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discussed below, the local standard for parking at a"large unit development" such as Great Northern Mall is inconsistent with the parking needs for the use as demonstrated by national parking studies. It is also important to note that the local parking code is based on a measure of "floor area" which is defined at 1161.04(c) as follows: "Floor area" means the total area of all the floors shall be measured from the exterior faces of the building, escept that an area used for storage of inerchandise or housing mechanical equipment may be excluded if approved lry the Building Offic'ial, or only the floor area occupied by the specific use (emphasis added) if so set forth in the schedule in Section 1161.05, Based on the foregoing sections of the Zoning Code, therefore, it is my understanding that the Great Northern Mall is required to provide 6.5 parking spaces for each 1,000 square feet of "total floor area" or for such lesser part of the entire floor area as interpreted by the Building Official. (The Building Offieial has indicated that the actual applicable floor area to parking ratio has, in the past, turned out to be about 5.2 pazking spaces per 1000 square feet of total floor area.) The interpretation of the amount of floor area to be considered for parking calculation is an important issue in this case. Industry Parking Standards . Effeetive parking standards are of interest to communities, to engineering and planning professionals, and to property owners thr.oughout the country due. to the costs and irripacts of having too much or too little parking. Hundreds and thousands of unneeded parking spaces require consumption of immense amounts of paving material; create significant maintenance and repair costs, and gerierate significant environmental impacts. Insufficient parking inconveniences patrons and reduces commercial revenues. For these reasons, professional organizations continuously monitor parking needs and issue periodic reports and recommendations. Among the most frequently consulted studies of shopping center parking requirements are those published by the Urban Land Institute (ULI). ITLI has recently (1999) published an updated second edition of Parking Rje4uirements for Shopping Centers. Compared to the previous edition (published in 1982), this report was prepared with the benefit of a much greater amount of parking data from large shopping centers in the size category of Great Northem Mall. The report thus provides the most up-to-date information for local officials, planners, and developers in making important decisions about needed parking facilities for large centers. The data provided in Parkin? Rec?uirements for Shopping Centers is based on a questionnaire completed by 500 shopping center respondents and a parked caz survey of 169 centers around the country. It is important to note that 70 of those centers exceeded 800,000 GLA. Their experience is thus relevant to an expanded Great Northern Mall (cunently 897,000 GLA, proposed 1,170,000 GLA). Page 3 of 6