Boulevard. The site has a parking supply of 292 spaces, for a parking ratio of 1.10 spaces per dwelling unit if all the units in the building were considered. However, not all of the 266 units are eligible to be served by the 292-space parking supply. The 82 efficiency units in the building are not allocated any parking spaces, and therefore the effective parking ratio for the building is 1.59 spaces per dwelling unit (292 spaces/ and 2-bedroom units). The manager stated that the 1- and 2-bedroom units have been offered parking and that they do not reserve all the spaces in the garage. Therefore, some of the efficiency units in the building are offered spaces on a monthly basis within the garage because larger units do not use all the spaces. The management of this development would not allow our field crew into the building to conduct actual occupancy counts. He said that the garage was "full" at night. If the garage was indeed 100% occupied at night (a condition we did not find in any of the other 17 locations studied), the peak parking demand would fall between 1.10 and

94 spaces per dwelling unit. Since the larger units are not using all of the spaces, the parking demand for these larger units is less than the 1.59 spaces per unit provided. Marina del Rey - Sites H and I Site H is a 224-unit apartment complex located on the marina. It provides 332 on-site spaces in a parking garage located under the apartment buildings. In addition, 19 guest spaces are provided outside of the garage at the entry to the complex. The parking supply ratio is 1.57 spaces per dwelling unit while the resulting parking demand experienced at the site is 1.22 spaces per occupied dwelling unit. Site I is located along Via Marina immediately across the street from the waterfront. It provides 351 spaces on-site in a garage under the apartments for a parking supply ratio of 2.09 spaces per dwelling unit. The parking occupancy counts showed a peak parking demand of 1.42 spaces per occupied dwelling unit. Santa Monica - Sites J and K Sites J and K represent the smallest and largest sites surveyed, respectively. Site J is an 88-unit condominium that provides only two-bedroom units. The secure parking garage under the building provides 192 parking spaces - two for each unit plus one guest space for every six units. The resulting supply ratio is 2.18 spaces per dwelling unit. The peak parking demand at this development showed a parking demand of 126 spaces, for a parking demand ratio of 1.43 spaces per occupied dwelling unit. Site K is a 532-unit apartment building with 62% of the units consisting of 1-bedroom apartments - a ratio very close to the proposed 350 East Ocean proposed project. Site K provides 700 parking spaces for a parking supply ratio of 1.32 spaces per dwelling unit. With 455 cars parked in the garage at the peak time, the project experiences a parking occupancy rate of 0.91 spaces per occupied dwelling unit. 11

95 DWELLING UNIT SIZE The proposed project at 350 East Ocean would have 64% of its units configured as 1- bedroom units. Of the sites surveyed, those developments with the highest proportion of studio and t-bedroorn units, along with their corresponding parking demand ratios, are as follows: Site % Studio and 'l-bedrocm Peak Parking Demand Proposed 350 East Ocean 64% A 92% 0.66 sp/du C 86% 0.77 sp/du H 65% 1.22 sp/du L 62% 0.91 sp/du As can be seen, the residential developments with the highest proportion of small units (Le., studio and t-bedroorn) have the lower parking demand ratios among the surveyed sites. With the proposed project at 350 East Ocean Boulevard having 64% small units, the proposed parking supply of 1.81 spaces per dwelling unit will be significantly higher than the demand patterns of any of the other developments with comparable small unit makeups. 12

96 II!. BACKGROUND DATA The data presented in the previous chapter suggests that the required parking supply in residential developments in the Southern California Coastal Zone does not have to be 2.16 spaces per dwelling unit in order to satisfy the on-site parking demand of these developments. The Coastal Zone parking requirements were established for the Long Beach Local Coastal Plan over 20 years ago. This chapter discusses some of the demographic changes that have taken place over that time period and compares the LCP requirement for residential parking with other code requirements. DEMOGRAPHICS The demographics of a region and/or a market shape the residential projects that serve that market. High-density projects attract young single people and older couples whose children have left home. Therefore, the need for larger units with their higher parking requirements is reduced. In the approximately 20 years since the Long Beach LCP has been developed, the trend is toward later marriages and families with fewer children. These factors lead to more (and older) single people and smaller families - all resulting in a reduction in parking demand over conditions prevalent 20 years ago. In the last 10 years, the growth in the economy and changes in individual preferences have led to a lifestyle where people prefer to not have roommates. This leads to a greater demand for one-bedroom units (occupied by one person) and a higher use of two-bedroom units by a single person who uses the second bedroom as a study, home office, weekend bedroom for a child in custody, or a guest bedroom for an occasional visitor. All of the above factors influence the size of units (with more small units being built), the density of habitation (with more single people occupying a one- or even two-bedroom unit) and the amount of parking needed to serve the new demographic. 13

97 PARKING ZONING CODES Many cities have recognized the trend toward smaller units and reduced number of people per unit and have adjusted their parking requirements accordingly. San Diego, San Francisco, Chicago and New York have reduced the on-site parking requirement for residential in order to encourage and support the development of transit in their downtowns. Table 2 shows a summary of parking zoning code requirements for selected California cities and counties. The parking requirement for each size unit is shown along with the requirement, if any, for additional guest parking. Also shown in the final column is a calculation of the parking requirement for the 350 East Ocean project if it were built under that code. The proposed parking supply for 350 East Ocean project in Long Beach would exceed the zoning code requirements in 36 cities and counties in California. Other major cities across the United States have revised their zoning codes to reduce the amount of on-site parking for residential developments, such as: Fort Lauderdale, Florida Dallas, Texas (Urban District) Dallas, Texas (Remainder) Seattle, Washington Tucson, Arizona Chicago, Illinois Salt Lake City, Utah No Parking Required 1.0 space per du 1.5 spaces per du spaces per du depending on the location within the City 1.25 spaces per du 1.0 space per du space per du Clearly the trend is to match the parking supply with the actual demand, and the parking zoning code requirements are being reduced to reflect lower parking demands. 14

98 TABLE 2 PARKING ZONING CODE REQUIREMENTS -. CALIFORNIA CITIES CITY PARKING SPACES REQUIRED PER UNIT (1) RESULTING SPACES REQ'O STUDIO 1 BR 2BR 3 BR GUEST FOR 350 E OCEAN Daly City a 934 Fairfield Fresno a 834 Hawaiian Gardens Hayward Irvine La Mirada a 934 Los Angeles Napa Newport Beach Oakland a 834 Oceanside Palm Springs Pasadena Redlands a 661 Richmond Riverside Riverside County Sacramento Salinas San Buenaventura San Diego CBD San Diego County San Francisco a 556 San Jose San Luis Obispo County Santa Barbara County Santa Maria Santa Monica ,002 Santa Rosa a 939 Stockton Thousand Oaks Vallejo Visalia West Hollywood Westminister (1) Source: California Parking Standards for Selected Cities and Counties, Walker Parking Consultants, June

99 RECENT PROJECT APPROVALS San Diego San Diego has over one dozen residential projects under construction or recently approved for construction in Downtown. Most are in or very near the Coastal Zone. These developments are following the City's Zoning Code that requires a minimum of 0.5 spaces per unit, but only allows a maximum of 1 space per unit for t-bedroorn and 2 spaces per unit for 2 or more bedrooms. Given the mix of small units in the downtown projects, all of the new developments are being constructed with parking ratios less than the 1.81 spaces per dwelling unit proposed by the 350 Ocean project in Long Beach. As an example of the downtown San Diego projects now underway, Camden Development Company is constructing a six-floor, 160-unit project near the wharf. The project will contain 133 t-bedroom and 27 2-bedroom units. The parking supply for the project will provide 210 parking spaces for the tenants and guests - a parking ratio of 1.31 spaces per dwelling unit. Long Beach Recent residential projects proposed in downtown Long Beach have been approved with on-site parking ratios lower than the Coastal Zone parking requirements. The Park at Harbour View, by Camden Development, on Ocean Boulevard proposes a mixed-use project with apartments, condominiums, retail, restaurant, office and hotel uses. This project was approved with an overall parking supply of 3,696 spaces (including the existing spaces under the Sumitomo Bank building) - 1,299 of which are allocated to the residential portions of the development. This results in a parking ratio of 1.66 spaces per dwelling unit. The 350 residential units associated with the Long Beach Plaza renovation were approved with a total of 700 nighttime spaces allocated to the residents. However, the overall parking demand for the project was calculated based on shared parking. During the peak parking hours of the day (mid-afternoon in this development) only 595 spaces 16

100 would be reserved for the residential units. This represents a parking ratio of 1.32 spaces per dwelling unit. Both of these developments are mixed-use projects where guest parking demand may be served by spaces that may also be shared with other uses. However, the amount of parking allocated to the reserved residential parking is less than that "normally" required for residential projects. The reserved parking supply for the residents is consistent with the parking supply proposed for the 350 East Ocean project, and it is consistent with the parking occupancy counts conducted in downtown Long Beach. Marina del Rey Los Angeles County recently approved a project on Panay Way and Via Marina on the west side of Marina del Rey. This mixed-use development included 1,201 residential units, boat slip reconstruction and the development of 10,000 sf of visitor-serving retail and commercial space. The project allocates 1,725 parking spaces to the residential units, representing a parking supply ratio of 1.44 spaces per dwelling unit. Los Angeles The Los Angeles Sports and Entertainment District is a recently approved, mixed-use development in downtown Los Angeles adjacent to the STAPLES Center. The project includes two hotels with 1,800 total rooms, a live theater with 7,000 seats, approximately 1 million square feet of retail/restaurant/entertainment and 300,000 square feet of office. The project also includes a residential component of 800 dwelling units. The parking supply for the project will consist of approximately 5,300 parking spaces of which 800 will be reserved for the residential units. This represents a parking ratio of 1.0 spaces per unit. PARKING COUNTS IN SAN DIEGO In researching locations for possible analysis as a part of this study, recent counts in high-rise apartment complexes in the University City/La Jolla area of the City of San 17

101 Diego. Darnell & Associates counted the parking supply and demand at seven apartment projects in November Occupancy counts were conducted hourly from 7pm to midnight on both weeknights and Saturday nights. As was the case in the Long Beach counts described in the previous chapter, the peak occupancy occurred consistently during the midnight weekday count. To be conservative, Darnell & Associates included the on-street curb spaces near each of the developments in the parking demand counts. Table 3 shows the results of the Darnell counts. Even with the adjacent curb spaces counted as on-site parking demand, the peak parking ratios for these sites ranged from 1.15 to 1.52 spaces per dwelling unit - well within the 1.81 spaces per du supply proposed for the 350 East Ocean project. Consistent with the 2001 counts conducted by Kaku Associates, the 1996 San Diego counts by Darnell show that the parking supply proposed by the 350 East Ocean project will be more than sufficient to meet the parking demand. 18

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103 IV. SUMMARY The proposed residential development At 350 East Ocean Boulevard in downtown long Beach will provide 1,008 parking spaces to support 556 apartment units. This parking ratio of 1.81 spaces per dwelling unit is less than the amount required by the Local Coastal Plan, but the project was approved by the City of Long Beach based on parking occupancy counts at other Long Beach developments. The California Coastal Commission has requested additional parking data be collected to justify the parking proposed for the development. Parking occupancy counts at eleven Southern California residential developments were conducted and the results of these counts show that the actual parking demand for guests and residents combined ranges form 0.66 to 1.59 spaces per occupied dwelling unit. Developments with a high proportion of studio and one-bedroom units (similar to the proposed 350 East Ocean project) tend to experience parking demands in the lower end of this range. A 1996 survey of seven high-density apartment complexes in northern San Diego showed peak parking demand ratios of 1.15 to 1.52 spaces per dwelling unit. In addition, a review of the zoning codes in California cities sowed that the proposed parking supply for the 350 East Ocean project would exceed the parking requirements in 36 cities in California. When the parking supply and demand at the eighteen study sites are compared to the proposed parking supply at the 350 East Ocean project, the parking demand at all of the study sites is less than the 1.81 spaces per dwelling unit proposed for the 350 East Ocean Boulevard project. There is no site that experiences a parking demand that would tax the proposed parking supply of the 350 East Ocean project. The usage patterns in the residential projects studied show that the parking supply proposed for the 350 East Ocean project would be more than adequate to meet the peak 20

104 parking demand. The proposed parking supply would accommodate peak parking demand with no project parking overflow onto adjacent streets. 21

105 Excerpts from ULI Shared Parking, 2 nd Edition

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107 About UU-the Urban Land Institute ULHhe Urban Land Institute 'IS a nonprofit education and research institute that is supported by its members. Its mission is to provide responsible leadership in the use of land in order to enhance the lotal environment. Ull sponsors education programs and forums to encourage an open international exchange of ideas and sharing of experiences; initiates research that anticipates emerging!and use trends and issues and proposes creative solutions based on that research; provides advisory services; and publishes a wide variety of materials to disseminate information on land use and development. Established in 1936, the Institute today has more than 26,000 members and associates from more than 80 countries representing the entire spectrum of the land use and development disciplines. Richard Rosan President About the International Shopping Centers Council of Founded in 1957, the International Council of Shopping Centers (I(SC) is the global trade association of the sbopping center industry. Its more than 54,000 members in the United States, Canada and more than 96 other countries include shopping center owners, developers, managers, marketing specialists, investors, lenders, retailers, and other professionals as well as academics and public officials. As the global industry trade association, Icse links with more than 25 national and regional shopping center councils throughout the world. Michael President P. Kercheval For mom information about lesc and the p~qdljcisa~d servicos that it elfers, includ;~8 puolic~tions and re,earch data, visillcscs Web sno at wwwtcsc.org. for more information about ULI and the rescurces lh~1 il offe(s rela(eo 10palking and 3 variety of other r~al estzte 3no urban development issues, vistt UU's Web site at Recommended bibiiogtdpflic li5ling: Smith, Ma<y 5. Shored Porking. Second [dilion. Wosh lnglnn, D.C.: UlHhc Urban Land Institule and the Internalional Council of $hoppi~g Centers, ULI( Number: SS~ IC~C Ca1~log Number: '279 Inteln~~ional Standard Book Number: lib(~ry of CMgr~ss Contrcl Numb,,(; Copy(ight 2005 by ULl-Ihe Urban Land lnstitutc and the lntelnalional Council 01Shopp:ng Centers UlI' 1025 thomas Jellcrson Street. NW. Suite 500 Wesl Wilshington. O.c ICSC: 1221Ave'lul' oi the Americas New York. NY P,;ntcd in the Unitr.d States 01 Arnenca, Ali fighls reserved, No part 01 lhis book may be reproduced in ~ny form or by 3ny means, eloctronic Of mechanical, Including photocopying and recording. or by any in1ormation storage and reldr.val system. without wrincn permission 01 the oublishor. Ii

108 Shared Parking Study Team Team Leader and Principal Author Mary S. Smith Senior Vice President Walker Parking Consultants Indianapolis, Indiana Other Contributors Patrick Gibson Vice Presidenl Kaku A,sociates Santa Monica, California Ransford S, McCourt Principal DKS Associatcs Porlland, Oregon Gerald Salzman Senior Planner Desmon Chicago, iliinoi~ Martin J. Wells President Wf:lIs Associates McLean, Virginia Jerry Wentzel Regional Manager DKS Associates 7ompa, Florida Review Committee Robert T. Dunphy Senior Resident Ff.lIow, Iransoonotto«and Infrastruclure ULHile Urban Land Imtitu/e Washington. D.C. Kemper Freeman President Bellevue Square Managers, Inc BeiJevue, Washington Kenneth H. Hughes President Hughes Develorment, L.P. Dallas, 7exas Jean Lambert Manager of Global Research International Council of Shopping Centers New York, New York Ronald A. Massett Senior Parking Specialist Wilbur Smith Associates Harrisburg. Pennsylvania MichoeJ P. McCarty Senior Vice President Simon Property Group Indianapolis, Indiana Joseph Stetlsrnith Director of Civil Engineering Simon Property Group Indianapolis, Indiana William A. Speer Prelsident Speer Consulting Intemationol Coronado, California James W. Todd President Thl! Peterso«Companies Fairfax. Virginia William R Eager President TDA Inc. SeoWe, Washington iii

109 UU Project Staff Rachelle L. Levitt Executive Vice President, Policy ond Practice Publisher Gayle Berens Vice President, Reol Estate Development Proctice ICSC Project Siaff Jean Lambert Manager or Global Research Rudo!ph E. Millian Senior Staff Vice President Director of Professionai Development Services Robert T. Dunphy Senior Resident Fellow for Tramportation Project Director Nancy H. Stewart Director, Book Program James A. Mulligan Managing [ditor Duke Johns Manuscript Editor and Infrastructure Patricia Montagni Director of Publications Michael P. Niemira Staff Vice President Chief Economist and Director of Research Jay Starr Senior Stoff Vice President Group Publisher, Director of Marketing and Membership Betsy VanBuskirk Art Director Byron Holly Book Designer Susan 5. Teachey/ON-Q Book Layout Design, Inc Craig Chapman DilBctOr, Publishing Operations Ronnie Van Alstyne Senior Administrative Assistant Iv

110 Introduction The Concept of Shared Parking Shared parking is the use of a parking space to serve two or more individual land uses without conflict or encroachment The ability to share parking spaces is the result of two conditions: II variations in the accumulation of vehicles by hour, by day, or by season at the individual land uses, and relationships among the land uses that result in visiting multipie land uses on the same auto trip. Although the ULI methodology for shared parking analysis was developed in the early 1980s,' the concept of shared parking was already well established: a lundarnental principle of downtown planning from the earliest days of the automobile has always been to share parking resources rather than to a'docate parking for each use Of buuding, The resurgence of many central cities resulting from the addition of vibrant res'dential, retail, restaurant. and entertainment developments (ant inues to rely heavily on shared parking for economic viabiiity in addition. mixed-use projects in many different settings have benefited from shared parking. Parking is a key element 01 any site development plan. Parking can consume 50 percent or more of the building and land area of a development. An oversupply of parking can result in excess storm drainage impacts and unnecessarily high expenses (surface stalls can cost \1>2,000 to ~!,3,OOO per space and structured spaces ~15,000 to 'f,25,ooo or more). Insufficient parking can result in lhe intrusion of parking into neighborhoods or adjoining properties, excessive vehicle circu.. Iation, and unhappy users. Ultimately, great parking alone won't make a mixed-use project successful; however, inadequate or poorly designed parking can limit its potential success The key goal of shared parking analvsrs, then, is to find the balance between providing adequate parking to support a development from a commercial viewpoint ane minimizing the negative aspects of excessive land area 01 resources devoted to parking. Mlxed..use developments that share parking result in greater density, better pedestrian conner- 1

111 lions, and, in turn, reduced reliance on driving, typically because multiple destinations can be accessed by walking. Higher-density development. especially on infi] sites, is also more likely to support alternative modes of travel, including whether shared parking is still appropriate, given changes in society. transportation. and mixed-use development trends. The consensus was that the underlying concept and methodology are stili viable, but that an update of the default factors transit and carpools. would be appropriate. The following three examples illustrate Concern for the negative impacts of growth has stimulated a search for better ways to develop land. "Smart growth" IS a collection of planning principles and strategies designed to facilitale development without sprawl. Smart growth projects typically are designed to create transportation options and reduce driving, especially for short trips. Walkable live/work/play environments, located near established transportation and infrastructure resources. are central how changing trends have affected parking needs. II When Shared Parking was!irst published, a multiscreen cinema complex had two or three screens. By the late 19905, new cinema developments had as many as 30 screens. It is far less likely that every seat in a 30-screen cineplex is filled than in a two- or three-screen cinema. The proliferation of these complexes has had a profound impact on the movie industry, and the parking needs of cineplexes will be discussed later in this report. to the concept. Some communities are questioning the economic costs of abandoning infrastructure in the city only to rebuild it further out.' Ironically, a critical element of such pedestrian-oriented districts is adequate parking. One of the hottest real estate trends is known as "place making," the development of town centers and urban villages with mixed uses in pedestrian-friendly settings. Another significant trend today is transit-oriented development, which seeks to cluster development near transit stations. With housing located within walking distance of rail transit, some II Changing lifestyles have led to a significant increase in the proportion of family meals eaten outside the home, which has caused a marked increase in the proportion of newly developed space that is occupied by restaurants. In 1955, 25 percent of expenditures for load in the United States was spent in restaurants (both limited and full service); in 2003, restaurants' share of the food dollar was 46.4 percent.' III As more women have joined the workforce. there has been an increase in the proportion of shopping trips that occur in trips and, in turn, some parking spaces can be eliminated. evenings and a Significant increase in "trip-chaining," owing Shared parking is a critical factor in the success of all these development approaches, and thus the importance of shared parking will continue to grow in future years. This report aims to provide planners, engineers, developers, and agencies with tools to better quantify and understand how to commuters making multiple stops to drop off or pick up children at daycare and to take care of household errands. A committee of the Institute 01 Transportation Engineers (lte) also agreed that the methodology recommended in the first edition of Shared Porking is still the correct approach to shared parking can be successful. shared parking analysls, but it called lor updating some Objective of the Second Edition The widely accepted methodology for shared parking analysis was established in 1983 with the publication of the first edition at Shared Parking. Two decades later, ULl and Icse convened a working group of parking experts to examine the question of default values." It found that almost half of all local governments had incorporated shared parking into local codes, either directly or as an option, and many of those codes cited the ULI shared parking methodology. The development of updated references on the parking needs of individual land uses also made an update of Shared 2 Shared Parking

112 Porking timely. In 1998, ULI and lesc commissioned an update of Parking Requirements {or Shopping Centers, the most widely recognized reference regarding that land use, That reference's second edition recommended a 10 percent reduction in the parking ratio for centers over 600,000 square feet and modified its recommendations for centers with more than 10 percent of GLA in restaurant, entertainment. or cineplex uses.' In particular, when more than 20 percent of the space in centers is allocated to those uses, shared parking analysis should be employed to determine the appropriate number of parking spaces, ITE also has updated its Trip Generation' and Parking Generation? publications. The third edition of Parking Generation includes four times as much data as the second edition, with over 100 land uses now incorporated. This document provides much-needed information on the parking needs of individual land uses, but it simply provides statistical analysis of the data. it makes no recommendations regarding appropriate parking ratios to be used in parking studies, including shared parking analysis. In fact, the limited data in many land use dassltications are not statistically reliable, and professional experience and judgment must be employed in their use, One of the purposes of this report is to lorrnulate recommendations regarding the parking ratios to be used in shared parking analysis, using, to the extent approprlate.the data found in Parking Generation. Both documents are complementary, ULI and lcse concluded that the timely coordination of an updated Shared Parking publication wilh these other documents would result in a vastly improved set of tools for transportation planners to determine the appropriate number of parking spaces for mixed-use developments. Definition of Terms A key to understanding the shared parking methodology is the definition 01 terms and assumptions inherent in the use of those terms, Parking ratio is the number of parking spaces that should be provided per unit of land use, if parking serves only that land use. The ratios recommended herein are based on the expected peak accumulation of vehicles at the peak hour on a design day (see below), assuming nearly 100 percent modal split to auto use and minimal ridesharlng. The recommended ratios also include consideration of ellectlve supply issues. Parking accumulation observed at a site. Parking supply is the number of parked vehicles is the total number of spaces available to serve a destination. It may include spaces that are on site, off site, on street, or shared with other uses. Effective parking supply is the number of occupied spaces at optimum operating efficiency. A parking facility will be perceived as full at somewhat less than its actual capacity, generally in the range of percent occupancy, (The range is because regular users learn where spaces are likely to be available at a particular time of day and thus require less of an extra cushion than unfamiliar users.) It is appropriate to have a small cushion of spaces over the expected peak-hour accumulation of vehicles. The cushion reduces the need to search the entire system for the last few parking spaces, thus reducing patron frustration. It further provides for operating fluctuations, misparked vehicles, snow cover, vehicle maneuvers, and vacancies created by reserving spaces for specific users, such as disabled parking, The effeclive supply cushion in a system also provides for unusual peaks in activities, A design day or design hour is one that recurs frequently enough to justify providing spaces for that level of parking activity, One does not build for an average day and have insufficient supply for the peak (if not multiple) hours on 50 percent of the days in a year. Conversely, it is not appropriate to design for the peak accumulation of vehicles ever observed at any site with that land use. That peak accumola- Introduction :3

113 tion might last only for an hour or so, while there are 8)60 hours in a year. A tralflc engineer does not design a street system to handle the peak volume that would ever occur; instead, the level of activity that represents the 85th or 90th percentile of observed traffic volumes in peak hours on average days is used for design. This second edition of Shared Parkillg uses the 85th percentile of peak-hour observations for recommended parking ratios, unless otherwise noted. Seechapter 3 for further discussion of design hour issues. Mode adjustment is employed to adjust the base parking ratios for local transportation characteristics. Two factors must be considered in such adjustments: modal split for private auto and auto occupancy, both of which are terms commonly used in transportation planning. The parking ratios herein assume that nearly all users arrive by private auto with typical auto occupancy for the specific use. It should be noted that even in locations without transit, some walking and dropoffs occur. as well as some ridesharing. The base ratios are appropriate for conditions of free parking and negligible use of public transit. The mode adiustrnent then reflects local transit availability, parking fees, ride sharing programs, and so on. See chapter 3 for further discussion of mode adlustrnents. Modal split is the percentage of persons arriving at a desti nation in different modes of transportation. Among the modes that may be available are commuter rail, light rail, bus, private automobile (including trucks, vans. and SUVs used for personal transportation), carpools and vanpools. walking, and bicycling. The percentage of persons who arrive at the destination by private automobile is generally called "auto mode split" and includes both driver and passengers. Auto occupancy is the average number of persons per private automobile arriving at the destination. Vehicle occupancy (as employed in transportation planning) refers to the average number of persons per vehicle including all vehicle types, such as public and chartered buses. Noncaptive ratio is an estimate of the percentage of parkers at a land use in a mixed-use development or district who are not already counted as being parked at another of the land uses. For example, when employees of one land use visit a nearby food court or coffee store, there usually is not any additional parking demand generated. Seechapter 3 for further discussion. Units of Land Uses Parking ratios are generally stated as a ratio of x spaces per y units, with the unit being the most statistically valid independent variable for that land use. In the vast majority of uses, the unit is square feet 01 building area. Other units that may be used are employees, dwelling units, hotel rooms, or seats. This publication uses the most widely accepted independent variable, generally in accordance with Parking Generation. The following terms describe specific formulas for parking ratios. Gross Floor Area (GFA): Total gross floor area, including exterior building walls of all floors of a building or structure. Also referred to as gross square feet or G5f< Gross Leasable Area (Gf.A): The portion of GFA that is available for leasing to a tenant. Generally, GLA is equal to GFA less "common" areas that are not leased to tenants. including spaces lor circulation to and from tenant spaces (lobbies, elevator cores, stairs, corridors, atriums, and so on), utility/mechanical spaces, and parking areas. Net floor Area (NFA): Total floor area, excluding exterior building walls. Net Rental Area (NRA): The portion of NFA that is rentable to a tenant. Also called net leasable area. Thus, GFA and GLA are calculated out-to-out of exterior walls, while NFA and NRA are calculated between interior faces of exterior walls. GLA is commonty used for shopping centers, but GFA or NFA is more commonly used for office uses. No matter what calculation method is employed, the 4 Shared Parking

114 vehicular parking and loading areas and the floor area occupied by mechanical, electrical, communications, and security equipment are deducted from the floor area for the purpose of calculating parking needs. Organization of This Report Chapter 2 of this report presents key findings, including the recommended default values for shared parking analysis. Chapter 3 discusses the methodology, with an example analysis, and chapter 4 discusses the parking needs of individual land uses and the derivation of the default values. Chapter 5 presents case studies, while chapter 6 discusses the design, operation, and management of shared parking. Notes 1. Ull-the Urban land!nslitule, Shored Porking (WDshlngton, D.c.: UlHhe Urban land tnstltute. 1983) 2. "About Small Growlh," (October 2003) ~ Restaurant tndustry Fcrecest, Nation.1 Restaurant Associ~tion. 4. HE Technical Council Cornrnit\(~Q 6f,52. SholM Pa!~in9 Planning Guidelines (Washington, D.c.: Institute 01Transportation Engineers. 1995). 5. Ull-ihe Urban l~nd Insli\ule Mid Ihe lnternatlo.~al Council 01 Shopping Centers. PorkiJl9 Rcquircmarl15 lor Shopping Centers, 2nd ed. (Washington, D.c.: UlHhe Urban Land Instilule. 1999). 6 ITE lechni,~i COimdl (ornmiuee, Trip Genero/ion. 7th ed. (Washington, D.c.: Institute of Transportation Eng;ne~rs, 2004). 1. lte Iecbnical Council COlllf'liuee. Po/king Genrrotion, 3rd ed. (W3sninglon, 0,(,: lnstitute of Transportation Engineers, 2004). Introduction 5

115 I<ey Findings ThiS report presents recommendations for the methodology as wefl as recommended default values for certain assumptions to be employed in a shared parking analysis Methodology Shared parking methodology provides a systematic way to apply appropriate adjustments to parking ratios tor each use in a mixed-use development or district. This methodology is summarized in Figure 2-1. Chapte- 3 discusses the importance of each of these steps. Steps 1 and 9, which involve developing an understanding of the project before starting analysis, and developing site design and parking management plans that wal facilitate shared parking (after the recommended number of spaces is deterrnlned). are often fie.. glected in many shared parking studies. The analysis may reliably project the peak accumulation 01 vehicles, but if the design and management of the parking system do not facili.. tate the sharing of spaces parking may be inadequate. While manegemeot practices can often be changed to improve the situation, a poorly designed site for shared parking often cannot be significantly improved, and more spaces may ultimately have to be adderl Chapter 6 is devoted to this topic. One of the key changes in the methodology from the first edition of Shared Parking is the separation of parking ratios into visitor/customer. employee/resident. and reserved components. This delineation lacilitales application of different noncaplive and mode adjustments, since those characteristics may be distinctly different in certain locations and with certain combinations of land uses. Most important, if spaces are reserved fo' specific users, they cannot be shared w;th other land uses. For example, in some cases where a shared parking analysis was found to be unreliable, it had assumed that residential spaces would be shared, but the residential leasing plan developed later in the process included separated. dedicated stalls for the residents' rarking needs. ~easing deals for office and retail tenants may also include reserved parking. Spaces that are

116 reserved for specific users are part of the parking needed for that land use, whether or not a vehicle is present. The terms "weekday" and "weekend" have also been modified. Weekdays are now defined as extending from 6 a.m. Monday to 5 p.rn. Friday. Weekends include Friday evening and all day Saturday. This categorization avoids increasing weekday factors to reflect Friday evening activity at restaurants. cinemas. and other venues where there is considerably more demand on Friday evenings than other weekdays. Parking requirements on Sundays are not considered here, as they are rarely a significant factor in parking planning and there is currently inadequate data on which to base recommended ratios for Sunday conditions at most land uses. When performed manually, the determination of critical scenarios for peak parking needs is usually an iterative process. Depending on the relative quantities of retail, dining, and entertainment, a shopping center may have peak demand in December or in July. Therefore, with few exceptions, it is important to develop several scenarios for modeling parking needs to assure that the peak hour is identified. ULI and lese have made available a shared parking model that greatly eases the number of iterations required to determine the overall peak need for parking. USing the default values recommended in this report. along with user input of quantities of land uses, mode, and noncaptive adjustments, the model calculates the parking needs in each hour of the day from 6 a.m. to midnight, weekdays and weekends, lor each month. It then determines the peak hour of the peak month for weekdays and weekends. If necessary, the user can make further manual adjustments to finalize the analysis. Key Findings '1

117 Shared Parking Methodology Gather and review project data II Type and quantity oi land uses RIILocal zoning standards and practices III Existing conditions. parking pricing. local users, and facilities if appropriate II Locel mode splits, transit and transportation demand management programs II Physical relationships between uses!!!iii Parking maflagemcnt strategies c_==~~~-=-=~t=-~=~====---'-~--~-- acceptable to the various parties Select parking ratios (spaccs/enit land use)!\iii! Weekends and weekdays II Visitor/customer, employee/resident. and fcservcd -"'"... " t Select factors and analyze differences In activity patterns IITime of day III Monthly Develop scenarios for critical parking need periods Adjust ratios lor modal split and persons per car lor each scenario Apply noncaptive adjustments for each scenario Do scenarios reflect all critical parking needs and management concerns? No Recommend a parking plan II Adequacy 01 parking!or key scenarios iii Evaluate potentia! Iacllitles and allocation of spaces lor key scenarios IIConfirm physical relat.onshlps between uses to encourage shared parking Yes II Recommend parking management plan to achieve prolectcd shared parking...~..~,---~, -----~..~,~----~-~--',---,--,-,.,-~_,_.,,~~-r., Note':Ste~7j~a~t~~ai!c~liy'~~iior;-oed,jntl~~.0U/!CSC~h~(ed Pilrkl~~moqe!. V

118 Another key change in the methodology is that it is strongly recommended that mode and noncaptive adjustments be modified lor each scenario. Generally speaking, these factors vary by four combinations of time/day of week: til weekday daytime, \l1li weekday evening, IIweekend daytime, and IIweekend evening. For example, a significantly higher proportion of the patrons of a restaurant near large concentrations of office workers will be captive on a weekday at noon than would be true that same evening. There may be differences in mode adjustments for employees on weekdays and weekends and by time of day, depending on the service schedules of local transit systems, the perception of security at certain times of the day, and other factors. Although captive market effects are discussed in this report for a number of land uses, the magnitude will be affected significantly by the combinations of land uses and more specifically the relative quantities. For example, the noncaptive adjustments lor a 1O,OOO-square-foot restaurant in a 40,OOO-square-loot strip shopping center will be distinctly different than the adjustments for a restaurant of that size in a mixed-use project with Significant office space or hotel rooms. Even ranges of noncaptive factors for each land use thus would be misleading. Therefore. suggested ranges of non captive factors are not tabulated in this report. The sole exception 1s hotels, where there typically is a rational relationship between the number of guest rooms and the square feet of restaurants and meeting and conference/ banquet space. Chapter 3 includes a discussion of how to develop noncaptive adjustments. and examples are provided in the case studies of chapter 5. Regarding step 5 of the methodology, the wide availability of information regarding modal splits for commuters in a particular community (or even in a census tract) greatly assists in the development of mode adjustments for employees. Information is also available on auto ownership by household that can be identified by community or a more specific area. This information can be obtained through local surveys of comparable conditions. Adjustments for differences in auto occupancy are more likely to affect employee parking than visitor parking. In particular, formal ridesharing programs at employment centers can and will increase the auto occupancy of commuters above that found in lowdensity suburban developments. Step 8 is another particularly critical step in the process. Even when one is using the UlI/lCSC model, which will determine the peak demand for the assumptions that have been entered into it, there may be other scenarios that should be factored into parking planning. It maybe important to document that one scenario indeed reflects greater demand, in order to encourage a developer's acceptance of the findings or to provide input for parking planning and management. The number 01 spaces provided in each parking area or facility may be driven by particular needs at specific times of the day that should be documented ensure adequate and convenient parking for tenants. Parking Ratios and Other Default Factors in order to This edition of Shared Parking Significantly increases the number of land uses for which recommended parking ratios are presented, and it subdivides some land uses into more relined categories. These changes are summarized in Table 2-1. Chapter 4 discusses each land use, the derivation of the parking ratios, and the sources for time of day and monthly factors in detail. The key findings, however, follow. Table 2-2 presents the recommended parking ratios. while Tables 2-3 and 2-4 present recommended monthly factors for customer and employee/resident parking needs, respectively. Tables 2-5 and 2-6 present tlrne-ot-day factors for weekdays and weekends, respectively. Key Findin.gs 9

119 Land Use Changes between First and Second Editions of Shared Parking Land Use 1 in Second Edition Office (701) <25,000 sq. ft Office (701) 25, ,000 sq. ft. Office (701) to SOO,OOO sq. ft Office (701) >500,000 sq. ft. Data Processing Center Medical/Dental Office (720) Bank with Drive-in (912) Land Use in Ftts..t ~Ed~it~iO;:!I1!-- C::.:o..:..m:.:.:m~ent Single category: Office Per Parking Generation. separation is appropriate. Fine/Casual Dining (Quality Restaurant. 931; High Turnover with Bar,932) Family Restaurant (High Turnover with Fast Food (lte Fast Food. 933) \9Diel~n4Mj619s~~~1l(i:s) i Residential,Rented(221, 222, 224) Residential, Owned (230) No Bar,932) Single category: Restaurant ";:;~. -.:.~:hie". :-\.'i Single category: Residenliel Unpublished study by team member and Parking Generation indicated separation is appropriate,... i ;Fi~t~eclitiQfjt~tlo.W~sapplj~~bii.forlt$#~~Bs.. :i. '. Per Parking G~rie(alio~,>s~pa;~tio~i;~p[lr~priaie. Specific time of day and adjustment factors are provided for suburban and oriented locations. Convention Center (455) Not covered Common in shared parki ng situa tions, especially in centlat business districts. :.':~'?}:.;. ';. : " '.,-';1:';SfQiHm~~JB~~~t~~'~MM'~t~~~~Q{;; 'J,;~~!!hq6h(49~)\.«:...:...,.< ;.' :...;".':. "'.;r:'n~f~jv~i~il Perfl)rl1lingA.rtsC~nter (411).. Ngtcov~r~d Common in shared parking situations. ~:~\';~~'@i~~:,~'4i,"t;;~,';~~i~i~ Significant,~1i~1~~!~j~~1~~!~;'" Nightclub ;.A.'.r. ~. n. '.~.,..i,.::. :.{..::.::: i:....:.,.::)':-:,.. ", -, ;.\=.:.:-:.:... ~a~~b.an~laqiu'n 'F66tbai(St~'di~~":' ",," Not covered.,.....' :.'i:..;indlri>v~ie"d',\: '. " No.t c{)ver~d.... "'N~i'~b~eied.: trend in reta il development. " : ;.;.~9mfu99ih~Mtfg.@~lng.~MHi~Q,~::....,,; :.,'. Comm.90 in sha.red parki~gsltuati~~s..::.(:~m.~~n ihsh~; d~i~iiit'~m~ii k...,:: ' Notes IT"~ ;"" Porking GM~raaC'll"nd US!,ccd~ I, provided in pmc'11ncs's. 1fi"~!e~1 of the ("! dition ()i ShOred Porking recommended that. hel :,w.c. f.co.o()() and too.ooo sqit, Uw rauo,hou!d be lineorly ic\erpol~(cd from 4.0:0 ~,o5p?ce, pel tllou~j~;~d sq i:. \'lh~ch 1.'.';% (:;ms:;..;c:~-;t -,'Jt(h 1h~th'!l1~cur(!::n~JLlJ(S( publ;i;()l~{j(ton PlJfki(;g Rt'qUi(!!Oi(!O::-; fur S.~icppl~I'JCeolers. H~c: tab!~!-.~;n',mq~el~ngthe oar!:i!"',g (ati()s,h~w/e:vf.f,lc~:(,n'~d r(~ta;fas noted ano t! ~,.ISvias not (C~,ip:,~t t~l)'dj,~a(wgardiflg the :'atk) to b{~used belween tioo.coa and 600,000 sq H 10 S h a red P a ( kin g

120 Summary of Recommended Base Parking Ratios (Spaces per Unit Land Use) Land Use W~kday Weekend Unit Source ~~ Visitor mp.\ql~. Visitor EJ!I.."p""locx;ve""e'-- ~ Community Shopping Center « sq. ft.) JksfiGlA 1. Rcgi()fJ~!S!mpping Center (400,090 ~o~oojooosq. :It.).... Slk!ing scalebihv~.en 400.0p()pnd ~OO.OOOsg.It..,I4!qlA.:;.]. s'uper Regiona I Shopping Center (>600,000 sq. It) Jksf GLA 1 Fjrie;Ca~~1Di~ing "<f15)ioj,o :.Il6[(;LA.. 2,3 family Restaurant Jksf GLA 3 "Fast-FoixIRes!.~u.raot. 12, ' q..lksi pt,a Nightclub S fbf GLA. A~tive Eotert~inrnent Custo~ to each ~efkln~'. ".: Cincplex Pertbrming Arts 1heater..o}... 0:07 Arena 0.27 am Pro foolballsi.adiumo PIO Baseball 5radium trealtn Club~.60.4 ConventionCenter 5.S 0.5 Holel..,.Business '. ), Hot~i"-Lei~Ule Rcsta~i~nVLO~~ge'.:....':.10, Conference~eli!c~/B<lf1qu1\t (20t~ $0 se, njgu~ sttooin).30,0. -. Conv~~H~nSpJc~(>50SQ. ft./guest,oom):iq,(i ".- Residential, Renl~ Residential, Owned OAiee (<25,000 sq. ft.) OJ Office (2!,OOQ to JqO.qoo sq. ft)slidin,gs<;a!e between :25.ooqsq: It:.. '106,000 ~Q. ft: OAiee (l ,000 sq. Il.) Slidingscale between 100,000 sq.it; OHico! >500,000 sq,"ft. Data Ploces5ing Office Me<licjVDenta'1 Ofnce Bank. Branch with Drive-in 500,000 sq. ft.: ) , , ,02 W :1,6 am 'i 0.Q /seat (/07 'i~~ai /seat ,01!Seat. J /sea\ 3 5, /ksfgfa fhf GLA 3 0,9:.p,l~Yr09~. 2).,.to.0.18 /roo~>: l,} ,..-.:.!kS(G0\ J,3, 5 ~6:~ ;J~}~0i:i:~< funi! ,72 i~nit2 0, Iksl GfA 2 -. \.0.# /k~!~fa:,1 MGFA 2 0,26 MGFA 2 O.5S /ksf GFA 2,3 1.5 iksl GFA.. 2,3 1.6!ks1 GFA 2 Notes f~atio5b:j~r.(i on v:<:=kp~(rjng spaces H~QOlrt;j ':i!!l1, v:~tui:lhj'100%.amcose and tyii;jj~ rict')h()dng f(-'l ~ljbu~b~lr. ccr\{nityo\s t.:\,,1:-: per H-:cus~nd sq.!t /1.0 spaces (~~so~vcdfor!'~s.;d(!(lts soie U5t;, ::!-1 hm;:-s.0 (J(i"/: q~rn(ll;:jr~r :;h(:redwith ~~~!si:i.or5<lnd::)t~lc(uses Sourcesr 1. Pwkirrg KE~wi(em('r'I:s fef 5'loppr'ng CrnlCfS. lnd cd. (\N~S; :'-g~o;,. D>C; au t,;',3 Urbi~ntJnd mstiture. 1999). :~.porku!g Gef!(>f:'Jlkm. 3:d ed. (VVa$lll:tgtoli, D.(.. \r:s;ilu\'(' ci T:-i:!n':ipod~Hon L(\:.;:f!~~;s. 200~) c. f"lj,a (dlec\",<j b'l \(';)n' i11e'"bqr>. }. ~O~l""V~,_ ~_X v$e!.l. -Park.no R(~Q'.iii ~me:)1$ for Hi:~~!:;-.Chf.~5: H;('?a(~:(Ig Pmf(l~ 5i()noJ.;\p(!\ 20~)-1, Ge(.~'GSaliooan. -lh~t\'i P3(kii~i~He..':"Much ~sf ncugh?" UfbG/i L~(i.i!'):L~:;HY 1988 "'"----.,.., Key Findings n "'---.

121 The first edition of Shared Porking employed a single ratio and drug stores (using more refined base ratios for each); of 3.0 spaces/ksf (per thousand square feet) for parking at rather, the base ratios recommended for shopping centers office uses on weekdays, with 0.5 spaces/ksf on weekends. should be employed for all retail tenancies. This edition stratifies office uses into six categories, four for Parking ratios for restaurants have also been considerably general office with ratios decreasing as size of office space modified in this edition. The first edition recommended a sinincreases (3.8 to 2.8 spaces/ksf on weekdays and 0.38 to gle ratio spaces/ksf for both weekdays and weekends 0.28 spaces/ksf on weekends), plus separate new categories for restaurant use. This second edition separates restaurants for data processing offices and medical and dental offices. In into three categories: fine/casual dining (with bars), family addition, a new category is now provided for bank branches restaurants (no bar), and fast-food restaurants. The Saturday with drive-in facilities. ratio for fine/casual dining remains 20.0 spaces/ksf. but the For retail, the update of Parking Requirements for Shopping weekday ratio is now 18.0 spaces/ksf with ratios of 15.0 on Ceniers in 1999 recommended the same parking ratios for Saturday and los on weekdays for family restaurants. In less than 400,000 square feet of retail (4.0 spaces/ksf) but addition to the lower ratios, a key reason for this differentlalowered the ratio for centers larger than 600,000 square feet tion between restaurants with and without bars is that Iarnfrom 5.0 spaces/ksf to 4.5 spaces/ksf, This change also ily restaurants have peak parking needs at noon, while results in slightly different ratios when scaled between fine/casual establishments peak in the evenings. Differenti- 400,000 and 600,000 square feet. This edition recom at ion also enables analysts to employ more captive patronmends a similarly scaled ratio of 3.5 to 4.0 spaces/ksf for age (and thus a lower noncaptive adjustment) for fast-food weekday parking needs, as compared with the flat 3.8 uses than for restaurants, where the typical patron stays spacesykst ratio of Shored PMking's first edition. Monthly and for an hour or more. Ratios of 15 spaces/ksf on weekdays and time-of-day factors for retail have been modified consider- 14 spaces/kst on Saturdays are recommended for fastably to represent more recent shopping patterns. food restaurants. Porking Requirements for Shopping Ceniers also recorn- The ratios for clneplexes have been lowered from 0.3 on mended that where dining and entertainment uses (including weekends and 0.25 on weekdays to 0.27 and 0.2, respeccinema) represent more than 20 percent of the total GLA, lively, reflecting the significant changes in the movie theater shared parking methodology should be employed, When din- business in the last 20 years. ing and entertainment uses constitute percent of the~j;>separate ratios of 1.65 and 1.85 spaces/unit are now rec- GLA, Porking Requiremenis for Shopping Centers recommended ommended as the starting paints tor rental and owned resithat the base ratio for retail be increased by 0.03 for each dential units (the same ratios are employed weekdays and additional 1 percent of dining/entertainment space over 10 weekends), rather than the single ratio of "1.0 spaces per auto percent. The case studies in chapter 6 indicate that the use of owned per dwelling unit" recommended in the first edition. shared parking methodology may be more accurate for shop- The latter was intended to be adjusted according to auto ownping centers where dining and entertainment uses exceed 10 ership per dwelling unit but was commonly used as simply 1.0 percent of the GLA. The case studies also confirm that it is not space/unit. For this edition, the study team concluded that it necessary or appropriate to further stratify retail uses such as was more appropriate to give ratios reflecting auto ownership discount superstores, big-box retail uses. and supermarkets for "cornfield" residential projects and to allow adjustment for 12 S h are d P 3 r kin g

122 the specific location of the units. (A cornfield project is a freestanding land use in an area with little or no transit and only weak pedestrian connections with other uses.) For hotels, while ratios of 1.25 spaces/room (for overnight guests and employees) continue to be used for business hotels on weekdays, 0. lower ratio of 1.18 spaces/room is now recommended for such hotels on the weekends, and reversed ratios of 1.18 and 1.25 spaces per room are recommended for weekdays and weekends, respectively, at leisure hotels. In addition, while the same ratio spaces/ksf is su11recommended for holel restaurants/lounges for weekdays and weekends, the recommended ratios for convention areas (now defined as more than 50 ksl/guest room) have been lowered from 30 spaces/ksf both weekdays and weekends to 20 ksf on weekdays and 10 ksf on weekends. The ratios for banquet/meeting space (20 to 50 ksl/guest room) have been converted from 05 spaces/seat to 30 spaces/ksl for weekdays and weekends. The sale category with recommended default values for mode and noncaptlve adjustments is hotels. The remaining eight uses presented in this edition wefe not considered in the first edition. These include nightclubs, active entertainment venues, performing arts theaters, arenas, pro football and baseball stadiums, health clubs, and convention centers. The time-of-day variations in parking needs continue to be the most significant determinants of the potential for shared parking at project sites. Where uses have been considered in both editions, the time-of-day factors recommended here are significantly different in many cases than those recommended previously. Seasonal variations also continue 10 have a large impact on parking, especially for retail demand and cinemas. A significant improvement in the reliability of the methodology has been achieved by considering the period between Christmas and New Year's Day as a "13th month" because cineplex activity patterns are considerably different in the poslholicay period than in the holiday shopping season. Captive markets also have a large inlluence on parking. Office workers and hotel guests in particular can provide important markets for nearby retail and restaurants without requiring additional parking. Significant levels of carpooling, transit, Or pedestrian access can reduce parking demands. Individual estimates must be made for particular local situations. Conclusion The shared parking study team evaluated significant amounts of national information that have been fovnd to be appropriate for estimating parking demand. Where good local data exist. however, such as peak parking statistics for single land uses, high transit use, or noncaptive rates, they are preferable to the national data. IIShared parking analysis is still a valid method for estimating parking requirements of mixed-use projects. There are now many more components, and this update includes estimates for a much wider range of land uses. II Designing for the peak hour of parking demand requires a broad consideration of many potential scenarios, as well as extensive data on the hourly and seasonal variations, much of which is included here. IIln order for shared parking to be most effective, it is important that all spaces be conveniently located and accessible to all users. VariOUS techniques of managing parking can be used to encourage the sharing of parking. Key Findings 13

123 Excerpt from ITE Parking Generation, 3 rd Edition

124