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Willow Village EIR - 5/14/19 Item E4

From: domainremoved <Adina>
Date: Sat, 11 May 2019 17:00:41 -0700

Honorable Council Members,

Given the City Council comments at the recent study session, the inclusion
of item E4 on the consent calendar seems unwarranted.

Item E4 would fund the initiation of the process of conducting an
Environmental Impact Report for the Willow Village project, using the
currently proposed projects as the base for study.

At the recent study session for Willow Village, multiple Council Members
identified the increasing jobs/housing imbalance as a significant concern
with the current proposal. As currently proposed, the project would add up
to 9000 jobs (up to 6,000 net new jobs on the site), and up to 1700 homes

Many thanks to the Council for raising the growing imbalance as a concern.
The new jobs would be over and above the ~10,000-15,000 jobs that Facebook
has already brought to Menlo Park, corresponding to less than 2,000 new
homes added in the Bayfront/Belle Haven area. The large and increasing
imbalance is driving substantial displacement, since higher-paid new
workers who wish to live near their jobs have the ability to outbid
previous residents. Responses to Council questions indicated that it
would be logically possible to reallocate the nearly 60 acre site to
accommodate more homes and fewer jobs.

The consent calendar is used for items that are expected to be
uncontroversial where no new discussion is needed. However, based on the
City Council comments at the study session, the project as it is currently
proposed diverges significantly from Council's concern about the
jobs/housing imbalance.

The Council, as the decision-making body for the EIR, would have the power
to approve a development that was *smaller* than the projects studied in
the EIR. But the Council couldn't come back and ask for space to be
reallocated between office and housing. The creation of significantly
different options would need to happen before the EIR process.

Therefore, I would urge the city council to remove this item from the
consent calendar, discuss whether the project's overall balance is in line
with the Council's goals, and if not, to come back with an agendized item
to recommend changes that would better reflect the Councils' goals
expressed in Council member comments.

Lastly, the staff report notes that the transportation analysis of the EIR
would be done using Level of Service as a metric (auto delay), rather than
Vehicle Miles Traveled, since VMT will not be mandated by the state until
July, 2020.

Though the mandate does not start until July 2020, a variety of other
cities, including San Francisco, Oakland, and San Jose are already using
VMT as the metric for EIRs. Cities are allowed to start earlier. Also,
cities can continue to use LOS as part of local policy, and Menlo Park
plans to continue to do so be able to assess the functioning of the roadway

Unfortunately, the use of LOS as the metric for EIR transportation
mitigation is likely to encourage the use of changes such as roadway
expansion to reduce auto delay, rather than the use of changes such as
improved transit, transportation demand management, and walking/bicycling,
strategies that relieve traffic by reducing the number of cars on the

Therefore, please use VMT as the metric for required EIR mitigations, so
that the city can invest in congestion relief using methods that improve
safety and sustainability, while continuing to use LOS as part of the
city's assessment.

Thank you.

- Adina
Adina Levin
Received on Sat May 11 2019 - 16:55:39 PDT

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