02 Environmental Commission Backup and Recommendation.pdf — original pdf

Backup

ENVIRONMENTAL COMMISSION MOTION 20221102-002 Date: November 2, 2022 Subject: Brodie Oaks Redevelopment PUD, C814-2021-0099 Seconded by: Kevin Ramberg Motion by: Jennifer Bristol WHEREAS, the Environmental Commission recognizes the applicant is Request PUD zoning for the property and; WHEREAS, the Environmental Commission recognizes that the applicant is proposing 11 acres of parkland dedication, although the density dictates 29 acres, and the applicant is proposing to address the additional 18 acres with a pay in lieu fee, and the Environmental Commission recognizes the environmental fragility of the area; and WHEREAS, the Environmental Commission recognizes the site is located in the Barton Creek Watershed and the Barton Springs Zone; and WHEREAS, the Environmental Commission recognizes that Staff recommends this PUD with conditions. THEREFORE, the Environmental Commission recommends the Brodie Oaks Redevelopment PUD with the following conditions: Staff Conditions: A. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8, Subchapter A, Article 13 (Save Our Springs Initiative) at the time of permit application except as modified below. a. Section A of 25-8-514 (Pollution Prevention Required) shall be modified to allow a maximum impervious cover for the site of 56% net site area. B. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8 Section A (Water Quality) at the time of permit application except as modified by the PUD ordinance. a. ECM 1.6.7.5 (D) shall be modified to allow captured runoff for beneficial reuse b. 25-8-341 shall be modified to allow cut not to exceed a maximum of fourteen (14) feet. c. 25-8-342 shall be modified to allow fill not to exceed a maximum of fourteen (14) feet. d. 25-8-281 shall be modified to allow encroachment into CEFs as indicated on Exhibit F. C. Additionally, development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with the following requirements 1 1 of 52a. Reduction in impervious cover from 84% NSA to 56% NSA b. Bring the site into compliance with SOS water quality treatment requirements c. Clustering impervious cover and disturbance 75-250’ away from Barton Creek Greenbelt d. Restoring 2 acres of the tract to native vegetation e. Provide 100% GSI for water quality controls f. Provide rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area g. Provide superior tree protections h. Comply with Austin Green Building 3-star rating i. Exceed landscaping requirements j. Provide superior open space and parkland dedication. and the following Environmental Commission Conditions: 1. 2. 3. 4. 5. Work with staff to reduce the maximum height of the buildings to reduce the canyon effects and reduce bird strikes in the Balcones Canyonlands Preserve zone Utilize dark skies best practices for all outdoor lighting Require all buildings to utilize bird friendly glass and building best practices Require on-site energy creation including solar and combined heat and cooling systems Increase EV stations prewiring preparation to 50% throughout the property including spaces at the free parking spaces at the park Include pollinator gardens and plants to support Monarch butterfly and other pollinators Utilize best practices to contain trash to ensure it does not spill over into Barton Creek Work with staff to consider mitigation within the Barton Creek Watershed to bridge the gap between the SOS impervious cover requirements Include restroom and dog waste station at the trailhead and neighborhood park Include natural play area best practices in the neighborhood park Environmental Commission will be kept apprised of void discovery during construction of Brodie Oaks PUD and notified timely by report and/ via email, especially as it relates to any structural or catastrophic voids encountered, including efficacy of water quality modeling and attenuation of the water quality features onsite. 9. 10. 11. 6. 7. 8. VOTE 9-1 For: Aguirre, Barrett Bixler, Bedford, Brimer, Bristol, Qureshi, Ramberg, Schiera, and Scott Against: Thompson Abstain: None Recuse: None Absent: Nickells Approved By: Kevin Ramberg, Environmental Commission Chair 2 2 of 52 ITEM FOR ENVIRONMENTAL COMMISSION AGENDA November 2, 2022 Brodie Oaks Redevelopment PUD C814-2021-0099 Armbrust & Brown (David Armbrust) 4107 S Capital of Texas Highway COMMITTEE MEETING DATE: NAME & NUMBER OF PROJECT: NAME OF APPLICANT OR ORGANIZATION: LOCATION: COUNCIL DISTRICT: 5 ENVIRONMENTAL REVIEW STAFF: Leslie Lilly, Environmental Program Coordinator, (512)535- 8914, Leslie.lilly@austintexas.gov WATERSHED: Barton Creek Watershed/Barton Springs Zone REQUEST: PUD zoning for the property STAFF RECOMMENDATION: STAFF CONDITION: Staff recommended with conditions A. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8, Subchapter A, Article 13 (Save Our Springs Initiative) at the time of permit application except as modified below. a. Section A of 25-8-514 (Pollution Prevention Required) shall be modified to allow a maximum impervious cover for the site of 56% net site area. B. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8 Section A (Water Quality) at the time of permit application except as modified by the PUD ordinance. 3 of 52a. ECM 1.6.7.5 (D) shall be modified to allow captured runoff for beneficial reuse b. 25-8-341 shall be modified to allow cut not to exceed a maximum of fourteen (14) feet. c. 25-8-342 shall be modified to allow fill not to exceed a maximum of fourteen (14) feet. d. 25-8-281 shall be modified to allow encroachment into CEFs as indicated on Exhibit F. C. Additionally, development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with the following requirements a. Reduction in impervious cover from 84% NSA to 56% NSA b. Bring the site into compliance with SOS water quality treatment requirements c. Clustering impervious cover and disturbance 75’-250’ away from Barton Creek Greenbelt d. Restoring 2 acres of the tract to native vegetation e. Provide 100% GSI for water quality controls. f. Provide rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area. g. Provide superior tree protections. h. Comply with Austin Green Building 3-star rating i. Exceed landscaping requirements. j. Provide superior open space and parkland dedication. 4 of 52 ENVIRONMENTAL COMMISSION MOTION 20221102-003 Seconded by: Kevin Ramberg Date: November 2, 2022 Subject: Brodie Oaks Redevelopment Site Specific SOS Amendment, C814-2021-0099 Motion by: Jennifer Bristol WHEREAS, the Environmental Commission recognizes the applicant is making a request in response to Council Resolution 20221011-076, consider a site-specific amendment to City Code Chapter 25-8, Subchapter A, Article 13 (Save Our Springs Initiative), as minimally required to allow for limits to impervious cover as proposed in application C814-2021-0099 for the Brodie Oaks PUD development. The proposed site-specific amendment should be included as part of the discussion and consideration of the Brodie Oaks PUD development and; WHEREAS, the Environmental Commission recognizes the site is located in the Barton Creek Watershed and the Barton Springs Zone; and WHEREAS, the Environmental Commission recognizes that Staff recommends this Site Specific SOS Amendment with conditions. THEREFORE, the Environmental Commission recommends the Brodie Oaks Redevelopment Site Specific SOS Amendment with the following conditions: Staff Conditions: A. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8, Subchapter A, Article 13 (Save Our Springs Initiative) at the time of permit application except as modified below. a. Section A of 25-8-514 (Pollution Prevention Required) shall be modified to allow a maximum impervious cover for the site of 56% net site area. B. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8 Section A (Water Quality) at the time of permit application except as modified by the PUD ordinance. a. ECM 1.6.7.5 (D) shall be modified to allow captured runoff for beneficial reuse b. 25-8-341 shall be modified to allow cut not to exceed a maximum of fourteen (14) feet. c. 25-8-342 shall be modified to allow fill not to exceed a maximum of fourteen (14) feet. d. 25-8-281 shall be modified to allow encroachment into CEFs as indicated on Exhibit F. C. Additionally, development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with the following requirements 1 5 of 52 a. Reduction in impervious cover from 84% NSA to 56% NSA b. Bring the site into compliance with SOS water quality treatment requirements c. Clustering impervious cover and disturbance 75-250’ away from Barton Creek Greenbelt d. Restoring 2 acres of the tract to native vegetation e. Provide 100% GSI for water quality controls f. Provide rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area g. Provide superior tree protections h. Comply with Austin Green Building 3-star rating i. Exceed landscaping requirements j. Provide superior open space and parkland dedication. and the following Environmental Commission Conditions: 1. 2. 3. 4. 5. Work with staff to reduce the maximum height of the buildings to reduce the canyon effects and reduce bird strikes in the Balcones Canyonlands Preserve zone Utilize dark skies best practices for all outdoor lighting Require all buildings to utilize bird friendly glass and building best practices Require on-site energy creation including solar and combined heat and cooling systems Increase EV stations prewiring preparation to 50% throughout the property including spaces at the free parking spaces at the park Include pollinator gardens and plants to support Monarch butterfly and other pollinators Utilize best practices to contain trash to ensure it does not spill over into Barton Creek Work with staff to consider mitigation within the Barton Creek Watershed to bridge the gap between the SOS impervious cover requirements Include restroom and dog waste station at the trailhead and neighborhood park Include natural play area best practices in the neighborhood park Environmental Commission will be kept apprised of void discovery during construction of Brodie Oaks PUD and notified timely by report and/ via email, especially as it relates to any structural or catastrophic voids encountered, including efficacy of water quality modeling and attenuation of the water quality features onsite. 9. 10. 11. 6. 7. 8. VOTE 9-1 For: Aguirre, Barrett Bixler, Bedford, Brimer, Bristol, Qureshi, Ramberg, Schiera, and Scott Against: Thompson Abstain: None Recuse: None Absent: Nickells Approved By: Kevin Ramberg, Environmental Commission Chair 2 6 of 52 COMMITTEE MEETING DATE: NAME & NUMBER OF PROJECT: NAME OF APPLICANT OR ORGANIZATION: LOCATION: ENVIRONMENTAL REVIEW STAFF: WATERSHED: REQUEST: COUNCIL DISTRICT: 5 STAFF RECOMMENDATION: STAFF CONDITION: ITEM FOR ENVIRONMENTAL COMMISSION AGENDA November 2, 2022 Brodie Oaks Redevelopment Site Specific SOS Amendment C814-2021-0099 Armbrust & Brown (David Armbrust) 4107 S Capital of Texas Highway Leslie Lilly, Environmental Program Coordinator, (512)535- 8914, Leslie.lilly@austintexas.gov Barton Creek Watershed/Barton Springs Zone In response to Council Resolution 20221011-076, consider a site- specific amendment to City Code Chapter 25-8, Subchapter A, Article 13 (Save Our Springs Initiative), as minimally required to allow for limits to impervious cover as proposed in application C814-2021-0099 for the Brodie Oaks PUD development. The proposed site-specific amendment should be included as part of the discussion and consideration of the Brodie Oaks PUD development. Staff recommended with conditions A. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8, Subchapter A, Article 13 (Save Our Springs Initiative) at the time of permit application except as modified below. a. Section A of 25-8-514 (Pollution Prevention Required) shall be modified to allow a maximum impervious cover for the site of 56% net site area. 7 of 52 B. Development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with 25-8 Section A (Water Quality) at the time of permit application except as modified by the PUD ordinance. a. ECM 1.6.7.5 (D) shall be modified to allow captured runoff for beneficial reuse b. 25-8-341 shall be modified to allow cut not to exceed a maximum of fourteen (14) feet. c. 25-8-342 shall be modified to allow fill not to exceed a maximum of fourteen (14) feet. d. 25-8-281 shall be modified to allow encroachment into CEFs as indicated on Exhibit F. C. Additionally, development associated with C814-2021-0099, located at 4107 S Capital of Texas Highway, shall comply with the following requirements a. Reduction in impervious cover from 84% NSA to 56% NSA b. Bring the site into compliance with SOS water quality treatment requirements c. Clustering impervious cover and disturbance 75’-250’ away from Barton Creek Greenbelt d. Restoring 2 acres of the tract to native vegetation e. Provide 100% GSI for water quality controls. f. Provide rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area. g. Provide superior tree protections. h. Comply with Austin Green Building 3-star rating i. Exceed landscaping requirements. j. Provide superior open space and parkland dedication. 8 of 52Brodie Oaks Redevelopment PUD 4107 S Capital of Texas Highway C814- 2021- 0099 Leslie Lilly Environmental Program Coordinator Watershed Protection C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 9 of 52C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 10 of 52Site Background • Proposed new PUD • Part of original 128-acre Barton Creek Plaza Development • Current site - 37.6 acres • Full Purpose Jurisdiction • Activity Center for Redevelopment in Sensitive Environmental Areas in Imagine Austin Vision Plan • Council District 5 C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 3 11 of 52C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 12 of 52C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 5 13 of 52Environmental Features • Barton Springs Watershed • Barton Springs Zone • Edward Aquifer Recharge and Contributing Zone • 84% Impervious Cover • Brodie Oaks Seep/Spring CEFs • Airman’s Cave • Non-compliant with SOS water quality requirements C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 14 of 52C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 15 of 52Land Use Plan C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 8 16 of 52Proposed Environmental Code Modifications • • • • 25-8-341 (Cut Requirements) shall be modified to allow cut not to exceed a maximum of fourteen (14) feet as indicated on Exhibit G. 25-8-342 (Fill Requirements) shall be modified to allow fill not to exceed a maximum of fourteen (14) feet as indicated on Exhibit G. 25-8-281 (Critical Environmental Features) shall be modified to allow encroachment into CEFs as indicated on Exhibit F. SOS Ordinance Section A of 25-8-514 (Pollution Prevention Required) shall be modified to allow a maximum impervious cover for the site of 56% net site area. C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 17 of 52C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 10 18 of 52E x h i b it G : G r a d i ng P l a n C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 11 19 of 52Exhibit F: Environment 1. Modify CEF setback for S-1/S-2 Impact to Airman’s Cave CEF 2. setback is limited of up to 80’ with conditions 3. Protective fencing for CEFs C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 12 20 of 52C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 13 21 of 52E x h i b it F : Wa t e r Q u a l i t y 1. Brodie PUD with comply with SOS with subgrade ponds for retention/reirrigation system and rainwater harvesting with beneficial reuse Infiltration testing 2. 3. Trenching > 5’ will be inspected by geologist C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 14 22 of 52Proposed Environmental Superiority • Clustering impervious cover 75-250’ away from Barton Creek Greenbelt • Restoring 2 acres of the tract to native vegetation • Provide 100% Green Stormwater Infrastructure for water quality controls that meet SOS non- degradation pollutant removal. • Provides rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area. • Provides superior tree protections. • Exceed landscaping requirements. • Provide superior open space and parkland dedication • Complies with Austin Green Building 3-star rating C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 23 of 52Additional Environmental Elements • Reducing impervious cover from 84% NAS to 56% NSA (36% decrease) • Rainwater will be used to offset potable water demands for irrigation and cooling tower makeup water (in accordance with 25-8-151 (Innovative Management Practices) • Remove retaining walls from greenbelt edge and restore more natural grade • LEED Neighborhood Development certification • U.S. Green Building Council SITES certification C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 24 of 52Exhibit F: Open Space C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 17 25 of 52AEGB 3 Star R ating 2022 Requirements • Bicycle parking and supporting facilities • Electric vehicle charging • Energy performance • Dual plumbing to reduce potable demand C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 18 26 of 52Recommendation S t a f f r e c o m m e n d s a p p r o v a l o f t h e P U D w i t h t h e f o l l o w i n g c o n d i t i o n s • Reduce impervious cover from 84% NSA to 56% NSA • Cluster impervious cover 75-250’ away from Barton Creek • Restore 2 acres of the tract to native vegetation • Provide 100% Green Stormwater Infrastructure for water quality controls that meet SOS non-degradation pollutant removal. • Provide rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area. • Provide superior tree protections. • Exceed landscaping requirements. • Complies with Austin Green Building 3-star rating • Provide superior open space and parkland dedication • LEED Neighborhood Development certification • U.S. Green Building Council SITES certification C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 27 of 52Brodie Oaks Redevelopment SOS Site-Specific Amendment 4107 S Capital of Texas Highway C814- 2021- 0099 Leslie Lilly Environmental Program Coordinator Watershed Protection C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 28 of 52What is an SOS Site-Specific Amendment • • • • • • • 1 9 9 2 S a v e O u r S p r i n g s o r d i n a n c e a d o p t e d b y c i t i z e n i n i t i a t i v e P e r 2 5 - 8 - 5 1 5 , v a r i a n c e s t o S O S a r e n o t a l l o w e d , p r o h i b i t i n g m o d i f i c a t i o n b y P U D o r d i n a n c e 2 5- 8 - 2 6 R e d e v e l o p m e n t E x c e p t i o n i n t h e B S Z d e e m e d n o t a p p r o p r i a t e O n l y a p p l i e s t o t h e B r o d i e O a k s R e d e v e l o p m e n t P U D p r o j e c t S u p e r m a j o r i t y o f C o u n c i l m u s t a p p r o v e a m e n d m e n t s t o S O S C o u n c i l R e s o l u t i o n 2 0 2 2 1 0 1 1 - 0 7 6 o n O c t o b e r 1 3 , 2 0 2 2 : “ T h e C i t y M a n a g e r i s d i r e c t e d t o i n i t i a t e s i t e s p e c i f i c v a r i a n c e s … . . C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 29 of 52Other SOS Site-Specific Amendments 10111 Dobbin Drive Garza Ranch Ordinance No. 20130926-051 C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 30 of 52C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 31 of 52SOS Requirements 2 5- 8 - 5 1 4 P o l l u t i o n P r e v e n t i o n R e q u i r e d • I m p e r v i o u s c o v e r i n t h e E d w a r d s A q u i f e r R e c h a r g e Z o n e i s 1 5 % N S A , 2 0 % N S A i n t h e C o n t r i b u t i n g Z o n e • W a t e r Q u a l i t y C o n t r o l s r e q u i r e d f o r r u n o f f f r o m a l l i m p e r v i o u s c o v e r t o m e e t u n d e v e l o p e d c o n d i t i o n s . C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 32 of 52Brodie Oaks SOS Site-Specific Amendment S e c t i o n A o f 2 5 - 8 - 5 1 4 ( P o l l u t i o n P r e v e n t i o n R e q u i r e d ) s h a l l b e m o d i f i e d t o a l l o w a m a x i m u m i m p e r v i o u s c o v e r f o r t h e s i t e o f 5 6 % n e t s i t e a r e a . B r o d i e P U D O r d i n a n c e 2 5- 8 - 3 4 1 s h a l l b e m o d i f i e d t o a l l o w c u t n o t t o e x c e e d a m a x i m u m o f f o u r t e e n ( 1 4 ) f e e t a s i n d i c a t e d o n E x h i b i t G . 2 5- 8 - 3 4 2 s h a l l b e m o d i f i e d t o a l l o w f i l l n o t t o e x c e e d a m a x i m u m o f f o u r t e e n ( 1 4 ) f e e t a s i n d i c a t e d o n E x h i b i t G . 2 5- 8 - 2 8 1 s h a l l b e m o d i f i e d t o a l l o w e n c r o a c h m e n t i n t o C E F s a s i n d i c a t e d o n E x h i b i t F. • • • • C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 33 of 52Land Use Plan C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 26 34 of 52E x h i b it F : Wa t e r Q u a l i t y 1. Brodie PUD with comply with SOS with subgrade ponds for retention/reirrigation system and rainwater harvesting with beneficial reuse Infiltration testing 2. 3. Trenching > 5’ will be inspected by geologist C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 27 35 of 52Recommendation S t a f f r e c o m m e n d s a p p r o v a l o f t h e S O S a m e n d m e n t w i t h t h e f o l l o w i n g c o n d i t i o n s • Reduce impervious cover from 84% NSA to 56% NSA • Cluster impervious cover 75-250’ away from Barton Creek • Restore 2 acres of the tract to native vegetation • Provide 100% Green Stormwater Infrastructure for water quality controls that meet SOS non-degradation pollutant removal. • Provide rainwater harvesting for landscape irrigation of not less than 50% of the landscaped area. • Provide superior tree protections. • Exceed landscaping requirements. • Complies with Austin Green Building 3-star rating • Provide superior open space and parkland dedication • LEED Neighborhood Development certification • U.S. Green Building Council SITES certification C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 36 of 52Questions? C o n t a c t I n f o r m a t i o n : L e s l i e L i l l y l e s l i e. l i l l y @ a u s t i n t e x a s . g o v C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 37 of 52C I T Y O F A U S T I N W A T E R S H E D P R O T E C T I O N D E P A R T M E N T 30 38 of 52 November 2, 2022 TO: Austin Environmental Commission Via Hand-delivery and email FROM: Bill Bunch, Executive Director, SOS Alliance RE: Brodie Oaks PUD needs changes to meet required “superior” standards, to comply with Austin’s Imagine Austin Comprehensive Plan, and to meet Water Forward and Climate Equity Plan goals Dear Chair Ramberg and Commissioners: Save Our Springs Alliance representatives have actively engaged with Applicant representatives off and on for over a year on this project. The goal has always been to reach agreement on all issues so that Brodie Oaks would be a model project that would set a very high standard for redevelopment in the Barton Springs watershed and for the larger Austin community. While we can agree on some key elements, and very much appreciate the Applicant’s efforts to engage with neighborhood and environmental representatives and provide answers to our questions, the project as currently proposed does not meet required “superior” standards on environmental issues and does not fully meet Imagine Austin, Austin Climate Equity, and Austin Water Forward environmental and planning standards. For context, the current development holds approximately 360,000 square feet. The proposed development would, according to the Applicant, total about 3.2 million square feet. Thus the proposal is not simply a significant increase in overall density but would rather be roughly a 900 percent increase in density. While some substantial density increase is readily supported, the scale and type of development proposed both push the project into “inferior” status and in direct conflict with multiple environmental standards and planning goals. SOS does support a narrowly tailored SOS ordinance site specific amendment for the Brodie Oaks PUD. This amendment would accept the Applicant’s proposed reduction in impervious cover from 84% gross site area to approximately 56% net site area and the Applicants commitment that SOS “pollution prevention” requirements would be met with SOS level water quality controls. 1 39 of 52Our consulting expert, Dr. Lauren Ross, Ph.D., P.E., has reviewed the details of the Applicant’s water quality controls. Dr. Ross generally agrees with the Staff that if implemented as described the water quality controls would provide the necessary treatment and capture volumes to meet the “pollution prevention” standards. In doing so, pollutant loading from the site would be greatly reduced, along with the impervious cover, as compared to the current development. The environmental shortfalls to “superiority” are, however, significant. We ask that the Environmental Commission vote to find that the proposed PUD is not environmentally superior and should be denied unless the following changes shortfalls are corrected: 1. Need for offsite mitigation land to reduce overall impervious cover to below 15% net site area and to mitigate for offsite pollution and environmental impacts. The Brodie Oaks tract rests within the Barton Springs recharge zone and thus is otherwise subject to a 15% net site area limit. We recognize that under the SOS redevelopment exception ordinance, the council has discretion to approve a much higher level of onsite impervious cover when considering the specific circumstances of a project. That SOS exception ordinance contemplates and in some cases requires the acquisition of land or conservation easements offsite so that the overall impervious cover (taking the two tracts together) meets SOS impervious cover standards. Absent this offsite mitigation requirement, the proposed PUD cannot be viewed as “superior” to either the SOS ordinance or the SOS redevelopment exception ordinance requirements. The SOS redevelopment ordinance provides in relevant part at Section 25-8-26: “(G) City Council shall consider the following factors in determining whether to approve a proposed redevelopment: (1) benefits of the redevelopment to the community; (2) whether the proposed mitigation or manner of development offsets the potential environmental impact of the redevelopment; (3) the effects of offsite infrastructure requirements of the redevelopment; and (4) compatibility with the City's comprehensive plan. (H) Redevelopment of property under this section requires the purchase or restriction of mitigation land if the site has a sedimentation/filtration pond. . . . (1) The combined gross site area impervious cover of the mitigation land and the portion of the redevelopment site treated by sedimentation/filtration ponds may not exceed 20 percent.” 40 of 52As noted below, several of these factors are implicated by the proposed redevelopment project. Offsite impacts will be substantial given that the project is heavy on office, retail, and hotel that will drive secondary development further out into the Barton Springs watershed, in direct conflict with Imagine Austin goals. As proposed there would be developed 1.2 million sq. feet of office, 140,000 sq. ft. of retail, and a 200 room hotel – all of which will create a demand for yet more housing over the Barton Springs Edwards Aquifer watershed. 2. Need to reduce height to meet Climate Equity Plan and “carbon neutral” goals Skyscrapers are not climate-friendly, primarily because of the “embodied” energy required to manufacture the concrete and steel required to support very tall buildings. There is now solid research showing that cities that develop with mid-rise and low-rise projects that are dense enough to support public transit and walkability and limit land consumption have greatly reduced greenhouse gas emissions when compared to skyscraper development. This short piece from October 2021 in Resilience provides an excellent summary on the issue. We do not have an exact height limit to recommend at this time but keeping the height low enough, in the 5 to 10 story range, that use of energy intensive steel and concrete construction can be minimized or avoided altogether, while being consistent with Imagine the Imagine Austin Comprehensive plan should be recommended. This would allow substantial increase in density and likely could accommodate all of the proposed residential development if the 1.2 million square feet of office and hotel were scaled back. Converting the internal streets from auto traffic to pedestrian malls would also allow more of the onsite impervious cover to be dedicated to buildings rather than car habitat. 3. Need to remove skyscrapers or other otherwise reduce density to meet Austin Water Forward “net zero water” goals. The skyscrapers in the plan not only push the site away from being “carbon neutral” but also result in the project failing to meet “net zero water” goals. These buildings and the extra density they accommodate translate into having too little available onsite water to meet summer cooling tower, landscaping, and other project water demands. By reducing the scale of the development, the project would be able to flush toilets and meet other onsite water demands that cannot be met as proposed. 4. Need to remove skyscrapers to be consistent with the Imagine Austin Comprehensive Plan’s call for an “activity center in a sensitive environmental area.” SOS respectfully disagrees with Staff’s stated conclusion that the proposed development is consistent with the Imagine Austin Comprehensive Plan. The “activity center in an environmentally sensitive area” designation calls for lower density, low- to mid-rise redevelopment that supports public transit without inviting major density centers into the Barton Springs watershed. As proposed, the project would be more on the order of a “satellite 41 of 52downtown,” especially when the large commercial tracts across Lamar and adjacent to the Brodie Oaks tract move toward redevelopment. The attached list of Imagine Austin and neighborhood plan references prepared by long-time Zilker neighborhood/South Lamar development expert Lorraine Atherton make clear that the proposal, in its current form, is not consistent with the Imagine Austin Comprehensive Plan and should be scaled back to be consistent. It is certainly not “superior” to the comprehensive plan requirements. 5. Parks need more attention and should be “public” and mostly kept natural and not converted to outdoor commercial areas controlled by the developer. 6. Please request that the matter be returned to the Environmental Commission when there is an actual draft zoning ordinance to be reviewed. We have learned from the Statesman PUD that having boards and commissions “review” a complex “zoning” ordinance that addresses far more than zoning when that ordinance does not actually exist leads to all kinds of problems – problems that are hidden from view or simply go unnoticed when they are not written down on paper. To address this problem, please include in your recommendation that the Environmental Commission be allowed to again review and make recommendations when there is an actual draft ordinance to review. Currently the staff back-up says there are 43 code modifications requested. Several of these have not been addressed here, and some of these are very important. For example, the proposal appears to mostly gut Hill Country Roadway Ordinance protections that are important not just for scenic beauty but also for air quality, urban heat island, and carbon capture. These issues deserve some attention, at least to the point of what is being lost from what would otherwise be required. Regretfully, we have not figured this one out yet. It only recently registered with us that the proposal would greatly reduce setbacks from a spring on the site. We also do not yet understand this issue but of course are concerned and don’t see how reducing setbacks from the spring can be environmentally superior. As to Airman’s Cave, we do believe that, given the unique geology of the site and the configuration of the cave, that the cave should be adequately protected. Thank you for your service to the community and for your consideration. Sincerely, 42 of 52Bill Bunch Enclosure Cc: David Armbrust, Pat Oles, Milo Burdette, Applicants Melissa Hawthorne, Barton Hills Neighborhood Assn. Lorraine Atherton, Zilker Neighborhood Assn. Hon. Ann Kitchen, Councilmember, District 5 43 of 52Here's a run-down of the passages relevant to the proposed Brodie Oaks PUD from Imagine Austin [with Lorraine’s comments in square brackets]. The references to building height are found on page 105. Here goes: Pages 100-103, Figures 4.2 (Bicycle and Pedestrian Networks), 4.3 (Transit Networks), 4.4 (Roadway Networks), and 4.5 (Growth Concept Map): On all maps, the dots indicating the activity center at Ben White and Lamar are positioned to the east, between Lamar and Manchaca, not on top of Barton Creek. Page 104, Growth Concept Map Definitions, Activity Centers and Corridors Centers that are already established by existing small-area plans . . . are drawn to reflect those plans. Centers without small-area plans are simply shown with a circle, indicating scale and general location. Specifying boundaries for these centers may occur through small-area plans" [In this case, the center's boundaries should now reflect the South Austin Combined neighborhood plan. The South Austin Combined NP captures perfectly the definition of an activity center in the third paragraph on page 104. The Brodie Oaks proposal, on the other hand, has no library, no college campus, no high school, no hospital, no playing fields, no housing choices other than high-rise multifamily, and no transit center. It has one bus stop, and the Brodie PUD proposal pushes it south to the equivalent of a highway on-ramp, isolating it from any possible pedestrian traffic.] Page 105, description of Regional Centers "The central regional center encompassing Downtown . . . is the most urban. It includes low- to high-rise residential and office buildings." [Regional Center is the only category that includes high-rise buildings. The intersection of Ben White and South Lamar is NOT a regional center in Imagine Austin. Also see page 124 below.] Page 105, description of Town Centers "The buildings found in a town center will range in size from one- to three-story houses, duplexes, townhouses, and row houses, to low- to midrise apartments, mixed use buildings, and office buildings. These centers will also be important hubs in the transit system." [Town Center is the only category that fits the "Activity center for redevelopment in sensitive environmental areas" designation for the intersection of Ben White and South Lamar. The South Austin Combined NP fits the Town Center description perfectly, with lots of variety embedded in a grid of South Austin bus routes with established routes to the north and east.] 44 of 52Page 106, Activity Centers for Redevelopment in Sensitive Environmental Areas “Five centers are located over the recharge or contributing zones of the Barton Springs Zone of the Edwards Aquifer or within water-supply watersheds. These centers are located on already developed areas and, in some instances, provide opportunities to address long-standing water quality issues and provide walkable areas in and near existing neighborhoods.” [Note that it says "existing neighborhoods," not "new."] “State-of-the-art development practices will be required of any redevelopment to improve stormwater retention and the water quality flowing into the aquifer or other drinking water sources. These centers should also be carefully evaluated to fit within their infrastructural and environmental context." [In this case, the size of the proposed project overwhelms the fire, power, water, and street infrastructure that can be provided within the environmental context. Attempts to provide that increased level of services to the Brodie site will necessarily divert resources away from the redevelopment of the Westgate and South Austin Hospital areas, which are already under way.] "The Growth Concept Map not only guides where Austin may accommodate new residents and jobs but also reflects the community intent to direct growth away from environmentally sensitive areas including, but not limited to, the recharge and contributing zones of the Barton Springs segment of the Edwards Aquifer, and to protect the character of neighborhoods by directing growth to areas identified by small area plans." [In this case, growth should be directed to the approved South Austin Combined neighborhood plan, which is well-positioned as an education, medical, and transportation hub, and able to absorb a large population in the redevelopment of large and small shopping centers.] "Protect Austin's natural resources and environmental systems by limiting land use and transportation development in sensitive environmental areas." "transit stops are identified as ‘proposed.’ As more detailed planning occurs, these may move. When this happens, the associated activity center should move as well." [In this case, the Westgate transit center has moved to Ben White at Victory, which means the associated activity center should be the South Austin Combined neighborhood plan area. Given the state highway department’s policies controlling the Lamar right of way south of Panther, it Page 107: Also, Page 108: 45 of 52will not be possible to change traffic patterns or make any substantial pedestrian or transit connections to the Brodie Center in the foreseeable future.] Page 118, Best Practices: “One of the most critical pieces of the code is the concept of ‘successional zoning.’ This allows rezoning only to the next most intense zone if the property abuts a more intense zone. This promotes a controlled evolution of the built environment and minimizes opportunities for developers to acquire a property and request a rezoning to a dramatically different intensity or use.” [In other words, rezoning of Brodie Oaks should not exceed the zoning across the street, which is GR with a VMU overlay.] Page 124, Figure 4.6, Combined Future Land Use Map: There is one, and only one, parcel designated as a bright blue "Activity Center." It is the Westgate Shopping Center, on the southeast corner of the Ben White-Lamar intersection. 46 of 52From: To: Cc: Subject: Date: Rivera, Andrew; Rhoades, Wendy Brodie Oaks PUD postponement request at Planning Commission C814-2021-0099 Monday, November 7, 2022 10:40:11 AM *** External Email - Exercise Caution *** Hello, Ms. Rhodes and Mr. Rivera, The Zilker Neighborhood Association requests that the Planning Commission rezoning hearing for the Brodie Oaks PUD, case C814-2021-0099 (items 2, 3, and 4 on the Nov 8 agenda), be postponed to November 15. We'd like to review materials presented at and after the Environmental Commission hearing, including but not limited to the affordable housing agreement and bonus calculations, the terms of the site-specific amendments to the SOS ordinance and the proposed restrictive covenant amendments, the parking calculations, the traffic and transit recommendations, the school impact analysis, the tree plans, the limits on excavations, the electric demand, the water and sewer demand, the fire and EMS demand, and conflicts with Imagine Austin and other planning guidelines. Thank you for your time. Best regards, David Piper, ZNA Secretary CAUTION: This email was received at the City of Austin, from an EXTERNAL source. Please use caution when clicking links or opening attachments. If you believe this to be a malicious and/or phishing email, please forward this email to cybersecurity@austintexas.gov. 47 of 52From: To: Subject: Date: Attachments: Rhoades, Wendy Rivera, Andrew RE: November 8, 2022 Planning Commission Agenda Tuesday, November 8, 2022 2:01:00 PM image001.png Andrew, Please see my responses below. Wendy From: Rivera, Andrew <Andrew.Rivera@austintexas.gov> Sent: Friday, November 4, 2022 2:11 PM To: Rhoades, Wendy <Wendy.Rhoades@austintexas.gov> Subject: FW: November 8, 2022 Planning Commission Agenda Wendy, Please see questions below from Commissioner Schneider. Thank you, Andrew From: Schneider, Robert - BC <BC-Robert.Schneider@austintexas.gov> Sent: Friday, November 4, 2022 1:16 PM To: Rivera, Andrew <Andrew.Rivera@austintexas.gov> Subject: Re: November 8, 2022 Planning Commission Agenda Hi Andrew -- I have some questions for staff regarding the Brodie Oaks PUD. I am unable to attend Tuesday's meeting but would appreciate their response for my own as well as other PC members better understanding of the case. Thanks! Rob Questions on Items 02, 03, and 04, Brodie Oaks PUD As I understand it, this is the first case for a development in an activity center in an environmentally sensitive area. The SOS ordinance would require strict limits on impervious cover if this were a new development (as opposed to a redevelopment). While the applicant is reducing the impervious cover on this site compared to the site’s existing coverage, it is expected to be at a significantly higher level than the standard for new development under SOS. Redevelopment under SOS envisions the ability of an applicant to offset impervious coverage that exceeds current SOS limits by acquiring land or conservation easements so the impervious coverage of the two tracts taken together meets or exceeds the 15% SOS ordinance standard. Is the applicant doing that? If not, does staff believe the proposal demonstrates superiority, and if not, could staff articulate its rationale for that analysis? RESPONSE: The Brodie Oaks PUD project is not eligible for the conditions of the BSZ Redevelopment Exception due to proposed impacts of Critical Environmental Features on the site; therefore, staff did not require the project to comply with the conditions described in 25-8-26, including the purchasing of mitigation land. However, staff would support any recommendation from Planning Commission or Council to adopt this requirement. Instead of the Redevelopment Exception, the applicant was directed by staff to follow the process for a site-specific SOS 48 of 52amendment to address proposed impervious cover limits. This process requires a higher level of approval at City Council (super majority) and a higher level of water quality protection (full compliance with SOS water quality non-degradation requirements) compared to the BSZ Redevelopment Exception. Staff finds the Brodie Oaks PUD project to be environmentally superior with the included site-specific SOS amendment for impervious cover. I understand that the applicant is proposing to provide support for affordable housing by donating a portion of the site’s land to Foundation Communities for affordable housing. The idea is this is the offset for the bonus heights the applicant is requesting for the office buildings on the site. In a recent case further north on Lamar, the “Taco Cabana” PUD, did the applicants offer both land and funding for an affordable housing project in order to to support its claim of superiority? What were the details of the Taco Cabana PUD’s affordable housing contribution? RESPONSE: Council approved an amendment to the 0.933 acre Taco Cabana PUD on October 17, 2019 that revised its affordable housing program to include two different community benefit contributions for a total of $3,700,000 as follows: 1) a $1,200,000 cash donation for affordable housing to the Housing and Planning Department, and 2) a $2,500,000 cash donation to a Non-Profit for acquisition of the site at 1508 South Lamar Boulevard. The complete affordable housing program in the amended Taco Cabana PUD ordinance is provided in Part 8 (please refer to pages 5-6) below: document.cfm (austintexas.gov) Is staff able to provide an analysis of the value of the affordable housing contribution on this site, and to what extent it demonstrates superiority? RESPONSE: The affordable housing requirement for office buildings is typically a fee-in-lieu. The fee-in-lieu is equivalent to $7 per SF of bonus area. While the amount of bonus area is not able to be determined until building permits, the Applicant has provided an estimate of approximately $8.6 million dollars. The Applicant’s commitment as part of this PUD is to provide for a new Foundation Communities affordable housing project with a minimum of 100 family-sized units affordable to residents earning between 30% – 60% of median income. The commitment also includes a restrictive covenant that will ensure the property remains affordable at these levels in perpetuity. This commitment is superior to the PUD requirements by: Requiring that units are constructed on-site in this High-Opportunity area instead of paying the Fee-in-lieu. The value of a new affordable housing complex is much higher than the potential fee-in-lieu commitment. Filing a restrictive covenant that ensures an affordability period in perpetuity instead of the PUD required 40-year period. Collaborating with Foundation Communities, an organization with a long track-record of delivering successful projects that support residents on many levels beyond affordability. For the residential units the applicant is planning, I understand applicant intends to develop on-site affordable units at the 10 percent standard in typical bonus programs for the city. Does staff believe that commitment demonstrates superiority to meet the PUD approval requirement? RESPONSE: The commitment to affordability on this site does meet superiority as a full package. The Applicant reports that the project is also committing to source-of-income protections and affirmative marketing provisions. From: Rivera, Andrew <Andrew.Rivera@austintexas.gov> Sent: Friday, November 4, 2022 11:01 AM To: Shaw, Todd - BC <BC-Todd.Shaw@austintexas.gov>; Hempel, Claire - BC <BC-Claire.Hempel@austintexas.gov> Subject: November 8, 2022 Planning Commission Agenda Dear Chair Shaw, Vice-Chair Hempel and Members of the Planning Commission: Below please find the link to the November 8, 2022 agenda and backup (prelim. proposed consent agenda attached). If you have not done so, please let me know if you will be absent Tuesday evening. Please fill out the form, link below, to inform me of your availability to attend Tuesday evening. An absence without informing me of a reason prior to the date of the scheduled meeting will result in an unexcused absence (City Code, § 2-1- 26). 49 of 52 Planning Commission Question and Answer 2, 3, and 4: Commission Shaw / Staff Response: As I understand it, this is the first case for a development in an activity center in an environmentally sensitive area. The SOS ordinance would require strict limits on impervious cover if this were a new development (as opposed to a redevelopment). While the applicant is reducing the impervious cover on this site compared to the site’s existing coverage, it is expected to be at a significantly higher level than the standard for new development under SOS. Redevelopment under SOS envisions the ability of an applicant to offset impervious coverage that exceeds current SOS limits by acquiring land or conservation easements so the impervious coverage of the two tracts taken together meets or exceeds the 15% SOS ordinance standard. Is the applicant doing that? If not, does staff believe the proposal demonstrates superiority, and if not, could staff articulate its rationale for that analysis? RESPONSE: The Brodie Oaks PUD project is not eligible for the conditions of the BSZ Redevelopment Exception due to proposed impacts of Critical Environmental Features on the site; therefore, staff did not require the project to comply with the conditions described in 25-8-26, including the purchasing of mitigation land. However, staff would support any recommendation from Planning Commission or Council to adopt this requirement. Instead of the Redevelopment Exception, the applicant was directed by staff to follow the process for a site-specific SOS amendment to address proposed impervious cover limits. This process requires a higher level of approval at City Council (super majority) and a higher level of water quality protection (full compliance with SOS water quality non-degradation requirements) compared to the BSZ Redevelopment Exception. Staff finds the Brodie Oaks PUD project to be environmentally superior with the included site-specific SOS amendment for impervious cover. I understand that the applicant is proposing to provide support for affordable housing by donating a portion of the site’s land to Foundation Communities for affordable housing. The idea is this is the offset for the bonus heights the applicant is requesting for the office buildings on the site. • In a recent case further north on Lamar, the “Taco Cabana” PUD, did the applicants offer both land and funding for an affordable housing project in order to to support its claim of superiority? What were the details of the Taco Cabana PUD’s affordable housing contribution? RESPONSE: Council approved an amendment to the 0.933 acre Taco Cabana PUD on October 17, 2019 that revised its affordable housing program to include two different community benefit contributions for a total of 50 of 52$3,700,000 as follows: 1) a $1,200,000 cash donation for affordable housing to the Housing and Planning Department, and 2) a $2,500,000 cash donation to a Non-Profit for acquisition of the site at 1508 South Lamar Boulevard. The complete affordable housing program in the amended Taco Cabana PUD ordinance is provided in Part 8 (please refer to pages 5-6) below: document.cfm (austintexas.gov) Is staff able to provide an analysis of the value of the affordable housing contribution on this site, and to what extent it demonstrates superiority? RESPONSE: The affordable housing requirement for office buildings is typically a fee-in-lieu. The fee-in-lieu is equivalent to $7 per SF of bonus area. While the amount of bonus area is not able to be determined until building permits, the Applicant has provided an estimate of approximately $8.6 million dollars. The Applicant’s commitment as part of this PUD is to provide for a new Foundation Communities affordable housing project with a minimum of 100 family-sized units affordable to residents earning between 30% – 60% of median income. The commitment also includes a restrictive covenant that will ensure the property remains affordable at these levels in perpetuity. This commitment is superior to the PUD requirements by: • Requiring that units are constructed on-site in this High-Opportunity area instead of paying the Fee-in-lieu. The value of a new affordable housing complex is much higher than the potential fee-in-lieu commitment. • Filing a restrictive covenant that ensures an affordability period in perpetuity instead of the PUD required 40-year period. • Collaborating with Foundation Communities, an organization with a long track-record of delivering successful projects that support residents on many levels beyond affordability. For the residential units the applicant is planning, I understand applicant intends to develop on-site affordable units at the 10 percent standard in typical bonus programs for the city. Does staff believe that commitment demonstrates superiority to meet the PUD approval requirement? RESPONSE: The commitment to affordability on this site does meet superiority as a full package. The Applicant reports that the project is also committing to source-of-income protections and affirmative marketing provisions. Commissioner Mushtaler/ Staff Response: 1. I would like to know which department oversees water quality runoff for a development site both during and after construction? I would like to know the city process for this. Development Services Department (DSD) water quality reviewers and Watershed Protection Department (WPD) engineering staff will review the construction plans before construction begins. DSD Environmental Inspectors will inspect the project during construction and provide a final inspection once construction is complete. The developer is also required to obtain an 51 of 52annual Barton Springs Zone operating permit, requiring them to submit an annual maintenance plan and maintain their water quality infrastructure to the standards required by current code and applicable ordinances. WPD staff will inspect the water quality facilities for compliance. I would like legal to comment on status of MOU between BCP and developer? Will be sent via separate communications. I would like to know more from watershed on how this area feeds into drinking supply? aquifers? potable water? Water runoff from the Brodie Oaks site does not impact the drinking supply for Austin since the water source for our drinking supply comes from the Colorado River upstream of the site and treated at a water treatment plant. Regarding the Edward’s Aquifer and based on the analysis of Austin Water and Watershed Protection staff, there is little to no point-source infiltrations on the Brodie Oaks site to the Edwards Aquifer due to an existing layer of Del Rio Clay. However, the runoff from the site has the potential of entering the Edward’s Aquifer at a point recharge feature in the Barton Creek Greenbelt. The proposed project is required to comply with the Save Our Springs non-degradation water quality requirements, which would prevent the project from increasing sediment and pollutant loads from the pre-developed condition for any water flowing offsite. The project also proposes to reduce potable water demands by harvesting rainwater off all buildings within the project and using it for beneficial reuse. 24 Commissioner Thompson / Staff Response: • For the Secondary metric, is it the Percent of SF units that are affordable? I wasn't aware Census included this data. If it is simply the number of SF homes, how does that indicate that we are preserving affordable housing? If we bulldoze 3 affordable homes and replace with 40 units, 10% of which are affordable how does the metric change? o At this time, the secondary metric is simply the percent of SF units out of the total universe of housing units within the station (and not tied to explicitly affordable SF units). ETOD Goal 3 aims to both preserve and increase both affordable housing and “attainable” (non-luxury) market-rate housing. These Complete Community Indicators (that this metric is part of) are intended to help staff find a starting point of future detailed station area planning that will follow approval of the Policy Plan. This metric allows us at a glance to see whether most of the residents living in a station area live in SF homes or not. For instance, if a station today has a large percentage of its existing housing stock as SF homes, it could indicate that allowing and/or incentivizing more types of housing units (beyond SF) could help increase the amount of attainable and affordable units overall, benefiting transit ridership as well as providing access to 52 of 52