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Fwd: Menlo Park General Plan Update EIR

From: domainremoved <George>
Date: Mon, 20 Jul 2015 19:48:17 -0700

City council should reject two attempts to usurp due process and fair
consideration of updated general plan proposals prior to the EIR or
adoption of recommendations of the General Plan Review committee, presently
on its agenda for its next meeting.. The first of these attempts is a
proposal in Staff report to amend the Transportation Impact guidelines to
allow a 25,000 square foot parcel in M-2 to be considered a 10,000 square
foot parcel if it provides traffic helpful amenities like bike lockers to
encourage bicyclists to replace car trips. The proposal suggests that by
subtracting prior usage of warehouse space, and adopting a consultants
report that bicyclist, transit, or pedestrian friendly amenities can deduct
Automobile Daily Trips (ADT) from ADT existing or projected. Of course no
statistics are provided nor are there any monitoring or enforcement
mechanisms mentioned for such a proposal. In fact it is not even mentioned
if the deduction for prior usage is from occupied businesses at the time of
the proposal, the test of the Specific Plan. More importantly these ATM
deductions are a critical part of the EIR for the General plan update, see
comments to connect Menlo below. And lastly these proposals would affect
traffic in the M 2 area, where Bell Haven residents can’t even get to the
arterials or freeways as reported in the Jeff Tumlin, Nelson Nygard,
presentation to the joint transportation/bicycle committee meeting.
Indeed, as Tumlin said, development at this time in Menlo Park should be
considered a privilege, and honor the interests of developers, the city,
and residents.



Secondly, the proposed economic plan attempted to be snuck in on the
consent calendar should either be rejected as premature, or put on hold
pending the conclusion of the General Plan update process and EIR. The 180
page plan is mostly blather and gibberish, but purports to recite several
development biases against residential interests, such as ignoring traffic
in the neighborhoods, adding FAR or extra stories near transit, closing off
the business district for more fund raisers for chamber of commerce such as
Connesieurs market place or other business and transportation closures.
These are also at issue in the General Plan update, and the City council
should not preempt them by adoption them, particularly on a consent
calendar prejudicing fair consideration in the General Plan update
process.



City council has promised residents candid communications and a fair
exposition of Staff proposals. Approval on a consent calendar of a one
sided development proposal by economic director Jim Cogan and a 250%
increase in size exemption from the Transportation Impact guidelines,
without fair consideration by ongoing general plan update process
considering these issues “ain’t it.”
---------- Forwarded message ----------
From: George Fisher <georgecfisher_at_(domainremoved)
Date: Mon, Jul 20, 2015 at 3:13 PM
Subject: Menlo Park General Plan Update EIR
To: connectmenlo_at_(domainremoved)
"Murphy, Justin I C" <jicmurphy_at_(domainremoved)
nhnagaya_at_(domainremoved)






Please consider the following comments and guidance on the scope and
content of the General Plan Update EIR.



1. The EIR is premature until the General Update is more specifically
finalized and reported. Until that time No adequate comparison of various
alternative revisions may be made with the general plan 1994 provisions and
requirements to adequately minizmize impacts and maximize benefits to the
city and its residents, as more specifically described below.

2. The NOP claims the maximum potential development under the general
plan update would consist of 2.1 million additional square feet of non
residential building space and 4500 additional multifamily dwelling units
beyond what is realistically achievable under the current Menlo Park
General Land Use element. It also states approximately 5,500 new jobs
would result from what ins reasonably achievable under the current General
Plan. However the amounst realistically achievable under the current land
use element is not specified or described, not is the specific quantity of
approved or built development specified. These numbers are essential to
further analyze whether they should be, or might be, included in the
general plan update, and more importantly to consider both a current
baseline of existing conditions against which to compare new development in
the EIR, or to set up alternative proposals to consider impacts and
benefits. The December 2014 existing conditions for example specified
1,347 housing units, and 1.866,569 square feet of new office space planned
and proposed, and only 112,693 new retail. I am not sure about new jobs.

a. Accurate numbers of non residential development, whether office
space or retail, residential units and jobs for current, proposed, revised
general plan, or maximum are essential to evaluate the relationship between
non residential development additional footage, generating how many new
jobs, generating how much needed housing, and what the affect of needed new
housing and jobs on schools, city finances, current residential
neighborhoods and minimizing impacts and maximizing benefits.

b. These numbers are needed to decide what should be included as
maximum under revised plan, and as alternatives to the maximum number to be
analyzed in the EIR.

c. It seems to be a base line of what currently exists against the
maximum to be developed should be one alternative.

d. The NOP states the its proposed no project alternative would include
development potential in the rest of Menlo park that also currently exists
under the general plan and zoning in place, which amount is not proposed to
change under the plan. However that amount must be disclosed both for
baseline comparisons and to be included in maximum development under the
revised general plan, because it will be included in any revised land use
or circulation revised general plan changes, and impacts must be analyzed.

e. Accurate numbers on existing, approved, and proposed under the
downtown el Camino Real specific plan need to be included for complete
comprehension of development.

3. More specificity is needed regarding proposed amendments to the
Transportation Impact Guidelines, the Circulation System Assessment program
(CSA) the current Roadway classification system prescribed in the 1994
general plan, average speeds, current cut through traffic, current traffic
volumes, and current residential neighborhood quality of life, and all
metrics used to protect the neighborhoods and quality of life. Although
the Circulation element reviews Goal IIA of the current general plan and
how it maintains traffic, pedestrian and quality of life in the
neighborhoods, the only proposed changes or program are limited to
measurements of safety (e.g. collision, and efficiency (eg, vehicle miles
traveled (VMT). This is insufficient to minimize impacts or maximize
benefits.

a. VMT is only a comparative number to be used on a per capita basis to
compare against other per capita numbers, such as region, Transportation
Analysis Zone (TAZ) or other and if the per capita measure favorably may be
sufficient for CEQA analysis. However no measurement is made of the
quantity of vehicle miles added to a particular roadway system and want
impacts to existing traffic, pedestrians, etc, quality of life, cut through
traffic or other impacts all relevant in an EIR. If there is an
efficiency standard for VMT, that standard should be stated, and an
explanation, it that standard affects quality of life or cut through
traffic or residential character of our neighborhoods.

b. Even if the state prescribes that traffic delay or los is no longer
an CEQA transportation issue, the affects of additional traffic to quality
of life, pedestrians or maintaining the character of residential life, a
specific goal and guideline of the revised general plan are relevant and
need to be compared with and without proposed changes to the system.

c. Any proposed Traffic Demand Management criteria to lower the
analysis of Average daily vehicle trips cut through or otherwise through
our residential neighborhoods needs to be stated and examined for impacts.
Additional proposals to increase FAR or height of buildings near transit
must be stated and analyzed.

d. If any proposed TDM criteria are to be used to offset actual ADT
either existing or projected, what monitoring and enforcement mechanisms
will be used to protect Neighborhoods and quality of life.

4. Reasonable alternatives must be studied to the proposed full build
out under the revised general plan and current general plan, with respect
to needed housing availability, below market housing necessities, job
creation, and the affect on Menlo park schools, including increased student
body of 5,000 new jobs and 5,000 new multifamily housing units.

a. The current baseline of approved and existing development, housing,
jobs and schools is one reasonable alternative.

b. Increasing the current base line by a factor such as 2x or 3x per
single category and not others would be a reasonable alternative to measure
impacts.

c. Residents need to understand what are alternatives to protect their
residential neighborhoods, and quality of life, and reasonable development.


5. What provisions will be analyzed re preventing cut through traffic
through our neighborhoods, including measurement, preclusion, enforcement,
and definition of cut through traffic.



Respectfully submitted,



George C. Fisher



-- 
George C. Fisher
​1121 Cotton Street
​Menlo Park, ca​
(650) 799 5480
Fax (650) 475 1849
georgecfisher_at_(domainremoved)http://www.gfisherlaw.com
-- 
George C. Fisher
2600 El Camino Real, Suite 410
Palo Alto, Ca 94306
(650) 799 5480
Fax (650) 475 1849
georgecfisher_at_(domainremoved)http://www.gfisherlaw.com
Received on Mon Jul 20 2015 - 19:46:22 PDT

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