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EIR for Greenheart project

From: domainremoved <Patti>
Date: Tue, 9 Sep 2014 11:10:37 -0700

Dear City Council and Staff:

Before you authorize embarking on an EIR for the Greenheart project, you
should address some important issues related to this:

   1. What is the project? As pointed out in my comments related to the
   Notice of Preparation, the various documents provided by the applicant and
   the city have inconsistent information about what constitutes the project,
   its uses and their relative square feet, amount of parking. The EIR needs
   to study ONE set of values and uses. Project Alternatives can be defined to
   study other values and uses. The documents identify a potential range of
   square feet and potential uses, not a single set. The EIR cannot proceed
   without this essential definition.

   2. The "No Project Alternative should be of the previously approved
   projects at 1300 El Camino Real and Derry Lane (approved by Planning
   Commission) for the parcels related to those projects. These were assumed
   to be built by the Specific Plan EIR.

   3. Where are the project plans? Only artistic renderings are available
   of selected elevations. There are no elevations of the office buildings,
   and none of any building from the north. There are no plans similar to
   those available for other projects at this point in their review.
   Stanford's project had plans, the recently proposed project at 1283-1295 El
   Camino Real has plans with elevations. As you should know, such plans are
   not construction plans, but are the kinds of plans available when projects
   are submitted. There are none for Greenheart project, making it appear as
   if the true project is being hidden.

   4. Background - the EIR proposal states it is assuming 1% annual growth
   as "background". With compound growth calculated, this means a 28% growth
   over 25 years - just as background. This assumption is highly
   inappropriate. Not only can roadways not absorb it, a good portion of such
   growth relates to discretionary decisions made by Menlo Park and other
   communities.

   5. EIR scope (and type) As stated in my prior communication regarding
   the Notice of Preparation: "It is not appropriate to exclude
   Population/Housing from the EIR study. Using the same analytical
   assumptions as used by the City’s consultant Lisa Wise Consulting, Inc.,
   the Greenheart project could generate more than 2.5 jobs/housing unit. This
   worsens the assumed average in the Specific Plan of 1.56. Since the
   Specific Plan did not assume the Greenheart site was an “opportunity site”,
   this impact is potentially significant and adverse because the project adds
   disproportionately more jobs than housing. Given the previously announced
   proposal at 500 El Camino Real, it may not be possible for development
   within the Specific Plan’s Maximum Buildout to make up for the additional
   jobs represented by the Greenheart project in addition to other approved
   and pending projects in order to achieve the Specific Plan’s average."

   Further:


   - None of the Alternatives studied in the Specific Plan EIR evaluated
      more than 240,820 SF of Commercial (office). No matter how "net new" is
      counted, the amount of office proposed (in addition to other approved and
      pending projects) exceeds by at least 40% that amount. All of
this could be
      consider growth-inducing,

      - The "net new" must consider what was in the background of the
      Specific Plan, adjusted for changes in FAR and how SF are counted. Table
      below from Page 4-5, Table 4-1 of ECR/D Specific Plan DEIR


          SQUARE FOOTAGE OF PROJECTS USED IN CUMULATIVE ANALYSIS

      *PROJECT*

      *NEW RESIDENTIAL*

      *EXISTING RESIDENTIAL *

      *NEW COMMERCIAL*

      *EXISTING COMMERCIAL*

      1300 ECR





      110,065

      28,584

      Derry

      108



      24,925

      21,29
      -

      - The EIR must consider what was assumed for the entire El Camino
      Real North quadrant of the ECR/D Specific Plan area. Neither the 1300 ECR
      and Derry Lane parcels were assumed to have any further
redevelopment so no
      square feet are assumed on those parcels in this chart. ALL
amounts beyond
      those shown above are incremental for the purposes of this EIR. The ECR/D
      Specific Plan did not anticipate a project of Greenheart's magnitude and
      location.
      From page 174 of Specific Plan FEIR Appendices:
      [image: Inline image 1]


Please ensure that appropriate and complete information is made available
and a full analysis is done regarding the Greenheart project. This needs to
begin with a REAL project description and building plans that are made
available as soon as possible to our community.

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


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Received on Tue Sep 09 2014 - 11:06:35 PDT

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