Agenda Item # 6.2 - Gilroy BPAC | Received 09/03/2023September 3,2023
Re:Architectural and Site Review (AS)
Project Number:AS 22-16
Project Title:E&P Properties New Warehouse Building
Project Applicant:Dennis Pauley
Project Location:Located at 201 and 221 Yamane Drive
Assessor Parcel No.APN 835-02-004 and 835-02-057
Gilroy Planning Commission,
Thank you for the opportunity to respond to the E&P Properties New Warehouse Building
Architectural and Site Review (AS).Comments below are based on the review of the AS.
Additional comments may be forthcoming pending final review.This project will have a direct
impact in the City of Gilroy by achieving our goal to reduce air emissions from on-road motor
vehicles and future developments.Improve air quality by encouraging our residents,
commuters,employees to mode shift from vehicles to cycling,increase walking as alternatives
to driving for short and first/last mile trips,and add new riders to the transit system.
This project should include a robust Transportation Demand Management (TDM)Program that
leverages nearby transit,bike lanes,and walking routes to further reduce Vehicle Miles Traveled
(VMT)and greenhouse gas (GHG)emissions.With its convenient location to transit,shopping,
and bike/ped facilities there are few barriers to reducing VMT at this project.With the recent
adoption of our City’s General Plan 2040,we as a community called for bold actions that include
continuing to promote cleaner modes of transportation.We encourage existing and proposed
development to incorporate Transportation Demand Management (TDM)measures such as
car-sharing,transit passes,and unbundling of parking (requiring separate purchase or lease of
a parking space)where such measures will result in a reduction in vehicle miles traveled,
reduction of required amount of parking or an increase in the use of alternate transportation
modes.We advocate that all new construction incorporate an all-electric model and be fossil
fuel free in order to reduce greenhouse gas emissions.
We are actively embracing,advancing ideas,and projects that promote the concept of free-
range people in the City of Gilroy.We advocate for building and planning that considers future
generations as well as current residents who don’t own cars.Advancing mobility options reflects
what we are teaching the youth in our community through Safe Routes to School and why we
are nationally recognized as a Bronze Bicycle Friendly Community from the League of American
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Bicyclists,as well as recognized by the World Health Organization as an Age-Friendly
Community.Continuing to leverage our Measure B Education &Encouragement (E&E)funding
for established work plans/programs will further enhance Gilroy’s efforts.Measure B E&E Bike
to Work Day,Community Bike/Walks Counts,Community Engagement,General,Online Media
Campaign,and Safe Routes to School work plans.
While there might be portions of our city that are isolated from transit,this development is not in
one of those areas.Gilroy has a fully connected bike network and transit options.We have a
large population that works,visits,and attends schools in Gilroy that benefits from local transit
and rideshare.Gilroy has the vision that the glass is half full,we have the ability to innovate,and
adapt to programs that will further reduce our VMT.Thank you to the Gilroy staff for their great
analysis and recommendations.
We have the following recommendations and comments based on the E&P Properties
New Warehouse Building Architectural and Site Review (AS)and our General Plan 2040
Mobility-
REACH Code for Electric Vehicle (EV)-Gilroy’s recent adoption of the 2022 California Green
Building Standards Code pertaining to electric vehicle (EV)charging for new residential and
non-residential construction REACH codes for EV’s applies to this project or CALGreen Tier 2
whichever requires more.
Land Use and Location (VMT/vehicle charged):The type of land use (residential,
commercial,institutional,etc.)affects the character of vehicle trips (home-based,work-based,
and other)associated with the charger location.The location of the charger will influence the
amount of use,the types of trips,and the distance of trips that are facilitated for EV use.The
combination of land use and location determined the vehicle-miles traveled (VMT)associated
with home-based,work-based,or other based trips shifted from fossil fuel to EVs.There are
several different approaches to estimating VMT for use in estimating EVCS benefits.
Method 1:EVCS Charging Activity Approach.Under this method,VMT is estimated based on
the expected charging activity per day.This approach assumes that the GHG reductions for an
EVCS are only related to the charging activity.The electricity (in kWh)delivered by the charger
is converted to miles using the average efficiency of a battery electric engine (kwh/mile),which
is then used to estimate both fossil-fuel vehicle GHG emissions and EV GHG emissions.This
approach requires estimation of daily charger use (see below),and EV GHG efficiency/mile to
establish associated mitigation.
Method 2:Location-Based VMT Approach.Under this method,VMT for EVs is based on the
land use and location of the EV charger,the number of vehicle charges per day,and vehicle
trips associated with that land use.For example,a residential EVCS would be assigned the
benefit of shifting all residential fossil-fuel vehicle VMT to EV VMT.Alternatively,the assumption
could be limited to home-based trip VMT.For non-residential development,VMT per charging
parking space would need to be estimated or VMT could be assigned based on work-trips only.
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This approach requires estimation of VMT per residential vehicle or non-residential charging
space.This is the approach used in the three CAPs reviewed for EVCS benefit quantification.
Recommend Shower,Locker,&Dressing Facilities-Provide employee showers and
dressing areas for each gender.Provide dressing rooms for each gender and one locker for
each required long-term bicycle parking space.Required lockers shall be located in relation to
required showers and dressing areas to permit access to locker areas by either gender.
Recommend a Dero Bike Fixit Station with Air Kit Bike Pump and Public Outdoor Feature-
We recommend placing this bike fixit station at a Public Outdoor Feature or near the bike
parking.This would add to the current network throughout the City.
https://www.dero.com/product/fixit/
General Plan Consistency-We agree with the following recommendations,and support the
City of Gilroy implementing their own Bike Parking Ordinance and VMT/TDM Ordinance so that
future developments don’t have to continue to rely on VTA.
-Bicycle Parking.The project will provide 10 short-term bicycle stalls and 7 long-term
bicycle stalls.The racks shall be “inverted U,”style and should be located near the
building entrance (i.e.,within constant visual range)unless it is demonstrated that they
create a public hazard or locating them there is otherwise infeasible.If space is
unavailable near building entrances,the racks must be designed so that the lock is
protected from physical assault.This complies with building code requirements for such
parking calculated based on 5%of vehicle parking.If parking is expanded,additional
facilities will be required.Provide clarification to the applicant that these are inverted “U”style
bike racks as written in the conditions.On packet page 34 the drawings show a “wave”style
bike rack which is no longer a city standard.
-Enhanced landscaping in the Murray-Las Animas Policy adds to our overall tree canopy
and increasing opportunities for shade when walking,biking,and taking transit.The
applicant proposes to plant over 100 trees on this site,as well as shrubs,grasses and
groundcover.The plant palette includes a total of eight tree species.Over 50 trees will be
planted along the street frontage,with the remainder dispersed throughout the site.
Complementary shrubs and groundcover would be planted and used to screen
equipment along the side of the building.
-6’sidewalks
-18 electric vehicle (EV)charging stalls
-The proposed project would utilize an all-electric design and no natural gas would be
consumed.
General Plan 2040 Mobility-The Mobility Element provides the framework for decisions in
Gilroy concerning the citywide transportation system.It seeks to create a balanced
transportation network that supports and encourages walking,bicycling,and transit ridership.
The goals and policies address a variety of topics,including multimodal transportation,complete
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streets,pedestrian facilities,bikeways,public transit,vehicular transportation,parking,and
goods movement.
Mobility 3.7-Traffic Impact Fee for Bicycle/Pedestrian Improvements
Support and finance the construction of pedestrian and bicycle improvements specified
in the Mobility Diagrams by using the comprehensive traffic impact fee.Support.The
funds shall be used to fund improvements identified in the City Traffic Circulation Master Plan,
which includes bikeways.
Goal of Mobility M4-Plan for efficient and convenient local and regional transit systems
that respond to the changing needs of Gilroy.Mobility 4.2-Transit and Development
require new developments to fully accommodate,enhance,and facilitate public transit,
including pedestrian and bicycle access to transit.What has this development done to
enhance pedestrian and bicycle access to transit?
Mobility 4.6-Santa Clara Valley Transportation Authority (VTA)
Coordinate with VTA on the planning of new transit routes within Gilroy and maintain a
strong relationship with VTA management to ensure continued cooperation.Was this
development project routed for plan review with our partner VTA,we have the opportunity to
shift riders towards transit through a robust Transportation Demand Management (TDM)
program?
Mobility 4.8-Consider Transit in Planning and Development Proposals
Coordinate with VTA on advance planning projects and development proposals that may
have implications for public transit and consider the VTA’s Transit Sustainability
Policy/Service Design Guidelines.What has this development done towards meeting this
general plan consistency?
Transit Service-The nearest VTA bus stops serving the development are Frequent Route 68
(Monterey Rd/Leavesley Rd)and Local Route 85 (Forest/Leavesley Rd)both less than one-half
mile south of the project site.Route 568 Rapid stops and Route 121 Express Gilroy-Lockheed
Martin located at Gilroy Transit Center.Caltrain provides service from Gilroy to San Francisco
(2-Hour Train Ride)Monday to Friday.Three trains leave the Downtown Gilroy Transit Center at
5:54am ·6:31am ·6:52am.You can take your bike with you or park it at a locker at the Gilroy
Transit Center.Caltrain currently serves riders from Gilroy to San Francisco,a 4th train will be
added,and a future extension south to Salinas.1 This is a great opportunity to promote the use
of public transit to the residents and visitors through outreach programs established in a
Transportation Demand Management (TDM)program.Leverage the Measure B E&E funding
the city has and the marketing outreach resources from Valley Transportation Authority (VTA)2.
Mobility 5.3-Promote Non-Auto Modes of Transportation Consider offering incentives as
part of a multimodal system approach,for projects that incorporate travel demand
2 https://www.vta.org/faq/how-do-i-start-riding-vta
1 https://www.tamcmonterey.org/monterey-county-rail-extension
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management techniques and promote transit ridership,biking,and walking in order to
reduce air pollution,energy consumption,and greenhouse gas emissions.We disagree
with the staff’s recommendation that the city does not yet have an incentive program,that this is
a small project and doesn’t require a Vehicle Miles Traveled (VMT)analysis.Gilroy has the
vision that the glass is half full,and we have the ability to innovate and adapt to programs that
will further reduce our VMT.Gilroy has budgeted and will implement our own TDM/VMT policy.
In 2023 we should not be “sweeping”climate impacts and transportation impacts under the rug
by deeming their impact will be significant and unavoidable.It takes a combination of all-electric
construction and VMT reductions to mitigate the negative impacts to our environment.We have
solutions that work,including interacting with transit agencies,to bring more frequent transit to
areas like Murray-Las Animas that are seeing an increase in development.This takes
innovation through policies and programs that we have.
The FIRSTCARBON SOLUTIONS CEQA Guidelines Consistency Checklist (VMT page
95-96)-The traffic report for the project found that though implementation of Transportation
Demand Management (TDM)strategies could potentially achieve a reduction in the project’s
VMT per worker below the Governor’s Office of Planning and Research (OPR)recommended
15 percent below existing VMT impact threshold,that some of the TDM strategies may not be
applicable or feasible to be implemented by the proposed project.29 OPR’s recommended 15
percent below existing VMT impact threshold encourages developments in transit-centered,
highly mixed-use areas to implement design features and trip reduction measures to take
advantage of existing multi-model infrastructure and land use mixes in reducing trip making
and/or trip lengths.However,many communities such as Gilroy have very limited multimodal
transportation infrastructure and lack a mix of complementary land uses.The minimal existing
multi-model infrastructure reduces the opportunity for non-vehicular trips to the site.Therefore,it
is unlikely that developments like the proposed project in these cities can achieve OPR’s
recommended 15 percent reduction in VMT.Therefore,absent the City adopting its own
City-specific VMT policies and impact thresholds,if the project cannot reduce its VMT per
worker to below the impact threshold,the proposed project’s VMT impact would be deemed
significant and unavoidable.
As shown in analysis above,the City of Gilroy does not have a CEQA qualified GHG reduction
plan.While the proposed buildings would be all-electric design and would provide clean air
vehicle parking spaces with EV charging facilities as required by Title 24 Standards,the
proposed project would have a significant VMT impact,which would result in the proposed
project conflicting with the BAAQMD GHG Guidelines threshold Criterion A.Therefore,the
proposed project would result in significant GHG emissions impacts since it cannot meet either
criterion A or B of the BAAQMD significance threshold.This finding is consistent with the
General Plan EIR’s determination that GHG impacts would be significant and unavoidable for
projects consistent with the General Plan’s buildout assumptions.
Response-Gilroy does not have limited multi-modal transportation infrastructure,and just like in
the above excerpt regarding transit access,parameters and definitions need to be provided for
these assessments to stand.While there might be portions of our city that are isolated from
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transit,this development is not in one of those areas.Gilroy has a fully connected bike network
and transit options.Many residents may be employed outside of Gilroy,and that is even more
reason that alternative transit modes will be sought out.As well,we have a large population that
works and attends school in Gilroy that benefits from local transit and rideshare.Gilroy has the
vision that the glass is half full,and we have the ability to innovate and adapt to programs that
will further reduce our VMT.Gilroy has budgeted and will implement our own TDM/VMT policy.
In 2023 we should not be “sweeping”climate impacts and transportation impacts under the rug
by deeming their impact will be significant and unavoidable.It takes a combination of all-electric
construction and VMT reductions to mitigate the negative impacts to our environment.We have
solutions that work,including interacting with transit agencies,to bring more frequent transit to
areas like Murray-Las Animas that are seeing an increase in development.This takes
innovation through policies and programs that we have.
Transportation Demand Management Mobility 1.12-Encourage existing and proposed
development to incorporate TDM measures such as car-sharing,transit passes,and
unbundling of parking (requiring separate purchase or lease of a parking space)where
such measures will result in a reduction in vehicle miles traveled,reduction of required
amount of parking or an increase in the use of alternate transportation modes.As
recommended in the CEQA Consistency Checklist (Page 95)TDM programs to include:
●Annual Clipper Card,VTA Passes or VTA’s Smart Pass
https://www.vta.org/go/fares/smartpass (The Smart Pass program allows employers,
developers,educational institutions,management companies or homeowners
associations the ability to purchase VTA transit passes at a bulk discount rate to provide
to employees or residents to encourage transit usage.Smart Passes are good for
unlimited use of VTA Bus and Light Rail services,seven days a week.The program also
includes an “Emergency Ride Home”provision that allows Smart Pass holders to take a
taxi home if they need to leave work in the middle of the day.)
●Expand Outthink’s Project Chrysalis E-Bike Program with the purchase of e-bikes or a
pool of e-bikes for rideshare in a central hub for the project.3
●Provide updated city bike maps to all employees/contractors from management in
correspondence.
●Provide routes to major transit connections,parks,schools,shopping,and restaurants.
●Annual presentation to the E&P Properties New Warehouse Building of current
bike/walk/transit options and incentive programs offered by the City of Gilroy currently
funded by the Measure B Education &Encouragement program.
●Encourage Bay Area Air Quality Management District’s and the Metropolitan
Transportation Commission’s (MTC)new post-pandemic compliance option for the
regional Commuter Benefits Program:Telework “Flex Your Work”program.Carpooling,
public transportation,vanpools,bicycling,walking and teleworking are flexible choices
Bay Area employees have when planning daily commutes.Both the new Commuter
Benefits Program Option 5:Telework and the “Flex Your Commute”program will
3 https://svcleanenergy.org/wp-content/uploads/CityChrysalis_FinalReport_29Mar2022_digital.pdf
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encourage sustainable commuting options as the Bay Area continues its recovery from
the pandemic and returns to the workplace.
Sincerely,
Gilroy Bicycle Pedestrian Advisory Committee (Gilroy BPAC)
GilroyBPAC@gmail.com
https://www.facebook.com/GilroyBPAC
We are a community group actively embracing,advancing ideas,and projects that promote the concept of
free-range people in Gilroy.We support building projects that are energy resilient and promote the
reduction of greenhouse gasses (GHG).We are seeking your input whether you are a BMX rider,trail
runner,recreational bike rider,MTB rider,walker,and hiker!#GilroyBPAC
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