Local zoning requires no parking

Michael, I think you may fall under the special circumstances choice on the letter template. My thoughts are that you are not adding new parking since these parking spaces existed prior to renovation and to the fact that the number of parking spaces is being reduced. I would think that in your narrative you explain your project and that even though your space is 75% less than the total building area, your project complies with Option 2 of Case 2. I would also reference a CIR ruling for NC SSc4.4 dated 5/23/08. The Ruling states, " In regard to the second question, the reduction in parking numbers as a result of the development of this project can be considered an equivalent approach to Option #4 – No New Parking. The submittal documentation should clearly identify the pre-development and post-development parking scenarios and numbers, demonstrating no net increase in parking as a result of this new project." In your case, it would be equivalent to Option 2 of Case 2. Either way, I think you can clearly argue you are meeting the credit intent. Good luck.