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Willow Village NOP

From: domainremoved <Patti>
Date: Mon, 16 Dec 2019 09:02:58 -0800

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City Council:
Please consider these comments and suggestions regarding the Willow Village Notice of Preparation (NOP):

VARIANTS
As a former Planning Commissioner, I find it odd and unsettling that the Willow Village project is so ill-defined that the EIR NOP seeks to study "variants" in five dimensions of the project, each of which could modify the physical environment. Each of these undefined project elements could present different environmental impacts, singly and in combination. Additionally, each of the variants could affect non-physical impacts that would be considered by the community and Council when project approval is considered. THE APPLICANT SHOULD BE ENCOURAGED TO COMPLETE THE PROJECT DEFINITION WITHOUT VARIANTS AND THEN RE-COMMENCE THE EIR PREPARATION PROCESS.

Among the listed variants are an Increased and a Reduced Housing scenario. With the current housing crisis, and worsened jobs/housing imbalance here in Menlo Park, it makes no sense to have a Reduced Housing variant or Reduced Housing Alternative.

ALTERNATIVES
Since EIR's are required to evaluate Alternatives, it does make sense to have an Increased Residential Alternative, to the maximum number of units allowed by current zoning, with no other aspect of the Project modified in the Alternative so that any differences in the Alternative's impacts are clearly associated with the additional housing units.

The NOP suggests it will study a “lower intensity” Alternative. Since there were so many NOP comments suggesting a look at the jobs/housing balance, it makes sense to evaluate an Alternative that reduces the Office (and jobs), but that does not also reduce the amount of Housing or other project uses. Such an Alternative also would make more clear what impacts are tied to the amount of Office. ENCOURAGE THAT A REDUCED INTENSITY ALTERNATIVE COMPRISE LESS OFFICE, NOT LESS HOUSING.

POPULATION/HOUSING
The NOP states that it will compare the project’s population growth to ConnectMenlo growth and compare the housing to ABAG projections. Since ABAG projections are not based on actual planned projects, and were considered as part of ConnectMenlo, the housing provided should be compared with that projected in ConnectMenlo. Where else would the housing be built? Menlo Park needs to hold itself accountable for its share of the housing problem, which is the result of a severe jobs/housing imbalance that this project appears would exacerbate even further. ENCOURAGE A COMPARISON OF HOUSING, ALSO, TO CONNECTMENLO, NOT TO ABAG PROJECTIONS.

STANDARDS OF SIGNIFICANCE
I hope the City Council will decide in its priority setting process to prioritize the establishment of standards of significance for our city. These would help us establish achieve Climate Change goals, and could be used to more accurately assess impacts in comparison with current local conditions and local targets. Our City has virtually none of these, and they were not established as part of ConnectMenlo General Plan. For example, despite numerous CEQA Guidelines (such as 12/18 Technical Advisory<http://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf>) Menlo Park has no Vehicle Miles Traveled (VMT) targets for overall VMT or for VMT/capita (housing) or for VMT/employee (office and retail). If key standards were set, they could be applied to EIR's for major projects such as this one. Creating them shouldn't take years of effort, either. Commissions can help do homework and make recommendations for Council consideration so at least the key ones can be applied to this and other major projects currently proposed. DON'T KICK THE CAN DOWN THE ROAD.

Willow Village would be the largest project in Menlo Park's history. The EIR process is one of several tools to evaluate its potential negative and positive impacts and desirability for our community. The EIR needs to provide the data the would help the community and Council understand its potential negative environmental impacts. Make sure it will.

Respectfully submitted,
Patti Fry
Menlo Park resident
Received on Mon Dec 16 2019 - 09:08:10 PST

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