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Mayor Pulido and Members of the City Council April 2, 2018 Page 4 • Move-In/Move-Out Loading Area. The project proposes 260 residential rental units, As with any large multi -family project, there will be a consistent turnover of units with a need for loading and unloading of furniture, appliances, and other personal belongings, Whether these move -ins will be handled by personal vehicles or moving vans, a designated area inside the parking structure is needed to avoid delays which will impact visitors to and tenants of the Xerox Building. The project's plans have no such designated area, leaving the assumption that move -ins and move -outs will share the loading area for the retail projects and for residential UPS, FedEx, and other deliveries which abuts Xerox Centre Drive. (This location will be addressed in the next bullet item.) Again, there is a "fair argument" that the absence of a designated move-in/move-out loading area within the project's parking structure will result in adverse traffic impacts. * Loading Area. The location of the loading area immediately adjacent to Xerox Centre Drive has the potential to impact traffic on Xerox Centre Drive and, consequently, on Cabrillo Park Drive, As noted above, by placing the loading area next to Xerox Centre Drive, the potential for multiple and inevitably overlapping uses of the designated loading area has been created. This potentially could impact both Xerox Building visitors and tenants and, if backups and delays occur, traffic on Cabrillo Park Drive. The size and location of the loading area appears geared to the retail operations, but presents potential stacking and double- parking Issues (and the resulting potential for impacts to Cabrillo Park Drive traffic) not just for retail deliveries, but also for the many daily FedEx, UPS, and Amazon deliveries to the residents of the 260 units. It appears that the location of the loading area simply has not taken into account its potential impacts on adjacent property. Typically, a project's loading area would be designed and located where the burden of overlapping uses would affect only the project itself and not its neighbors. That is not the case here and, as a result, creates a "fair argument" that an impact could arise, thus necessitating additional analysis in the project's EIR. • Parking Variance. We addressed issues related to the parking variance at the Planning Commission and were pleased that the Planning Commission rejected the variance. We are also pleased to see that the Staff Report does not recommend approval of the parking variance. In short, the proposed variance does not meet the requirements of your City code for the issuance of a variance. There are no "special circumstances" or other conditions specified in your Zoning Ordinance that would allow the granting of a parking variance. Beyond the fact that a parking variance would not be legally valid under your zoning ordinance, given the proximity of the Xerox Building parking structure to the proposed