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6/16 Agenda Item F2 - discussion about General Plan NOP

From: domainremoved <Patti>
Date: Fri, 12 Jun 2015 13:01:29 -0700

Dear Honorable Mayor and Councilmembers,
I wish to draw your attention to the issue of defining "maximum potential
 development" in the General Plan update Notice of Preparation
conversation.
It is critical that this definition be made more clear and measurable.

As I understand EIR's, the project scenario and alternative scenarios to be
studied are clearly quantified and represent what is expected to occur
during the timeframe to be studied. As pointed out in my prior letter
(below) to the Planning Commission, the language in the staff report
(middle of what is now page 72, or page 272 of your entire packet) makes
reference to an amount of potential development that is not easily
measured. It is based on something that is not a concrete and easily
quanitified fact but instead is a potentially debatable and not easily
measured concept: "[growth] beyond what is already realistically
achievable under the current Menlo Park General Plan Land Use Element."
 Growth is easy to measure from a fixed point, such as from the amount of
square feet and residential units currently built and approved. So why
obfuscate and make things unnecessarily complex? Additional discussion is
in the letter below.

I want to point out the staggering magnitude of the growth proposed for a
community that really cares about financial sustainability, about
responsible growth that ensures a healthier balance of jobs and housing,
and about potential impacts on traffic, schools, and residential quality of
life. The proposed total amount of development and ratio of types of
development appear to worsen, not improve. each of those factors, when
improvement is what many of us residents hope a long-term plan would
accomplish. Please reconsider the absolute amounts and ratio in the context
of what has been already approved and not-yet-built. Now is the time to
make changes, not after the NOP is issued.

The General Plan and its EIR should not be vehicles to create and study
"worst case scenarios" but rather to create and study the amount and type
of development that is desired (i.e., "the project") for and by our
community. Those are not at all the same things. The zoning ordinance
changes that implement the revised General Plan will allow what is studied
("the project") so it should be what the entire community understands and
accepts as its future.

Respectfully submitted,
Patti Fry
Former Planning Commissioner

---------- Forwarded message ----------
From: Patti L Fry <pattilfry_at_(domainremoved)
Date: Mon, Jun 8, 2015 at 2:50 PM
Subject: tonight's discussion about General Plan NOP
To: "planning.commission_at_(domainremoved)


Dear Planning Commissioners,
I offer the following observations for your discussion about the "maximum
potential development" to be studied in the GP update:

TYPES OF USES Because the M-2 has traditionally been the economic
breadbasket of Menlo Park, I think it's essential for the GP update to
evaluate non-residential development in at least two categories --
nonresidential development that could directly provide sales tax or TOT
revenue, and development that would not. Since my time on the Planning
Commission (2000-2004), Menlo Park has experienced a huge loss of M-2
businesses that have provided significant revenue to the city.
The GPAC documents contend that the virtues of office are the ripple effect
of office jobs. That is only pertinent if the primary issue is job
creation. Far bigger issues in Menlo Park are the budget impacts of lost
sales/use tax revenue and TOT, traffic, and school impacts. Property tax
growth is kept low by Prop 13, meaning that its growth can't keep up with
city expenses.

MAXIMUM POTENTIAL DEVELOPMENT Clarity is critical regarding what the
maximum means. Among things It could mean are
a) the maximum studied in the EIR (i.e., the development ASSUMED in the
stated timeframe),
b) the maximum "to be allowed" (i.e., a true maximum until another maximum
is set through a GP update),
c) the maximum that the zoning would support (i.e., what is truly
ALLOWABLE, even if it may not occur).
Each of these is very different.

These differences matter very much. The previous General Plan of 1994
contained a stated "maximum" that was reached within about 5 years even
though the timeframe studied and the intended life of the GP were
considerably longer. Further the zoning changes allowed additional
development without modifying the GP at all.

Similarly, the 2012 El Camino Real/Downtown Specific Plan articulated a
"maximum allowable development" that was also studied in its EIR that had a
timeframe of 30 years: This maximum was 474,000 SF non-residential and 680
residential units.. The lowest FAR in the Specific Plan was 0.75. If that
were applied to the 130 acres in the Plan area, the total ALLOWED SF
was 4,247,100 SF (existing plus new). Because many zoning districts had
higher Base FAR and much higher Bonus FAR, the total ALLOWED SF was much
greater. Note that less than half of that low-end calculation would be
non-residential, that is an order of magnitude more development possible
than was studied and described as "maximum allowable development" - and
that is at the lowest FAR allowed in any zoning district of the Plan area.
Some districts allow more than double that amount.. The amount of existing
development has not ever been quantified.

Another example from the ECR/Downtown Specific Plan: The EIR assumed a
ratio of jobs and housing that would slightly improve Menlo Park's overall
currently imbalanced ratio. Projects proposed to date have a markedly worse
ratio, and the overall ratio cannot be improved enough within the "maximum
allowable development" even though the zoning allows more development. This
very point was made by the Sierra Club, that the allowed ratio in zoning
rules did not match what was forecast and desired. See
http://ccin2.menlopark.org/archive6/att-5982/Letter_to_Menlo_Park_Counci_11-18-13.pdf

I mention all of this because the wording in the staff report in the middle
of page E6 states that "The maximum potential development would consist of
approximately 2.1 million additional square feet of nonresidential building
space and 4,500 additional multifamily dwelling units beyond what is
already realistically achievable under the current Menlo Park General Plan
Land Use Element." Questions directly related to this that should be
asked include:

a) are these maximums for the entire city or just the M-2 area?
b) how much nonresidential SF and how many residential dwelling units
currently exist (where), how much/how many have been approved but are not
yet built, and how much/how many are in the pipeline?
c) how much more development (nonresidential and residential) COULD be
built using current zoning (and where). If this cannot be answered, there
should be no attempt to study only the amount beyond what is currently
possible. In other words, if we cannot quantify what is still possible
under current zoning, even though the current GP's maximum has long been
passed, then we cannot possibly assess the impacts of development beyond
that.
d) what does "realistically achievable" mean? Isn't that an assertion that
makes assumptions about market conditions that can vary widely depending on
shortages and credit? Remember, this is a long-term document and analysis
that should span various types of market cycles.
e) what is the relationship between the maximums? The NOP Is for an EIR
that will study several scenarios. These scenarios should evaluate the
maximum POSSIBLE of each type of development.

I urge that the "maximum potential development" to be set and studied in
the GP update refer specifically to that development (residential units and
non-residential SF, sales/tot revenue-generating and non) which would be
incremental to the currently built or approved projects, not incremental to
what is possible under current zoning. Evaluation of incremental growth to
what exists/approved would provide a picture of future development impacts.
An evaluation of scenarios of incremental growth beyond an unidentified
potential (i.e., under current zoning) is meaningless. No one could
realistically assess the incremental impacts, including on traffic
patterns..

A holistic view and assessment [of that increment] would help us all
understand more fully the [incremental] impacts on infrastructure, water
supply, traffic congestion, GHG emissions, [schools] .etc.

TOTAL DEVELOPMENT The total amount of nonresidential (mostly office),
ANOTHER 2.1 million SF, on top of currently approved and pipeline amounts
of nonresidential SF (nearly 2 million SF), is simply staggering. The
number of new jobs and ripple effect on traffic and schools and housing
shortages are simply staggering as well. Our much-larger neighbor to the
south, Palo Alto just imposed a 50,000 SF/year limit on office development
after experiencing office/R&D growth totaling about 400,000 SF since 2008,
a fraction (1/5) of what smaller Menlo Park already faces before
considering this additional amount. See editorial
www.paloaltoonline.com/news/2015/03/27/editorial-development-limits-a-modest-start

IMO our community has very serious discussions that should occur right now
about what it wants to be. Nearly all of the community outreach has been in
Belle Haven, not throughout the community, especially about the total
amount. Even if this proposed amount occurs over 30 years, it goes way
beyond anything Menlo Park has [ever] experienced. [It goes without saying,
] Menlo Park has yet to experience the nearly 2 million already
approved/pipeline [and all of its impacts, good and bad].

Respectfully submitted,
Patti Fry
Menlo Park resident
Received on Fri Jun 12 2015 - 12:58:07 PDT

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