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"...it is estimated that during 40 percent of the hours of tlle year, over half of the available spaces will be empty." The recorrimended parking ratios are specifically designed for centers in which retail shops occupy S0% or more of the GLA. This is because non-retail uses such as cinemas, large restaurants, and sizeable food courts have significantly different impacts on parking demand and should be addressed separately if they aze a significant proportion of the GLA. The report also notes that the majority of centers responding to the survey are auto- dependent centers. Only 175 of the 500 responding centers are served by public transit, a factor which may reduce parking demand. Consistent with these industry recommendations is the experience of Simon Properties with other shopping centers which it owns and operates around the country. Parking ratios have been reduced at many of these centers, with the approval of the host communities, in recognition of the changing needs for parking. The representative from Simon can more fully describe these locations and their continued successful operations. Applying Industry Parking Standards to Great Northern Mall The industry parking standards should be used as a guideline-for evaluating the requested pazking variance at Great 1`+Torthern Ma11. The standards are applicable as follows: The parking ratio for Great Northern should be calculated based on GLA instead of the "total floor area" standard of the local code. GLA is more appropriate for this type of commercial development. - • The recommended parking ratio for a shopping center exceeding 600,000 s.f, of GLA is 4:5 spaces per 1,000 s.f o£GLA. The proposed Great Northem expansion will increase the GLA from 896,777 s.f to 1,170,277 s.f, The proposed parking facilities will result in a parking ratio of 4.51 spaces per 1,000 s.f of GLA. • It should be noted that Crreat Northern does not have a cinema or other entertainment facilities which increase parking demand beyond the demand of retail. The GLA devoted to the food conrt and restaurants, which may also generate higher parking demand, is also very low, reportedly less than 4% of the GLA. • Great Northem is served by RTA buses, a travel alternative which may reduce parking needs. • Several uses included within Great Northern's GLA are very low generators of parking demand. These include the Goodyear and Sears automotive centers and the J.C. Penney furniture store. Page 5 of 6