Dear Mr. Edwards:
The City has reviewed the Final Mitigated Negative Declaration and Initial Study with respect to the potential impacts of the proposed Continuation High School on San Jose [sic] as well as the projects conformance with the City of San Jose Municipal Code and San Jose 2020 General Plan. The City does not consider the Initial Study to be complete nor the Mitigated Negative Declaration to be adequate as it relates to parking impacts. In response to our comments regarding the parking deficiency and the need for a parking study, the District indicated that a parking assessment had previously been completed; however, a copy was not included in the Initial Study. A copy of the parking assessment was not made available to the City of San Jose, even though the City had requested a copy.
The City of San Jose Municipal Code/Zoning Ordinance contains the parking requirements for new development in San Jose based upon the type of development proposed. The proposed Continuation High School does not conform to the City of San Jose Municipal Code/Zoning Ordinance because it does not meet the City of San Jose Municipal Code/Zoning Ordinance parking requirements which are identified in Section 20.12.215. of Title 20 of the Municipal Code/Zoning Ordinance. Projects found to be inconsistent with this Municipal Code requirement are considered by the City to have the potential for a significant impact on the environment.
The Municipal Code/Zoning Ordinance parking requirement for middle schools is one parking space for each teacher and each employee. The parking requirement for high schools, however, is one parking space fore each teacher and for each employee, plus one for each seven students. The Municipal Code/Zoning Ordinance parking requirement for the addition of the proposed Continuation High School would be 105 spaces for the high school (50 spaces for high school students, 49 spaces for high school staff and six spaces for visitors). The District is proposing to add only 60 parking space for the entire proposed high school project, which will provide parking for only 3 percent of the students in addition to the 49 high school employees.
In our letter of Oct. 20, 1999, the City requested a copy of the parking analysis, which should adequately analyze both the current proposed parking demand for the high school, should include the present and proposed use of transit by the students, and should conclude that reduced parking would be warranted. To date, the School District has not provided a copy of the parking analysis to City staff, nor has it been included in the Initial Study. In the absence of the requested parking analysis, the City considers the project to be inconsistent with the San Jose municipal Code since it does not provide adequate parking for the proposed project, and it likely to result in parking impacts upon the surrounding neighborhood.
Because the project may result in a significant land use compatibility impact, a Mitigated Negative Declaration should not be issued for the project until a parking study is completed and incorporated into the Initial Study that ensures that parking from the project will not impact the surrounding neighborhood. A copy of the revised Initial Study including the parking analysis should be provided to the City.
The City of San Jose appreciates the opportunity to review and comment on this project.
Sincerely,
Joseph Horwedel
Deputy Director of Planning
Willow Glen, California Since 1992
