Item 3 - Exhibit 05 - Letter of JustificationMarch 13, 2020
City of Los Gatos Staff and Planning Commission,
RE: Letter of Justification for an Amendment to Approved Architectural and Site Approval S-13-090
We are requesting a modification to our Approved Architectural and Site Approval, File Number S-13-
090 to modify the Market Hall Building to remove the underground level of the project.
As approved, the Market Hall Building included 303 total parking spaces across four levels – three above
ground levels with a combined 176 parking spaces, and one underground parking level with 129 spaces.
As shown in the table below, of these, 50 are reserved for the use of the Senior Affordable Housing. The
Specific Plan dictates that commercial space within Phase 1 of North Forty shall comply with the Down
Town Parking Requirements per Town Code Section 29.10.150(b). Parking Guidelines call for 62 for the
main Market Hall space, 7 for the proposed bakery, and 5 for the community room, and 50 for the
residential portion, for a total of 124 parking spaces. This means that, as approved, the Market Hall
building is providing 179 parking spaces beyond what are required.
Market Hall - Parking Requirements
Use Size(1) Ratio (2) Parking Req Original Parking Revised Parking
Senior Housing 50 ½ space per unit 25 129 Level 0 Level 0
Senior Guest 50 ½ space per unit 25 63 Level 1 59 Level 1
Market Hall 18,729 1 space per 300 sqft 62 69 Level 2 70 Level 2
Bakery 2,032 1 space per 300 sqft 7 42 Level 3 47 Level 3
Comm. Room 2,772 1 space per 590 sqft 5 Total: Excess: Total: Excess:
Total 23,583 124 303 179 176 52
1)Size based on latest building permit plans
2)Ratio per city code and specific plan – 1 space per 300 for retail, ½ space per unit for residential
The Market Hall was originally designed with a basement level by Grosvenor, with the intent to use the
excess parking for future development in Phase II of North 40. With Grosvenor no longer involved in
Phase I of the project, SummerHill has no need for parking beyond what is required by Town Code and
the specific plan.
SummerHill is proposing to remove the subterranean parking level. This leaves the Market Hall project
with an excess of 52 parking spaces above what is required by the zoning code to serve the commercial
interests at North 40.
Removal of the underground parking will have a number of benefits, both over the course of
construction as well as in the future operation of the Market Hall. The construction of a subterranean
parking structure necessarily entails a number of impacts such as excavation, off hauling of soil, and
significant additional construction time. During operation, reducing the number of excess parking spaces
provided will limit traffic impacts, green house gasses, and encourage the utilization of public transit,
bikes, and other more environmentally sustainable methods for utilizing Market Hall.
Construction Impacts
EXHIBIT 5
Construction of Market Hall as currently designed involves the off haul of approximately 18,200 cubic
yards of soil. It is anticipated that this will require approximately 1,700 truck trips to remove material
from the site, and 400 inbound truck-loads of concrete to complete the basement. Eliminating the
basement parking will eliminate the need for these truck trips to and from the site during construction.
Benefits for operations
A fundamental concept in transportation planning is the idea of ‘induced demand’. This is a
phenomenon where, by providing excess capacity (such as on a highway, road, or in a parking structure),
additional demand is effectively created to utilize this space. Providing so many extra parking spaces in
Market Hall runs the risk of inducing additional demand for the project. This induced demand has
negative effects on the surrounding community by increasing traffic, noise, and pollution. Additionally,
lowering the number of parking spaces will increase the appeal of better and more sustainable transit
options such as biking or public transit to access the site.
Vacant parking garages can also serve to attract unwanted behavior since they are out of site of the
public, residents, and police. Eliminating the basement level will therefor also remove a potential future
source of public and private nuisance and of public safety enforcement inquiries, leading to better
operations for the site.
Fundamentally, the underground parking level is neither required nor needed by the project. Its
removal, and the removal of the associated excavation, soil off haul and concrete pours, will benefit the
community due to reduced construction activity, a faster horizon for the affordable housing, and
reducing traffic during both construction and operation. Market Hall will still provide 52 parking spaces
above what is required by code, and no negative impact on the surrounding community will occur based
on this change.