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Fwd: Greenheart 1300 El Camino Real comments

From: domainremoved <Patti>
Date: Mon, 23 Jan 2017 11:30:41 -0800

Fyi. My comments to the Planning Commission re the 1300 el camino project. It remains ill-defined.

How can you possibly assess its benefits or its impacts? Even ConnectMenlo had more precision.

Demand a firm Project before proceeding.

More in another note to follow.
Patti

Sent from my iPhone...pls excuse typos

Begin forwarded message:
>>
>>
>> ---------- Forwarded message ----------
>> From: Patti L Fry <pattilfry_at_(domainremoved)
>> Date: Mon, Dec 12, 2016 at 11:34 AM
>> Subject: Greenheart 1300 El Camino Real comments
>> To: "planning.commission_at_(domainremoved)
>> Cc: City Council <city.council_at_(domainremoved)
>>
>>
>> Planning Commissioners:
>>
>> You have a big responsibility on behalf of the community - especially during the busy holiday season when few of us residents can participate actively in project reviews - to conduct due diligence on the proposed Greenheart project and its EIR and to make recommendations to the City Council about its negative impacts and potential benefits. I am eager to see this blighted site cleaned up (the developer has ignored multiple requests to do that, by the way), and developed. However, I have the following concerns.
>>
>> THE PROJECT IS NOT DEFINED - it is one thing for the EIR to have studied a range of potential uses, but it is another thing for the project to remain poorly defined. It is now at the stage when you are asked to consider paint colors and use permit for outdoor seating for restaurants but it is not clearly that restaurants really are proposed. As worded, the project's community serving uses could be a bank, real estate office, or business services - each of which has very different vibrancy and usefulness to the public than stores and restaurants. The developer wants you to consider a real estate office, presumably for the housing buildings, as "community serving". It would only benefit the landlord, the realtor and the tenants, not the greater community; it is office space.
>> The developer wants you to evaluate the project and its benefits even though there is no specific amount of office or community serving space; those are still being presented to you as ranges that have a difference equivalent to a half acre of space. There is not a specific project in front of you yet.
>> ** You should recommend that the "Community serving uses" be specified clearly - both in type and amount of space - before recommending approval of Statement of Overriding Considerations instead of agreeing that the currently vague benefits outweigh the negative impacts.
>> ** You also should recommend consideration of a Use Permit ONLY when specific restaurant uses are proposed, not now when there is no proposal for a clear type, size or location of any restaurants.
>>
>> THE PROJECT DOES NOT SUPPORT THE SPECIFIC PLAN - The Specific Plan (E-4) states "The El Camino Real Mixed Use/Residential designation emphasizes residential use in close proximity (approximately 1/2 mile) to the station area and downtown, in order to support area businesses, transit use and overall downtown vibrancy. This designation also allows for a variety of retail, office and public and semipublic uses." This project is not really "mixed use residential"; it is "mixed use office".
>> Proposed at the bonus level in THE zoning district of the Specific Plan that has "Residential" in its title it is proposed to include nearly 100% of the office allowed but only 57% of the housing units allowed. Translated to how many individuals or families could have a new home: the site only proposes 183 units but could provide 322 sorely needed housing units. It could provide 139 more!
>> ** Recommend either that the project be approved as a Base level project with the maximum Base level housing of 206 units OR at the Public Benefit Bonus level size with the maximum housing in order to support the Specific Plan's vision of this area being primarily residential.
>>
>> THE PROJECT'S BENEFITS ARE INSUFFICIENT - In addition to the lost opportunity to provide more housing, the project adds significant new traffic, deemed adverse and unavoidable, that would further congest the most congested part of El Camino Real. Those estimates are likely to be understated considerably because the EIR assumes an unrealistic amount of space per office worker (300 SF whereas national office estimates are 1/2 of that). As described in the staff report, the offices are targeted at tech incubators, which often house quadruple the number of workers that were analyzed in the EIR. The negative impacts could be far worse than described
>>
>> The $2.1 million payment is too low. It is approximately 1/3 of the extra profit described in the flawed BAE Financial Impact Analysis. I use the term "flawed" because it assumed 86 more underground parking spaces at a cost of $3,655,000 that would not be required if only 1,000 parking spaces are provided, and it does not assume ANY revenue for the parking that the developer stated in council chambers would be charged to tenants. With the reduced underground parking costs, the profit at the Bonus level would be at least $10 million, not counting the initial and ongoing revenue from charging for parking spaces.
>> ** You should recommend a public benefit bonus payment of at least $5 million as shared benefit for the bonus size and its considerable negative impacts.
>>
>> THE PROJECT SHOULD HAVE A TRIP CAP - Because the "effectiveness of the TDM program cannot be reliably predicted" (FEIR B12), and the amount of traffic could be quadruple the amount estimated in the FEIR if the offices have a similar worker space allocation as the new Spaces tech incubator business near Facebook, there should be a trip cap with penalties if it is exceeded. After all, this is in the heart of our town and is next to transit.
>> ** You should recommend that the required mitigation measures and the Development Agreement include a specific trips limit that allows no more trips than the net impact during peak hours and daily that was assumed in the Final EIR.
>>
>> PROJECT and DEVELOPMENT AGREEMENT APPROVALS WOULD BE PREMATURE - the implications of grade separation on this project's transportation circulation could be profound if Oak Grove and/or Glenwood are lowered, which would occur in the proposed grade separation alternatives. Not only would motor vehicle traffic flows be affected, bike movements would also be affected, and intersections either blocked or complicated.
>>
>> Additionally, the City has not conducted nexus studies in order to determine appropriate impact fees for housing impacts or for transportation improvements. For reference FEIR (3-33) states "the City has not adopted a valid nexus study that allows for the collection of a housing impact fee" The Lisa Wise Consulting Inc firm pointed out in 2014 the lack of a mechanism for the City to fund public improvements in the Specific Plan area.
>> **You should recommend that the City put the horses before the cart, and adopt nexus studies and impact fees to address impacts of projects like this one that would worsen the housing shortage, worsen traffic congestion, and not pay their fair share of needed public improvements.
>>
>> I heartily encourage appropriate development on this site. That should be a residential-intensive project that improves, not worsens, Menlo Park's abysmal jobs/housing ratio. That should also be a project that is truly transit-oriented, rather than significantly worsening traffic in the most congested part of our downtown area. Approvals of any project should be based on a well-defined, not ambiguously described, project. It is time for this developer to be clear about its intentions rather than continue to be vague. You need to demand that specificity as part of your due diligence.
>>
>> Sincerely,
>> Patti Fry
>> Menlo Park resident and former Planning Commissioner
>
> __,_._,___
Received on Mon Jan 23 2017 - 11:40:15 PST

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