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comments on Facebook Expansion project review

From: domainremoved <Patti>
Date: Mon, 26 Sep 2016 10:53:06 -0700

Dear Planning Commissioners,
You have a very full plate tonight to review all the materials submitted to
you regarding the Facebook Expansion Project, with minimal time for you or
the public to digest it. Please take your time to do appropriate due
diligence on behalf of our residential community. The incredibly poor
timing of this meeting at the same time as the Presidential debate, the
schedule for which was available long ago, may seriously affect public
participation tonight, too.

I ask that you take the big picture view: this is a project that will
greatly benefit Facebook while imposing enormous impacts on our community.
If you take seriously the City's environmental goals, particularly those
related to climate change, you should look hard at the fact that
Alternatives are environmentally preferable. And you should look hard for
opportunities to lessen this Projects negative impacts.

This note focuses on a few issues related to the FEIR, draft trip
management program, and the proposed Development Agreement (DA):

FEIR - it is astounding that the FEIR still asserts that the impacts on
housing demand are minimal because so few current Facebook employees live
here. While that may be a fact, that is not at all believable as a
predictor of future demand from either current or future employees. . There
has been no survey of current employees that would substantiate their
DESIRE to live in Menlo Park, so it is absurd on the face that those who
live in Menlo Park are the only ones who want to live here. Indeed, a
number of Facebook employees recently wrote to the City Council asking for
prompt approval of the housing that they believe Facebook will be building
in Menlo Park.

The housing shortage is worsening, and traffic is projected to worsen as
well, both in Menlo Park and the region. More Facebook employees will want
to live in Menlo Park. More housing will need to be built "somewhere" above
the numbers that are currently planned and that construction will have an
environmental impact. The EIR needs to be fixed to acknowledge that reality.

Concerns about the specific impacts on intersections and roadways of the
Menlo Gateway project and major proposed projects such as the Stanford
campus in Redwood City, the El Camino projects proposed by Greenheart and
Stanford, were dismissed as already addressed in the C/CAG model. I remain
highly concerned that a general model is being used when there is more
specific information about impacts on specific intersections and roadways
in the environmental studies of these projects. The EIR is supposed to deal
with reality and help identify mitigation measures to address specific

In the projections of traffic, worker density assumptions in the FEIR
remain at 350 SF/worker because "no tenants have been identified" (response
I35.21) We know that most tech companies have a density of ~ 150 SF/work,
like Facebook, and some as low as 75 SF/worker such as the new Spaces
building at 101 Jefferson. The EIR is supposed to be conservative. Using an
average worker density of 350 SF/worker is far from that. This needs to be
fixed to reflect reality.

Concerns about traffic impacts and neighborhood cut-through traffic,
particularly when roadways and intersections become overly congested, were
essentially dismissed. When asked where does that overflow traffic go (some
of which the traffic models can't even address the volumes because they are
greater than the models' design), the FEIR says "Unserved demand
generally disperses,"
(I35.22) to other times of day and other modes of getting around. But the
project does not propose any new ways of helping people get around. It may
not be possible to avoid peak hours. Facebook has substantial ability to
help alleviate these problems and contribute more to solutions. They have
to be asked, or required.

The plan has major flaws that need addressed. These include:
Staff report pages G2 and G3 outline exclusions to what is counted against
the rush hour and daily trip caps. For example, this policy would allow 12
special events per year. While it is totally appropriate for Facebook to
hold special events, there should be an incentive, not this DISincentive,
to schedule them so they do not disrupt further the traffic in Menlo Park
at peak hours and to make transit/transportation arrangements that minimize
the impacts. This needs fixed.

On page G6, it states "Violations of the Trip Cap for the East Campus are
independent of violations of the West Campus Trip Cap." Facebook is a
single employer who should manage traffic impacts across its campuses.
Violations have impacts on Menlo Park regardless of which campus is the
source. There would be more incentive to address them if all violations
were counted together and the penalties applied accordingly. Change this.

Our community should be aghast that the City is proposing to approve a
draft agreement with no commitment on Facebook's part to build ANY
housing ( Planning
Commission staff report file page 301 (Q24) when this project adds 6,550
new workers. There have been statements that Facebook intends to build
1,500 units of housing, but there is no commitment to build *any* of them,
just a commitment to "plan and design". The DA could include a commitment
to build those units in Menlo Park, thus not making it contingent upon the
Zoning Ordinance Amendment that would allow that. The DA could include a
commitment to provide sufficient funds in escrow for such construction. The
DA must include this commitment to run with the land; the draft DA
specifically excludes this. Ideally, Facebook would provide additional
funding to address the regional housing problem it is exacerbating.
For reference, the DA states:

*"Section 8.1.6 Commitment to Design Housing Units Pending Completion of
General Plan Update. Subject to completion and approval of the pending
ConnectMenlo process, which proposes updating the City’s General Plan and
rezoning portions of the Bayfront area for mixed-use and residential uses,
Facebook shall commit to the planning and design of at least 1,500 housing
units on the approximately 56-acre site known as the Menlo Science &
Technology Park located in the Bayfront area. Facebook further agrees that
any future **application to develop residential units on the Menlo Science
& Technology Park site will include a commitment to include no less than
15% BMR units and/or workforce housing units (regardless of whether the
proposed units are for sale or rentals). Facebook shall have no obligation
to construct these units or to submitting an application for the future
redevelopment of the Menlo Science & Technology Park site. The parties
further recognize that any future redevelopment would be subject to a
future discretionary review process including environmental review under
the California Environmental Quality Act. In addition, this obligation
shall only apply so long as the Menlo Science & Technology Park site is
owned by Facebook (or an affiliate of Facebook) and shall not run with the
land or bind bona-fide third party purchasers of the Menlo Science &
Technology Park site in the event of a sale. " *

The proposed langugage sets some bad precedents. These should be modified.
It says (T58) that any one of the findings is sufficient justification for
the project. No, it is the combination of benefits that should be weighed
against any project's adverse impacts. Not just one.

In several places, this draft asserts that the project is "near existing
transportation". No it is not. These erroneous assertions need fixed (T59
and T61)
There is an erroneous statement that "The Project is consistent with the
City’s Climate Action Plan and would support the City's efforts to reduce
dependency on fossil fuels and nonrenewable." As the EIR shows (T61), the
project worsens GHG emissions. This needs to be deleted.

The Planning Commission is entrusted to do the detailed due diligence
needed to provide the best possible outcomes for our community. Please take
the time to get into the details and recommend appropriate adjustments.
Facebook, as a major local employer, has demonstrated goodwill towards our
community and can be expected to rise to the occasion when asked. More
should be asked to ensure the impacts are minimized and the benefits

Respectfully submitted,
Patti Fry
Former Menlo Park Planning Commissioner
Received on Mon Sep 26 2016 - 10:58:44 PDT

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