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Comments on DEIR 1300 El Camino Real Greenheart Project

From: domainremoved <George>
Date: Mon, 4 Apr 2016 15:59:12 -0700

Thomas Rogers, Principal Planner
                 April 4, 2016

City of Menlo Park

Community Development Department, Planning Division

Email: throgers_at_(domainremoved)

Re. Comments on DEIR 1300 El Camino Real Greenheart Project.

The DEIR does not provide a sufficient degree of analysis to provide
decision makers with information that intelligently takes account of
environmental consequences as required by CEQA Guideline 15151, or
otherwise, for the following reasons and facts:

1. Cut through traffic is a significant Menlo Park environmental problem,
which remains unanalyzed in the DEIR or otherwise. No residential street
cut-through traffic study has been done, nor any analysis of cut through
safety, including speeding or affects on residential quality of life.
“Quality Living “ is that City Slogan on the City Website title page,
with reference to ”Menlo Park’s outstanding quality of life”.
  Neighborhood quality of life, particularly advertised as “outstanding”,
and cut through traffic safety are questions independent of, and cannot be
extrapolated from, intersection delays or roadway capacities.

a. There are only two Menlo Park Gateway points from Menlo park to
101/84, at Marsh and Willow Roads. There is only one Menlo Park Gateway
point to 280 from Sand Hill Road, although the Alameda can access 280 via
Woodside road in Redwood City Many city routes can be used to access theses
and other points depending upon congestion or traffic delays on primary

b. Approximately 800 (42% of E and 35% of W, including Junipero Serra)
 of every 1,000 daily automobile office trips from the Greenheart project
need to access 280, 101 and 84. See DEIR Figure 3.1-11 (staff has confirmed
figure mislabeled as retail, actually employment or office and provided
detail of the composite group percentages 37% E and 33%W in addition to
other E and West routes. Only 14% of total trips access ECR N and S.)
 There are no direct routes to any of these highway gateways and many
indirect routes become consistently congested, even before any
consideration of addition of project traffic, even at base level, much less
at claimed public benefit developmental increases..

                                               i. The DEIR itself
acknowledges that every intersection on Middlefield on the three direct
routes from the project, Glenwood/Valparaiso, Oak Grove and Ravenswood,
will have significant impacts not avoidable, and Oak grove and Ravenswood
road segments to Middlefield are similarly impacted. No cut through
analysis has been made of the affects of those impacts and cut throughs
cannot be extrapolated directly from severity of impact as stated below.

                                             ii. Similarly trips
heading west are admittedly similarly impacted at intersections of Oak
Grove Ravenswood, and Glenwood/Valparaiso on ECR and at Oak Grove and Menlo
intersections on University avenue and roadway segments between them and
ECR , as well as Valparaiso road segment from ECR to the Alameda. These
impacts cannot be simply announced, without an analysis of cut through
traffic on cross streets from arterial streets to and from project routes
on neighborhood cut through streets.

                                            iii. Why are these
intersections and roadway segments limited to those immediately adjacent to
the project site? Why not examine all intersections and routes to the
gateways? Additional roadways segments both E and W should have been
included in the study as well as Intersections on them (See comment letter
of July 31, 2014, attached in DEIR Appendix 1-2)

c. Menlo Park City circulation and transportation impact requirements,
attached in DEIR appendix, mandate that auto trip route studies be based on
fastest routes available “preferably based on a travel-time study . . .
[and] potential cut-through traffic through residential neighborhoods
should also be identified in the travel time study." No travel time study
appears to have been done and there have been no cut through traffic routes
through residential neighborhoods identified in the DEIR or otherwise.

d. Traffic congestion delay is not linear and worsens as additional
cars are delayed. Therefore no assumption can be made that the impacts
demonstrated in the DEIR, although significant and unavoidable can be
linearly interpreted or extrapolated to mean no neighborhood road volume
impacts (all proportional to existing traffic per Menlo Park CSA) or
intersections. You can’t extrapolate traffic congestion from intersection
delays or roadway capacities. Moreover you can’t extrapolate traffic
congestion from vehicle/capacity ratios per hour on Routes of Regional
significance or intersection levels of Service. Merely throwing such
numbers in the DEIR without any explanation of affects on traffic
congestion or cut through traffic is meaningless.

                     e. The Menlo Park impacts to residential streets
are comparisons to existing traffic on those streets, not
comparisons to existing roadway capacity (see page 4 of 8, CSA attached to
DEIR, Paragraph B, e.g., “on local streets . . . [if]the ADT is less
than 750 and the project related traffic increased the ADT by 25%.” Thus
the Stanford cut through traffic analysis found impacts although all
numbers used were below the roadway capacities. No measurements have been
made on neighborhood streets used as cut throughs to the project or to
101/84 or 280.

f. Waze and Google travel time studies at commute times show
Greenheart auto routes will not only cut through many Menlo park
neighborhood streets, increasing safety and quality of life issues, but
also include routes through Atherton and Palo Alto. Many cut-through
traffic trips also come to and from Menlo Park from adjacent cities, mainly
Palo Alto.

g. The Stanford project cut through analysis showed impacts on
neighborhood streets, which is not considered in this DEIR. They Should be.

2. The DEIR near term analysis is defective. A 1% annual increase is
insufficient and analysis does not include the Stanford Project on the
grounds it is not an approved project, only pending. Since the Stanford
Project and Greenheart projects are both on ECR and will be developed at
the same time the projects need to be included together in the EIR.
Otherwise only the cumulative numbers, which include the Stanford Project
must be the only ones used for impact determination.

a. Other Menlo Park EIRs include both pending and approved projects in
its near term analysis. In fact, the Stanford EIR NOP specified in the
recent contract for such approved by the City Council includes all pending
and approved projects, See Staff Report Number 16-044-CC.

b. 1% annual growth from Palo Alto and Redwood city is not realistic
for such traffic, which will include to and from the new hospital and back
and forth between Stanford and its new Redwood city campus, much less the
rampant development in Palo Alto and Redwood city. The recent Menlo Park
existing condition general plan traffic surveys show more than 1% growth on
Menlo Park streets including ECR.

3. The Traffic Generation Numbers, Reductions and Deductions do not give
an accurate representation of the anticipated project and impacts from the

a. Deducting traffic from past businesses, which may or may not have
been realistic when those businesses are operating, should not be deducted
from new traffic generation compared to current traffic. Those prior
businesses were not operating when the existing traffic was measured and
therefor are arbitrary deductions

b. The 22% reduction across the board for Greenheart generated traffic
is inexplicable, and not sufficiently explained, calculated or justified.

c. Deducting 525 trips per day for cars already using ECR who would be
anticipated to stop to use the Greenheart Retail is pure fiction and has no
basis. It is based on retail, and Greenheart is only committing to
community serving businesses, not retail. Community serving businesses
such as lawyers, investment advisors, real estate agents and other office
businesses do not attract “drive by” business in the same manner as retail.

4. Prior EIR’s such as the Specific Plan EIR or other projects in the
Specific Plan or project area do not have comparable impact analysis, and
cannot be used to evaluate this DEIR. The Greenheart project was not an
opportunity in the Specific Plan or its EIR and must be added to any
numbers. The Specific uses are different, but more importantly, EIRs done
in poor economic conditions have a totally different context than those
done in boom economic conditions. Ask any resident if their cut through
traffic has increased in the last few years.

 Please let me know if you have any questions on the data and points in
this letter. Thank you.

 George C Fisher

 1121 Cotton Menlo Park, CA

CC Menlo Park City council

CC Menlo Park Planning Commission
Received on Mon Apr 04 2016 - 16:05:09 PDT

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