We respectfully submit the following request for a ruling regarding the application of this credit for rehabilitation projects where the existing parking capacity is not known. The existing pavement was excessively worn and weathered from many years of disuse-significant portions of the asphalt were broken or severely deteriorated and no parking stripes were visible. Consequently, it was not possible to determine how many parking spaces existed prior to our renovation. Our new parking area is in the same approximate location and area as the previous parking area. With no known numerical capacity previous to our project, we were unable to demonstrate that we provided "no new parking capacity." If the site were treated as "new construction," our requirement would be to not exceed minimum zoning requirements. According to the zoning requirements, 93 stalls were required, however we reduced the onsite parking to 54 stalls, providing 46% less parking than required by zoning. We not only met the requirements of "new construction" but surpassed them. As per the 1/18/2005 ruling, this is almost enough for an exemplary parking reduction credit. May we elect to use the "new construction" guidelines for rehabilitation projects which have no documentable existing parking capacity? If this is not acceptable, is there another method recommended for projects where the existing parking capacity cannot be determined?
The project team is proposing to use the new construction path of providing parking at or below code requirements for a rehabilitation project. The project is maintaining the same total parking area but cannot prove an existing parking count. The new parking count will be 46% below code requirements. It is acceptable to use the new construction path in this case since the new parking area is roughly equivalent to the existing area, regardless of actual count. This ruling is also consistent with the structure of this credit in v2.2. Applicable Internationally.