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Fwd: Facebook Willow Village EIR NOP comments

From: domainremoved <Patti>
Date: Mon, 7 Oct 2019 09:55:52 -0700

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Planning Commissioners:
I am writing with additional comments and a correction to my previous email regarding the NOP:

Metrics and standards: The ConnectMenlo General Plan projections of growth should be used as the standard of evaluation, not ABAG projections. In some past projects' EIR's, impacts on such things as demand for housing have been written off because ABAG projected more housing would occur in the area despite the fact that ABAG's projections are not based on approved projects in the area or in Menlo Park; further, the ABAG housing projections have not proven to be reliable. This sort of circular reasoning has allowed projects to escape being part of the solution to the housing shortage, and allowed enormous job growth without commensurate growth in housing where people can live.
Menlo Park undertook a comprehensive planning effort to update its General Plan, with a primary focus on the "M-2"/"Bayfront" area within a timeframe through 2040. This went into effect January 6, 2017, and should be used as the standard for evaluating all types of growth and related impacts.

A correction: Based on the Facebook Development Agreement ("DA") Review document of 1/8/18, I had assumed there was a requirement to build 1,500 housing units on what is now the Willow Village and office park project site. However, the language in the Facebook Expansion Project DA inexplicably had no such requirement to build anything even though that project was projected to add 6,550 employees; in fact, that project's EIR concluded there was no impact on housing demand! But, it required Facebook to plan and design 1,500 housing units in a future project, while not requiring the building of any units. Text below from the DA, pages 23-24.

Please note that this requirement regarding planning for housing does not even run with the land, unlike most other provisions of entitlements. This re-emphasizes the importance to analyze impacts (negative and positive) by Phase in case Facebook/ Hibiscus Properties/Peninsula Innovation Partners or any future property owner decides to stop development along the way.

Respectively submitted,
Patti Fry, Menlo Park resident and former Planning Commissioner

---------- Forwarded message ---------
From: Patti L Fry <MenloPatti_at_(domainremoved)
Date: Sun, Oct 6, 2019 at 4:56 PM
Subject: Facebook Willow Village EIR NOP comments
To: <planning.commission_at_(domainremoved)

Dear Planning Commissioners,
Please consider the following comments regarding the scope and content of the EIR for the proposed "Willow Village" and office park project:

Phasing: The Willow Village and office park project is the largest project in Menlo Park history, according to news articles. The project is proposed to occur in phases. With uncertainties about the economy and other factors that could affect timing of these phases, the impacts of each proposed phase should be analyzed separately by Phase as they are proposed to occur (i.e., Phase 1, Phase 1 and Phase 2, all Phases). That way, measures necessary to mitigate or eliminate negative impacts can be identified and implemented as impacts occur by Phase rather than at the end of the final Phase, which may be many years in the future.

ConnectMenlo growth discrepancy: The ConnectMenlo General Plan approved in late 2016 has nearly reached its 2040 development projections, especially of Office, and its non-residential development cap, and is projected to exceed its hotel room cap. But not the cap or projections for housing units.
Thus, growth that was purported to occur over time is happening in a very short period and in an unbalanced way relative to projections. This time-concentration of growth and the impacts on the jobs/housing growth imbalance should be studied in this EIR.

Housing need impacts: Since the Facebook West Expansion Campus Development Agreement 8.1.6 (excerpt from 1/8/18 review attached) states that "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.", the EIR for the Willow Village project can only claim 235 housing units out of the proposed "approximately 1,735 housing units" to satisfy any incremental housing needs resulting from the rest of the Willow Village project. In other words, 1,500 units are related to the Facebook West Expansion project, its impacts, and its Development Agreement, not this project.
The Facebook West Expansion Development Agreement 15% BMR commitment seems to relate to "any future application" such as this one, however.

Alternative: An Alternative that must be studied is Reduced Office (only), at most at the Base level, while keeping proposed Housing and Retail/Community Serving Uses constant with the Proposed Project. As mentioned above, the ConnectMenlo 2040 projections for Office and Hotel are nearly reached, and it may not make sense for the city to approve exceeding those caps for some time. Thus, given the extreme regional housing shortage and high local needs for retail and other community serving uses, any Reduced Intensity Alternative should only comprise a reduction of Office square footage,

Metrics: The jobs/housing balance anticipated in the ConnectMenlo General Plan projections should be a standard by which this project is measured. Further, this project should be measured within the context of Facebook's footprint in Menlo Park. The Facebook worker density appears to be far higher than previously projected for the buildings occupied by Facebook. This project provides an opportunity to "right size" the impacts, rather than add to them, so the cumulative impact should be measured. Trips, greenhouse gas emissions, demand for water and housing, air quality, noise, etc. are all related to the overall growth.

Secondly, since traffic congestion is horrific in Menlo Park, the impacts of this project should be measured both by VMT (CEQA requirement now, I believe) as well as by congestion-related standards such as Level of Service at intersections and on roadways. Gridlock must be addressed.

Considerations: Considerations regarding the project should explicitly include its displacement of the Menlo Park Fire Protection district and Urban Search and Rescue training and storage facility, a dialysis clinic, Community Legal Services of East Palo Alto, and other community-serving tenants.

Respectfully submitted,
Patti Fry, Menlo Park resident and former Planning Commissioner

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Received on Mon Oct 07 2019 - 09:48:18 PDT

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