i would like to remind public members please silence your mobile devices when speaking before the commission state your name for the record. i would like to take role at this time. (roll call) we do expect

commissioner richards shortly. first is consideration of items for continuance. item one 2016-004403 c.u.a. 2222 broadway to may 2, 2019. items 2a and 2b. at 3140-3150 are proposed to continue to may 2, 2019. 20th street review is withdrawn. no speaker cards. >> does any member of the public have public comment on these items? this is the items proposed for

opinion you cans. with that -- continuance. commissioner koppel. >> vice president joel koppel: . >> second. >> on that motion to continue items as proposed commissioner hillis. >> aye. >> johnson, koppel and president melgar. aye. >> that passes unanimously 5-0. if you could rule on 2b. >> i will continue item 2b to the date specified. >> thank you. commissioners that places us to the consent calendar. they are considered routine by the planning commission and may be acted upon by a single roll call vote. there will be no separate discussion of these items unless a member of the commission, the

public or the staff so requests. item 42018-00532 c.u.a. at 468 valley street and a tem5. 2019-000325 c.u.a. i have no speaker cards. >> any member of the public who would like to comment on these items? >> with that, comment is closed. commissioner moore. >> commissioner moore: i ask to take valley street off consent as demolition. we typically review. i would like it off consent. >> thank you. commissioner moore. do you want to make a motion for

the other one? >> commissioner moore: i make a motion to an approval continuance of 3600 taraval street. >> i move for approval. thank you. >> seeing nothing further on the motion to approve item 5 under your consent calendar, commissioner hillis, johnson, moore, koppel and president melgar. so moved commissioners. that passes unanimously 5-0. item 4 is removed. shall we hear that at the beginning of the regular calendar. that places us under 6 consideration of adoption draft minutes for march 14, 2019. >> does any member of the public wish to provide public comment on the minutes. this is for the minutes from

march 14th. okay. with that public comment is now closed. commissioner hillis. >> thank you commissioners on the motion for march 14, 2019. (roll call). >> so moved that passes unanimously 5-0 places us on item 7. commission comments and questions. >> commissioner moore. >> commissioner moore: i have three items i would like to ask the commission to close the memory tonight. my reaction. she passed away on monday totally unexpected. fabulous waterfront neighborhood advocate. strong person, often in front of

the commission when we dealt with issues on the waterfront. the passing is unexpected i ask we close in her memory. i wanted to bring this up a few weeks ago an article. 100,000 homes are empty in san francisco. i would like to ask the director, perhaps not today but at some point to comment on how the sources for making such a statement were put together. 100,000 empty communities in light of the struggle we go through every week is absolutely unfathomable. i do not know how to identify the sources by which the data are compiled. i would like for guidance inputting that on ongoing discussions. i can pass this around for those who haven't seen it.

my third comment is going to b e a little bit emotional. i need to talk about memo to planning commission dated marc march 26. it is not on the agenda today but it speaks to changes in how we look at roof decks. i want to go back and reflect that throughout 2018, we made major strides in this commission to present policy and act on policy which much reflected and simplified how we look at drs which deal with roof decks. the memo in front of us that was also stuck in this very large package of this week's commission package does the opposite from what i think the commission had been supporting. i have to unfortunately say for me it is a misstep in the use of

discretionary power to come up with something which is completely counter to the major tenants of what we stand for. i like the director to, one, put a hold on this becoming law by tomorrow, april 5th so says the attachment to the memo. number two, allow the commission and the community to hear of what we all embraced on august 30th when a formal hear everything was held with respect to the subject matter. it was an executive summary, hearing date august 30th. residential roof deck policies which very clearly summarized the sensitivities and triggers which have been coming throughout the commission for at least the last three years and has gotten stronger and stronger to how we look at roof decks. we are not speaking just from the building, large building, we

are talking about roof additions in smaller neighborhoods. i strongly urge that this would be on hold until we have an ability to discuss with you and your staff where this should go because in the end, we have the discretion to again hear this as unnecessary. i want to stop. i am emotionally choked about it. you have taken it to the guidelines and then this shows up and it just doesn't do it. >> thank you, commissioner moore. director, did you want to say something? >> i was going to talk about this in my comments. i will do it now. what we proposed is department policy which there are several such policies in the department. what we attempted to do was

incorporate the direction you have been giving us over the last couple years on roof decks. you feel there is something we didn't capture correctly. i am happy to ask staff to hold off and have a hearing. the idea these would be interim policies and that we would report back to you in six months how they are working. if that is not correctly capturing your concerns, we need further discussion. that was the intent of these particular standards and procedures. >> thank you, director ram. i understood that from you, but i have also gotten an ear full from members of the public. we may want to be more cautious about it. commissioner moore. >> commissioner moore: i appreciate your saying it would be interim policy. any interim policy instills bad habits. i would suggest we are really strong in the major improvements

this commission has worked on very, very hard to bring on a better track. >> thank you, commissioners. >> we can move on to department matters, item 8 director's announcements. >> a couple announcements. we have talked about the roof decks. we will schedule a hearing on that. second thing is that article about the 100,000 units. i caught light of that. i think we need to look at the method. i can't imagine the number is near that. that is one quarter of the city housing stock. the city has only 400,000 units in total. >> this is in the entire bay area. >> okay. i don't know the number for the city. okay. we will look at that. the methods of calculating and discovering what units are truly vacant is an inexact sigh tense.

eye sense -- science. i am stunned to hear about ms. woods' passing. we worked with her closely. she was on the advisory board of our study of the rail yard plan, and she has been actively involved in the community in that part of the city for years and years and years. i am very sad to hear of her passing. she was a gracious person who i really enjoyed working with and speaking with. i am sad to hear of her passing. i would reiterate to have the meeting adjourned in her memory. thank you. >> if there is nothing further we will move to item nine. preview of past events of the board of supervisors per visors, board of appeals and historic preservation commission. >> i have the week of march 18

and this week. the land-use committee on march 18th considered supervisor peskin's ordinance to amend the open space from $4 per square foot to $6 per square foot for the conversion every tail to office. you -- of the retail to office. land use hearing there was public comment. >> i am sorry to interrupt you. >> i didn't see these speaker cards requesting to speak under director's report. >> i thought you were speaking under public comment. you can speak to the director's report. i am sorry to interrupt you. i have kathleen courtney, bruce bowen and. >> kathleen courtney. i was surprised and delighted to hear kathrin moore's comments.

we consider the statement a violation of the planning department process. it is something some of us have worked on over the last 30 or 40 years to work closely with the planning department and we considered it an insult really. we were part of the original 207 people that were not contacted about the august 2018 document. we worked hard, talked, negotiated, and i am not aware of any significant outreach that has occurred since then. we urge the commission to set this policy aside. in our neighborhood we have 13 alleys between 13 and 7 feet wide curb to curing within a seven blob radius -- block radius. these are small buildings that

will be adversely affected. it is different from the one we have been working with for the last year. thank you very much. >> thank you, ms. courtney. >> good afternoon, commissioners. thank you president melgar for allowing us to speak on this item. yes, i want to reiterate the same points that ms. courtney brought up. i also want to -- i am indignant and i find this insulting, frankly. we worked on this with the commission and with the planning department. i personally remember last year a whole bunch of activists part of our neighborhood organization came here, spent the time to testify about the perils of these roof decks that are going up and we have to come her as

part of dr. spend the entire day to argue against them. nine out of 10 times you side with us. these are not good uses of roofs and not good planning. we decided on this in may, august. imagine my surprise when i find the memo dated march 28th. i have no idea how this came out. this is definitely an abuse of discretionary power, and at this point we have no choice but talking to our supervisors and asking for change in planning code. if policies could come and go and this is bait and switch at some point this has to be part of the planning code so things like this would not happen. if we were not paying attention to this policy, all of a sudden changing. the only reason we paid attention is because the valley

iis disproportionately affected any person stature and money wants a view. what place other than top of 28th street and duncan. these are the views. this is not for somebody spending that money, this is not going to be used. this is a marketing tool. this speculate or is going to laugh all the way to the bank, and this is what we are trying to stop. this is a speculative behavior and allowing these decks to go up is going to add to the pocket of speculators. it is not going to do anything for the public. furthermore the process. please, do not implement this. if there is going to be a policy implemented we have to go back to the policy on august 30th. thank you very much. >> thank you. mr. bowen. >> thank you, commissioners.

san francisco land use coalition. in the interest of transparency i strongly support the previous speaker's comments. >> any other public comment on this item? with that public comment is now closed. >> very good. that places us on item 9 for review of past events of the board of supervisors, board of appeals and historic preservation commission. >> so this past on march 18th land use committee heard supervisor peskin's from $4 to $6 for conversion every tail to office. you heard this on february 21st. at land use there was public comment from the union square landowners about the increased fee. the committee voted to recommend the item to the full board. this week at land use committee

the mayor considered the small business streamlining ordinance. this item would among other theirs reduce the buffer around l c.u. resolution and ll c.u. resolution to 300 feet and rationalize liquor license restrictions. you heard this march 7th and voted to prove with modification to retain the conditional use for outdoor activity areas associated with bar use. after coming from staff it was continued to the call of the chair. the full board the week of marcd the ordinance to remove the grandfathering exception for inclusion housing on state housing. it was continued at that time. then they also passed on the streamlining contracting for homeless services and siding of

homeless shelters. this week the homeless shelter passed second read. supervisor peskin's ordinance on state bonus projects passed the first read. the union scare park recreation passed first read. the board heard the appeal for 10 year contract renewal and use permit for the outside music festival. it raised issues around the noise from the event. it should not be exempt and the department should imposition mitigation measures and thresholds. while it does increase the noise levels the duration is limited and does not result in significant noise impact. most public comment stated noise

was too loud and limits should be imposed. public comment for upholding the comments stated the noise was not too loud they are part of living in the urban setting andt was a benefit. they asked how the department analyzes the noise impacts and asked questions how to address the noise complaints. the supervisor fewer acknowledged the festival has trade-offs for the communities but the benefits out weigh the benefits. the appeal was denied unanimously. that concludes my report. >> thank you, mr. star. >> good afternoon. tim try department staff with two items from the historic preservation. the commission afforded a positive recommendation for landmark designation to 2851,

24th street. there was a good deal of discussion among the commissioners whether or not to extend the designation to the interior gallery spaces. there was a concern limitations in designated the interior volume would provide -- would result in restrictions that would limit new uses and contracting for that site. as a result, the commission decided to designate the exterior of the building the mural o on the exterior and the storefront immediately on the interior, sort of the storefront base and decided not to designate the volume. that recommendation will go to the full board and then referred to the land-use committee shortly. second item was 2031 bush street. in the japan town neighborhood.

the japanese language school. the building is significant for a variety of reasons including current use as language center. the possessing center for japanese internment during world war ii. booker t washington use during the war and return back to the japanese language school after the war when the japanese were allowed to move back to san francisco. the owners were there and support the designation and commission unanimously recommended initiation there is one more hearing at commission then to the full board for consideration. those are the two items to share. i am happy to answer any questions. >> thank you, mr. fry. is that it? >> i have no report for the board of appeals. that must be it.

commissioners that places us under general public comment. members of the public may address the commission on items of interest to the public that are within the subject matter. each member of the public may address the commission for up to three minutes. i have no speaker cards. >> good afternoon, commissioners, alex landberg. i am here to talk about generally something you are going to see today and down the line. today represents one of the first approv approvals or first opportunity to look at and approve the cannabis cultivation rush for southeast san francisco. i am a long time district 10 resident. i found myself over the past couple weeks working with a lot of elders and folks involved in

the equity side of things to start organizing how we in the neighborhood approach what is clearing a land rush. while i don' don't want to speak specifically to the projects you are looking at i do want to encourage you to take a certain approach to evaluating them. to see whether or not they meet the goals we have seen in the equity ordinance and all of the talk we have heard about what the opportunities of the cannabis industry are for hunters point, local contractors and workers and those incarcerated in the past. as you do that think back to the approval you had of the project on haut street where you saw broad turnout from everyone who we talk about is going to be benefiting from this growing industry. judge for yourself as you

evaluate projects whether or not there is that kind every sponsor whether or not you have a situation of a dog that didn't bark. you don't see meaningful commitment beyond a couple words on the page in an application. it will be some folks may show up on the projects down the line. i hope you take a hard look and set an example how these projects should move forward. thank you. >> thank you. any other public comment? okay. with that general public comment is now closed. >> commissioners that places us under the regular calendar. item four will be considered now. 2018-00532 at 468 valley street. conditional use authorization.

>> good afternoon, president melgar and members of the commission. planning department staff. the project before usa conditional use authorization for the demolition of an existing two story, 1696 square foot single family dwelling and construction of four story 4755 square foot two dwelling units. it is the existing structure was constructed as single family home in 1907. historic resource evaluation was conducted and concluded the home is not considered a resource. properties in the immediate area consist of residential one to three story single and multi family dwellings constructed between the early 1900s and late 1980s. the subject exhibits a variety of architectural styles.

the properties are located within the rh2 zoning district. the existing structure is approximately 1696 square feet with one bedroom and one bathroom and mesh i measures 27t and 5 inches in height. two three bedroom dwelling units with two 300 for unit one and 1822 for unit two the height is 49 feet and 5 inches with first floor 12 feet from front believe and 17 feet and 8 inches from the front property. to date staff received one comment in support. staff recommends approval of this conditional use authorization in that the project is on balance consistent with objectives and policies of the general plan. the project involves demolition

of the residential structure it will provide two family units of very comparable size. department finds the project to be necessary, desirable and compatible with the surrounding neighborhood and not detrimental to persons or properties in the vicinity. this concludes staff's presentation. i am available to answer questions. the sponsor is also here. >> thank you. we will hear from the project sponsor. >> good afternoon. commissioners. i am here on behalf of the project sponsor who is also here to answer questions if you have that. i will keep my comments fairly short. this project will replace a one unit building with two.

>> units. they would be about 2100 square feet and 1-800-conveyor feet. i -- square feet. no -- 1800 square feet. it will increase residential dense see consistent with rh2. we feel this is necessary and desirable replacing a single unit fallen into disrepair with two moderate units. the owner worked closely with the planning staff t to ensure design and scale is compatible and meets the design guidelines. it will increase the housing stock and availability of family housing and it is not requesting variances or code exceptions. for these reasons we ask you please approve the conditional use authorization. we are available for questions. >> did the project sponsor want to speak or are we done? okay. any public comment on this item?

okay. public comment is now closed. commissioner moore. >> commissioner moore: question is to mr. washington. we spend a great deal of time a year or two ago on discussing the effect or the geometry of popouts in rear yards. in drawing 8, 1.1. there is a first floor pop up which to my understanding has to be of equal depth to meet the yard requirements. on the east side it is a one story, 6.7 by 6.7 square feast. west is from three story to two story to one story. my understanding of the rules you explained at that time and many times we all learn on the run. those pieces have to be of equal

size. >> southwest team leader. could youlaborate on your question? are you questioning whether or not this is compliant with the rear set back requirements? >> compliant with the popout and extent of popout on either side on the first floor. that is what i'm looking at. west side has deeper piece. both sides are to be symmetrical. >> that is not consistent with the popout. the rear set back appears to be in full compliance. >> the hatched area? >> that's correct. it is in compliance with rear set back requirements and popout allowance. >> that is what at that particular discussion we were

told could not be more than 5 feet. >> in that circuit may have been a situation where it was actually extending beyond the required set back line that would allow the popout. in this instance the rear set back of the building is consistent and the amount included in the popout is compliant with what our code would require. >> i have to take your word for that. the residential design guidelines speak about the gradual stepping of buildings. however, this is far taller than the surrounding uses. how did you address that? >> this is residential. they looked at it from the standpoint that the alteration or new construction is of such scale that is relatively consistent with the massing on that block. if you go to the front elevati

elevations, the residential design team felt this alteration, there is a variety of different housing heights along the block face. they felt this would still become pat believe. the existing house is pushed back. it will move forward. it has a hip roof and they are going with a flat roof on the new floor and it is going to have a floor taller but set back at such a point it is not going to change the visual massing along if street to such a degree that we felt it was consistent with our standards. we also weigh into the fact that again we are creating a situation now, taking an existing house with one bedroom and increasing the density to

the point where we get two family sized dwellings that will be of equal flats which is the direction we are giving the builders when they are coming with this proposal when they are taking down a house and putting up something and consistent with the rh2 district. >> the other point b to make to the commission. these are large units. that is fine with multiple bedrooms. not particularly family oriented for the reason there is such a significant degree of excavation that the lower unit literally sits in the hall like a bunker. there is nothing wrong otherwise but that needs to be brought to everybody's attention. that is an unusual layout. >> this particular design is coming in with two relatively

equal flats with habitable space on the bottom lower level. as the second level is primarily full flat and above that is the second flat with the popout on the roof. they are ofrel i feel equal size. that is the direction we have been giving buildings over the years in situations like this. initially they are allter operations. we are calling them demolition which is new construction. >> i am not arguing with you. i am fully cog any san cognizanu are saying. they are not family oriented for people with four or five children. they are comfortably large units. >> thank you.

commissioner koppel. >> vice president joel koppel: g direct the project sponsor in the direction we are typically looking to see the projects go. i make a motion to approve. >> second. >> on that motion to approval this matter with conditions. (roll call). so moved that motion passes unanimously 5-0. places us on item 10 for the market street draft environmental impact report. comments will be accepted until 5:00 p.m. on april 15, 2019. >> could i get the screen, please. >> good afternoon, president

melgar and members of the commission. chris thomas planning coordinator for the better market street project. purpose of the hearing is comments on the draft environmental impact report for the proposed better market street project. joining me are wade, principal environmental planner and allison, resources team manager along with christine, project member. public works and the sf m.t.a. and city consultant. your commission was provided notice of availability for the draft at the public review which began on february 28 and continues through 5:00 p.m. april 15, 2019.

propose to provide a project to a 2.2-mile long corridor along market street between stewart and octavia. the project also including portions of streets intersecting market street for off corridor intersections, a loop formed by charles j brennan and mcallister and the portion of valencia street between market street. the project would restrict private vehicle access, establish lanes, change muni stop locations and stop characteristics including enlarging the enter islands.

the project would result in a new bikeway in each direction to be gauge separated from the curb lane separated from the pedestrian zone changes to the loading zones and vehicular parking on the side streets. relocatering the bikeway to require relocation of the lights and replacement of the existing break with a new ada compliantser u surface with the -- surface on the sidewalk. the bikeway in the street on the curb lane. generally sharing with transit and traffic. in the proposed the bikeway is now up at the sidewalk level. this would necessitate the movement every aligning of the path of gold standards.

for the historic f line trolley. the overhead contact system and state-of-the-art good repairs upgrades for the subsurface utilities. streetscape would be altered with removal of trees and replacement with more disease resistant trees. with implementation of street life showns. throughout the corridor. the draft e.i.r. analyzed the western variant it includes the 0.6 market street. a point 300 feet east of the haze and market street intersection. in this area the western area

would provide wider sidewalks and further restrict private vehicle access to improve bicycle safety, comfort and mobility. the draft e.i.r. finding the project would result in significant level related to cultural resources, circulation and noise specifically project will impact the cumulative impacts related to add verse change to design landscape associated with market street plan. project level impacts to cumulative impacts related to transportation and circulation while the project is under consideration. cumulative impact with respect to transit operations on the muni 27 bryant line and considerable contribution to cumulative impact related to noise from the projected.

the redevelopment plan and historic preservation held a project hearing on march 20th. i believe you have been provided a letter with summary. there are copies of letter for the public to review and will be put at the project website. historic preservation commission provided comments regarding riotingretention of the granites and new materials should be compatible with the landscape district. they urged commission to review potential impacts to the z un i restaurant that could result from the modifications proposed by the western variant. they found the historic resources and ranges studied to be adequate. the draft analyzed five alternatives.

two partial alternatives and corelments alternative. as you know they are analyzed when there is an impact to the cultural landscape district. alternative b is full preservation alternative to avoid impacts by not implementing the bikeway avoiding changes to the sidewalks and leaving the path of gold standards and brick surface among the other contributing features in the existing condition. alternative c is partial preservation alternative one to include sidewalk level bikeway and changes proposed by the project but include the sidewalk surface that references the existing brick to the extent allowed by ada standards. this would result in a significant impact to the

landscape district less than the proposed project. alternative d is partial preservation two. it would retain the existing streetscapes. changing boarding islands and stops would occur it would be modified as proposed by the project. partial alternative two would result in impact to the landscape district, less than the proposed project. we don't have an exhibit for alternative e. this alternative would include the same features as proposed project exempt not include the subsurface good repair. it would allow the proposed project to proceed with less construction related effects. full alternative is supervisor

pier your but would have the impacts to circulation and noise. to conclude comments today should be directed to the accuracy of information contained in the draft e.i.r. for members of the public pospeak please speak slowly to assist stenographer. comments will be transcribed and responded to in writing in the document which will respond to all verbal and written comments received and revise the draft e.i.r. as popeiate. those interested in comments may submit comments to me, chris thomas. 1650 mission street, suite 400, san francisco. or sfgov. the planning department will

prepare the document to contain responses to all comments on the draft er for today and sent to the planning department by 5:00 p.m. on a.m. 15. we anticipate the public indicate in the fall of this year with the certification hearing following that. this concludes my presentation. thank you.

the boarding island. this is concern for the elderly and disabled also for the general public. the plan reduces the number of boarding islands to six inbound and four outbound. distances between islands ranges from a long 1082 feet to completely unacceptable 2867 feet. this is over half a mile. distances between six of the 10 stops exceeds 2000 feet. this creates an extremely adverse on all transit passengers and is not adequately discussed i in the dir.

if this is adopted it will mitigate the adverse impacts. the enhanced concept preserves reasonable stops facing while still reducing the number of stops from what currently exists. in addition there is a failure to include island stops at fourth street. the intersection of the new central subway which is due to open later this year. this is totally contrary to good transit practice. it makes a long access path to and from the central subway platform longer. asto stop at fourth street is a necessity. aside from the comments on the dir i would like to thank

commissioner moore and director ram for recognizing the passing of ms. woods. it is my pleasure to work with her for many, many years on waterfront related situations. she has been a font of knowledge. i don't think anyone understands the waterfront in the manner in which she did. it is a tremendous loss to the city. thank you. >> next speaker, please.

>> hundreds of thousands of people ride this and market street is one of our most dangerous streets for people walking and biking. we need to take the opportunity to create a street that is safe and inviting for all users to prevent future lives lost. the proposed project will make market street safer for people biking with the bike lines we are in full support of. i want to echo the support. the project proposal could go further by including elements of that in the proposed plymouth. strengthen vehicle restrictions an raised bike lines would create a continuous protected

and safe bicycle route through the core of our city. it's only fair to consider options that include safety for all users throughout the entire project. ultimately the better market street project is key to san francisco for everybody that use the street. and we need to do everything we can to create a safe street so that everyone in the city can feel safe using market street. this will determine how stave and inviting market street is and we can't limit safety measures. we need to do as much as we can and approve a great project. thank you for the opportunity to comment on the project. we'll be submitting more detailed written comment to address the environmental report directly.

>> thank you. next speaker, please. >> i'd like to take the opportunity to remind members of the public the meeting is intended to receive public comment on the draft and environmental impact report not on the project itself. >> i live at 100 van ness and part of the better mark working group and have been a member of the predecessor committees an involved in civic center in many ways. generally i'm strongly in favor of the plan and think the a.r. draft is by and large accurate. it's inclusive. it took forever to prepare as you know and thinks have changed and it makes a comment on page

4a, 63 and 64 leading to cultural resources the existing hurdles to the underground transit stations won't be disturbed. that's not accurate. the city has had a policy of getting rid of the crement -- cement portals where it could and it replaced them with a structure that's safer and doesn't attract graffiti and that policy should be continued. mta and bart has a program to build canopies and have two finished. they have a contract out to build several more one of which at eighth and one in front of

the theatre. the second thing i wanted to mention is that the historic section it marks those figures involved in the development program but didn't talk about the politics or issues raised by the projects. and in my book for the flyer for which i gave out may 15th, in 1971 a number of people criticized those and the head of the art commission. >> could you please into the mic. and a famous sculptor called the work of the fountain brutal and

has no relationship to anything and you have to design a place for people to sit on the grass. if we're going to highlight the historic part of that area we need to include the stories. the consults need to include all that in the material. >> thank you. next speaker, please. >> hello commissioner. i work in the city downtown. i have a family and my kids go to school here. these projects are great for make the roads safer but i would like you guys to keep in mind there's still families here and have to get to schools and i want to say don't forget about us that have to get to work and get our kids to school and can't use bike lines. we have to transport them because the schools are

scattered all over the place so take that into consideration. thank you. >> thank you mr. flores. next speaker, please. >> i'm the executive director of san francisco transit riders and we're the advocate for an always-growing public transit. we've been actively involved in this project. we have concerns the project isn't going far enough. we submitted written comments and first the deir budget meets inappropriate criteria and worsens congestion and costs more to operate. we think it's insulting to transit users and it use the dysfunctional system as the base for comparison. as an organization we recommend the system as the base casep