FEIR- Volume I of III

Page 165

SEACA, Public Counsel, CBC, and NRDC Comments on the CASP DEIR November 23, 2011 P. 69 of 78 Density Bonus Super Density Bonus Super Density Bonus

1.5

2.025:1

35%

1.5

3:1

100%

7%

18%

1.5

4:1

167%

10%

25%

11%

20%

This COD alternative would substantially lessen the significant and unavoidable impacts of the Proposed Alternative, and would also reduce impacts the DEIR has thus far failed to identify. Specifically, by retaining lower-income residents, who heavily use transit and other non-vehicular modes of travel, the significant and unavoidable transportation impacts could be drastically reduced. As discussed above, the existing CASP-area population has only a 42 percent automobile share. (DEIR, p. S-3). By mitigating against displacement and providing increased incentives for new affordable development, the COD would sharply reduce the 86 percent automobile share estimated in the transportation analysis. The Minagar Report, discussed above and incorporated fully into these comments affordable housing requirement proposed in [the COD] alternative will generate approximately 27 percent fewer p. 29). Using standard Trip Generation, 8th Ed., trip generation rates developed by the Institute of for the land uses proposed in the CASP, the Minagar Report was able to calculate that this alternative would result in an overall reduction in peak hour trips of 4.74 percent. (Minagar Report, p. 31). The Minagar Report also calculated potential trip reductions for variations on the COD alternative. (Id). The potential vehicular emissions would also be reduced under the COD because it would prohibit developers from purchasing land solely to provide parking to residents. This would aspect would further incentivize transit and non-vehicular travel. oposed Alternative significant and unavoidable ozone precursors and greenhouse gases. The alternative would also have the benefit of reducing significant impacts to land use, as discussed above, relating to inconsistencies with existing plans and policies. The COD is also consistent with the Project purposes, identified in DEIR Section 2.2.1.2. Most importantly, the COD will meet the purpose provid[ing] a range of housing types and price levels that offer many choices, including home ownership for people of diverse ages, ethnicities, household sizes, and incomes, p. 2-14), to a greater extent than would the Proposed Alternative, because the COD would prevent the adverse displacement. By retaining and enhancing housing affordable to low-income workers who are likely to use transit, Id). The affordable hou

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