HomeMy WebLinkAbout2018-11-14 Planning & transportation commission Agenda Packet_______________________
1. Spokespersons that are representing a group of five or more people who are identified as present at the meeting at the
time of the spokesperson’s presentation will be allowed up to fifteen (15) minutes at the discretion of the Chair, provided
that the non-speaking members agree not to speak individually.
2. The Chair may limit Oral Communications to 30 minutes for all combined speakers.
3. The Chair may reduce the allowed time to speak to two minutes or less to accommodate a larger number of speakers.
Planning & Transportation Commission
Regular Meeting Agenda: November 14, 2018
Council Chambers
250 Hamilton Avenue
6:00 PM
Call to Order / Roll Call
Oral Communications
The public may speak to any item not on the agenda. Three (3) minutes per speaker.1,2
Agenda Changes, Additions, and Deletions
The Chair or Commission majority may modify the agenda order to improve meeting management.
City Official Reports
1. Assistant Directors Report, Meeting Schedule and Assignments
2. Draft 2019 Meeting Schedule and Assignments
Study Session
Public Comment is Permitted. Three (3) minutes per speaker.1,3
3. Provide Feedback on Conceptual Design Options to Improve Multimodal Connectivity
and Safety along El Camino Real Between Stanford Avenue and Lambert Avenue
Action Items
Public Comment is Permitted. Applicants/Appellant Teams: Fifteen (15) minutes, plus three (3) minutes rebuttal.
All others: Three (3) minutes per speaker.1,3
4. PUBLIC HEARING. Recommendation to the City Council an Ordinance Amending Palo
Alto Municipal Code (PAMC) Title 18 (Zoning), Chapter 18.31 (CEQA Review) to Add
Environmental Review and Compliance Regulations for Development Projects in
Furtherance of and to Implement the Comprehensive Plan Environmental Impact
Report (EIR) Mitigation Measures, as Documented in the Mitigation Monitoring and
Reporting Plan Adopted by Council Resolution 9721 on November 13, 2017.
Environmental Assessment: Not a Project.
_______________________
1. Spokespersons that are representing a group of five or more people who are identified as present at the meeting at the
time of the spokesperson’s presentation will be allowed up to fifteen (15) minutes at the discretion of the Chair, provided
that the non-speaking members agree not to speak individually.
2.The Chair may limit Oral Communications to 30 minutes for all combined speakers.
3.The Chair may reduce the allowed time to speak to two minutes or less to accommodate a larger number of speakers.
Approval of Minutes
Public Comment is Permitted. Three (3) minutes per speaker.1,3
5.September 26, 2018 Draft Planning & Transportation Commission Meeting Minutes
6.October 10, 2018 Draft Planning & Transportation Commission Meeting Minutes
Committee Items
Commissioner Questions, Comments, Announcements or Future Agenda Items
Adjournment
Draft Meeting
Minutes
Draft Meeting Minutes
_______________________
1. Spokespersons that are representing a group of five or more people who are identified as present at the meeting at the
time of the spokesperson’s presentation will be allowed up to fifteen (15) minutes at the discretion of the Chair, provided
that the non-speaking members agree not to speak individually.
2. The Chair may limit Oral Communications to 30 minutes for all combined speakers.
3. The Chair may reduce the allowed time to speak to two minutes or less to accommodate a larger number of speakers.
Palo Alto Planning & Transportation Commission
Commissioner Biographies, Present and Archived Agendas and Reports are available online:
http://www.cityofpaloalto.org/gov/boards/ptc/default.asp. The PTC Commission members are:
Chair Ed Lauing
Vice Chair Susan Monk
Commissioner Michael Alcheck
Commissioner Przemek Gardias
Commissioner William Riggs
Commissioner Doria Summa
Commissioner Asher Waldfogel
Get Informed and Be Engaged!
View online: http://midpenmedia.org/category/government/city-of-palo-alto/ or on Channel
26.
Show up and speak. Public comment is encouraged. Please complete a speaker request card
located on the table at the entrance to the Council Chambers and deliver it to the Commission
Secretary prior to discussion of the item.
Write to us. Email the PTC at: Planning.Commission@CityofPaloAlto.org. Letters can be
delivered to the Planning & Community Environment Department, 5th floor, City Hall, 250
Hamilton Avenue, Palo Alto, CA 94301. Comments received by 2:00 PM two Tuesdays preceding
the meeting date will be included in the agenda packet. Comments received afterward through
2:00 PM the day of the meeting will be presented to the Commission at the dais.
Material related to an item on this agenda submitted to the PTC after distribution of the
agenda packet is available for public inspection at the address above.
Americans with Disability Act (ADA)
It is the policy of the City of Palo Alto to offer its public programs, services and meetings in a
manner that is readily accessible to all. Persons with disabilities who require materials in an
appropriate alternative format or who require auxiliary aids to access City meetings, programs,
or services may contact the City’s ADA Coordinator at (650) 329-2550 (voice) or by emailing
ada@cityofpaloalto.org. Requests for assistance or accommodations must be submitted at least
24 hours in advance of the meeting, program, or service.
Planning & Transportation Commission
Staff Report (ID # 9656)
Report Type: City Official Reports Meeting Date: 11/14/2018
City of Palo Alto
Planning & Community Environment
250 Hamilton Avenue
Palo Alto, CA 94301
(650) 329-2442
Summary Title: City Official Report
Title: Assistant Directors Report, Meeting Schedule and Assignments
From: Jonathan Lait
Recommendation
Staff recommends that the Planning and Transportation Commission (PTC) review and
comment as appropriate.
Background
This document includes the following items:
• PTC Meeting Schedule
• PTC Representative to City Council (Rotational Assignments)
• Tentative Future Agenda
Commissioners are encouraged to contact Yolanda Cervantes
(Yolanda.Cervantes@CityofPaloAlto.org) of any planned absences one month in advance, if
possible, to ensure availability of a PTC quorum.
PTC Representative to City Council is a rotational assignment where the designated
commissioner represents the PTC’s affirmative and dissenting perspectives to Council for quasi-
judicial and legislative matters. Representatives are encouraged to review the City Council
agendas (http://www.cityofpaloalto.org/gov/agendas/council.asp) for the months of their
respective assignments to verify if attendance is needed or contact staff. Prior PTC meetings are
available online at http://midpenmedia.org/category/government/city-of-palo-alto/boards-
and-commissions/planning-and-transportation-commission.
The Tentative Future Agenda provides a summary of upcoming projects or discussion items.
Attachments:
• Attachment A: November 14, 2018 PTC Meeting Schedule and Assignments (DOCX)
Draft Planning & Transportation Commission
2018 Meeting Schedule & Assignments
2018 Schedule
Meeting Dates Time Location Status Planned Absences
1/10/2018 6:00 PM Council Chambers Regular Riggs, Waldfogel
1/17/2018 6:00 PM Council Chambers Special
1/31/2018 6:00 PM Council Chambers Regular
2/14/2018 6:00 PM Council Chambers Regular
2/28/2018 6:00 PM Council Chambers Regular Cancelled
3/14/2018 6:00 PM Council Chambers Regular
3/28/2018 6:00 PM Council Chambers Regular Riggs
4/11/2018 6:00 PM Council Chambers Regular
4/25/2018 6:00 PM Council Chambers Regular Lauing, Riggs
5/09/2018
5/22/2018
6:00 PM
6:00 PM
Council Chambers
Council Chambers
Regular
Special
Cancelled(Alcheck,
Lauing, Monk, Riggs)
Alcheck
5/30/2018 6:00PM Council Chambers Regular
6/13/2018 6:00 PM Council Chambers Regular Alcheck, Riggs
6/27/2018 6:00 PM Council Chambers Regular Alcheck
7/11/2018 6:00 PM Council Chambers Regular Cancelled
7/25/2018 6:00 PM Council Chambers Regular Gardias, Riggs
8/08/2018 6:00 PM Council Chambers Regular Cancelled
8/29/2018 6:00 PM Council Chambers Regular
9/12/2018 6:00 PM Council Chambers Regular Riggs, Waldfogel
9/26/2018 6:00 PM Council Chambers Regular
10/10/2018 6:00 PM Council Chambers Regular Riggs
10/31/2018 6:00 PM Council Chambers Regular Cancelled
11/14/2018 6:00 PM Council Chambers Regular
11/28/2018 6:00 PM Council Chambers Regular Cancelled
12/12/2018 6:00 PM Council Chambers Regular
12/26/2018 6:00 PM Council Chambers CANCELLED
2018 Assignments - Council Representation (primary/backup)
January February March April May June
Ed Lauing Susan Monk Doria Summa Przemek Gardias Michael Alcheck Billy Riggs
Asher Waldfogel Michael Alcheck Przemek Gardias Susan Monk Ed Lauing Doria Summa
July August September October November December
Asher Waldfogel Ed Lauing Przemek Gardias Susan Monk Michael Alcheck Asher Waldfogel
Billy Riggs Michael Alchek Asher Waldfogel Doria Summa Przemek Gardias Ed Lauing
Draft Planning & Transportation Commission
2018 Tentative Future Agenda
November 5, 2018 Draft-All Dates and Topics Subject to Change
The Following Items are Tentative and Subject to Change:
Meeting Dates Topics
November 28, 2018 Cancelled
December 12, 2018 • Study Session on Case Study of Neighborhood Traffic Impacts
• 2321 Wellesley: Zone Change
• Amendments to Wireless Facilities Requirements (18.42.10)
• 3200 El Camino Real Parmani Hotel
Planning & Transportation Commission
Staff Report (ID # 9825)
Report Type: City Official Reports Meeting Date: 11/14/2018
City of Palo Alto
Planning & Community Environment
250 Hamilton Avenue
Palo Alto, CA 94301
(650) 329-2442
Summary Title: 2019 PTC Meeting Dates
Title: Draft 2019 Meeting Schedule and Assignments
From: Jonathan Lait
Recommendation
Staff recommends that the Planning and Transportation Commission review and provide
feedback regarding the Draft 2019 Meeting Schedule and Assignments.
PTC1 Liaison & Contact Information
Jonathan Lait, AICP, Assistant Director
(650) 329-2679
jonathan.lait@cityofpaloalto.org
Attachments:
• Attachment A: Draft 2019 Meeting Schedule and Assignments (DOCX)
1 Emails may be sent directly to the PTC using the following address: planning.commission@cityofpaloalto.org
Draft Planning & Transportation Commission
2019 Meeting Schedule & Assignments
2019 Schedule
Meeting Dates Time Location Status Planned Absences
1/30/2019 6:00 PM Council Chambers Regular
2/13/2019 6:00 PM Council Chambers Regular
2/27/2019 6:00 PM Council Chambers Regular
3/13/2019 6:00 PM Council Chambers Regular
3/27/2019 6:00 PM Council Chambers Regular
4/10/2019 6:00 PM Council Chambers Regular
4/24/2019 6:00 PM Council Chambers Regular
5/08/2019 6:00 PM Council Chambers Regular
5/29/2019 6:00 PM Council Chambers Regular
6/12/2019 6:00 PM Council Chambers Regular
6/26/2019 6:00 PM Council Chambers Regular
7/10/2019 6:00 PM Council Chambers Regular
7/31/2019 6:00 PM Council Chambers Regular
8/14/2019 6:00 PM Council Chambers Regular
8/28/2019 6:00 PM Council Chambers Regular
9/11/2019 6:00 PM Council Chambers Regular
9/25/2019 6:00 PM Council Chambers Regular
10/09/2019 6:00 PM Council Chambers Regular
10/30/2019 6:00 PM Council Chambers Regular
11/13/2019 6:00 PM Council Chambers Regular
12/11/2019 6:00 PM Council Chambers Regular
2019 Assignments - Council Representation (primary/backup)
January February March April May June
Doria Summa Asher Waldfogel Ed Lauing Michael Alcheck Billy Riggs TBD
Michael Alcheck Billy Riggs Doria Summa Asher Waldfogel Ed Lauing Michael Alcheck
July August September October November December
Ed Lauing TBD Michael Alcheck TBD Billy Riggs Doria Summa
Billy Riggs Doria Summa TBD Ed Lauing TBD Ed Lauing
Draft Planning & Transportation Commission
2019 Tentative Future Agenda
November 5, 2018 Draft-All Dates and Topics Subject to Change
The Following Items are Tentative and Subject to Change:
Meeting Dates Topics
January 30, 2019 TBD
Planning & Transportation Commission
Staff Report (ID # 9556)
Report Type: Study Session Meeting Date: 11/14/2018
City of Palo Alto
Planning & Community Environment
250 Hamilton Avenue
Palo Alto, CA 94301
(650) 329-2442
Summary Title: El Camino Real Safety+Connectivity Planning
Title: Provide Feedback on Conceptual Design Options to Improve
Multimodal Connectivity and Safety along El Camino Real
Between Stanford Avenue and Lambert Avenue
From: Jonathan Lait
Recommendation
Staff recommends that the Planning and Transportation Commission (PTC) take the following
action(s):
1. Discuss preliminary results of the Grand Boulevard Initiative: Creating Safe and Healthy
Corridor Communities planning project and provide input to staff on Conceptual Design
Option 1 and Option 2.
Report Summary
El Camino Real has long been the focus of local and regional planning activity. From the City of
Palo Alto’s 2007 Draft El Camino Real Master Plan and the 2002 South El Camino Real Design
Guidelines, to the broader vision of the Grand Boulevard Initiative, many challenges and
opportunities related to land use, design, and transportation have been raised.
Unlike past city-led efforts, the Grand Boulevard Initiative: Creating Safe and Healthy Corridor
Communities planning project is highly focused, both spatially and topically. Spatially, the
project limits are a short segment of El Camino Real: Stanford Avenue to Lambert Avenue.
Topically, safety is the prime criteria: 51 bicyclist and pedestrian involved crashes have occurred
along this 0.8-mile section between 2005 and 2015.
Background
One of the eight goals in the Comprehensive Plan 2030 Transportation Element centers on
providing a safe environment for all modes on Palo Alto streets and is further described as the
first priority of citywide transportation planning.
City of Palo Alto
Planning & Community Environment Department Page 2
In early 2015, results of a collaborative collision analysis along El Camino Real, conducted
through interagency partnerships forged through the Grand Boulevard Initiative, revealed high
bicycle and pedestrian collision rates on El Camino Real between Stanford Avenue and Lambert
Avenue.
A unique multi-agency grant application proposal was selected as the preferred method to
undertake a planning process to comprehensively engage communities, incorporate feedback,
and develop potential streetscape concept plans. SamTrans, as one of the coordinating
agencies of the Grand Boulevard Initiative, volunteered to be the primary grant applicant.
In fall 2015, SamTrans, in collaboration with the City’s Office of Transportation and Redwood
City’s Community Development Department, submitted a grant application to Caltrans’s
Sustainable Transportation Planning Grant Program called Grand Boulevard Initiative: Creating
Safe and Healthy Corridor Communities. The primary goal of the project is to develop
streetscape design options in response to high bicycle and pedestrian collision rates along two
segments of El Camino Real in the respective partner cities.
SamTrans’s Communities project proposal was awarded $349,074 by Caltrans in summer 2016.
In January 2017, the City of Palo Alto entered into a funding agreement with SamTrans,
authorizing use of $22,613 in matching local funds for the project.
Throughout 2018, public meetings and surveys presented facts and solicited community
feedback on transportation-related concerns in the study area. The Planning & Transportation
Commission study session is one element in the final phase of the project’s outreach before
concluding in January 2019 with conceptual plans and a summary of public feedback.
Commission feedback is sought on two attached conceptual designs.
Discussion
Community feedback and analysis of technical data indicate multimodal safety, mobility, and
connectivity are key areas for potential improvement along the study corridor. These
categories, among others, guided development of the two conceptual design options for the
study corridor. Analysis of these factors is provided in the following paragraphs followed by a
summary of the design options and several questions for commission discussion around areas
of concern.
SAFETY
Between 2006 and 2015, 51 people walking or biking along El Camino Real between Stanford
and Lambert Avenue were involved in a collision. This is an average of five people each year
over a 10-year span. The collision data originate from the Statewide Integrated Traffic Records
System (SWITRS) and were analyzed by Fehr & Peers, the lead transportation planning and
engineering consulting firm working on this study. The following tables are a summary of
City of Palo Alto
Planning & Community Environment Department Page 3
bicycle and pedestrian crash profile graphics and maps, which are available as an attachment to
this report.
This Area Intentionally Blank
See Table on Following Page
City of Palo Alto
Planning & Community Environment Department Page 4
Pedestrian Collision Profiles 2006-2015
Total Crashes: 20
Four Frequent
Crash Types
Summary of Pedestrian-Involved
Collisions
Potential Causes &
Countermeasures
Side-Street Stop
Controlled Intersection
• 7 crashes occurred at side-street
stop-controlled intersections
• 4 crashes: Driver failure to yield
• 3 crashes: Pedestrian crossing El
Camino Real
• Causes: High speeds; impaired sight
lines; limited gaps in traffic; distance
between crosswalks
• Countermeasures: curb extensions;
remove some parking to clear sight
lines; slow vehicle turns
Vulnerable Populations
(Seniors)
• 7 crashes involved injuries to
seniors walking
• Sunrise Senior Living facility is
adjacent to the corridor
• Senior-friendly design: longer walk
signal times
• Focus pedestrian improvements
adjacent to senior centers
Red Light Violations • 6 crashes where either a vehicle or
pedestrian entered intersection
against the signal
• Shorter signal cycles at key intersections
Permitted Right Turns • 6 crashes occurred when vehicle
was turning right onto or off of El
Camino Real.
• 5 of 6 occurred at signalized
intersections and while pedestrian
was in crosswalk
• Same as Side-Street Stop crash
countermeasures
Bicyclist Collision Profiles 2006-2015
Total Crashes: 31
Four Frequent
Crash Types
Summary of Bicycle-Involved
Collisions
Potential Causes &
Countermeasures
High Speed Traffic and
Shared Travel Lane
• 9 crashes: midblock sideswipe and
rear-end collisions
• Occurred when vehicle was
changing lanes
• Causes: Bicyclists share high-speed auto
travel lanes
• Countermeasures: traffic calming; driver
education; wayfinding directing cyclists
to alternate routes; and/or dedicated
bicycle facilities
Wrong-Way Bicycling • 9 crashes: Occurs when cyclist is
travelling in the street opposite the
direction of motor vehicle traffic
• Existing facilities do not meet a cyclist’s
desire lines
• Expand cycling facilities and ensure
reasonably short signal cycle lengths
Side Streets and
Driveways
• 5 Crashes: Vehicle or bicyclist
entering or exiting El Camino Real
and failed to yield to a vehicle or
bicyclist travelling on the street.
• Causes: inhibited sight lines; limited
gaps in traffic; right of way confusion
• Countermeasures: clear sight lines;
clarify right-of-way at intersections
Red Light Violation • 4 crashes: vehicle or bicycle
entered the intersection during a
red light.
• Shorter signal cycles at key intersections
The nine reported sideswipe and rear-end bicycle-involved collisions are a surprising outlier and
offer insight towards potential countermeasures. These collision types are uncommon on urban
roads where there are either few cyclists or motor traffic speeds and volumes are low enough
City of Palo Alto
Planning & Community Environment Department Page 5
that travel lanes may be shared between bicyclists and motor vehicles with less crash risk. On El
Camino Real, neither of these conditions appears to be present. Motor traffic routinely exceed
the 35MPH posted speed limit and high vehicle volumes likely complicate passing maneuvers
around cyclists within the travel lane. Furthermore, despite the automobile-dominant
environment, cyclists are still traveling on El Camino Real.
Bicycle and Pedestrian Collision “heat map” showing location and frequency of collisions along the study corridor.
CONNECTIVITY
Bicycle and pedestrian connectivity issues generally relate to the quality of east-west crossings
of El Camino Real and needs along El Camino Real.
Most continuous east-west streets which cross El Camino Real are classified either an existing
or planned bikeway connection or suggested safe route to school. However, with the exception
of Stanford Avenue and El Camino Real, few intersections have received substantial upgrades.
Some intersections, such as College Avenue have a marked crosswalk, but no type of control,
such as a signal, which is not recommended in the latest federal design guidelines.
Furthermore, the distance between crossings can be long, reinforcing the perception that El
Camino Real is a barrier to community connectivity.
Along El Camino Real, there are no on-street bicycle facilities, and as the collision findings note,
sharing the road can be hazardous. Despite the discomfort with cycling on an automobile-
oriented road, the land use characteristics of the corridor likely contribute to travel demand by
bicycle, particularly within the study area. Businesses, offices, community facilities, and
increasingly mixed-use residential land uses directly front El Camino Real, necessitating that
those approaching via bicycle complete their trip on at least a few blocks of El Camino Real.
Other major destinations such as Palo Alto Square and the Stanford/Palo Alto Community
Playing Fields, may only be reached conveniently from most residential neighborhoods via El
Camino Real.
City of Palo Alto
Planning & Community Environment Department Page 6
Existing and proposed bicycle network in the vicinity of the study area. With the exception of the Stanford Perimeter
Trail, which ends at Stanford Avenue and El Camino Real, all bikeways are east-west oriented. Star icons denote
major destinations.
MOBILITY AND ACCESS
In the Comprehensive Plan, El Camino Real is classified as an arterial, a roadway typology
commonly associated with mobility and higher travel speeds. Additionally, the corridor hosts
the city’s most frequent and heavily patronized bus services: VTA line 22 and 522. Community
feedback touched on the importance the road plays in moving large volumes of motor traffic
relatively quickly and that it would remain a major force along the corridor, moderated with
streetscaping and safety countermeasures. However, based on results from dot exercises and
online surveys, opinions diverged regarding the need for on-street auto parking along El Camino
Real.
Project staff organized a stakeholder meeting with CalMOCA, a California Avenue Merchant
organization, and the feedback received was to retain parking supply and focus bicycle and
pedestrian improvements on east-west connectivity.
Parking occupancy surveys conducted as part of the project partially reflect this result: parking
occupancy is relatively low along most block faces within the study area. In the graphic below,
dark red indicates occupancy greater than 85%, or when parking would be difficult to find.
In addition to potential changes to curbside uses, the project is considering new transit “queue
jump” lanes approaching the El Camino Real and Page Mill Road intersection. The operations of
the lanes were evaluated using traffic simulation software which can better account for random
arrivals of vehicles and corridor congestion than traditional methods. Initial results show
significant travel time savings for both transit riders and drivers of private vehicles, but street
trees and right-of-way acquisition would be required along the Palo Alto Square and
City of Palo Alto
Planning & Community Environment Department Page 7
Stanford/Community Playing Fields frontages. The following results from the preliminary
analysis show significant reductions in delay. Further analysis and approvals from Caltrans and
Santa Clara County Roads and Airports would be required if detailed conceptual design and
steps toward implementation were desired.
Table: Transit Delay (seconds) at Page Mill Rd/El Camino Real
PM AM
Southbound Northbound Southbound Northbound
Background Cond. 100 110 70 100
Option 1 + Option 2 -35 (35.0%) -15 (15.0%) - -40 (40.0%)
On-street parking occupancy along El Camino Real within the limits of the study area.
CONCEPTUAL DESIGNS
After compiling community feedback from two outreach events and two surveys, the project
team developed conceptual design plans for two options along the study corridor (El Camino
Real; Stanford Ave to Lambert Ave). The following are a summary of the key differences
between the two options. Full-size concept plans are presented as attachments.
City of Palo Alto
Planning & Community Environment Department Page 8
Option 1 Option 2
Bicycle • Protected bicycle lanes along
the study corridor, including at
key intersections
• No bike facility on El Camino
Real
• Potential enhancement or
implementation of parallel
bikeways
Transit Reliability • Queue jump lanes at Page Mill/El Camino Real; some property
acquisition required
• Bus bulb-out boarding areas with passenger amenities
• Substantial reduction in delay for transit at the intersection
• Moderate reduction in delay for automobiles
Parking • All on-street parking removed
along El Camino in the study
area
• Additional parking management
analysis required
• Some on-street parking
removed to achieve safety
benefits
Pedestrian • Install curb extensions to shorten crossings, improve visibility, slow
turning vehicles
• Potential shorter traffic signal cycles
• New controlled mid-block pedestrian crossings at College Avenue;
Grant Avenue and Olive Avenue, reducing distance between crossings.
• Opportunity for streetscaping & placemaking with new pedestrian light
fixtures, street trees, and furnishings.
As shown in the table, there are several major changes proposed in either or both option 1 and
2, for which staff is seeking Commission feedback:
1) In the study area, one option would remove all on-street parking and install protected
bicycle lanes. What are commissioner preferences for curbside uses along the study
corridor?
2) Both options include a bus transit “queue jump” lane on the El Camino Real approaches
to the Page Mill Road/El Camino Real intersection, requiring right-of-way acquisition
and removal of street trees along the Palo Alto Square and Stanford Playing Field
frontages. What benefits and drawbacks do commissioners see with this aspect of the
project? Are there additional features or considerations that should be included?
Analysis
The City’s 2012 Bicycle and Pedestrian Transportation Plan and 2017 Comprehensive Plan 2030
are two primary policy documents which informed development of the concept plans. The two
conceptual design options presented for consideration are consistent with many goals, plans
and programs identified in the Transportation Element of the Comprehensive Plan 2030. There
are a few differences and factors to consider, however:
City of Palo Alto
Planning & Community Environment Department Page 9
• Option 1 (Protected Bike Lanes) would result in safer bicycle access to destinations along
El Camino Real and respond to the known bicycle collision pattern along the corridor.
Option 2 does not provide an equivalent degree of bicyclist connectivity or safety.
• Bus Queue Jump Lanes: Transit priority treatments are identified as a mitigation
measure in the Comprehensive Plan 2030 EIR and were conceptually developed with
feedback from VTA.
The project options are consistent with the following goals, policies, and programs in the
Comprehensive Plan 2030 Transportation Element:
Goal T-1: Create a sustainable transportation system, complimented by a mix of land uses, that
emphasizes walking, bicycling, use of public transportation and other methods to reduce GHG
emissions and the use of single occupancy motor vehicles.
Policy T-1.1: Take a comprehensive approach to reducing single-occupant vehicle trips
by involving those who live, work and shop in Palo Alto in developing strategies that
make it easier and more convenient not to drive.
Policy T-1.3: Reduce GHG and pollutant emissions associated with transportation by
reducing VMT and per-mile emissions through increasing transit options, supporting
biking and walking, and through the use of zero-emission vehicle technologies to meet
City and State goals for GHG reductions by 2030.
Policy T-1.6: Encourage innovation and expanded transit access to regional destinations,
multi-modal transit stations, employment centers and commercial centers, including
those within Palo Alto through the use of efficient public and/or private transit options
such as rideshare services, on-demand local shuttles and other first/last mile
connections.
Policy T-1.9: Continue to encourage the provision of amenities such as seating, lighting
and signage, including real-time arrival information, at bus and shuttle stops and train
stations to increase rider comfort, safety and convenience.
Program T1.12.3: Work with VTA to study the feasibility of, and if warranted provide,
traffic signal prioritization for buses at Palo Alto intersections, focusing first on regional
transit routes. Also, advocate for bus service improvements on El Camino Real such as
queue jump lanes and curbside platforms.
Policy T-1.19: Provide facilities that encourage and support bicycling and walking.
Goal T-2: Decrease delay, congestion, and VMT with a priority on our worst intersections and
our peak commute times, including school traffic.
City of Palo Alto
Planning & Community Environment Department Page 10
Policy T-2.3: Use motor vehicle LOS at signalized intersections to evaluate the potential
impact of proposed projects, including contributions to cumulative congestion. Use
signal warrants and other metrics to evaluate impacts at unsignalized intersections.
Policy-T-3.5: When constructing or modifying roadways, plan for use of the roadway by
all users.
Goal T-3: Maintain an efficient roadway network for all users.
Program T3.5.1: Continue to use best practices in roadway design that are consistent
with complete streets principles and the Urban Forest Master Plan, focusing on bicycle
and pedestrian safety and multi-modal uses. Consider opportunities to incorporate best
practices from the National Association of City Transportation Officials guidelines for
urban streets and bikeways, tailored to the Palo Alto context.
Policy-T-3.7: Encourage pedestrian-friendly design features such as sidewalks, street
trees, on-street parking, gathering spaces, gardens, outdoor furniture, art and
interesting architectural details.
Goal T-5: Encourage attractive, convenient, efficient and innovative parking solutions for all
users.
Goal T-6: Provide a safe environment for motorists, pedestrians, and bicyclists on Palo Alto
streets.
Policy T-6.1: Continue to make safety the first priority of citywide transportation
planning. Prioritize pedestrian, bicycle, and automobile safety over motor vehicle level
of service at intersections and motor vehicle parking.
Public Notification, Outreach & Comments
Outreach activities are structured into three stages. The following have occurred or are
planned:
Stage 1: Winter 2018
• Pop-up event at the California Avenue Farmer’s Market
• Online Survey
Stage 2: Summer 2018
• Pop-up event at the California Avenue Farmer’s Market
• Online Survey
Stage 3: Fall 2018
• Pop-up event at the California Avenue Farmer’s Market
• PABAC Meeting
City of Palo Alto
Planning & Community Environment Department Page 11
• Planning Commission Meeting
• Evening Open House Community Meeting.
• Online Survey
City Council: Winter 2019
• City Council Meeting [Tentative]
The survey link was emailed to a list of those interested in project updates as well as to local
school communities, posted to the project website, and distributed at outreach events. The
online surveys completed to date have generated 1,700 comments about where improvements
should be focused and were instrumental in shaping the two concept plans. The final survey is
open for community feedback now and is on the project website here.
Project Schedule & Future
Commission feedback received at this meeting will be shared at the winter 2019 City Council
meeting and ultimately incorporated into a final report prepared at the conclusion of the
Communities study. The final report and concept plans represent the final deliverables for the
Communities study and will potentially allow the city to develop and implement changes along
all or a portion of the corridor, if ultimately authorized by City Council.
The City does have $4.6 million in separate grant funding available to prepare design plans and
construct multimodal streetscape improvements along El Camino Real between Stanford
Avenue and Grant Avenue. However, employing this funding will require additional outreach
and design, work for which staff have not identified resources to support.
Environmental Review
The study session is a preliminary review process in which commissioners may provide
comment, but no formal action will be taken. Therefore, no review under the California
Environmental Quality Action (CEQA) is required at this time. The proposed action will be
assessed in accordance with CEQA prior to any request for a formal recommendation.
Report Author & Contact Information PTC1 Liaison & Contact Information
Jarrett Mullen, Senior Transportation Planner Jonathan Lait, AICP, Interim Director
(650) 329-2218 (650) 329-2679
jarrett.mullen@cityofpaloalto.org jonathan.lait@cityofpaloalto.org
Attachments:
• Attachment A: Option 1 Concept Plan (PDF)
• Attachment B: Option 2 Concept Plan (PDF)
• Attachment C: California Ave 3d Rendering Option 1+2 [FINAL]reduced (PDF)
1 Emails may be sent directly to the PTC using the following address: planning.commission@cityofpaloalto.org
City of Palo Alto
Planning & Community Environment Department Page 12
• Attachment D: Hansen Way 3d Rendering Option 1+2 (PDF)
SHERMANAVE
CALIFORNIAAVE
CAMBRIDGEAVE
COLLEGEAVE
OXFORDAVE
STANFORDAVE
EL
C
A
M
I
N
O
R
E
A
L
EL
C
A
M
I
N
O
R
E
A
L
EXI
S
T
I
N
G
BUS
S
T
O
P
ACACIAAVE
PORTAGEAVE
HANSENWAY
EL
C
A
M
I
N
O
R
E
A
L
LAMBERTAVE
STAN
F
O
R
D
PERI
M
E
T
E
R
TRAI
L
OLIVEAVE
PEPPERAVE
SHERIDANAVE
GRANTAVE
PAGE MILL RD
EX
I
S
T
I
N
G
BU
S
S
T
O
P
BUS
S
T
O
P
POT
E
N
T
I
A
L
REL
O
C
A
T
E
D
BU
S
S
T
O
P
PORTAGEAVE
LAMBERTAVE
EX
I
S
T
I
N
G
BU
S
S
T
O
P
SEE
B
U
S
S
T
O
P
D
E
T
A
I
L
1
RE
L
O
C
A
T
E
D
BU
S
S
T
O
P
SEE
B
U
S
S
T
O
P
D
E
T
A
I
L
1
BU
S
S
T
O
P
SEE
B
U
S
S
T
O
P
D
E
T
A
I
L
1
BU
S
S
T
O
P
SEE
B
U
S
S
T
O
P
D
E
T
A
I
L
1
EL
C
A
M
I
N
O
R
E
A
L
:
be
t
w
e
e
n
St
a
n
f
o
r
d
A
v
e
a
n
d
L
a
m
b
e
r
t
A
v
e
OP
T
I
O
N
1
:
I
n
s
t
a
l
l
P
r
o
t
e
c
t
e
d
B
i
k
e
L
a
n
e
s
i
n
P
l
a
c
e
o
f
O
n
-
S
t
r
e
e
t
P
a
r
k
i
n
g
SEP
A
R
A
T
E
RIG
H
T
T
U
R
N
PH
A
S
E
A
D
D
E
D
DE
D
I
C
A
T
E
D
R
I
G
H
T
T
U
R
N
LAN
E
C
O
N
S
O
L
I
D
A
T
E
D
T
O
MAK
E
R
O
O
M
F
O
R
PR
O
T
E
C
T
E
D
B
I
K
E
L
A
N
E
SEP
A
R
A
T
E
RIG
H
T
T
U
R
N
PH
A
S
E
A
D
D
E
D
DRI
V
E
W
A
Y
RE
M
O
V
E
D
D
U
E
T
O
RE
D
E
V
E
L
O
P
M
E
N
T
DRI
V
E
W
A
Y
REM
O
V
E
D
D
U
E
T
O
RED
E
V
E
L
O
P
M
E
N
T
DRI
V
E
W
A
Y
APP
R
O
A
C
H
A
D
D
E
D
TO
S
I
G
N
A
L
T
I
M
I
N
G
RIG
H
T
T
U
R
N
SLI
P
L
A
N
E
S
CLO
S
E
D
NO
R
I
G
H
T
T
U
R
N
ON
R
E
D
T
O
PRO
T
E
C
T
B
I
K
E
B
O
X
NO
R
I
G
H
T
T
U
R
N
ON
R
E
D
T
O
PR
O
T
E
C
T
B
I
K
E
B
O
X
BU
S
S
T
O
P
T
O
B
E
D
E
S
I
G
N
E
D
P
E
R
PE
N
D
I
N
G
V
T
A
D
E
S
I
G
N
S
T
A
N
D
A
R
D
S
BUS
S
T
O
P
T
O
B
E
D
E
S
I
G
N
E
D
P
E
R
PEN
D
I
N
G
V
T
A
D
E
S
I
G
N
S
T
A
N
D
A
R
D
S
BUS
S
T
O
P
T
O
B
E
D
E
S
I
G
N
E
D
P
E
R
PEN
D
I
N
G
V
T
A
D
E
S
I
G
N
S
T
A
N
D
A
R
D
S
BUS
S
T
O
P
T
O
B
E
D
E
S
I
G
N
E
D
PER
P
E
N
D
I
N
G
V
T
A
D
E
S
I
G
N
STA
N
D
A
R
D
S
BU
S
S
T
O
P
T
O
B
E
D
E
S
I
G
N
E
D
PE
R
P
E
N
D
I
N
G
V
T
A
D
E
S
I
G
N
ST
A
N
D
A
R
D
S
BU
S
S
T
O
P
T
O
B
E
D
E
S
I
G
N
E
D
PER
P
E
N
D
I
N
G
V
T
A
D
E
S
I
G
N
STA
N
D
A
R
D
S
SEP
A
R
A
T
E
B
I
C
Y
C
L
E
SIG
N
A
L
P
H
A
S
I
N
G
SEP
A
R
A
T
E
B
I
C
Y
C
L
E
SIG
N
A
L
P
H
A
S
I
N
G
DE
T
A
I
L
1
EL
C
A
M
I
N
O
R
E
A
L
:
b
e
t
w
e
e
n
S
t
a
n
f
o
r
d
A
v
e
a
n
d
L
a
m
b
e
r
t
A
v
e
OP
T
I
O
N
1
:
I
n
s
t
a
l
l
P
r
o
t
e
c
t
e
d
B
i
k
e
L
a
n
e
s
i
n
P
l
a
c
e
o
f
O
n
-
S
t
r
e
e
t
P
a
r
k
i
n
g
* pe
n
d
i
n
g
e
v
a
l
u
a
t
i
o
n
o
f
p
e
d
e
s
t
r
i
a
n
v
i
s
i
b
i
l
i
t
y
Rem
o
v
e
E
x
i
s
t
i
n
g
C
u
r
b
Pro
p
o
s
e
d
T
r
a
f
f
i
c
S
i
g
n
La
n
d
s
c
a
p
e
M
e
d
i
a
n
s
Har
d
s
c
a
p
e
A
r
e
a
Sid
e
S
t
r
e
e
t
S
t
o
p
I
n
t
e
r
s
e
c
t
i
o
n
Ex
i
s
t
i
n
g
C
u
r
b
Pro
p
o
s
e
d
C
u
r
b
Nee
d
f
o
r
I
m
p
r
o
v
e
m
e
n
t
Pot
e
n
t
i
a
l
I
m
p
r
o
v
e
m
e
n
t
App
r
o
v
e
d
P
r
o
j
e
c
t
s
Pen
d
i
n
g
P
r
o
j
e
c
t
s
STANFORD AVE
Tra
f
f
i
c
s
i
g
n
a
l
imp
r
o
v
e
m
e
n
t
Im
p
r
o
v
e
d
Way
f
i
n
d
i
n
g
S
i
g
n
a
g
e
Sa
f
e
R
o
u
t
e
s
t
o
Sch
o
o
l
Fre
q
u
e
n
t
P
u
b
l
i
c
Co
m
m
e
n
t
:
I
m
p
r
o
v
e
Bik
e
C
r
o
s
s
i
n
g
Tw
o
-
s
t
a
g
e
L
e
f
t
-
t
u
r
n
Bicy
c
l
e
B
o
x
Rig
h
t
t
u
r
n
o
n
red
r
e
s
t
r
i
c
t
i
o
n
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
s
OXFORD AVE
COLLEGE AVE
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
Red
c
u
r
b
t
o
i
m
p
r
o
v
e
sig
h
t
d
i
s
t
a
n
c
e
Ne
w
p
e
d
e
s
t
r
i
a
n
hyb
r
i
d
b
e
a
c
o
n
Fre
q
u
e
n
t
P
u
b
l
i
c
Com
m
e
n
t
:
I
m
p
r
o
v
e
Ped
C
r
o
s
s
i
n
g
Ke
y
C
o
l
l
i
s
i
o
n
T
h
e
m
e
:
Sid
e
S
t
r
e
e
t
s
CAMBRIDGE AVE
Bicy
c
l
e
c
o
l
l
i
s
i
o
n
hot
s
p
o
t
Key
C
o
l
l
i
s
i
o
n
The
m
e
:
R
e
d
Ligh
t
V
i
o
l
a
t
i
o
n
s
Traf
f
i
c
s
i
g
n
a
l
im
p
r
o
v
e
m
e
n
t
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
CALIFORNIA AVE
Rig
h
t
t
u
r
n
o
n
red
r
e
s
t
r
i
c
t
i
o
n
Gree
n
b
i
c
y
c
l
e
mar
k
i
n
g
Tw
o
-
s
t
a
g
e
le
f
t
-
t
u
r
n
bic
y
c
l
e
b
o
x
*
Im
p
r
o
v
e
d
way
f
i
n
d
i
n
g
sig
n
a
g
e
Ped
e
s
t
r
i
a
n
col
l
i
s
i
o
n
h
o
t
s
p
o
t
Saf
e
R
o
u
t
e
s
t
o
Sch
o
o
l
Fre
q
u
e
n
t
P
u
b
l
i
c
Co
m
m
e
n
t
:
I
m
p
r
o
v
e
Ped
C
r
o
s
s
i
n
g
Fre
q
u
e
n
t
P
u
b
l
i
c
Com
m
e
n
t
:
I
m
p
r
o
v
e
Bik
e
C
r
o
s
s
i
n
g
Key
C
o
l
l
i
s
i
o
n
The
m
e
:
P
e
r
m
i
t
t
e
d
Rig
h
t
T
u
r
n
s
Cro
s
s
w
a
l
k
en
h
a
n
c
e
m
e
n
t
SHERMAN AVE
Red
c
u
r
b
t
o
i
m
p
r
o
v
e
sig
h
t
d
i
s
t
a
n
c
e
Key
C
o
l
l
i
s
i
o
n
T
h
e
m
e
:
Sid
e
S
t
r
e
e
t
s
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
GRANT AVE
Left
-
t
u
r
n
acc
e
s
s
r
e
m
o
v
a
l
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
New
p
e
d
e
s
t
r
i
a
n
hyb
r
i
d
b
e
a
c
o
n
SHERIDAN AVE
Red
c
u
r
b
t
o
im
p
r
o
v
e
s
i
g
h
t
dist
a
n
c
e
Ped
e
s
t
r
i
a
n
co
l
l
i
s
i
o
n
h
o
t
s
p
o
t
Key
C
o
l
l
i
s
i
o
n
Th
e
m
e
:
Sid
e
S
t
r
e
e
t
s
Cro
s
s
w
a
l
k
en
h
a
n
c
e
m
e
n
t
OREGON EXPY / PAGE MILL RD
Rem
o
v
e
sli
p
l
a
n
e
Freq
u
e
n
t
P
u
b
l
i
c
Com
m
e
n
t
:
R
o
a
d
w
a
y
Mai
n
t
e
n
a
n
c
e
N
e
e
d
e
d
Traf
f
i
c
s
i
g
n
a
l
im
p
r
o
v
e
m
e
n
t
Gre
e
n
b
i
c
y
c
l
e
ma
r
k
i
n
g
Two
-
s
t
a
g
e
lef
t
-
t
u
r
n
bic
y
c
l
e
b
o
x
Im
p
r
o
v
e
d
way
f
i
n
d
i
n
g
sig
n
a
g
e
Freq
u
e
n
t
P
u
b
l
i
c
Com
m
e
n
t
:
I
m
p
r
o
v
e
Ped
C
r
o
s
s
i
n
g
Freq
u
e
n
t
P
u
b
l
i
c
Com
m
e
n
t
:
I
m
p
r
o
v
e
Bike
C
r
o
s
s
i
n
g
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
Cro
s
s
w
a
l
k
en
h
a
n
c
e
m
e
n
t
s
PEPPER AVE
OLIVE AVE
Im
p
r
o
v
e
d
way
f
i
n
d
i
n
g
sig
n
a
g
e
Bicy
c
l
e
c
o
l
l
i
s
i
o
n
hot
s
p
o
t
Cro
s
s
w
a
l
k
en
h
a
n
c
e
m
e
n
t
New
p
e
d
e
s
t
r
i
a
n
hyb
r
i
d
b
e
a
c
o
n
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
s
ACACIA AVE
PORTAGE AVE / HANSEN WAY
Righ
t
t
u
r
n
o
n
red
r
e
s
t
r
i
c
t
i
o
n
Key
C
o
l
l
i
s
i
o
n
The
m
e
:
P
e
r
m
i
t
t
e
d
Rig
h
t
T
u
r
n
s
Rem
o
v
e
slip
l
a
n
e
Traf
f
i
c
s
i
g
n
a
l
im
p
r
o
v
e
m
e
n
t
Two
-
s
t
a
g
e
lef
t
-
t
u
r
n
bicy
c
l
e
b
o
x
Im
p
r
o
v
e
d
way
f
i
n
d
i
n
g
sig
n
a
g
e
Bicy
c
l
e
c
o
l
l
i
s
i
o
n
hot
s
p
o
t
Ped
e
s
t
r
i
a
n
co
l
l
i
s
i
o
n
h
o
t
s
p
o
t
Key
C
o
l
l
i
s
i
o
n
The
m
e
:
R
e
d
Lig
h
t
V
i
o
l
a
t
i
o
n
s
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
Cro
s
s
w
a
l
k
en
h
a
n
c
e
m
e
n
t
s
LAMBERT AVE
Im
p
r
o
v
e
d
way
f
i
n
d
i
n
g
sig
n
a
g
e
SHERMANAVE
CALIFORNIAAVE
CAMBRIDGEAVE
COLLEGEAVE
OXFORDAVE
STANFORDAVE
EL
C
A
M
I
N
O
R
E
A
L
EL
C
A
M
I
N
O
R
E
A
L
EXI
S
T
I
N
G
BUS
S
T
O
P
ACACIAAVE
PORTAGEAVE
HANSENWAY
EL
C
A
M
I
N
O
R
E
A
L
LAMBERTAVE
STAN
F
O
R
D
PERI
M
E
T
E
R
TRAI
L
OLIVEAVE
PEPPERAVE
SHERIDANAVE
GRANTAVE
PAGE MILL RD
EX
I
S
T
I
N
G
BU
S
S
T
O
P
BUS
S
T
O
P
POT
E
N
T
I
A
L
REL
O
C
A
T
E
D
BU
S
S
T
O
P
PORTAGEAVE
LAMBERTAVE
EX
I
S
T
I
N
G
BU
S
S
T
O
P
SEE
B
U
S
S
T
O
P
D
E
T
A
I
L
1
RE
L
O
C
A
T
E
D
BU
S
S
T
O
P
SEE
B
U
S
S
T
O
P
D
E
T
A
I
L
1
BU
S
S
T
O
P
SEE
B
U
S
S
T
O
P
D
E
T
A
I
L
1
BU
S
S
T
O
P
SEE
B
U
S
S
T
O
P
D
E
T
A
I
L
1
EL
C
A
M
I
N
O
R
E
A
L
:
be
t
w
e
e
n
St
a
n
f
o
r
d
A
v
e
a
n
d
L
a
m
b
e
r
t
A
v
e
OP
T
I
O
N
2
:
M
a
i
n
t
a
i
n
O
n
-
S
t
r
e
e
t
P
a
r
k
i
n
g
a
n
d
F
o
c
u
s
o
n
P
a
r
a
l
l
e
l
B
i
c
y
c
l
e
S
t
r
e
e
ts
NO
R
I
G
H
T
T
U
R
N
ON
R
E
D
T
O
PR
O
T
E
C
T
B
I
K
E
B
O
X
SEP
A
R
A
T
E
RIG
H
T
T
U
R
N
PH
A
S
E
A
D
D
E
D
DR
I
V
E
W
A
Y
REM
O
V
E
D
D
U
E
T
O
RED
E
V
E
L
O
P
M
E
N
T
DRI
V
E
W
A
Y
RE
M
O
V
E
D
D
U
E
T
O
RE
D
E
V
E
L
O
P
M
E
N
T
DRI
V
E
W
A
Y
APP
R
O
A
C
H
A
D
D
E
D
TO
S
I
G
N
A
L
T
I
M
I
N
G
RIG
H
T
T
U
R
N
SLIP
L
A
N
E
S
CLO
S
E
D
BU
S
S
T
O
P
T
O
B
E
DES
I
G
N
E
D
P
E
R
P
E
N
D
I
N
G
VTA
D
E
S
I
G
N
S
T
A
N
D
A
R
D
S
BUS
S
T
O
P
T
O
B
E
DES
I
G
N
E
D
P
E
R
P
E
N
D
I
N
G
VTA
D
E
S
I
G
N
S
T
A
N
D
A
R
D
S
BU
S
S
T
O
P
T
O
B
E
DES
I
G
N
E
D
P
E
R
P
E
N
D
I
N
G
VT
A
D
E
S
I
G
N
S
T
A
N
D
A
R
D
S
BU
S
S
T
O
P
T
O
B
E
DE
S
I
G
N
E
D
P
E
R
P
E
N
D
I
N
G
VT
A
D
E
S
I
G
N
S
T
A
N
D
A
R
D
S
AC
C
E
S
S
T
O
P
R
O
P
O
S
E
D
D
R
I
V
E
W
A
Y
F
O
R
AP
P
R
O
V
E
D
D
E
V
E
L
O
P
M
E
N
T
P
R
O
J
E
C
T
T
O
B
E
AC
C
O
M
O
D
A
T
E
D
W
I
T
H
B
U
S
S
T
O
P
D
E
S
I
G
N
SEP
A
R
A
T
E
B
I
C
Y
C
L
E
SIG
N
A
L
P
H
A
S
I
N
G
SE
P
A
R
A
T
E
B
I
C
Y
C
L
E
SIG
N
A
L
P
H
A
S
I
N
G
DRI
V
E
W
A
Y
T
O
B
E
R
E
M
O
V
E
D
AS P
A
R
T
O
F
A
P
P
R
O
V
E
D
DE
V
E
L
O
P
M
E
N
T
P
R
O
J
E
C
T
DE
T
A
I
L
1
EL
C
A
M
I
N
O
R
E
A
L
:
b
e
t
w
e
e
n
S
t
a
n
f
o
r
d
A
v
e
a
n
d
L
a
m
b
e
r
t
A
v
e
OP
T
I
O
N
2
:
M
a
i
n
t
a
i
n
O
n
-
S
t
r
e
e
t
P
a
r
k
i
n
g
a
n
d
F
o
c
u
s
o
n
P
a
r
a
l
l
e
l
B
i
c
y
c
l
e
S
t
r
e
e
t
s
* pe
n
d
i
n
g
e
v
a
l
u
a
t
i
o
n
o
f
p
e
d
e
s
t
r
i
a
n
v
i
s
i
b
i
l
i
t
y
Rem
o
v
e
E
x
i
s
t
i
n
g
C
u
r
b
Pro
p
o
s
e
d
T
r
a
f
f
i
c
S
i
g
n
La
n
d
s
c
a
p
e
M
e
d
i
a
n
s
Har
d
s
c
a
p
e
A
r
e
a
Sid
e
S
t
r
e
e
t
S
t
o
p
I
n
t
e
r
s
e
c
t
i
o
n
Ex
i
s
t
i
n
g
C
u
r
b
Pro
p
o
s
e
d
C
u
r
b
Nee
d
f
o
r
I
m
p
r
o
v
e
m
e
n
t
Pot
e
n
t
i
a
l
I
m
p
r
o
v
e
m
e
n
t
App
r
o
v
e
d
P
r
o
j
e
c
t
s
Pen
d
i
n
g
P
r
o
j
e
c
t
s
BEGINNING OF STUDY SEGMENT
END OF STUDY SEGMENT
STANFORD AVE
Tra
f
f
i
c
s
i
g
n
a
l
imp
r
o
v
e
m
e
n
t
Im
p
r
o
v
e
d
Way
f
i
n
d
i
n
g
S
i
g
n
a
g
e
Sa
f
e
R
o
u
t
e
s
t
o
Sch
o
o
l
Fre
q
u
e
n
t
P
u
b
l
i
c
Co
m
m
e
n
t
:
I
m
p
r
o
v
e
Bik
e
C
r
o
s
s
i
n
g
Tw
o
-
s
t
a
g
e
L
e
f
t
-
t
u
r
n
Bicy
c
l
e
B
o
x
Rig
h
t
t
u
r
n
o
n
red
r
e
s
t
r
i
c
t
i
o
n
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
s
OXFORD AVE
COLLEGE AVE
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
Red
c
u
r
b
t
o
i
m
p
r
o
v
e
sig
h
t
d
i
s
t
a
n
c
e
Ne
w
p
e
d
e
s
t
r
i
a
n
hyb
r
i
d
b
e
a
c
o
n
Fre
q
u
e
n
t
P
u
b
l
i
c
Com
m
e
n
t
:
I
m
p
r
o
v
e
Ped
C
r
o
s
s
i
n
g
Ke
y
C
o
l
l
i
s
i
o
n
T
h
e
m
e
:
Sid
e
S
t
r
e
e
t
s
CAMBRIDGE AVE
Bicy
c
l
e
c
o
l
l
i
s
i
o
n
hot
s
p
o
t
Key
C
o
l
l
i
s
i
o
n
The
m
e
:
R
e
d
Ligh
t
V
i
o
l
a
t
i
o
n
s
Traf
f
i
c
s
i
g
n
a
l
im
p
r
o
v
e
m
e
n
t
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
CALIFORNIA AVE
Rig
h
t
t
u
r
n
o
n
red
r
e
s
t
r
i
c
t
i
o
n
Gree
n
b
i
c
y
c
l
e
mar
k
i
n
g
Tw
o
-
s
t
a
g
e
le
f
t
-
t
u
r
n
bic
y
c
l
e
b
o
x
*
Im
p
r
o
v
e
d
way
f
i
n
d
i
n
g
sig
n
a
g
e
Ped
e
s
t
r
i
a
n
col
l
i
s
i
o
n
h
o
t
s
p
o
t
Saf
e
R
o
u
t
e
s
t
o
Sch
o
o
l
Fre
q
u
e
n
t
P
u
b
l
i
c
Co
m
m
e
n
t
:
I
m
p
r
o
v
e
Ped
C
r
o
s
s
i
n
g
Fre
q
u
e
n
t
P
u
b
l
i
c
Com
m
e
n
t
:
I
m
p
r
o
v
e
Bik
e
C
r
o
s
s
i
n
g
Key
C
o
l
l
i
s
i
o
n
The
m
e
:
P
e
r
m
i
t
t
e
d
Rig
h
t
T
u
r
n
s
Cro
s
s
w
a
l
k
en
h
a
n
c
e
m
e
n
t
SHERMAN AVE
Red
c
u
r
b
t
o
i
m
p
r
o
v
e
sig
h
t
d
i
s
t
a
n
c
e
Key
C
o
l
l
i
s
i
o
n
T
h
e
m
e
:
Sid
e
S
t
r
e
e
t
s
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
GRANT AVE
Left
-
t
u
r
n
acc
e
s
s
r
e
m
o
v
a
l
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
New
p
e
d
e
s
t
r
i
a
n
hyb
r
i
d
b
e
a
c
o
n
SHERIDAN AVE
Red
c
u
r
b
t
o
im
p
r
o
v
e
s
i
g
h
t
dist
a
n
c
e
Ped
e
s
t
r
i
a
n
co
l
l
i
s
i
o
n
h
o
t
s
p
o
t
Key
C
o
l
l
i
s
i
o
n
Th
e
m
e
:
Sid
e
S
t
r
e
e
t
s
Cro
s
s
w
a
l
k
en
h
a
n
c
e
m
e
n
t
OREGON EXPY / PAGE MILL RD
Rem
o
v
e
sli
p
l
a
n
e
Freq
u
e
n
t
P
u
b
l
i
c
Com
m
e
n
t
:
R
o
a
d
w
a
y
Mai
n
t
e
n
a
n
c
e
N
e
e
d
e
d
Traf
f
i
c
s
i
g
n
a
l
im
p
r
o
v
e
m
e
n
t
Gre
e
n
b
i
c
y
c
l
e
ma
r
k
i
n
g
Two
-
s
t
a
g
e
lef
t
-
t
u
r
n
bic
y
c
l
e
b
o
x
Im
p
r
o
v
e
d
way
f
i
n
d
i
n
g
sig
n
a
g
e
Freq
u
e
n
t
P
u
b
l
i
c
Com
m
e
n
t
:
I
m
p
r
o
v
e
Ped
C
r
o
s
s
i
n
g
Freq
u
e
n
t
P
u
b
l
i
c
Com
m
e
n
t
:
I
m
p
r
o
v
e
Bike
C
r
o
s
s
i
n
g
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
Cro
s
s
w
a
l
k
en
h
a
n
c
e
m
e
n
t
s
PEPPER AVE
OLIVE AVE
Im
p
r
o
v
e
d
way
f
i
n
d
i
n
g
sig
n
a
g
e
Bicy
c
l
e
c
o
l
l
i
s
i
o
n
hot
s
p
o
t
Cro
s
s
w
a
l
k
en
h
a
n
c
e
m
e
n
t
New
p
e
d
e
s
t
r
i
a
n
hyb
r
i
d
b
e
a
c
o
n
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
s
ACACIA AVE
PORTAGE AVE / HANSEN WAY
Righ
t
t
u
r
n
o
n
red
r
e
s
t
r
i
c
t
i
o
n
Key
C
o
l
l
i
s
i
o
n
The
m
e
:
P
e
r
m
i
t
t
e
d
Rig
h
t
T
u
r
n
s
Rem
o
v
e
slip
l
a
n
e
Traf
f
i
c
s
i
g
n
a
l
im
p
r
o
v
e
m
e
n
t
Two
-
s
t
a
g
e
lef
t
-
t
u
r
n
bicy
c
l
e
b
o
x
Im
p
r
o
v
e
d
way
f
i
n
d
i
n
g
sig
n
a
g
e
Bicy
c
l
e
c
o
l
l
i
s
i
o
n
hot
s
p
o
t
Ped
e
s
t
r
i
a
n
co
l
l
i
s
i
o
n
h
o
t
s
p
o
t
Key
C
o
l
l
i
s
i
o
n
The
m
e
:
R
e
d
Lig
h
t
V
i
o
l
a
t
i
o
n
s
Cro
s
s
w
a
l
k
enh
a
n
c
e
m
e
n
t
Cro
s
s
w
a
l
k
en
h
a
n
c
e
m
e
n
t
s
LAMBERT AVE
Im
p
r
o
v
e
d
way
f
i
n
d
i
n
g
sig
n
a
g
e
El
C
a
m
i
n
o
R
e
a
l
a
t
H
a
n
s
e
n
W
a
y
(L
o
o
k
i
n
g
N
o
r
t
h
-
E
a
s
t
)
-
O
p
t
i
o
n
1
El
C
a
m
i
n
o
R
e
a
l
a
t
H
a
n
s
e
n
W
a
y
(L
o
o
k
i
n
g
N
o
r
t
h
-
E
a
s
t
)
-
O
p
t
i
o
n
2
Planning & Transportation Commission
Staff Report (ID # 9432)
Report Type: Action Items Meeting Date: 11/14/2018
City of Palo Alto
Planning & Community Environment
250 Hamilton Avenue
Palo Alto, CA 94301
(650) 329-2442
Summary Title: CEQA Ordinance Update
Title: PUBLIC HEARING. Recommendation to the City Council an
Ordinance Amending Palo Alto Municipal Code (PAMC) Title 18
(Zoning), Chapter 18.31 (CEQA Review) to Add Environmental
Review and Compliance Regulations for Development Projects
in Furtherance of and to Implement the Comprehensive Plan
Environmental Impact Report (EIR) Mitigation Measures, as
Documented in the Mitigation Monitoring and Reporting Plan
Adopted by Council Resolution 9721 on November 13, 2017.
Environmental Assessment: Not a Project.
From: Jonathan Lait
Recommendation
Staff recommends that the Planning and Transportation Commission (PTC) recommend
approval of the proposed ordinance amending Palo Alto Municipal Code (PAMC) Chapter 18.31
to the City Council, including approval of the relevant standards in the List of Standard
Requirements for Development Projects which is incorporated by reference in the ordinance.
Report Summary
The proposed ordinance addresses implementation of six mitigation measures identified in the
Comprehensive Plan Update Environmental Impact Report (EIR) and associated Mitigation
Monitoring and Reporting Plan (MMRP). The six mitigation measures require updates to the
local California Environmental Quality Act (CEQA) Guidelines, as codified in Palo Alto Municipal
Code (PAMC) Chapter 18.31, CEQA Review. These mitigation measures identify additional
requirements for specific types of development projects in order to reduce impacts on either
air quality or aesthetics throughout Palo Alto. In addition to addressing these six mitigation
measures, the proposed ordinance would codify three best management practices to ensure
these are implemented for all projects, regardless of whether an environmental analysis is
required to be prepared in accordance with CEQA.
City of Palo Alto
Planning & Community Environment Department Page 2
Background
On November 13, 2017, Council adopted Resolution No. 9721 (Attachment C), certifying the
Comprehensive Plan Update EIR, making the required findings under CEQA and adopting the
associated MMRP (Attachment D). The Council also adopted Resolution No. 9722, adopting the
City of Palo Alto Comprehensive Plan Update. The certified EIR and adopted MMRP identified
six mitigation measures that require the City to amend its local CEQA guidelines established in
Chapter 18.31 of the PAMC. The proposed ordinance included in Attachment A would amend
Chapter 18.31 in order to implement these required mitigation measures.
Discussion
The staff recommendation includes two components: 1) the proposed ordinance; and 2) the
List of Standard Requirements for Development Projects, which is incorporated by reference in
the ordinance. Both are described in further detail below.
Ordinance Amending Chapter 18.31
Table 1 below summarizes the six mitigation measures addressed in the ordinance. The analysis
section summarizes how each of these mitigation measures is addressed in the ordinance.
Table 1: Mitigation Measures Requiring Updates to PAMC Chapter 18.31
Comprehensive Plan
EIR Mitigation
Measure
Requirement
MM Air-2a The City shall amend its local CEQA Guidelines and Municipal Code to
require, as part of the City’s development approval process, that
applicants for future development projects comply with the current
BAAQMD basic control measures for reducing construction emissions of
PM10 (Table 8-2, Basic Construction Mitigation Measures Recommended
for All Proposed Projects, of the BAAQMD CEQA Guidelines).
MM AIR‐2b The City shall amend its local CEQA Guidelines to require that, prior to
issuance of construction permits, development project applicants that are
subject to CEQA and have the potential to exceed the BAAQMD screening
criteria listed in the BAAQMD CEQA Guidelines shall prepare and submit to
the City of Palo Alto a technical assessment evaluating potential project
construction‐related air quality impacts. The evaluation shall be prepared
in conformance with BAAQMD methodology in assessing air quality
impacts. If construction‐related criteria air pollutants are determined to
have the potential to exceed the BAAQMD thresholds of significance, as
identified in the BAAQMD CEQA Guidelines, the City of Palo Alto shall
require that applicants for new development projects incorporate
mitigation measures (Table 8‐3, Additional Construction Mitigation
Measures Recommended for Projects with Construction Emissions Above
City of Palo Alto
Planning & Community Environment Department Page 3
Table 1: Mitigation Measures Requiring Updates to PAMC Chapter 18.31
Comprehensive Plan
EIR Mitigation
Measure
Requirement
the Threshold, of the BAAQMD CEQA Guidelines or applicable construction
mitigation measures subsequently approved by BAAQMD) to reduce air
pollutant emissions during construction activities to below these
thresholds. These identified measures shall be incorporated into all
appropriate construction documents (e.g., construction management
plans) submitted to the City.
MM Air 2-C To ensure that development projects that have the potential to exceed the
BAAQMD screening criteria air pollutants listed in the BAAQMD CEQA
Guidelines reduce regional air pollutant emissions below the BAAQMD
thresholds of significance, the proposed Plan shall include policies that
address the following topic: require compliance with BAAQMD
requirements, including BAAQMD CEQA Guidelines.
MM AIR‐3a The City of Palo Alto shall update its CEQA Procedures to require that
future non‐residential projects within the city that: 1) have the potential to
generate 100 or more diesel truck trips per day or have 40 or more trucks
with operating diesel‐powered TRUs, and 2) are within 1,000 feet of a
sensitive land use (e.g., residential, schools, hospitals, nursing homes), as
measured from the property line of a proposed project to the property line
of the nearest sensitive use, shall submit a health risk assessment (HRA) to
the City of Palo Alto prior to future discretionary project approval or shall
comply with best practices recommended for implementation by the
BAAQMD.
The HRA shall be prepared in accordance with policies and procedures of
the State Office of Environmental Health Hazard Assessment and the Bay
Area Air Quality Management District. If the HRA shows that the
incremental cancer risk exceeds the BAAQMD significance thresholds, the
applicant will be required to identify and demonstrate that mitigation
measures are capable of reducing potential cancer and non-cancer risks to
an acceptable level, including appropriate enforcement mechanisms.
Mitigation measures and best practices may include but are not limited to:
• Restricting idling on-site beyond Air Toxic Control Measures
idling restrictions, as feasible.
• Electrifying warehousing docks.
• Requiring use of newer equipment and/or vehicles.
• Restricting off-site truck travel through the creation of truck
routes.
City of Palo Alto
Planning & Community Environment Department Page 4
Table 1: Mitigation Measures Requiring Updates to PAMC Chapter 18.31
Comprehensive Plan
EIR Mitigation
Measure
Requirement
Mitigation measures identified in the project-specific HRA shall be
identified as mitigation measures in the environmental document and/or
incorporated into the site development plan as a component of a
proposed project.
MM AIR-3b To ensure that new industrial and warehousing projects with the potential
to generate new stationary and mobile sources of air toxics that exceed
the BAAQMD project-level and/or cumulative significance thresholds for
toxic air contaminants and PM2.5 listed in the BAAQMD CEQA Guidelines
reduce emissions below the BAAQMD thresholds of significance, amend
the City’s CEQA guidelines to require compliance with BAAQMD
requirements.
MM AES-4 The City shall amend its local CEQA guidelines to require development
projects of a certain size or location to prepare an analysis of potential
shade/shadow impacts. The analysis shall focus on potential impacts to
public open spaces (other than public streets and adjacent sidewalks)
between 9:00 a.m. and 3:00 p.m. from September 21 to March 21. The
analysis shall identify whether the project would shadow open spaces
during these times, explain how the project meets City design
requirements and other City policy goals, and describe ways to mitigate
substantial shade and shadow impacts through feasible building and site
design features.
In addition to addressing these six mitigation measures, the proposed ordinance would codify
three best management practices that Planning staff already consistently requires as conditions
of approval for projects. These are being incorporated into the code amendment to ensure that
they continue to be implemented for all projects, as applicable, regardless of whether an
environmental analysis is required to be prepared in accordance with CEQA.
These three requirements include 1) a requirement for certain development projects to
conduct a nesting bird survey prior to construction, demolition, or vegetation removal during
the avian nesting season; 2) a requirement for all development projects to implement best
management practices for the protection of historic, archeological, paleontological and tribal
cultural resources if they are found during earthmoving activities; and 3) a requirement for
development projects within the California-Olive-Emerson Plume to install a vapor barrier
system or identify other acceptable design features to address impacts of volatile organic
compounds (VOCs) on future users.
City of Palo Alto
Planning & Community Environment Department Page 5
List of Standard Requirements for Development Projects
Some of these mitigation measures refer to recommendations of other responsible agencies,
such as the Bay Area Air Quality Management District (BAAQMD) or State Office of
Environmental Health Hazard Assessment. However, as new information becomes available or
state regulations change, these agencies regularly update their guidelines. Because some of
these required mitigation measures include specific implementation details that may need to
be refined over time to reflect updated guidance, the proposed ordinance incorporates by
reference a separate List of Standard Requirements for Development Projects. This list would
include finer details such as recommended screening criteria, recommended air quality
thresholds, methodology for preparing specific analyses, and recommended mitigation. As
specified in the ordinance, the list would be maintained by the Director of Planning and
Community Environment and refined, as needed, to reflect current best management practices
and agency recommendations.
Analysis1
The following summarizes how the code amendment addresses each of the six Comprehensive
Plan Update EIR mitigation measures.
MM Air-2a
To address MM Air-2a, the ordinance in Attachment A proposes that the following language be
added to the Municipal Code as Section 18.31.040(A):
All development projects shall implement the Bay Area Air Quality Management
District’s (BAAQMD) basic control measures for reducing construction emissions of PM10
Construction emissions of particulate matter of up to ten microns in size (PM10) are primarily
generated by earthmoving activities. PM10 (i.e., dust) is a criteria pollutant that can be reduced
through the implementation of standard best management practices, such as watering soil
prior to earthmoving activities. The Bay Area Air Quality Management District (BAAQMD) CEQA
Guidelines, Table 8-2, includes a list of recommended best management practices that should
be implemented for projects. This proposed language would make these recommendations a
requirement for all development projects, consistent with the requirements of MM Air-2a.
Because the BAAQMD may refine or update their recommendations for dust control over time,
the details of the required measures are included in the List of Standard Requirements for
Development Projects, which would be updated as needed to require the most recent
applicable guidance from the BAAQMD on dust control.
MM AIR‐2b and AIR-2c
1 The information provided in this section is based on analysis prepared by the report author prior to the public
hearing. Planning and Transportation Commission in its review of the administrative record and based on public
testimony may reach a different conclusion from that presented in this report and may choose to take an
alternative action from the recommended action.
City of Palo Alto
Planning & Community Environment Department Page 6
To address these mitigation measures, the ordinance in Attachment A proposes that the
following language be added to the Municipal Code as Section 18.31.040(B):
Prior to issuance of any construction permit, including any building or grading permit,
the applicant for a development project that meets or exceeds the screening levels for
criteria air pollutants under the BAAQMD CEQA Guidelines shall prepare and submit to
the Director a technical assessment evaluating potential project construction-related air
quality impacts. If any construction related criteria air pollutant exceeds the BAAQMD
thresholds of significance, the applicant shall incorporate mitigation measures to reduce
air pollutant emissions during construction to below the thresholds. Any required
measures shall be incorporated into all appropriate construction documents submitted
to the City.
BAAQMD has identified a list of projects, based on size and type, which are assumed to be
below the BAAQMD recommended thresholds of significance. The proposed language would
require that any project seeking a construction permit, and which exceeds BAAQMD’s screening
levels, based on the size and type of development, would be required to prepare an analysis
evaluating their construction-related air quality impacts to determine whether the project
exceeds the BAAQMD recommended thresholds. It also requires incorporation of mitigation for
projects found to exceed the thresholds.
Because BAAQMD reviews and updates their screening levels, thresholds of significance, and
recommended mitigation as new information becomes available, the details of these current
BAAQMD recommendations have been incorporated into the List of Standard Requirements for
Development Projects and may be updated by the Director in the future to ensure consistency
with the most recent applicable BAAQMD guidance.
MM AIR‐3a
To address MM Air-3a, the ordinance includes new language as Section 18.31.040(C) which
states:
Prior to the issuance of any planning entitlement and/or building permit, non‐residential
projects within the City that (1) will generate 100 or more diesel truck trips per day or
have 40 or more trucks with operating diesel‐powered transportation refrigeration
units, and (2) are within 1,000 feet of a sensitive land use (e.g., residential, schools,
hospitals, nursing homes) as measured from the property line of a proposed project to
the property line of the nearest sensitive use, shall submit a health risk assessment
(HRA) to the City of Palo Alto and comply with best practices recommended for
implementation by BAAQMD to reduce toxic air contaminants. The HRA shall be
prepared in accordance with the methodology outlined in the List of Standard
Requirements for Development Projects maintained by the Director of Planning. If the
HRA shows that the incremental cancer risk exceeds the BAAQMD significance
thresholds, the applicant must identify reduction measures and demonstrate that the
measures are capable of reducing potential cancer and non-cancer risks to an
City of Palo Alto
Planning & Community Environment Department Page 7
acceptable level, including identification of appropriate enforcement mechanisms. Any
reduction measures identified in the HRA shall be identified as requirements in the
environmental document or incorporated into the site development plan as a
component of the project.
Consistent with MM AIR-3a, this language codifies the requirement that projects of a certain
type and location, must prepare a Health Risk Assessment (HRA) prior to issuance of any
entitlement or building permit. Because guidance from the State Office of Environmental
Health Hazard Assessment and BAAQMD on HRAs may be refined over time, information on the
methodology for preparing an HRA is provided in the List of Standard Requirements for
Development Projects and would be updated, as needed, to reflect any changes in agency
recommendations.
MM AIR-3b
To address MM Air-3b, the ordinance includes new language as Section 18.31.040(D) which
states:
Prior to the issuance of any planning entitlement and/or building permit, any new
industrial or warehousing project with the potential to generate new stationary or
mobile sources of air toxics must prepare an analysis to determine whether the project
would exceed the BAAQMD project-level and/or cumulative significance thresholds for
toxic air contaminants and PM2.5. If the project is found to exceed the BAAQMD
recommended thresholds, the applicant shall identify measures to reduce emissions in
accordance with the BAAQMD recommendations to below the thresholds.
This language requires an analysis of toxic air contaminants and PM2.5 for any new industrial or
warehousing projects in the City to determine whether the project exceeds BAAQMD’s
recommended thresholds. Because BAAQMD may revise their recommended thresholds in the
future, the specific thresholds are provided in the List of Standard Requirements for
Development Projects and may be updated by the Director of Planning and Community
Environment.
MM AES-4
To address MM AES-4, the ordinance includes new language as Section 18.31.040(E) which
states:
With the exception of single family residences, any project that includes the
construction of a new building(s) two-stories or taller, and located adjacent to public
open spaces (other than public streets and adjacent sidewalks), shall prepare an analysis
of potential shade/shadow impacts. The analysis of the new building(s) shall focus on
potential impacts to public open spaces between 9:00 a.m. and 3:00 p.m. from
September 21 to March 21. The analysis shall identify whether the project would
shadow public open spaces during these times, explain how the project meets City
City of Palo Alto
Planning & Community Environment Department Page 8
design requirements, policies and goals, and describe ways to mitigate substantial shade
and shadow impacts through feasible building and site design features.
In accordance with the requirements of MM AES-4, the proposed code language specifies which
types of project shall be required to prepare an analysis of shade/shadow impacts and what the
analysis shall entail.
Nesting Bird Surveys
The proposed ordinance includes new language as Section 18.31.040(I) which states:
Prior to demolition, vegetation removal, or construction of any new building or building
addition during the avian nesting season (February 15th through September 31st) on a
site used for commercial, mixed-use, multi-family or open space and with existing
mature trees, an avian biologist shall conduct a nesting bird survey and document the
findings of the survey in a report provided to the Director of Planning no more than 14
days prior to the start of work.
Planning staff has been requiring avian nesting surveys as mitigation measures in
environmental documents or as conditions of approval if the identified criteria have been met.
However, some projects may only require a ministerial permit (e.g. housing projects subject to
SB 35). In order to ensure that all applicable projects are required to protect nesting birds in
accordance with the Migratory Bird Treaty Act, staff recommends that this standard
requirement be codified.
Cultural, Archeological, Paleontological, and Tribal Cultural Resources
The proposed ordinance includes new language as Section 18.31.040(J) which states:
During construction on any site throughout the City, if a previously unknown
archaeological, cultural, or paleontological resource is unearthed, all earth disturbing
work within the vicinity of the find shall be temporarily suspended or redirected until an
archaeologist, historian or paleontologist, depending on the nature of the find, has
evaluated the nature and significance and has determined appropriate protection for
the resource. Protection may include such measures as avoidance or preparation of a
Treatment Plan and curation of the resource. If the potential resource is identified as
Native American in origin, a Native American representative, based on the nature of the
find, shall be consulted. If the City determines that the resource is a tribal cultural
resource, a mitigation plan shall be prepared and implemented in accordance with state
guidelines and in consultation with appropriate Native American group(s). The plan
would include avoidance of the resource or, if avoidance of the resource is infeasible,
the plan would outline the appropriate treatment of the resource in coordination with
the archeologist and the appropriate Native American tribal representative.
Planning staff, in practice, requires this best management practice for all projects subject to
CEQA. However, this best management practice should be followed for all projects throughout
City of Palo Alto
Planning & Community Environment Department Page 9
the City in the event that an unknown resource is discovered, regardless of the type or size of
development and regardless of whether the project is subject to CEQA. Therefore, staff
recommends that this standard requirement be codified.
Vapor Barrier System
The proposed ordinance includes new language as Section 18.31.040(K) which states:
For projects within the California-Olive-Emerson (COE) Plume area, a vapor membrane
system shall be installed to mitigate vapor intrusion and reduce exposure of future
occupants in the basement and/or building above to volatile organic compounds. The
vapor membrane system shall:
i. Envelop the below grade portion of the proposed building, including areas below
and above the groundwater table
ii. Include a fan triggered by CO sensors for ventilation
iii. Include an HVAC system to control air floors from sub-grade levels upward into
occupied levels
iv. Include air relief vents for any elevator hoistways within the building
v. Maintain a positive pressure in the residential space relative to the sub-grade
parking levels
The applicant may propose an alternative to the vapor membrane system along with
sufficient evidence to conclude that the proposed alternative sufficiently reduces
potential exposure of future occupants to vapor intrusion (e.g. designing to provide
sufficient natural ventilation), or otherwise provide evidence to show that
contamination screening levels do not warrant installation of a vapor membrane system
or design alternative.
Post construction indoor air monitoring shall be conducted for any vapor membrane
system that is installed to sufficiently show that the system reduces the exposure of
future residents to volatile organic compounds to below acceptable thresholds
identified by other state and responsible agencies.
CEQA only addresses impacts of the project on the environment, not impacts of the
environment on the project. Therefore, the City does not make significance conclusions in
accordance with CEQA related to the potential impacts of volatile organic compounds (VOCs)
on future occupants of a site. Where a building is constructed over a site where VOCs are
present, such as many of the sites within the California-Olive-Emerson Plume, the VOCs must
be properly ventilated to ensure that they do not become entrapped in the building. Codifying
this requirement ensures that all projects, even those that are ministerial, are required to
comply with these safety precautions to protect future users.
Environmental Review
City of Palo Alto
Planning & Community Environment Department Page 10
The subject project has been assessed in accordance with the authority and criteria contained
in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the
environmental regulations of the City. This Ordinance does not meet the definition of a project
under Section 21065 of the California Environmental Quality Act. The project includes
implementation of Mitigation Measures to reduce impacts on aesthetics and air quality for a
project previously approved in accordance with CEQA and do not, in themselves, result in any
potential environmental impacts.
Public Notification, Outreach & Comments
The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper
and mailed to owners and occupants of property within 600 feet of the subject property at least
ten days in advance. Notice of a public hearing for this project was published in the Palo Alto
Daily Post on November 2, which is 12 days in advance of the meeting. Postcard mailing
occurred on October 31, which is 14 days in advance of the meeting.
Public Comments
As of the writing of this report, no project-related, public comments were received.
Alternative Actions
In addition to the recommended action, the Planning and Transportation Commission may:
1. Approve the ordinance with modified language or findings;
2. Continue the project to a date (un)certain
Report Author & Contact Information PTC2 Liaison & Contact Information
Claire Hodgkins, AICP, Planner Jonathan Lait, AICP, Interim Director
(650) 329-2116 (650) 329-2679
claire.hodgkins@cityofpaloalto.org
jonathan.lait@cityofpaloalto.org
Attachments:
• Attachment A: Ordinance Amending CEQA Review Chapter to Implement
Comprehensive Plan EIR Mitigation Measures (PDF)
• Attachment B: List of Standard Requirements for Development Projects (DOCX)
• Attachment C: Resolution 9721 Comp Plan EIR Findings Resolution (PDF)
• Attachment D: Mitigation Monitoring and Reporting Program (PDF)
2 Emails may be sent directly to the PTC using the following address: planning.commission@cityofpaloalto.org
Not Yet Approved
DRAFT
Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Amending Palo Alto Municipal
Code (PAMC) Title 18 (Zoning), Chapter 18.31 (CEQA Review) to Amend the
Chapter Title and Add a New Subsection 18.31.040 Establishing Environmental
Review and Compliance Regulations for Development Projects to Implement
the Comprehensive Plan and Environmental Impact Report Mitigation
Measures
The Council of the City of Palo Alto ORDAINS as follows:
SECTION 1. Findings and Declarations. The City Council finds and declares as follows:
A. On November 13, 2017, the Council adopted Resolution No. 9721, certifying and making
required findings under the California Environmental Quality Act (CEQA) for the
Comprehensive Plan Update Environmental Impact Report (EIR) and adopting the
associated Mitigation Monitoring and Reporting Plan (MMRP). Among the mitigation
measures identified in the EIR and MMRP were six mitigation measures that require the
City to amend its local CEQA guidelines established in Chapter 18.31 of the Palo Alto
Municipal Code. This Ordinance implements these required mitigation measures.
B. Five of the six mitigation measures address air quality impacts (Impact Air-2 and Impact
Air-3). As identified in the EIR, Palo Alto is in a region that is in “nonattainment” for ozone
and particulates and new development implemented under the Comprehensive Plan
could considerably increase these pollutants and expose sensitive receptors to substantial
concentrations of air pollution. To reduce these cumulative air quality impacts,
compliance with standard best management practices (BMPs) of the Bay Area Air Quality
Management District (BAAQMD) by all new development projects, including those that
may be subject to ministerial approval or may otherwise be exempt under CEQA, is
appropriate and necessary to protect and promote the health, safety and general welfare
of the city and region. Requiring these BMPs for all development projects reduces air
quality emissions, further protects biological resources, cultural and tribal cultural
resources, and paleontological resources, and reduces noise impacts.
C. The sixth mitigation measure addresses a potential aesthetic impact associated with
shade and shadow from new development projects (Impact AES-4). As identified in the
EIR, the MMRP and Resolution No. 9721, requiring project-level analysis of potential
shade/shadow impacts and mitigation through feasible building and site design features
will ensure appropriate disclosure and avoidance of potential impacts to the extent
possible.
SECTION 2. Chapter 18.31 (CEQA Review) of Title 18 (Zoning) of the Palo Alto Municipal Code is
hereby amended as follows, to modify the Chapter title and to add a new Section 18.31.040:
Not Yet Approved
DRAFT
2
[The modifications to the ordinance from the original ordinance are shown in strikethrough
(deletions) and underlines (additions).]
Chapter 18.31
CEQA REVIEW
ENVIRONMENTAL REVIEW
Sections: 18.31.010 Delegation of CEQA Authority
18.31.020 Incorporation of State CEQA Guidelines
18.31.030 CEQA Appeals
18.31.040 Standard Environmental Measures for
Development Projects
18.31.010 Delegation of CEQA Authority
The Director or other decision maker as delegated in this Code shall have authority to make
California Environmental Quality Act (CEQA) decisions relating to planning and land use
entitlements, except that any Environmental Impact Report requiring a statement of overriding
considerations shall be considered by the City Council. For projects requiring a statement of
overriding considerations, the Director shall refer any action on the entitlements to the City
Council.
18.31.020 Incorporation of State CEQA Guidelines
The full text of the State CEQA Guidelines adopted as 14 California Code of Regulations, Title
14, Section 15000, et seq., and any subsequent amendments thereto, are hereby incorporated
by reference into this Chapter. If there is a conflict between the procedural provisions of the
State Guidelines and this Chapter, the more restrictive provision shall apply.
18.31.030 CEQA Appeals
Any person may appeal to the City Council from the decision of a non-elected decision-making
body or official of the City to certify an environmental impact report, approve a negative
declaration or mitigated negative declaration or determine that a project is not subject to
Public Resources Code Section 21080 et seq. (California Environmental Quality Act) if that
decision is not otherwise subject to further administrative review. Any such appeal must be
filed on a form specified by the Director and must be filed within the same time period
governing appeals of the underlying entitlement decision or within fourteen consecutive
calendar days of the date that the environmental decision is made, if there is no appeal of the
entitlement. The appellant shall state the specific reasons for the appeal. The appeal must be
accompanied by the required filing fee.
Not Yet Approved
DRAFT
3
18.31.040 Standard Environmental Measures for Development Projects
A. All development projects shall implement the Bay Area Air Quality Management
District’s (BAAQMD) basic control measures for reducing construction emissions of
PM10.
B. Prior to issuance of any construction permit, including any building or grading permit,
the applicant for a development project that meets or exceeds the screening levels for
criteria air pollutants under the BAAQMD CEQA Guidelines shall prepare and submit to
the Director of Planning a technical assessment evaluating potential project
construction-related air quality impacts. If any construction related criteria air pollutants
exceeds the BAAQMD thresholds of significance, the applicant shall incorporate
mitigation measures to reduce air pollutant emissions during construction to below the
thresholds. Any required mitigation measures shall be incorporated into all appropriate
construction documents submitted to the City.
C. Prior to the issuance of any planning entitlement and/or building permit, non-residential
projects within the City that (1) will generate 100 or more diesel truck trips per day or
have 40 or more trucks with operating diesel-powered transportation refrigeration
units, and (2) are within 1,000 feet of a sensitive land use (e.g., residential, schools,
hospitals, nursing homes) as measured from the property line of a proposed project to
the property line of the nearest sensitive use, shall submit a health risk assessment
(HRA) to the City and comply with best practices recommended for implementation by
BAAQMD to reduce toxic air contaminants. The HRA shall be prepared in accordance
with the methodology described in the List of Standard Requirements for Development
Projects maintained by the Director of Planning. If the HRA shows that the incremental
cancer risk exceeds the BAAQMD significance thresholds, the applicant must identify
reduction measures and demonstrate that the measures are capable of reducing
potential cancer and non-cancer risks to an acceptable level, including identification of
appropriate enforcement mechanisms. Any reduction measures identified in the HRA
shall be identified as requirements in the environmental review document or
incorporated into the site development plan as a component of the project.
D. Prior to the issuance of any planning entitlement and/or building permit, any new
industrial or warehousing project with the potential to generate new stationary or
mobile sources of air toxics must prepare an analysis to determine whether the project
would exceed the BAAQMD project-level and/or cumulative significance thresholds for
toxic air contaminants and PM2.5. If the project is found to exceed the BAAQMD
thresholds, the applicant shall identify measures to reduce emissions in accordance with
the BAAQMD recommendations to below the thresholds.
E. With the exception of single family residences, any project that includes the
construction of a new building(s) two-stories or taller, and located adjacent to public
Not Yet Approved
DRAFT
4
open spaces (other than public streets and adjacent sidewalks), shall prepare an analysis
of potential shade/shadow impacts. The analysis of the new building(s) shall focus on
potential impacts to public open spaces between 9:00 a.m. and 3:00 p.m. from
September 21 to March 21. The analysis shall identify whether the project would
shadow public open spaces during these times, explain how the project meets City
design requirements, policies and goals, and describe ways to mitigate substantial shade
and shadow impacts through feasible building and site design features.
F. The BAAQMD measures, standards, and thresholds (collectively, “BAAQMD Standards”)
referenced in the above subsections of this Section 18.31.040 may be amended from
time to time. References to the BAAQMD Standards in this Section are to the BAAQMD
Standards in effect at the time that the development application is reviewed and
considered for approval. The BAAQMD Standards are described in the City’s List of
Standard Requirements for Development Projects.
G. The Director shall be authorized to promulgate, maintain and update the List of
Standard Requirements for Development Projects which may include a description of the
applicable BAAQMD Standards including, but not limited to, screening levels,
methodology for preparing the evaluation, thresholds of significance used for the
evaluation, and the recommended mitigation, if required.
H. All development shall comply with the List of Standard Requirements for Development
Projects, to the extent that these measures are applicable to the development activity.
I. Prior to demolition, vegetation removal, or construction of any new building or building
addition, during the avian nesting season (February 15th through September 31st) on a
site used for commercial, mixed-use, multi-family or open space and with existing
mature trees, an avian biologist shall conduct a nesting bird survey and document the
findings of the survey in a report provided to the Director no more than 14 days prior to
the start of work.
J. During construction on any site in the city, if a previously unknown archaeological,
cultural, or paleontological resource is unearthed, all earth disturbing work within the
vicinity of the find shall be temporarily suspended or redirected until an archaeologist,
historian or paleontologist, depending on the nature of the find, has evaluated the
nature and significance and has determined appropriate protection for the resource.
Protection may include such measures as avoidance or preparation of a Treatment Plan
and curation of the resource. If the potential resource is identified as Native American in
origin, a Native American representative, based on the nature of the find, shall be
consulted. If the City determines that the resource is a tribal cultural resource, a
mitigation plan shall be prepared and implemented in accordance with state guidelines
and in consultation with appropriate Native American group(s). The plan would include
Not Yet Approved
DRAFT
5
avoidance of the resource or, if avoidance of the resource is infeasible, the plan would
outline the appropriate treatment of the resource in coordination with the archeologist
and the appropriate Native American tribal representative.
K. For projects within the California-Olive-Emerson (COE) Plume area, a vapor membrane
system shall be installed to mitigate vapor intrusion and reduce exposure of future
occupants in the basement and/or building above to volatile organic compounds. The
vapor membrane system shall:
i. Envelop the below grade portion of the proposed building, including areas below
and above the groundwater table
ii. Include a fan triggered by CO sensors for ventilation
iii. Include an HVAC system to control air floors from sub-grade levels upward into
occupied levels
iv. Include air relief vents for any elevator hoistways within the building
v. Maintain a positive pressure in the residential space relative to the sub-grade
parking levels
The applicant may propose an alternative to the vapor membrane system along with
sufficient evidence to conclude that the proposed alternative sufficiently reduces
potential exposure of future occupants to vapor intrusion (e.g. designing to provide
sufficient natural ventilation), or otherwise provide evidence to show that
contamination screening levels do not warrant installation of a vapor membrane system
or design alternative.
Post construction indoor air monitoring shall be conducted for any vapor membrane
system that is installed to sufficiently show that the system reduces the exposure of
future residents to volatile organic compounds to below acceptable thresholds
identified by other state and responsible agencies.
SECTION 3. If any section, subsection, clause or phrase of this Ordinance is for any reason held
to be invalid, such decision shall not affect the validity of the remaining portion or sections of the
Ordinance. The Council hereby declares that it should have adopted the Ordinance and each
section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or
more sections, subsections, sentences, clauses or phrases be declared invalid.
SECTION 4. This Ordinance does not meet the definition of a project under Section 21065 of
the California Environmental Quality Act.
Not Yet Approved
DRAFT
6
SECTION 5. This Ordinance shall be effective on the thirty-first day after the date of its passage
and adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
Assistant City Attorney City Manager
____________________________
Director of Planning and Community
Environment
List of Standard Requirements for Development Projects
As referenced in Palo Alto Municipal Code Section 18.31.040, the Director of Planning shall
have the authority to promulgate, maintain and update a List of Standard Requirements for
Development Projects to reflect the most recent guidance from responsible agencies. The most
recent list shall be made available on the City’s Department of Planning and Community
Environment, Current Planning website.
This list is provided to assist applicants in determining the standards that must be
implemented. The BAAQMD measures, standards, and thresholds (collectively, “BAAQMD
Standards”) referenced in Palo Alto Municipal Code Section 18.31.040 may be amended from
time to time. References to the BAAQMD Standards in the Code are to the BAAQMD Standards
in effect at the time that the development application is reviewed and considered for approval.
BASIC CONSTRUCTION PM10 CONTROL MEASURES
The following requirements in Table 1 are BAAQMD’s recommended measures for all proposed
projects to reduce emissions of PM10 from construction activities. These measures reflect those
identified in Table 8-2, Basic Construction Mitigation Measures Recommended for All Proposed
Projects, in BAAQMD’s CEQA Air Quality Guidelines dated May 2017. In accordance with PAMC
Section 18.31.040, these measures shall be implemented for all development projects.
Table 1: Basic Construction Mitigation Measures Recommended for ALL Proposed Projects
1. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access
roads) shall be watered two times per day.
2. All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power
vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
4. All vehicle speeds on unpaved roads shall be limited to 15 mph.
5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building
pads shall be laid as soon as possible after grading unless seeding or soil binders
are used.
6. Idling times shall be minimized either by shutting equipment off when not in use or reducing the
maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title
13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for
construction workers at all access points.
7. All construction equipment shall be maintained and properly tuned in accordance with
manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined
to be running in proper condition prior to operation.
8. Post a publicly visible sign with the telephone number and person to contact at the Lead Agency
regarding dust complaints. This person shall respond and take corrective action within 48 hours. The
Air District’s phone number shall also be visible to ensure compliance with applicable regulations.
CRITERIA AIR POLLUTANTS
As discussed in PAMC Section 18.31.040(B), BAAQMD identifies screening criteria to determine
whether construction emissions of criteria air pollutants would be potentially significant (i.e.
exceed the recommended BAAQMD threshold). If a project meets the screening criteria, the
project would not exceed the BAAQMD recommended threshold and therefore further analysis
is not required. If a project does not meet the criteria, further analysis is required.
Criteria air pollutants include Reactive Organic Gases (ROG), Oxides of Nitrogen (NOX), and
particulate matter (PM10 and PM2.5).
The screening levels identified in this list are consistent with those outlined in Table 3-1 and
Section 3.5.1, Construction Air Pollutants and Precursors, of BAAQMD’s California
Environmental Quality Act Air Quality Guidelines, dated May 2017.
Screening Criteria
If the project is below the screening level size shown in Table 2 and the two criteria below are
also met, the project would not exceed the thresholds of significance for construction. If the
project exceeds these identified screening criteria, further analysis would be required to
determine if the project exceeds the BAAQMD’s recommended thresholds of significance for
criteria pollutants.
1. All Basic Construction Mitigation Measures would be included in the project design and
implemented during construction; and
2. Construction-related activities would not include any of the following:
a. Demolition;
b. Simultaneous occurrence of more than two construction phases (e.g., paving and
building construction would occur simultaneously);
c. Simultaneous construction of more than one land use type (e.g., project would
develop residential and commercial uses on the same site) (not applicable to high
density infill development);
d. Extensive site preparation (i.e., greater than default assumptions used by the Urban
Land Use Emissions Model [URBEMIS] for grading, cut/fill, or earth movement); or
e. Extensive material transport (e.g., greater than 10,000 cubic yards of soil
import/export) requiring a considerable amount of haul truck activity.
Table 2: Criteria Air Pollutant and Precursor Screening Level Sizes
Land Use Type
Construction-Related
Screening Size
Single-family 114 du
Apartment, low-rise 240 du
Apartment, mid-rise 240 du
Apartment, high-rise 249 du
Condo/townhouse, general 240 du
Condo/townhouse, high-rise 252 du
Mobile home park 114 du
Retirement community 114 du
Congregate care facility 240 du
Day-care center 277 ksf
Elementary school 277 ksf
Elementary school 3904 students
Junior high school
277 ksf
Junior high school
3261 students
High school
277 ksf
High school
3012 students
Junior college (2 years)
277 ksf
Junior college (2 years)
3012 students
University/college (4 years)
3012 students
Library
277 ksf
Place of worship
277 ksf
City park
67 acres
Racquet club
277 ksf
Racquetball/health
277 ksf
Quality restaurant
277 ksf
High turnover restaurant
277 ksf
Fast food rest. w/ drive thru
277 ksf
Fast food rest. w/o drive thru
277 ksf
Hotel
554 rooms
Motel
554 rooms
Free-standing discount store
277 ksf
Free-standing discount superstore
277 ksf (ROG)
Discount club
277 ksf
Regional shopping center
277 ksf
Electronic
Superstore
277 ksf
Home improvement superstore
277 ksf
Strip mall
277 ksf
Hardware/paint store
277 ksf
Supermarket
277 ksf
Convenience
market (24
hour)
277 ksf
Convenience
market with
gas pumps
277 ksf
Bank (with drive-through)
277 ksf
General
office
building
277 ksf
Office park 277 ksf
Government office building 277 ksf
Government (civic center) 277 ksf
Pharmacy/drugstore w/ drive through 277 ksf
Pharmacy/drugstore w/o drive through 277 ksf
Medical office building 277 ksf
Hospital 277 ksf
Hospital 337 beds
Warehouse 259 ksf
General light industry 259 ksf
General light industry 11 acres
General light industry 540 employees
General heavy industry 259 ksf
General heavy industry 11 acres
Industrial park 259 ksf
Industrial park 11 acres
Industrial park 577 employees
Manufacturing 259 ksf
Notes: du = dwelling units; ksf = thousand square feet; Screening levels include indirect and area
source emissions. Emissions from engines (e.g., back-up generators) and industrial sources subject to
Air District Rules and Regulations embedded in the land uses are not included in the screening
estimates and must be added to the above land uses.
Refer to Appendix D for support documentation.
Source: Modeled by EDAW 2009.
Methodology for the Evaluation and Thresholds of Significance
Refer to section 8.1 of the BAAQMD’s California Environmental Quality Act Air Quality Guidelines,
dated May 2017, for a step by step process to calculate construction related criteria pollutant
generation. The basic steps include calculating emissions from fugitive dust, mobile sources, and off-
gassing and obtaining the sum to determine total unmitigated emissions for ROG, NOx, PM10 and PM2.5.
Fugitive dust is not quantified unless the basic construction control measures for PM10 are not used.
Because these are required in accordance with PAMC Section 18.31.040(A) these will not need to be
quantified. The sum is then compared relative to the daily recommended thresholds identified by the
BAAQMD. If they are found to exceed thresholds, the mitigation described below shall be implemented
to reduce impacts. A summary of the appropriate steps is provided below in Table 3.
Table 3: Example Construction Criteria Air Pollutant and Precursor Significance
Determination
Emissions (lb/day or tpy)*
Step Emissions Source ROG NOX PM10 PM2.5
2 Fugitive Dust
Emissions
- - - -
Mobile Sources B B B B
Off-gassing C - - -
3 Total Unmitigated
Emissions
B+C=D B+C=D B+C=D B+C=D
4 Total basic
Mitigated
Emissions
E E E E
BAAQMD
Threshold
54 lb/day
54 lb/day
82 lb/day
54 lb/day
5 Basic Mitigated
Emissions
Exceed BAAQMD
Threshold?
Is E > 54
lb/day? (If Yes,
significant. Go
to step 6. If
No,
less than
significant)
Is E > 54
lb/day? (If Yes,
significant. Go
to step 6. If No,
less than
significant)
Is B* > 82
lb/day? (If
Yes,
significant.
Go
to step 6. If
No,
less than
significant)
Is B* > 54
lb/day? (If Yes,
significant. Go
to step 6. If No,
less than
significant)
6 Total Additional
Mitigated
Emissions
F F F F
7 Additional
Mitigated
Emissions
Exceed BAAQMD
Threshold?
Is F > 54
lb/day? (If Yes,
significant and
unavoidable. If
No, less than
significant with
mitigation
incorporated)
Is F > 54
lb/day? (If Yes,
significant and
unavoidable. If
No, less than
significant with
mitigation
incorporated)
Is F* > 82
lb/day? (If
Yes,
significant
and
unavoidable.
If
No, less than
significant
with
mitigation
incorporated)
Is F* > 54
lb/day? (If Yes,
significant and
unavoidable. If
No, less than
significant with
mitigation
incorporated)
* Applies to construction equipment exhaust only.
Notes: tpy = tons per year.; lb/day = pounds per day; NOX = oxides of nitrogen; PM2.5 = fine
particulate matter with an
aerodynamic resistance diameter of 2.5 micrometers or less; PM10 = respirable particulate matter
with an aerodynamic
resistance diameter of 10 micrometers or less; ROG = reactive organic gases;
Refer to Appendix D for support documentation.
Recommended Mitigation
If the proposed project still exceeds the BAAQMD recommended daily thresholds, the following
additional construction mitigation measures shall be implemented. If, with implementation of
this mitigation, the project still exceeds the thresholds, the project shall be considered to have
a significant and unavoidable impact on air quality from criteria pollutants.
Table 4: Additional Construction Mitigation Measures Recommended for Projects with
Construction Emissions Above the Threshold
1. All exposed surfaces shall be watered at a frequency adequate to maintain minimum soil moisture
of 12 percent. Moisture content can be verified by lab samples or moisture probe.
2. All excavation, grading, and/or demolition activities shall be suspended when average wind speeds
exceed 20 mph.
3. Wind breaks (e.g., trees, fences) shall be installed on the windward side(s) of actively disturbed
areas of construction. Wind breaks should have at maximum 50 percent air porosity.
4. Vegetative ground cover (e.g., fast-germinating native grass seed) shall be planted in disturbed
areas as soon as possible and watered appropriately until vegetation is established.
5. The simultaneous occurrence of excavation, grading, and ground-disturbing construction activities
on the same area at any one time shall be limited. Activities shall be phased to reduce the amount of
disturbed surfaces at any one time.
6. All trucks and equipment, including their tires, shall be washed off prior to leaving the site.
7. Site accesses to a distance of 100 feet from the paved road shall be treated with a 6 to 12 inch
compacted layer of wood chips, mulch, or gravel.
8. Sandbags or other erosion control measures shall be installed to prevent silt runoff to public
roadways from sites with a slope greater than one percent.
9. Minimizing the idling time of diesel powered construction equipment to two minutes.
10. The project shall develop a plan demonstrating that the off-road equipment (more than 50
horsepower) to be used in the construction project (i.e., owned, leased, and subcontractor vehicles)
would achieve a project wide fleet-average 20 percent NOX reduction and 45 percent PM reduction
compared to the most recent ARB fleet average. Acceptable options for reducing emissions include
the use of late model engines, low-emission diesel products, alternative fuels, engine retrofit
technology, after-treatment products, add-on devices such as particulate filters, and/or other options
as such become available.
11. Use low VOC (i.e., ROG) coatings beyond the local requirements (i.e., Regulation 8, Rule 3:
Architectural Coatings).
12. Requiring that all construction equipment, diesel trucks, and generators be equipped with Best
Available Control Technology for emission reductions of NOx and PM.
13. Requiring all contractors use equipment that meets CARB’s most recent certification standard for
off-road heavy duty diesel engines.
HEALTH RISK ASSESSMENT FOR CANCER RISK
If a health risk assessment (HRA) is required in accordance with PAMC Section 18.31.040(D),
The HRA shall be prepared in accordance with policies and procedures of the State Office of
Environmental Health Hazard Assessment and the Bay Area Air Quality Management District. As
discussed in BAAQMD’s California Environmental Quality Act Air Quality Guidelines, dated May
2017, these procedures are outlined in the California Air Pollution Control Officers Association’s
(CAPCOA’s) guidance document, Health risk Assessment for Proposed Land Use Projects, which
can be found here:
http://www.capcoa.org/wp-content/uploads/2012/03/CAPCOA_HRA_LU_Guidelines_8-
6-09.pdf
If the health risk assessment concludes that incremental cancer risk exceeds the BAAQMD
significance thresholds, reduction measures must be identified and demonstrate that they are
capable of reducing potential cancer and non-cancer risks to an acceptable level, including
appropriate enforcement mechanisms. Mitigation measures and best practices may include but
are not limited to:
o Restricting idling on‐site beyond Air Toxic Control Measures idling restrictions, as
feasible.
o Electrifying warehousing docks
o Requiring use of newer equipment and/or vehicles.
o Restricting off‐site truck travel through the creation of truck routes.
1
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Resolution No. 9721
Resolution of the Council of the City of Palo Alto Making Certain Findings
Concerning Significant Environmental Impacts, Mitigation Measures and
Alternatives, Adopting a Mitigation Monitoring and Reporting Program, and
Adopting a Statement of Overriding Considerations for the Comprehensive
Plan Update, For Which an Environmental Impact Report Was Prepared in
Accordance with the California Environmental Quality Act
RECITALS
A. The City of Palo Alto, a municipal corporation (“City”) has prepared that certain
comprehensive update to its general plan, entitled “Our Palo Alto 2030” (referred to herein as
the “Comprehensive Plan Update”), proposed for approval and adoption by the City Council.
B. Approval of the Comprehensive Plan Update would constitute a project under the
provisions of the California Environmental Quality Act of 1970, together with related state
implementation guidelines promulgated thereunder (“CEQA”).
C. The City Council, in compliance with CEQA, prepared an Environmental Impact
Report (EIR) to provide an assessment of the potential environmental consequences of
adopting and implementing the proposed Comprehensive Plan Update and associated zoning
amendments.
D. The environmental review process under CEQA commenced and was undertaken
concurrently with the preparation and consideration of the Comprehensive Plan Update, which
included the participation of a Citizens Advisory Committee (“CAC”) that met for almost two
years and hearings before the City Council to consider the CAC recommendations. This process
allowed the Comprehensive Plan Update to take into account any potential environmental
impacts identified in the EIR and include policies to address those impacts.
E. A Draft Environmental Impact Report (“Draft EIR”) for the Comprehensive Plan
Update was prepared analyzing four alternatives (also referred to as “scenarios”) in equal level
of detail. The Draft EIR was circulated for public review from February 5, 2016 to June 8, 2016,
during which time the City held several public hearings to receive comments on the Draft EIR.
F. During the Comprehensive Plan development and review process, the City Council
directed the evaluation of two additional alternatives or scenarios, which were subsequently
analyzed in a Supplement to the Draft EIR that was circulated for public review from February
10, 2017 to March 31, 2017, during which time the City Council and Planning and
Transportation Commission held additional public hearings to receive comments on the Draft
EIR and the Supplement.
G. After receiving the CAC’s recommendations on the Comprehensive Plan Update, the
City Council identified the parameters of the preferred alternative through several public
hearings.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
2
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
H. A Final Environmental Impact Report was prepared, which Final Environmental
Impact Report is comprised of the Draft EIR dated February 5, 2016, together with the
Supplement to the Draft EIR dated February 10, 2017, and the Final Environmental Impact
Report dated August 30, 2017 (collectively, all of said documents are referred to herein as the
“EIR”).
I. Prior to the adoption of this Resolution, the Planning and Transportation
Commission of the City of Palo Alto, on September 27, 2017, reviewed the EIR prepared for the
Comprehensive Plan Update (also sometimes referred to herein as the “Project”), held a public
hearing, and recommended to the City Council that it certify and find the Final EIR was
completed in accordance with the requirements of CEQA.
J. Over three Council meetings, on October 23 and 30 and November 13, 2017, the
Council held a duly noticed public hearing on the Comprehensive Plan Update and EIR, and on
November 13, 2017, certified the EIR in accordance with CEQA by adoption of Resolution No.
9720.
K. The Council is the decision-making body for adoption of the proposed
Comprehensive Plan Update.
L. CEQA requires that in connection with approval of a project for which an
environmental impact report has been prepared that identifies one or more significant
environmental effects of the project, the decision-making body of a public agency make certain
findings regarding those effects.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PALO ALTO AS
FOLLOWS:
The City Council, in the exercise of its independent judgment, makes and adopts the following
findings to comply with the requirements of CEQA, including Sections 15091, 15092, and 15093
of the CEQA Guidelines, based upon the entire record of proceedings for the Project. All
statements set forth in this Resolution constitute formal findings of the City Council, including
the statements set forth in this paragraph and in the recitals above.
1. The City Council was presented with, and has independently reviewed and analyzed the
EIR and other information in the record and has considered the information contained
therein prior to acting upon and approving the Project, and bases the findings stated
below on such review.
2. The EIR provides an adequate basis for considering and acting upon the Comprehensive
Plan Update Project. The City Council has considered all of the evidence and arguments
presented during consideration of the Project and the Final EIR. In determining whether
the Project may have a significant impact on the environment, and in adopting the
findings set forth herein, the City Council certifies that it has complied with Public
Resources Code Sections 21081, 21081.5, and 21082.2.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
3
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
3. The City Council agrees with the characterization of the EIR with respect to all impacts
initially identified as “less than significant” and finds that those impacts have been
described accurately and are less than significant as so described in the Final EIR. This
finding does not apply to impacts identified as significant or potentially significant that
are reduced to a less than significant level by mitigation measures included in the EIR.
The disposition of each of those impacts and the mitigation measures adopted to
reduce them are addressed specifically in the findings below.
4. The Mitigation Monitoring and Reporting Program (MMRP) includes all mitigation
measures adopted with respect to the Project and explains how and by whom they will
be implemented and enforced.
5. The EIR considers a reasonable range of potentially feasible alternatives, sufficient to
foster informed decision making, public participation and a reasoned choice, in
accordance with CEQA.
6. The Final EIR contains responses to comments received on a Draft EIR and a Supplement
to the Draft EIR. The Final EIR also contains corrections and clarifications to the text and
analysis of the Draft EIR and Supplement to the Draft EIR, where warranted. The City
Council does hereby find that such changes and additional information are not
significant new information under CEQA because such changes and additional
information do not indicate that any of the following would result from approval and
implementation of the Project: (i) any new significant environmental impact or
substantially more severe environmental impact (not already disclosed and evaluated in
the DEIR and Supplement to the Draft EIR), (ii) any feasible mitigation measure
considerably different from those analyzed in the Draft EIR and Supplement to the Draft
EIR that would lessen a significant environmental impact of the Project has been
proposed and would not be implemented, or (iii) any feasible alternative considerably
different from those analyzed in the DEIR and the Supplement to the Draft EIR that
would lessen a significant environmental impact of the Project has been proposed and
would not be implemented. The City Council does find and determine that recirculation
of the Final EIR for further public review and comment is not warranted or required
under the provisions of CEQA.
7. The City Council does hereby make the following findings with respect to significant
effects on the environment of the Project, as identified in the EIR, with the
understanding that all of the information in this Resolution is intended as a summary of
the full administrative record supporting the EIR, which full administrative record should
be consulted for the full details supporting these findings.
I. STATUTORY REQUIREMENTS FOR FINDINGS
Significant effects of the Comprehensive Plan Update project were identified in the Draft EIR
and the Supplement to the Draft EIR. CEQA §21081 and CEQA Guidelines §15091 require that
the Lead Agency prepare written findings for identified significant impacts, accompanied by a
brief explanation of the rationale for each finding. Less than significant effects (without
mitigation) of the project were also identified in the Draft EIR and the Supplement to the Draft
EIR. CEQA does not require that the Lead Agency prepare written findings for less than
significant effects.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
4
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
CEQA requires that the Lead Agency adopt mitigation measures or alternatives, where feasible,
to avoid or mitigate significant environmental impacts that would otherwise occur with
implementation of the project. Project mitigation or alternatives are not required, however,
where substantial evidence in the record demonstrates that they are infeasible or where the
responsibility for modifying the project lies with another agency. Specifically, CEQA Guidelines
§15091 states:
(a) No public agency shall approve or carry out a project for which an EIR has been certified
which identifies one or more significant environmental effects of the project unless the
public agency makes one or more written findings for each of those significant effects,
accompanied by a brief explanation of the rationale for each finding. The possible
findings are:
(1) Changes or alterations have been required in, or incorporated into, the project
which avoid or substantially lessen the significant environmental effect as identified
in the final EIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another
public agency and not the agency making the finding. Such changes have been
adopted by such other agency or can and should be adopted by such other agency.
(3) Specific economic, legal, social, technological, or other considerations, including
provision of employment opportunities for highly trained workers, make infeasible
the mitigation measures or project alternatives identified in the final EIR.
The “changes or alterations” referred to in §15091(a)(1) above, that are required in, or
incorporated into, the project which mitigate or avoid the significant environmental effects of
the project, may include a wide variety of measures or actions as set forth in Guidelines
§15370, including avoiding, minimizing, rectifying, or reducing the impact over time, or
compensating for the impact by replacing or providing substitute resources.
II. FINDINGS ON SIGNIFICANT IMPACTS AND MITIGATION MEASURES
Pursuant to Public Resources Code Section 21081 and CEQA Guidelines Section 15091, the City
Council hereby makes these findings with respect to the potential for significant environmental
impacts from adoption and implementation of the Comprehensive Plan Update and Zoning
Code amendments ("proposed project") and the means for mitigating those impacts. For the
purpose of these findings, the term “Environmental Impact Report” (EIR) means the Draft EIR,
Supplement to the Draft EIR, and Final EIR documents collectively, unless otherwise specified.
These findings do not attempt to describe the full analysis of each environmental impact
contained in the EIR. Instead, the findings provide a summary description of each impact,
describe the applicable mitigation measures identified in the EIR and adopted by the City, and
state the findings on the significance of each impact after imposition of the adopted mitigation
measures. A full explanation of these environmental findings and conclusions can be found in
the EIR. These findings hereby incorporate by reference the discussion and analysis in the EIR
that support the EIR's determinations regarding significant project impacts and mitigation
measures designed to address those impacts. The facts supporting these findings are found in
the record as a whole for the project.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
5
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
In making these findings, the City ratifies, adopts, and incorporates into these findings the
analysis and explanation in the EIR, and ratifies, adopts, and incorporates into these findings
the determinations and conclusions of the EIR relating to environmental impacts and mitigation
measures, except to the extent that any such determinations and conclusions are specifically
and expressly modified by these findings.
Aesthetics
Impact AES-1: Implementation of the proposed Plan would have the potential to substantially
degrade the existing visual character or quality of the area and its surroundings.
Mitigation Measure AES-1: To ensure that increased residential densities would not degrade
the visual character or quality of the area, the proposed Plan shall include policies that achieve
the following:
High-quality building and site design.
Compatibility with the neighborhood and adjacent structures.
Enhancement of existing commercial centers.
Requirements for landscaping and street trees.
Preservation and creation of a safe and inviting pedestrian environment.
Appropriate building form, massing, and setbacks.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively ensure
implementation of this mitigation measure during the course of development proposals and
capital improvement projects. For example:
Policy L-2.12: Encourage new development and redevelopment to incorporate greenery and
natural features such as green rooftops, pocket parks, plazas and rain gardens.
Policy L-3.1: Ensure that new or remodeled structures are compatible with the
neighborhood and adjacent structures.
Policy L-4.5: Maintain and enhance the University Avenue/Downtown area as a major
commercial center of the City, with a mix of commercial, civic, cultural, recreational and
residential uses. Promote quality design that recognizes the regional and historical
importance of the area and reinforces its pedestrian character.
Policy L-4.7: Maintain Stanford Shopping Center as one of the Bay Area’s premiere regional
shopping centers. Promote bicycle and pedestrian use and encourage any new development
at the Center to occur through infill.
Policy L-4.8: Maintain the existing scale, character and function of the California Avenue
business district as a shopping, service and office center intermediate in function and scale
between Downtown and the smaller neighborhood business areas.
Policy L-4.10: Recognize and preserve Town and Country Village as an attractive retail center
serving Palo Altans and residents of the wider region. Future development at this site should
preserve its existing amenities, pedestrian scale and architectural character while also
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
6
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
improving safe access for bicyclists and pedestrians and increasing the amount of bicycle
parking.
Policy L-4.15: Encourage maximum use of Neighborhood Centers by ensuring that the
publicly maintained areas are clean, well-lit and attractively landscaped.
Policy L-5.2: Provide landscaping, trees, sidewalks, pedestrian path and connections to the
citywide bikeway system within Employment Districts. Pursue opportunities to include
sidewalks, paths, low water use landscaping, recycled water and trees and remove grass turf
in renovation and expansion projects.
Policy L-6.1: Promote high-quality design and site planning that is compatible with
surrounding development and public spaces.
Policy L-6.2: Use the Zoning Ordinance, design review process, design guidelines and
Coordinated Area Plans to ensure high quality residential and commercial design and
architectural compatibility.
Policy L-9.3: Treat residential streets as both public ways and neighborhood amenities.
Provide and maintain continuous sidewalks, healthy street trees, benches and other
amenities that promote walking and “active” transportation.
Policy T-3.7: Encourage pedestrian-friendly design features such as sidewalks, street trees,
on-street parking, gathering spaces, gardens, outdoor furniture, art and interesting
architectural details.
Policy T-3.8: Add planting pockets with street trees to provide shade, calm traffic and
enhance the pedestrian realm.
Policy T-6.1: Continue to make safety the first priority of citywide transportation planning.
Prioritize pedestrian, bicycle and automobile safety over motor vehicle level of service at
intersections and motor vehicle parking.
Policy N-2.8: Require new commercial, multi-unit and single-family housing projects to
provide street trees and related irrigation systems.
The incorporation of relevant policies into the proposed Plan ensures that future development
and capital improvements under the proposed Plan would avoid significant degradation of the
existing visual character and quality.
Resulting Significance: Less than Significant
Impact AES-4: Implementation of the proposed Plan would have the potential to substantially
shadow public open space (other than public open streets and adjacent sidewalks) between
9:00 a.m. and 3:00 p.m. from September 21 to March 21.
Mitigation Measure AES-4: The City shall amend its local CEQA guidelines to require
development projects of a certain size or location to prepare an analysis of potential
shade/shadow impacts. The analysis shall focus on potential impacts to public open spaces
(other than public streets and adjacent sidewalks) between 9:00 a.m. and 3:00 p.m. from
September 21 to March 21. The analysis shall identify whether the project would shadow open
spaces during these times, explain how the project meets City design requirements and other
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
7
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
City policy goals, and describe ways to mitigate substantial shade and shadow impacts through
feasible building and site design features.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measure AES-4 would amend the City’s local CEQA guidelines
to require project-level analysis of potential shade/shadow impacts, as well as measures to
mitigate potential impacts through feasible building and site design features. Implementation
of this mitigation measure would ensure the future development projects and capital
improvement projects that are subject to CEQA would disclose and avoid potential
shade/shadow impacts to the extent feasible.
Resulting Significance: Less than Significant
Air Quality
Impact AIR-1: Without inclusion of air quality policies, implementation of the proposed Plan
could conflict with or obstruct implementation of the applicable air quality plan.
Mitigation Measure AIR-1: To ensure consistency with the 2010 Bay Area Clean Air Plan, the
proposed Plan shall include policies that achieve the following:
Reduction in emissions of particulates from automobiles, manufacturing, construction
activity, and other sources (e.g., dry cleaning, wood burning, landscape maintenance).
Support for regional, State, and federal programs that improve air quality.
Support for transit, bicycling, and walking.
Mix of uses (e.g., housing near employment centers) and development types (e.g., infill) to
reduce the need to drive.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively ensure
implementation of this mitigation measure during the course of development proposals and
capital improvement projects. For example:
Policy L-1.1: Limit future urban development to currently developed lands within the urban
service area. The boundary of the urban service area is otherwise known as the urban
growth boundary. Retain undeveloped land west of Foothill Expressway and Junipero Serra
as open space, with allowances made for very low-intensity development consistent with
the open space character of the area. Retain undeveloped land northeast of Highway 101 as
open space.
Policy L-2.1: Maintain a citywide structure of Residential Neighborhoods, Centers and
Employment Districts. Integrate these areas with the City’s and the region’s transit and
street system.
Policy L-2.2: Enhance connections between commercial and mixed use centers and the
surrounding residential neighborhoods by promoting walkable and bikeable connections
and a diverse range of retail and services that caters to the daily needs of residents.
Policy L-2.3: As a key component of a diverse, inclusive community, allow and encourage a
mix of housing types and sizes designed for greater affordability, particularly smaller housing
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
8
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
types, such as studios, cohousing, cottages, clustered housing, accessory dwelling units and
senior housing.
Policy L-2.4: Use a variety of strategies to stimulate housing near retail, employment, and
transit.
Policy L-2.6: Create opportunities for new mixed use development consisting of housing and
retail.
Policy T-1.1: Take a comprehensive approach to reducing single-occupant vehicle trips by
involving those who live, work and shop in Palo Alto in developing strategies that make it
easier and more convenient not to drive.
Policy T-1.6: Encourage innovation and expanded transit access to regional destinations,
multi-modal transit stations, employment centers and commercial centers, including
those within Palo Alto through the use of efficient public and/or private transit options such
as rideshare services, on-demand local shuttles and other first/last mile connections.
Policy T-1.16: Promote bicycle use as an alternative way to get to work, school, shopping,
recreational facilities and transit stops.
Policy T-1.19: Provide facilities that encourage and support bicycling and walking.
Policy T-5.12: To promote bicycle use, increase the number of safe, attractive and well-
designed bicycle parking spaces available in the city, including spots for diverse types of
bicycles and associated equipment, including trailers, prioritizing heavily travelled areas such
as commercial and retail centers, employment districts, recreational/cultural facilities, multi-
modal transit facilities and ride share stops for bicycle parking infrastructure.
Policy T-6.1: Continue to make safety the first priority of citywide transportation planning.
Prioritize pedestrian, bicycle and automobile safety over motor vehicle level of service at
intersections and motor vehicle parking.
Policy N-5.1: Support regional, State, and federal programs that improve air quality in the
Bay Area because of its critical importance to a healthy Palo Alto.
Policy N-5.2: Support behavior changes to reduce emissions of particulates from
automobiles.
Policy N-5.3: Reduce emissions of particulates from, manufacturing, dry cleaning,
construction activity, grading, wood burning, landscape maintenance, including leaf blowers
and other sources.
The incorporation of relevant policies into the proposed Plan ensures that future development
projects and capital improvement projects under the proposed Plan will support emissions
reductions, support air quality improvement programs, support alternative modes of transport,
and support reduced driving. In this way, Mitigation Measure AIR-1 would support BAAQMD’s
implementation of control measures in the 2010 Bay Area Clean Air Plan.
Resulting Significance: Less than Significant
Impact AIR-2: Implementation of the proposed Plan could violate an air quality standard;
contribute substantially to an existing or project air quality violation; and/or result in a
cumulatively considerable net increase of any criteria pollutant for which the Project region is
nonattainment under an applicable federal or State ambient air quality standard (including
releasing emissions which exceed quantitative thresholds for ozone precursors).
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
9
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Mitigation Measure AIR-2a: The City shall amend its local CEQA Guidelines and Municipal Code
to require, as part of the City’s development approval process, that future development projects
to comply with the current BAAQMD basic control measures for reducing construction
emissions of PM10 (Table 8-2, Basic Construction Mitigation Measures Recommended for All
Proposed Projects, of the BAAQMD CEQA Guidelines).
Mitigation Measure AIR-2b: The City shall amend its local CEQA Guidelines to require that,
prior to issuance of construction permits, development project applicants that are subject to
CEQA and have the potential to exceed the BAAQMD screening-criteria listed in the BAAQMD
CEQA Guidelines prepare and submit to the City of Palo Alto a technical assessment evaluating
potential project construction-related air quality impacts. The evaluation shall be prepared in
conformance with BAAQMD methodology in assessing air quality impacts. If construction-
related criteria air pollutants are determined to have the potential to exceed the BAAQMD
thresholds of significance, as identified in the BAAQMD CEQA Guidelines, the City of Palo Alto
shall require that applicants for new development projects incorporate mitigation measures
(Table 8-3, Additional Construction Mitigation Measures Recommended for Projects with
Construction Emissions Above the Threshold, of the BAAQMD CEQA Guidelines or applicable
construction mitigation measures subsequently approved by BAAQMD) to reduce air pollutant
emissions during construction activities to below these thresholds. These identified measures
shall be incorporated into all appropriate construction documents (e.g., construction
management plans) submitted to the City.
Mitigation Measure AIR-2c: To ensure that development projects that have the potential to
exceed the BAAQMD screening criteria air pollutants listed in the BAAQMD CEQA Guidelines
reduce regional air pollutant emissions below the BAAQMD thresholds of significance, the
proposed Plan shall include policies that require compliance with BAAQMD requirements,
including BAAQMD CEQA Guidelines.
Mitigation Measure AIR-2d: Implement Mitigation Measures TRANS-1a and TRANS-1b. In
addition, to reduce long-term air quality impacts by emphasizing walkable neighborhoods and
supporting alternative modes of transportation, the proposed Plan shall include policies that
achieve the following:
Enhanced pedestrian and bicycle connections between commercial and mixed-use centers.
Finding: Changes or alterations have been required in, or incorporated into, the proposed
project, which avoid or substantially lessen the significant environmental effect identified in the
EIR, but not to a level of less than significant. There are no additional feasible mitigation
measures and no feasible alternatives that avoid this significant effect, as further addressed in
Section III, Findings Concerning Alternatives.
Rationale for Finding: The City is located in a region that is in “nonattainment” for ozone and
particulates. While the mitigation measures listed below would reduce emissions of these
pollutants, they cannot eliminate Palo Alto’s contribution to regional air quality problems.
Mitigation Measure AIR-2a would require adherence to the current BAAQMD basic control
measures for reducing construction emissions of PM10.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
10
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Mitigation Measure AIR-2b would require implementation of BAAQMD-approved mitigation
measures, if future development projects in Palo Alto could generate construction exhaust
emissions in excess of the BAAQMD significance thresholds. An analysis of emissions generated
from the construction of specific future projects under the proposed Plan would be required to
evaluate emissions compared to BAAQMD’s project-level significance thresholds during
individual environmental review.
To implement Mitigation Measure AIR-2c, the proposed Plan includes Policy N-5.2 and would
apply to future development projects and capital improvements projects that are subject to
CEQA. Policy N-5.2 states: “Support the Bay Area Air Quality Management District (BAAQMD) in
its efforts to achieve compliance with existing air quality regulations by continuing to require
development applicants to comply with BAAQMD construction emissions control measures and
health risk assessment requirements.”
Through Mitigation Measure TRANS-1a and proposed Policy L-2.2, the City would ensure that
future development projects and capital improvement projects: “Enhance connections between
commercial and mixed use centers and the surrounding residential neighborhoods by
promoting walkable and bikeable connections and a diverse range of retail and services that
caters to the daily needs of residents.” However, , analysis of post-mitigation conditions in the
Supplement to the Draft EIR shows that implementation of transportation mitigation measures
would nominally reduce emissions but would not reduce emissions below BAAQMD’s project-
level thresholds, which, based on BAAQMD guidance, are generally used to determine if a
project generates a substantial increase in emissions. Therefore, no additional mitigation
measures are available and the impact is considered significant and unavoidable.
Resulting Significance: Significant and Unavoidable
Impact AIR-3: Implementation of the proposed Plan would expose sensitive receptors to
substantial concentrations of air pollution.
Mitigation Measure AIR-3a: The City of Palo Alto shall update its CEQA Procedures to require
that future non-residential projects within the city that: 1) have the potential to generate 100 or
more diesel truck trips per day or have 40 or more trucks with operating diesel-powered TRUs,
and 2) are within 1,000 feet of a sensitive land use (e.g., residential, schools, hospitals, nursing
homes), as measured from the property line of a proposed project to the property line of the
nearest sensitive use, shall submit a health risk assessment (HRA) to the City of Palo Alto prior
to future discretionary project approval or shall comply with best practices recommended for
implementation by the BAAQMD.
The HRA shall be prepared in accordance with policies and procedures of the State Office of
Environmental Health Hazard Assessment and the Bay Area Air Quality Management District. If
the HRA shows that the incremental cancer risk exceeds the BAAQMD significance thresholds,
the applicant will be required to identify and demonstrate that mitigation measures are capable
of reducing potential cancer and non-cancer risks to an acceptable level, including appropriate
enforcement mechanisms.
Mitigation measures and best practices may include but are not limited to:
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
11
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Restricting idling on-site beyond Air Toxic Control Measures idling restrictions, as feasible.
Electrifying warehousing docks.
Requiring use of newer equipment and/or vehicles.
Restricting off-site truck travel through the creation of truck routes.
Mitigation measures identified in the project-specific HRA shall be identified as mitigation
measures in the environmental document and/or incorporated into the site development plan
as a component of a proposed project.
Mitigation Measure AIR-3b: To ensure that new industrial and warehousing projects with the
potential to generate new stationary and mobile sources of air toxics that exceed the BAAQMD
project-level and/or cumulative significance thresholds for toxic air contaminants and PM2.5
listed in the BAAQMD CEQA Guidelines reduce emissions below the BAAQMD thresholds of
significance, amend the City’s CEQA guidelines to require compliance with BAAQMD
requirements.
Mitigation Measure AIR-3c: The proposed Plan shall include policies to mitigate potential
sources of toxic air contaminants through siting or other means to reduce human health risks
and meet the Bay Area Air Quality Management District’s applicable threshold of significance.
Policies shall also require that new sensitive land use projects (e.g., residences, schools,
hospitals, nursing homes, parks or playgrounds, and day care centers) within 1,000 feet of a
major stationary source of TACs and roadways with traffic volumes over 10,000 vehicles per day
consider potential health risks and incorporate adequate precautions, such as high-efficiency air
filtration, into project design.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measures AIR-3a and AIR-3b would ensure that mobile
sources of TACs not covered under BAAQMD permits are considered during subsequent project-
level environmental review and development of individual projects would be required to
achieve the incremental risk thresholds established by BAAQMD. Mitigation Measures AIR-3c
would ensure that potential health risks are considered for new sensitive land uses sited near
potential sources of toxic air contaminants, and that adequate precautions are incorporated
into such projects. The proposed Plan includes Policy N-5.5 to ensure exposure to pollutants and
resulting health risks are considered during the siting of sensitive land uses: “Mitigate potential
sources of toxic air contaminants through siting or other means to reduce human health risks
and meet the Bay Area Air Quality Management District’s applicable threshold of significance.
When siting new sensitive receptors such as schools, day care facilities, parks or playgrounds,
medical facilities and residences within 1,000’ of stationary sources of toxic air contaminants or
roadways used by more than 10,000 vehicles per day, require projects to consider potential
health risks and incorporate adequate precautions such as high-efficiency air filtration into
project design.”
Resulting Significance: Less than Significant
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
12
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Impact AIR-4: Implementation of the proposed Plan could create or expose a substantial
number of people to objectionable odors unless policies are integrated into the proposed
Plan.
Mitigation Measure AIR-4: To reduce odor impacts, the proposed Plan shall include policies
requiring:
Buffers, mechanical, and other mitigation methods to avoid creating a nuisance.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes Policy N-5.4 to ensure that future
development projects and capital improvement projects do not result in objectionable odors:
“All potential sources of odor and/or toxic air contaminants shall be adequately buffered, or
mechanically or otherwise mitigated to avoid odor and toxic impacts that violate relevant
human health standards.” This policy, along with CEQA review of projects using BAAQMD’s odor
screening distances and compliance with BAAQMD Regulation 7, would ensure that odor
impacts are minimized and reduced to a less-than-significant level.
Resulting Significance: Less than Significant
Cultural Resources
Impact CULT-1: Implementation of the proposed Plan could adversely affect a historic
resource listed or eligible for listing on the National and/or California Register, or listed on the
City’s Historic Inventory.
Mitigation Measure CULT-1: To ensure the protection of potentially historic resources, the
proposed Plan shall include policies that achieve the following:
Process for reviewing proposed demolition or alteration of potentially historic buildings.
Protection of archaeological resources.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes the policies that collectively support
implementation of this mitigation measure. For example:
Policy L-7.2: If a proposed project would substantially affect the exterior of a potential
historic resource that has not been evaluated for inclusion into the City’s Historic Resources
Inventory, City staff shall consider whether it is eligible for inclusion in State or federal
registers prior to the issuance of a demolition or alterations permit. Minor exterior
improvements that do not affect the architectural integrity of potentially historic buildings
shall be exempt from consideration. Examples of minor improvements may include repair or
replacement of features in kind, or other changes that do not alter character-defining
features of the building.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
13
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Policy L-7.14: Protect Palo Alto’s archaeological resources, including natural land formations,
sacred sites, the historical landscape, historic habitats and remains of settlements here
before the founding of Palo Alto in the 19th century.
The incorporation of relevant policies into the proposed Plan ensures that the potential historic
resources would be considered for inclusion on State and federal registers prior to demolition or
alteration, and that archaeological resources would be protected. Through implementation of
these measures, the City would ensure the ongoing protection of potential historic and
archaeological resources that have not already been identified and protected.
Resulting Significance: Less than Significant
Impact CULT-2: Implementation of the proposed Plan could eliminate important examples of
major periods of California history or prehistory.
Mitigation Measure CULT-2: Implement Mitigation Measure CULT-1.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Through implementation of Mitigation Measure CULT-1, the City would
maintain processes and procedures to ensure the ongoing protection of historic and
archaeological resources, including important examples of California’s history and prehistory.
Resulting Significance: Less than Significant
Impact CULT-3: Implementation of the proposed Plan could cause damage to an important
archaeological resource as defined in Section 15064.5 of the CEQA Guidelines.
Mitigation Measure CULT-3: Implement Mitigation Measure CULT-1. In addition, to ensure that
future development would not damage archaeological resources, the proposed Plan shall
include policies that achieve the following:
Archaeological surveys and mitigation plans for future development projects.
Developer compliance with applicable regulations regarding the identification and
protection of archaeological and paleontological deposits, and unique geologic features.
Appropriate tribal consultation and consideration of tribal concerns.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure. For example:
Policy L-7.15: Appropriate tribal consultation and consideration of tribal concerns.
Policy L-7.16: Archaeological surveys and mitigation plans for future development projects.
Policy L-7.17: Developer compliance with applicable regulations regarding the identification
and protection of archaeological and paleontological deposits, or unique geologic features.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
14
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
The incorporation of relevant policies into the proposed Plan ensures that the City would
require archaeological surveys and mitigation plans for future development projects and capital
improvement projects that are subject to CEQA review, as well as compliance with
archaeological protection regulations and tribal consultation. Implementation of these policies
would avoid significant impacts to archaeological resources. In addition, through
implementation of Mitigation Measure CULT-1, the City would maintain processes and
procedures to ensure the ongoing protection of archaeological resources.
Resulting Significance: Less than Significant
Impact CULT-5: Implementation of the proposed Plan would have the potential to directly or
indirectly destroy a unique paleontological resource or site or unique geologic feature.
Mitigation Measure CULT-5: Implement Mitigation Measure CULT-3.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measure CULT-3 would incorporate policies into the proposed
Plan to require compliance with paleontological protection regulations. These policies would
ensure that future development projects and capital improvement projects subject to CEQA
would avoid significant impacts to paleontological resources and unique geologic features.
Resulting Significance: Less than Significant
Impact CULT-7: Implementation of the proposed Plan, in combination with past, present, and
reasonably foreseeable projects, would result in significant cumulative impacts with respect
to cultural resources.
Mitigation Measure CULT-7: Implement Mitigation Measures CULT-1 and CULT-3.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Through implementation of Mitigation Measure CULT-1, the City would
maintain processes and procedures to ensure the ongoing protection of historic and
archaeological resources. These processes and procedures would protect historic and
archaeological resources. Mitigation Measure CULT-3 would incorporate policies into the
proposed Plan to require archaeological surveys and mitigation plans for future development
projects and capital improvement projects, as well as compliance with archaeological and
paleontological protection regulations and tribal consultation. These policies would ensure that
future projects avoid significant impacts to archaeological and paleontological resources and
that the City’s contribution to potential cumulative impacts to historic, archaeological, and
paleontological resources would be reduced to a less-than-significant level.
Resulting Significance: Less than Significant
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
15
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Greenhouse Gas Emissions
Impact GHG-3: The proposed Plan would expose people or structures to the physical effects of
climate change, including but not limited to flooding, extreme temperatures, public health,
wildfire risk, or other impacts resulting from climate change, requiring mitigation.
Mitigation Measure GHG-3: To address the potential impacts associated with exposing people
to the effects of climate change, the proposed Plan shall include policies that achieve the
following:
Monitoring and response to flooding risks caused by climate change-related changes to
precipitation patterns, groundwater levels, sea level rise, tides, and storm surges.
Cooperative planning with federal, State, regional, and local public agencies on issues
related to climate change (including sea level rise and extreme storms).
Preparation of response strategies to address sea level rise, increased flooding, landslides,
soil erosion, storm events, and other events related to climate change.
Implementation of adaptive strategies to address impacts of sea level rise on Palo Alto’s
levee system.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies and programs that collectively
support implementation of this mitigation measure. For example:
Policy N-4.12: Encourage Low Impact Development (LID) measures to limit the amount of
pavement and impervious surface in new development and increase the retention,
treatment and infiltration of urban stormwater runoff. Include LID measures in major
remodels, public projects and recreation projects where practical.
Policy N-8.2: With guidance from the City’s Sustainability and Climate Action Plan (S/CAP)
and its subsequent updates and other future planning efforts, reduce greenhouse gas
emissions from City operations and from the community.
Policy N-8.4: Continue to work with regional partners to build resiliency policy into City
planning and capital projects, especially near the San Francisco Bay shoreline, while
protecting the natural environment.
Program N8.4.1: Prepare response strategies that address sea level rise, increased flooding,
landslides, soil erosion, storm events and other events related to climate change. Include
strategies to respond to the impacts of sea level rise on Palo Alto’s levee system.
Policy S-1.9: Design Palo Alto’s infrastructure system to protect the life and safety of
residents, ensure resiliency in the face of disaster and minimize economic loss, including in
the context of climate change and sea level rise.
Program S1.10.3: Implement the mitigation strategies and guidelines provided by the LHMP,
including those that address evolving hazards resulting from climate change.
Policy S-2.9: Prohibit new habitable basements in the development of single-family
residential properties within 100-year flood zones of the FEMA-designated Special Flood
Hazard Area.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
16
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Policy S-2.10: Monitor and respond to the risk of flooding caused by climate change-related
changes to precipitation patterns, groundwater levels, sea level rise, tides and storm surges.
Policy S-2.11: Support regional efforts to improve bay levees.
Program S2.11.1: Work cooperatively with the Santa Clara Valley Water District and the San
Francisquito Creek Joint Powers Authority to provide flood protection from high tide events
on San Francisco Bay, taking into account the impacts of future sea level rise, to provide one
percent (100-year) flood protection from tidal flooding, while being sensitive to preserving
and protecting the natural environment.
Program S2.11.2: Work with regional, State, and federal agencies to develop additional
adaptive strategies to address flood hazards to existing or new development and
infrastructure, including environmentally sensitive levees.
The incorporation of relevant policies into the proposed Plan ensures that the City considers the
impact of climate change when making future decisions about development projects and capital
improvement projects. The programs listed above illustrate ways the City is engaging in planning
and strategies to reduce the risks associated with the effects of climate change. The policies and
programs collectively ensure that the City reduces potential climate change hazards to the
extent feasible.
Resulting Significance: Less than Significant
Hydrology
Impact HYD-2: The proposed Plan could substantially degrade or deplete ground water
resources or interfere substantially with groundwater recharge such that there would be a net
deficit in aquifer volume or a lowering of the local groundwater table level.
Mitigation Measure HYD-2: To reduce potential impacts associated with construction
dewatering the proposed Plan shall include policies that achieve the following:
Avoidance of the impacts of basement construction for single-family homes on the
natural environment and safety.
Conservation of subsurface water resources.
Construction techniques and recharge strategies to reduce subsurface and surface water
impacts.
Monitoring of dewatering and excavation projects.
Cooperation with other jurisdictions and regional agencies to protect groundwater.
Protection of groundwater as a natural resource.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies and programs that collectively
support implementation of this mitigation measure. For example:
Policy L-3.5: Avoid negative impacts of basement construction for single-family homes on
adjacent properties, public resources and the natural environment.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
17
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Policy N-4.7: Ensure regulation of groundwater use to protect it as a natural resource and to
preserve it as a potential water supply in the event of water scarcity.
Policy N-4.8: Conserve and maintain subsurface water resources by exploring ways to reduce
the impacts of residential basement dewatering and other excavation activities.
Program N4.8.1: Research and promote new construction techniques and recharge
strategies developed to reduce subsurface and surface water impacts and comply with City
dewatering policies.
Program N4.8.2: Explore appropriate ways to monitor dewatering for all dewatering and
excavation projects to encourage maintaining groundwater levels and recharging of the
aquifer where needed.
The incorporation of relevant policies into the proposed Plan ensures that the City would
continue to work to reduce the environmental effects associated with construction dewatering,
including impacts to adjacent properties and subsurface water resources. The programs listed
above illustrate the City commitment to advancing these policies. Implementation of Mitigation
Measure HYD-2 would also ensure cooperation with other agencies to protect groundwater
resources and would reduce impacts to groundwater resources to a less-than-significant level.
Resulting Significance: Less than Significant
Land Use
Impact LAND-1: The proposed Plan could adversely change the type or intensity of existing or
planned land use patterns in the area.
Mitigation Measure LAND-1: To ensure that the intensity of future development would not
adversely change the land use patterns or affect the livability of Palo Alto neighborhoods, the
proposed Plan shall include policies that achieve the following:
Strengthening of residential neighborhoods.
Vitality of commercial areas and public facilities.
High-quality building and site design.
Architectural compatibility of new development.
Compatible infill development.
Avoidance of abrupt changes in the scale of development where residential districts abut
more intense uses.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure. For example:
Policy L-1.2: Maintain and strengthen Palo Alto’s varied residential neighborhoods while
sustaining the vitality of its commercial areas and public facilities.
Policy L-1.3: Infill development in the urban service area should be compatible with its
surroundings and the overall scale and character of the city to ensure a compact, efficient
development pattern.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
18
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Policy L-3.1: Ensure that new or remodeled structures are compatible with the
neighborhood and adjacent structures.
Policy L-6.1: Promote high-quality design and site planning that is compatible with
surrounding development and public spaces.
Policy L-6.2: Use the Zoning Ordinance, design review process, design guidelines and
Coordinated Area Plans to ensure high quality residential and commercial design and
architectural compatibility.
Policy L-6.7: Where possible, avoid abrupt changes in scale and density between residential
and non-residential areas and between residential areas of different densities. To promote
compatibility and gradual transitions between land uses, place zoning district boundaries at
mid-block locations rather than along streets wherever possible.
Policy L-9.4: Maintain and enhance existing public gathering places and open spaces and
integrate new public spaces at a variety of scales.
Policy L-9.6: Create, preserve and enhance parks and publicly accessible, shared outdoor
gathering spaces within walking and biking distance of residential neighborhoods.
The incorporation of relevant policies into the proposed Plan ensures that the City will require
development and capital improvements allowed under the proposed Plan to achieve high-
quality design, architectural compatibility, and context-sensitive building design, strengthening
residential and commercial areas and avoiding adverse effects associated with the type or
intensity of land use patterns.
Resulting Significance: Less than Significant
Impact LAND-2: The proposed Plan would allow development that could be incompatible with
adjacent land uses or with the general character of the surrounding area, including density
and building height.
Mitigation Measure LAND-2: Implement Mitigation Measure LAND-1. In addition, to further
reduce potential impacts to visual character and ensure compatibility with adjacent land uses,
the proposed Plan shall include policies that achieve the following:
Use of City procedures, plans, and requirements to ensure high-quality building design and
architectural compatibility.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure. For example:
Policy L-6.2: Use the Zoning Ordinance, design review process, design guidelines and
Coordinated Area Plans to ensure high quality residential and commercial design and
architectural compatibility.
Policy L-6.7: Where possible, avoid abrupt changes in scale and density between residential
and non-residential areas and between residential areas of different densities. To promote
compatibility and gradual transitions between land uses, place zoning district boundaries at
mid-block locations rather than along streets wherever possible.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
19
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
The incorporation of relevant policies into the proposed Plan ensures that the City will require
development projects and capital improvement projects to provide appropriate land use
transitions and adhere to design requirements for compatibility and high-quality design, and to
avoid adverse effects associated with incompatible land uses, effectively avoiding adverse
effects associated with the intensity of planned land uses.
Resulting Significance: Less than Significant
Impact LAND-5: The proposed Plan could physically divide an established community.
Mitigation Measure LAND-5: To avoid potential impacts from physically dividing an established
community, the proposed Plan shall include policies that achieve the following:
Enhanced connections to and from parks, schools, and community facilities for all users.
Safe and convenient pedestrian, bicycle, and transit connections between residential areas
and commercial centers.
Cooperation with other agencies to improve circulation connections.
Grade separation of rail crossings.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure during the course of development proposals and
capital improvement projects. For example:
Policy L-1.6: Use coordinated area plans to guide development in areas of Palo Alto where
significant change is foreseeable. Address both land use and transportation, define the
desired character and urban design traits of the areas, identify opportunities for public open
space, parks and recreational opportunities, address connectivity to and compatibility with
adjacent residential areas; and include broad community involvement in the planning
process.
Policy L-2.2: Enhance connections between commercial and mixed use centers and the
surrounding residential neighborhoods by promoting walkable and bikeable connections
and a diverse range of retail and services that caters to the daily needs of residents.
Policy T-1.17: Require new office, commercial and multi-family residential developments to
provide improvements that improve bicycle and pedestrian connectivity as called for in the
2012 Palo Alto Bicycle + Pedestrian Transportation Plan.
Policy T-1.21: Maintain pedestrian- and bicycle-only use of alleyways Downtown and in the
California Avenue area where appropriate to provide connectivity between businesses and
parking and transit stops, and consider public art in the alleyways as a way to encourage
walking.
Policy T-3.2: Enhance connections to, from and between parks, community centers,
recreation facilities, libraries and schools for all users.
Policy T-3.13: Work with Caltrans, Santa Clara County and VTA to improve east and west
connections in Palo Alto and maintain a circulation network that binds the city together in
all directions.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
20
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Policy T-3.15: Pursue grade separation of rail crossings along the rail corridor as a City
priority.
Policy T-8.12: Support the development of the Santa Clara County Countywide Bicycle
System, and other regional bicycle plans.
The incorporation of relevant policies into the proposed Plan ensures that future development
projects and capital improvement projects will enhance connections with community facilities,
improve safety for non-automotive connections, address grade separation of rail crossings, and
involve cooperation with other agencies to improve circulation. City action consistent with
these policies would improve accessibility throughout the city and ensure that established
communities are not physically divided.
Resulting Significance: Less than Significant
Noise
Impact NOISE-1: Implementation of the proposed Plan would have the potential to cause the
average 24-hour noise level (Ldn) to increase by 5.0 decibels (dB) or more in an existing
residential area, even if the Ldn would remain below 60 dB.
Mitigation Measure NOISE-1a: To ensure that average 24-hour noise levels associated with
long-term operational noise would not increase by 5.0 decibels (dB) or more in an existing
residential area, the proposed Plan shall include policies that achieve the following:
Location of land uses in areas with compatible noise environments.
Use of the guidelines in the “Land Use Compatibility for Community Noise Environment”
table in the proposed Plan to evaluate the compatibility of proposed land uses with existing
noise environments.
Clear guidelines for maximum outdoor noise levels in residential areas.
Adherence to the interior noise requirements of the State of California Building Standards
Code (Title 24) and the Noise Insulation Standards (Title 25).
Inclusion of a noise contour map in the proposed Plan.
Reduction of noise impacts of development on adjacent properties.
Evaluation of noise impacts on existing residential, open space, and conservation land.
Requirement for new projects in the Multiple Family, Commercial, Manufacturing, or
Planned Community districts to demonstrate compliance with the Noise Ordinance.
Mitigation Measure NOISE-1b: To reduce potential impacts to new land uses from aircraft
noise, the proposed Plan shall include policies that achieve the following:
Compliance with the airport-related land use compatibility standards for community noise
environments.
Prohibition of incompatible land use development within the 60 dBA CNEL noise contours of
the Palo Alto airport, as established in the adopted County of Santa Clara Airport Land Use
Commission Comprehensive Land Use Plan (CLUP) for the Palo Alto Airport.
Mitigation Measure NOISE-1c: To reduce potential impacts to new land uses from railway noise,
the proposed Plan shall include policies that achieve the following:
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
21
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Minimization of noise spillover from rail-related activities into adjacent residential or noise-
sensitive areas.
Building design that reduces impacts from noise and ground borne vibrations associated
with rail operations.
Guidelines for interior noise levels.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure during the course of development proposals and
capital improvement projects. For example:
Policy N-6.1: Encourage the location of land uses in areas with compatible noise
environments. Use the guidelines in Table N-1 to evaluate the compatibility of proposed
land uses with existing noise environments when preparing, revising, or reviewing
development proposals. Acceptable exterior, interior and ways to discern noise exposure
include:
The guideline for maximum outdoor noise levels in residential areas is an Ldn of 60 dB.
This level is a guideline for the design and location of future development and a goal for
the reduction of noise in existing development. However, 60 Ldn is a guideline which
cannot necessarily be reached in all residential areas within the constraints of economic
or aesthetic feasibility. This guideline will be primarily applied where outdoor use is a
major consideration (e.g., backyards in single-family housing developments, and
recreational areas in multiple family housing projects). Where the City determines that
providing an Ldn of 60 dB or lower outdoors is not feasible, the noise level in outdoor
areas intended for recreational use should be reduced to as close to the standard as
feasible through project design.
Interior noise, per the requirements of the State of California Building Standards Code
(Title 24) and Noise Insulation Standards (Title 25), must not exceed an Ldn of 45 dB in
all habitable rooms of all new dwelling units.
Policy N-6.2: Noise exposure(s) can be determined from (a) the noise contour map included
in this plan, (b) more detailed noise exposure studies, or (c) on area-specific or project-
specific noise measurements, as appropriate.
Policy N-6.5: Protect residential and residentially-zoned properties from excessive and
unnecessary noise from any sources on adjacent commercial or industrial properties.
Policy N-6.7: While a proposed project is in the development review process, the noise
impact of the project on existing residential land uses, public open spaces and public
conservation land should be evaluated in terms of the increase in existing noise levels for
the potential for adverse community impact, regardless of existing background noise levels.
If an area is below the applicable maximum noise guideline, an increase in noise up to the
maximum should not necessarily be allowed.
Policy N-6.8: The City may require measures to reduce noise impacts of new development
on adjacent properties through appropriate means including, but not limited to, the
following:
Orient buildings to shield noise sensitive outdoor spaces from sources of noise.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
22
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Construct noise walls when other methods to reduce noise are not practical and when
these walls will not shift similar noise impacts to another adjacent property.
Screen and control noise sources such as parking lots, outdoor activities and mechanical
equipment, including HVAC equipment.
Increase setbacks to serve as a buffer between noise sources and adjacent dwellings.
Whenever possible, retain fences, walls or landscaping that serve as noise buffers while
considering design, safety and other impacts.
Use soundproofing materials, noise reduction construction techniques, and/or
acoustically rated windows/doors.
Include auxiliary power sources at loading docks to minimize truck engine idling.
Control hours of operation, including deliveries and trash pickup, to minimize noise
impacts.
Policy N-6.9: Continue to require applicants for new projects or new mechanical equipment
in the Multifamily, Commercial, Manufacturing or Planned Community districts to submit an
acoustical analysis demonstrating compliance with the Noise Ordinance prior to receiving a
building permit.
Policy N-6.12: Ensure compliance with the airport related land use compatibility standards
for community noise environments, shown in Table N-1, by prohibiting incompatible land
use development within the 60 dBA CNEL noise contours of the Palo Alto airport.
Policy N-6.13: Minimize noise spillover from rail related activities into adjacent residential or
noise-sensitive areas.
Policy N-6.14: Reduce impacts from noise and ground borne vibrations associated with rail
operations by requiring that future habitable buildings use necessary design elements such
as setbacks, landscaped berms and soundwalls to keep interior noise levels below 45 dBA
Ldn and ground-borne vibration levels below 72 VdB.
Mitigation Measure NOISE-1a incorporates policies into the proposed Plan to require adherence
to noise guidelines, reduce potential noise impacts for adjacent properties, ensuring that long-
term operational noise in residential areas would not increase by unacceptable levels.
Mitigation Measure NOISE-1b would incorporate policies into the proposed Plan to require
compliance with airport-related compatibility standards and prohibit development within the
60 dBA CNEL noise contour of the Palo Alto Airport, ensuring that new sensitive receptors are
not exposed to unacceptable levels of noise from operation of the Palo Alto Airport.
Mitigation Measure NOISE-1c would incorporate policies into the proposed Plan to address
impacts associated with rail operations and require interior noise level guidelines and vibration
impact analyses, ensuring that new construction near the rail corridor is adequate to address
railway noise and vibration, to the extent feasible.
Resulting Significance: Less than Significant
Impact NOISE-2: Implementation of the proposed Plan would have the potential to cause the
Ldn to increase by 3 dB or more in an existing residential area, thereby causing the Ldn in the
area to exceed 60 dB.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
23
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Mitigation Measure NOISE-2: Implement Mitigation Measures NOISE-1a, NOISE-1b, and
NOISE-1c.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c would be
implemented by including policies in the proposed Plan to ensure that noise levels in residential
areas would not increase by unacceptable levels and ensure that new noise sources would be
controlled and/or mitigated so as to comply with City standards.
Resulting Significance: Less than Significant
Impact NOISE-3: Implementation of the proposed Plan would have the potential to cause an
increase of 3 dB or more in an existing residential area where the Ldn currently exceeds 60 dB.
Mitigation Measure NOISE-3: Implement Mitigation Measures NOISE-1a, NOISE-1b, and
NOISE-1c.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c would be
implemented by including policies in the proposed Plan to ensure that noise levels in residential
areas would not increase by unacceptable levels and would ensure that new noise sources
would be controlled and/or mitigated so as to comply with City standards.
Resulting Significance: Less than Significant
Impact NOISE-4: Implementation of the proposed Plan would have the potential to result in
indoor noise levels for residential development to exceed an Ldn of 45 dB.
Mitigation Measure NOISE-4a: Implement Mitigation Measure NOISE-1a.
Mitigation Measure NOISE-4b: The Land Use Noise Compatibility Guidelines established in the
1998 Comprehensive Plan shall be maintained.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measure NOISE-1a would be implemented by including
policies in the proposed Plan to ensure that long-term operational noise in residential areas
would not increase by unacceptable levels by maintaining the City’s Land Use Noise
Compatibility Guidelines, which would be used to evaluate new development projects and
capital improvement projects.
Resulting Significance: Less than Significant
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
24
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Impact NOISE-5: Implementation of the proposed Plan would have the potential to expose
persons to or generate excessive ground-borne vibration or ground-borne noise levels.
Mitigation Measure NOISE-5a: To ensure that future development would not result in
significant construction-related vibration impacts, the proposed Plan shall include policies that
limit the hours of construction around sensitive receptors, and require formal, ongoing
monitoring and reporting throughout the construction process for larger development projects,
as well as the use of pertinent industry standards and City guidelines to avoid significant
vibration impacts during construction or operations.
Mitigation Measure NOISE-5b: Implement Mitigation Measure NOISE-1c.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes the following policy and program that
collectively ensure implementation of this mitigation measure during the course of
development proposals and capital improvement projects:
Policy N-6.11: Continue to prioritize construction noise limits around sensitive receptors,
including through limiting construction hours and individual and cumulative noise from
construction equipment.
Program N6.11.1: For larger development projects that demand intensive construction
periods and/or use equipment that could create vibration impacts, such as the Stanford
University Medical Center or major grade separation projects, require a vibration impact
analysis, as well as formal, ongoing monitoring and reporting of noise levels throughout the
entire construction process, pertinent to industry standards. The monitoring plan should
identify hours of operation and could include information on the monitoring locations,
durations and regularity, the instrumentation to be used and appropriate noise control
measures to ensure compliance with the noise ordinance.
The incorporation of this policy and program into the proposed Plan requires vibration analyses
and vibration mitigation plans, as well as limits for vibration around vibration-sensitive
receptors.
Resulting Significance: Less than Significant
Impact NOISE-6: Implementation of the proposed Plan would have the potential to expose
people to noise levels in excess of established State standards.
Mitigation Measure NOISE-6: Implement Mitigation Measures NOISE-4a and NOISE-4b.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measure NOISE-1a would be implemented by including
policies in the proposed Plan to ensure that new land uses would be reviewed for compatibility
with their surroundings and would not increase noise by unacceptable levels, and Mitigation
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
25
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Measure NOISE-4b would be implemented by maintaining the City’s Land Use Noise
Compatibility Guidelines in the proposed Plan.
Resulting Significance: Less than Significant
Impact NOISE-7: Implementation of the proposed Plan would have the potential to result in
the exposure of persons to or generation of noise levels in excess of standards established in
the local General Plan or noise ordinance, or applicable standards of other agencies.
Mitigation Measure NOISE-7: Implement Mitigation Measures NOISE-1a, NOISE-1b, NOISE-1c,
NOISE-4a, and NOISE-4b.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c would be
implemented by including policies in the proposed Plan to ensure that residential areas would
not be affected by new noise sources and would maintain the City’s Land Use Noise
Compatibility Guidelines.
Resulting Significance: Less than Significant
Impact NOISE-8: Implementation of the proposed Plan could result in a potentially substantial
temporary or periodic increase in ambient noise levels in the project vicinity above levels
existing without the project.
Mitigation Measure NOISE-8: To ensure that future development would not result in significant
impacts to sensitive receptors from construction noise, the proposed Plan shall include policies
that achieve the following:
Construction noise limits around sensitive receptors.
Monitoring and reporting plans for construction noise levels of larger development projects.
Noise control measures to ensure compliance with the noise ordinance.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes the following policy and program that
collectively ensure implementation of this mitigation measure during the course of
development proposals and capital improvement projects:
Policy N-6.11: Continue to prioritize construction noise limits around sensitive receptors,
including through limiting construction hours and individual and cumulative noise from
construction equipment.
Program N6.11.1: For larger development projects that demand intensive construction
periods and/or use equipment that could create vibration impacts, such as the Stanford
University Medical Center or major grade separation projects, require a vibration impact
analysis, as well as formal, ongoing monitoring and reporting of noise levels throughout the
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
26
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
entire construction process, pertinent to industry standards. The monitoring plan should
identify hours of operation and could include information on the monitoring locations,
durations and regularity, the instrumentation to be used and appropriate noise control
measures to ensure compliance with the noise ordinance.
The incorporation of this policy and program into the proposed Plan limits construction noise
around sensitive receptors, requires monitoring and reporting plans for construction noise of
larger development projects, and requires noise control measures, reducing temporary or
periodic increases to ambient noise levels to less-than-significant levels.
Resulting Significance: Less than Significant
Impact NOISE-11: Implementation of the proposed Plan, in combination with past, present, and
reasonably foreseeable projects, may result in significant cumulative impacts with respect to
noise.
Mitigation Measure NOISE-11a: Implement Mitigation Measure NOISE-1c.
Mitigation Measure NOISE-11b: To address overall community noise impacts from train noise
to the extent such noise is within the City’s control and in excess of established State and/or City
standards, the proposed Plan shall include policies that achieve the following:
Efforts to develop and implement technological methods to reduce train whistle noise from
Caltrain.
Evaluation of at-grade rail crossings as potential Quiet Zones based on Federal Railroad
Administration (FRA) rules and guidelines.
Grade separation of rail crossings as a City priority.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies and programs that would collectively
implement this mitigation measure during the course of development proposals and capital
improvement projects. For example:
Policy T-3.15: Pursue grade separation of rail crossings along the rail corridor as a City
priority.
Policy N-6.13: Minimize noise spillover from rail related activities into adjacent residential or
noise-sensitive areas.
Program N6.13.1: Encourage the Peninsula Corridors Joint Powers Board to pursue
technologies and grade separations that would reduce or eliminate the need for train
horns/whistles in communities served by rail service.
Program N6.13.2: Evaluate changing at-grade rail crossings so that they qualify as Quiet
Zones based on Federal Railroad Administration (FRA) rules and guidelines in order to
mitigate the effects of train horn noise without adversely affecting safety at railroad
crossings.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
27
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
The incorporation of these policies and programs into the proposed Plan ensures the City’s
focus on methods to reduce train whistle noise from Caltrain, evaluation of at-grade crossings as
potential Quiet Zones, and the prioritization of grade separation. In addition, Mitigation
Measure NOISE-1c would address new sources of noise in existing residential areas.
Implementation of Mitigation Measures NOISE-1c and NOISE-11b would minimize the
possibility for community-wide ambient noise increases due to cumulative sources to the extent
feasible. After implementation of the new policies and mitigation measures, impacts from
cumulative noise increases would be considered less than significant.
Resulting Significance: Less than Significant
Public Services
Impact PS-7: Implementation of the proposed Plan would result in an adverse physical impact
from the construction of additional parks and recreation facilities in order to maintain
acceptable performance standards.
Mitigation Measure PS-7: To address the potential physical impacts of park
construction/improvement, the Comprehensive Plan Update shall include policies that achieve
the following:
Evaluation and mitigation of the construction impacts associated with park and recreational
facility creation and expansion.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes the following policy that ensures
implementation of this mitigation measure during the course of development proposals and
capital improvement projects:
Policy N-1.13: Evaluate and mitigate the construction impacts associated with park and
recreational facility creation and expansion.
The incorporation of this policy into the proposed Plan requires evaluation and mitigation of
construction impacts associated with the creation or expansion of park and recreational
facilities. Facility construction projects developed consistent with this policy would avoid
adverse physical impacts to the extent feasible.
Resulting Significance: Less than Significant
Impact PS-8: Implementation of the proposed Plan would have the potential to result in
substantial cumulative adverse physical impacts associated with the provision of new or
physically altered parks and recreational facilities, need for new or physically altered parks
and recreation facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios or other performance objectives.
Mitigation Measure PS-8: Implement Mitigation Measure PS-7.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
28
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Implementation of Mitigation Measure PS-7 would ensure that facility
construction projects developed consistent with referenced policies would avoid adverse
physical impacts to the extent feasible. Therefore, the creation of new parkland would not
contribute to potential significant cumulative impacts associated with new park construction.
Resulting Significance: Less than Significant
Transportation
Impact TRANS-1: Implementation of the project would cause an intersection to drop below its
motor vehicle level of service standard, or deteriorate operations at representative
intersections that already operate at a substandard level of service.
Mitigation Measure TRANS-1a: Adopt a programmatic approach to reducing motor vehicle
traffic, with the goal of achieving no net increase in peak-hour motor vehicle trips from new
development, with an exception for uses that directly contribute to the neighborhood character
and diversity of Palo Alto (such as ground-floor retail and below-market-rate housing). The
program should, at a minimum, require new development projects above a specific size
threshold to prepare and implement a Transportation Demand Management (TDM) Plan to
achieve the following reduction in peak-hour motor vehicle trips from the rates included in the
Institute of Transportation Engineers’ Trip Generation Manual for the appropriate land use
category and size. These reductions are deemed aggressive, yet feasible, for the districts
indicated.
45 percent reduction in the Downtown district
35 percent reduction in the California Avenue area
30 percent reduction in the Stanford Research Park
30 percent reduction in the El Camino Real Corridor
20 percent reduction in other areas of the city
TDM Plans must be approved by the City and monitored by the property owner or the project
proponent on an annual basis. The Plans must contain enforcement mechanisms or penalties
that accrue if targets are not met and may achieve reductions by contributing to citywide or
employment district shuttles or other proven transportation programs that are not directly
under the property owner’s control.
Mitigation Measure TRANS-1b: Require new development projects to pay a Transportation
Impact Fee for all those peak-hour motor vehicle trips that cannot be reduced via TDM
measures. Fees collected would be used for capital improvements aimed at reducing motor
vehicle trips and motor vehicle traffic congestion.
Mitigation Measure TRANS-1c: The proposed Plan shall include policies to ensure collaboration
with regional agencies and neighboring jurisdictions, and identification and pursuit of funding
for rail corridor improvements and grade separation. Policies shall support grade separation of
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
29
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
rail crossings along the rail corridor as a City priority, and the undertaking of studies and
outreach necessary to advance grade separation of Caltrain to become a “shovel ready” project.
Mitigation Measure TRANS-1d: Consistent with State requirements, the City shall adopt a
Multimodal Improvement Plan to address impacts to Congestion Management Program
facilities. In addition, the proposed Plan shall include policies to engage in regional
transportation planning and advocate for specific transit improvements and investments, such
as Caltrain service enhancements and grade separations, Dumbarton Express service, enhanced
bus service on El Camino Real with queue-jump lanes and curbside platforms, high-occupancy
vehicle (HOV)/high-occupancy toll (HOT) lanes, and additional VTA bus service.
Mitigation Measure TRANS-1e: The proposed Plan shall include policies to encourage the
PAUSD to analyze decisions regarding school assignments to reduce peak-period motor vehicle
trips to and from school sites.
Finding: Palo Alto is located in a dynamic region with a transportation network that is often
quite congested. In this context, even small changes over time can contribute to significant
traffic congestion. Changes or alterations have been required in, or incorporated into, the
proposed project, which avoid or substantially lessen the significant environmental effect
identified in the EIR, but not to a level of less than significant. There are no additional feasible
mitigation measures and no feasible alternatives that avoid this significant effect, as further
addressed in Section III, Findings Concerning Alternatives.
Rationale for Finding: The proposed Plan includes policies and programs that collectively
support implementation of this mitigation measure during the course of the City’s review of
development proposals and capital improvement projects. For example:
Program T1.2.2: Formalize TDM requirements by ordinance and require new developments
above a certain size threshold to prepare and implement a TDM Plan to meet specific
performance standards. Require regular monitoring/reporting and provide for enforcement
with meaningful penalties for noncompliance. The ordinance should also:
Establish a list of effective TDM measures that include transit promotion, prepaid transit
passes, commuter checks, car sharing, carpooling, parking cash-out, bicycle lockers and
showers, shuttles to Caltrain, requiring TMA membership and education and outreach to
support the use of these modes.
Allow property owners to achieve reductions by contributing to citywide or employment
district shuttles or other proven transportation programs that are not directly under the
property owner’s control.
Provide a system for incorporating alternative measures as new ideas for TDM are
developed.
Establish a mechanism to monitor the success of TDM measures and track the
cumulative reduction of peak hour motor vehicle trips. TDM measures should at a
minimum achieve the following reduction in peak hour motor vehicle trips, with a focus
on single-occupant vehicle trips. Reductions should be based on the rates included in
the Institute of Transportation Engineers’ Trip Generation Manual for the appropriate
land use category:
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
30
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
- 50 percent reduction in the Downtown district
- 35 percent reduction in the California Avenue area
- 30 percent reduction in the Stanford Research Park
- 30 percent reduction in the El Camino Real Corridor
- 20 percent reduction in other areas of the city
Require new development projects to pay a Transportation Impact Fee for all those peak-
hour motor vehicle trips that cannot be reduced via TDM measures. Fees collected would
be used for capital improvements aimed at reducing vehicle trips and traffic congestion.
Policy T-2.6: Work with PAUSD to ensure that decisions regarding school assignments are
analyzed to reduce peak period motor vehicle trips to and from school sites.
Policy T-3.15: Pursue grade separation of rail crossings along the rail corridor as a City
priority.
Program T3.15.1: Undertake studies and outreach necessary to advance grade separation of
Caltrain to become a “shovel ready” project and strongly advocate for adequate State,
regional and federal funding for design and construction of railroad grade separations.
Policy T-8.1: Engage in regional transportation planning and advocate for specific transit
improvements and investments, such as Caltrain service enhancements and grade
separations, Dumbarton Express service, enhanced bus service on El Camino Real with
queue jumping and curbside platforms, HOV/HOT lanes and additional VTA bus service.
Policy T-8.2: Participate in regional planning initiatives for the rail corridor and provide a
strong guiding voice.
Implementation of the TDM measures and other measures to reduce driving under Mitigation
Measures TRANS-1a through TRANS-1e would result in a lower auto mode share, higher
number of transit trips, lower VMT, and lower VMT per capita compared to pre-mitigation
conditions. However, affected intersections are operating close to or below LOS standards under
existing conditions, so even small increases in traffic at these intersections would trigger
impacts.
Under Mitigation Measure TRANS-1d, the City will prepare and adopt a Multimodal
Improvement Plan to address impacts to Congestion Management Program (CMP) facilities. The
EIR identifies significant impacts at three intersections included in the County’s CMP: El Camino
Real (State Route 82) at San Antonio Road (in Mountain View) (referred to as Intersection #8 in
the EIR analysis), Foothill Expressway/Junipero Serra Boulevard at Page Mill Road (Intersection
#9), and Foothill Expressway at Arastradero Road (Intersection #10). VTA’s Congestion
Management Agency (CMA) guidelines state that, “Deficiency plans should be prepared by the
Member Agency in which the deficient CMP System facility or set of facilities is located.”
Multimodal Improvement Plan requirements will be met for these three intersections as
follows:
Intersection #8 (El Camino Real at San Antonio Road) is located in Mountain View and Los
Altos. Therefore, planning for the intersection is not under the jurisdiction of the City of Palo
Alto. The City of Mountain View is currently drafting a Multimodal Improvement Plan that
includes this intersection and can and should adopt the Multimodal Improvement Plan when it
is complete. As required by VTA, acting as the Congestion Management Agency (“CMA”), the
City of Palo Alto will participate in development of this Multimodal Improvement Plan.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
31
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Intersection #9 (Foothill Expressway/Junipero Serra Boulevard at Page Mill Road) is located
within the city but is under the County’s jurisdiction. This intersection was grandfathered in with
an automobile LOS of F in 1991. Freeway segments and congestion management program
(CMP) intersections that operated at LOS F when monitoring began in 1991 are considered
exempt from meeting the CMP standard. Therefore, it is exempt from the requirement to
prepare a Multimodal Improvement Plan.
Intersection #10 (Foothill Expressway at Arastradero Road) is located within the city but is
under the County’s jurisdiction. The City of Palo Alto will be adopting a new Transportation
Nexus Study and Transportation Impact Fee shortly after adoption of the Comprehensive Plan
Update and the certification of the Comprehensive Plan Update EIR. This nexus study, and
impact fee calculation, will address the City’s share of a full grade-separation at this
intersection. Preliminary designs and cost estimates for this grade-separation project have been
developed by the Santa Clara County Department of Roads and Airports. With the construction
of this project, this intersection should operate at an acceptable level of service, and no longer
require the development of a Multimodal Improvement Plan.
All of the above traffic mitigation measures would reduce, but not eliminate, Impact TRANS-1.
Resulting Significance: Significant and Unavoidable
Impact TRANS-3: Implementation of the project would cause a freeway segment or ramp to
drop below its level of service standard, or deteriorate operations that already operate at a
substandard level of service.
Mitigation Measure TRANS-3a: The City shall require new development projects to prepare and
implement TDM programs, as described in TRANS-1a. TDM programs for worksites may include
measures such as private bus services and free shuttle services to transit stations geared
towards commuters.
Mitigation Measure TRANS-3b: The proposed Comprehensive Plan shall include policies that
advocate for efforts by Caltrans and the Valley Transportation Authority to reduce congestion
and improve traffic flow on existing freeway facilities consistent with Statewide GHG emissions
reduction initiatives.
Policies shall support the application of emerging freeway information, monitoring, and control
systems that provide non-intrusive driver assistance and reduce congestion.
Policies shall support, where appropriate, the conversion of existing traffic lanes to exclusive bus
and high-occupancy vehicle (HOV)/high-occupancy toll (HOT) lanes on freeways and
expressways, including the Dumbarton Bridge, and the continuation of an HOV lane from
Redwood City to San Francisco.
Finding: Palo Alto is located in a dynamic region with a transportation network that is often
quite congested. In this context, even small changes over time can contribute to significant
traffic congestion. Changes or alterations have been required in, or incorporated into, the
proposed project, which avoid or substantially lessen the significant environmental effect
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
32
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
identified in the EIR, but not to a level of less than significant. There are no additional feasible
mitigation measures and no feasible alternatives that avoid this significant effect, as further
addressed in Section III, Findings Concerning Alternatives.
Rationale for Finding: The proposed Plan includes policies that collectively ensure
implementation of this mitigation measure during the course of development proposals and
capital improvement projects. For example:
Policy T-8.6: Advocate for efforts by Caltrans and the Valley Transportation Authority to
reduce congestion and improve traffic flow on existing freeway facilities consistent with
Statewide GHG emissions reduction initiatives.
Policy T-8.7: Support the application of emerging freeway information, monitoring and
control systems that provide non-intrusive driver assistance and reduce congestion.
Policy T-8.8: Where appropriate, support the conversion of existing traffic lanes to exclusive
bus and HOV lanes or Express/HOT lanes on freeways and expressways, including the
Dumbarton Bridge, and the continuation of an HOV lane from Redwood City to San
Francisco.
The TDM measures called for in Mitigation Measures TRANS-1a and TRANS-3b, which include a
TDM mitigation program and other measures, would reduce but not eliminate the impacts on
freeway segments.
Resulting Significance: Significant and Unavoidable
Impact TRANS-6: Implementation of the project would impede the operation of a transit
system as a result of congestion.
Mitigation Measure TRANS-6: The proposed Comprehensive Plan shall include policies to
collaborate with transit agencies in planning for and implementing convenient, efficient,
coordinated, and effective bus service.
Finding: Palo Alto is located in a dynamic region with a transportation network that is often
quite congested. In this context, even small changes over time can contribute to significant
traffic congestion. Changes or alterations have been required in, or incorporated into, the
proposed project, which avoid or substantially lessen the significant environmental effect
identified in the EIR, but not to a level of less than significant. There are no additional feasible
mitigation measures and no feasible alternatives that avoid this significant effect, as further
addressed in Section III, Findings Concerning Alternatives.
Rationale for Finding: The proposed Plan includes the following policy that ensures
implementation of this mitigation measure:
Policy T-1.12: Collaborate with transit agencies in planning and implementing convenient,
efficient, coordinated and effective bus service in Palo Alto that addresses the needs of all
segments of our population.
The incorporation of this policy into the proposed Plan ensures that the City would pursue
methods to give priority to buses and transit facilities. Even with implementation of Mitigation
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
33
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Measure TRANS-6, congestion at all intersections and on all roadway segments where buses
operate would not be eliminated.
Resulting Significance: Significant and Unavoidable
Impact TRANS-8: Implementation of the project would create the potential demand for
through traffic to use local residential streets.
Mitigation Measure TRANS-8: The proposed Comprehensive Plan shall include policies to
identify specific improvements that can be used to discourage drivers from using local,
neighborhood streets to bypass traffic congestion on arterials.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes the following policy that ensures
implementation of this mitigation measure:
Policy T-4.3: Identify specific improvements that can be used to discourage drivers from
using local, neighborhood streets to bypass traffic congestion on arterials.
Implementation of Mitigation Measure TRANS-8 would ensure that the City pursues
improvements to reduce the use of local streets as bypass routes to avoid congestion on
arterials. The EIR notes that implementation of traffic calming is highly site-specific, depending
on the physical characteristics of the street, the circulation pattern of a neighborhood, and
whether the residents support specific measures, among many other factors. It is not possible
at the Comprehensive Plan level to determine where traffic calming measures would be
appropriate or feasible or which specific measures should be implemented along a given
roadway or at a given intersection.
Resulting Significance: Less than Significant
Impact TRANS-9: Implementation of the project would create an operational safety hazard.
Mitigation Measure TRANS-9: Implement Mitigation Measure TRANS-8.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: Under Mitigation Measure TRANS-8, the City would pursue
improvements to reduce the use of local streets as bypass routes to avoid congestion on
arterials. Implementation of this mitigation measure would ensure that safety hazards
associated with through traffic are reduced to a less-than-significant level.
Resulting Significance: Less than Significant
Utilities
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
34
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Impact UTIL-15: Without the adoption of policies to promote recycling and conservation, the
proposed Plan could potentially fall out of compliance with federal, State, and local statutes
and regulations related to solid waste.
Mitigation Measure UTIL-15: To ensure that future development would comply with applicable
solid waste regulations, the proposed Plan shall include policies that achieve the following:
Ninety-five percent landfill diversion by 2030, and ultimately zero waste.
Reduced solid waste generation.
Use of reusable, returnable, recyclable, and repairable goods, through enforcement of the
2016 Plastic Foam Ordinance expansion.
Enhanced recycling and composting programs for all waste generators.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies that collectively support
implementation of this mitigation measure. For example:
Policy S-3.8: Strive for 95 percent landfill diversion by 2030, and ultimately zero waste, by
enhancing policies and programs for waste reduction, recycling, composting and reuse.
Policy S-3.9: Reduce solid waste generation through requiring salvage and reuse of building
materials, including architecturally and historically significant materials.
Policy S-3.11: Encourage the use of reusable, returnable, recyclable and repairable goods,
and discourage the use of single use plastic water bottles and extended polystyrene
(Styrofoam), through enforcement of the City’s 2016 Plastic Foam Ordinance expansion and
continued incentives, education and responsible City purchasing policies.
The incorporation of relevant policies into the proposed Plan ensures the City’s ongoing
commitment to recycling and conservation in compliance with federal, State, and local laws.
Implementation of Mitigation Measure UTIL-15 would ensure that the City complies with
applicable solid waste regulations.
Resulting Significance: Less than Significant
Impact UTIL-17: The proposed Plan would not result in a substantial increase in natural gas
and electrical service demands that would require the new construction of energy supply
facilities and distribution infrastructure or capacity enhancing alterations to existing facilities.
However, without the adoption of policies in support of energy efficiency and conservation,
the proposed Plan would result in a potentially significant impact, requiring mitigation.
Mitigation Measure UTIL-17: To ensure that future development would maximize energy
efficiency and conservation the proposed Plan shall include policies that achieve the following:
Maximized conservation and efficient use of energy.
Continued procurement of carbon-neutral energy.
Investment in cost-effective energy efficiency and energy conservation programs.
Provision of public education programs addressing energy conservation and efficiency.
Use of cost-effective energy conservation measures in City projects and practices.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
35
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Adherence to State and federal energy efficiency standards and policies.
Consideration of a transition to a carbon-neutral natural gas supply.
Finding: Changes or alterations have been required in, or incorporated into, the project, which
avoid or substantially lessen the significant environmental effect identified in the EIR.
Rationale for Finding: The proposed Plan includes policies and programs that collectively
support implementation of this mitigation measure. For example:
Policy N-7.1: Continue to procure carbon neutral energy for both long-term and short-term
energy supplies, including renewable and hydroelectric resources, while investing in cost-
effective energy efficiency and energy conservation programs.
Policy N-7.4: Maximize the conservation and efficient use of energy in new and existing
residences and other buildings in Palo Alto.
Program N7.4.1: Continue timely incorporation of State and federal energy efficiency
standards and policies in relevant City codes, regulations and procedures and higher local
efficiency standards that are cost-effective.
Program N7.4.3: Incorporate cost-effective energy conservation measures into construction,
maintenance and City operation and procurement practices.
Program N7.4.5: Continue to provide public education programs addressing energy
conservation and efficiency.
Program N7.7.1: Evaluate the potential for a cost-effective plan for transitioning to a
completely carbon-neutral natural gas supply.
Policy N-7.8: Support opportunities to maximize energy recovery from organic materials
such as food scraps, yard trimmings and residual solids from sewage treatment.
Policy S-3.10: Continue to implement the City’s Environmentally Preferred Purchasing policy
and programs to reduce waste, toxic product use, resource consumption and to maximize
energy efficiency.
The incorporation of relevant policies and programs into the proposed Plan ensures that the
City will continue its ongoing commitment to energy efficiency and conservation.
Implementation of Mitigation Measure UTIL-17 would ensure that the City is engaging in
planning to reduce natural gas and electricity demands in order to reduce potential impacts
associated with the construction of energy supply facilities.
Resulting Significance: Less than Significant
III. FINDINGS CONCERNING ALTERNATIVES
Significant and Unavoidable Impacts
CEQA provides that decision-makers should not approve a project as proposed if there are
feasible alternatives or feasible mitigation measures that would substantially lessen the
significant impacts of the project (CEQA Section 21002). The EIR identified feasible mitigation
measures that would reduce several of the potentially significant impacts to less than
significant, as further set forth in the Section II findings above. However, the following impacts
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
36
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
in the EIR remain significant after mitigation (i.e., significant and unavoidable) and no feasible
mitigation or project alternative is identified to reduce impact to less than significant:
1. Impact AIR-2: Implementation of the proposed Plan could violate an air quality standard;
contribute substantially to an existing or project air quality violation; and/or result in a
cumulatively considerable net increase of any criteria pollutant for which the Project region
is nonattainment under an applicable federal or State ambient air quality standard
(including releasing emissions which exceed quantitative thresholds for ozone precursors).
2. Impact TRANS-1: Implementation of the project would cause an intersection to drop below
its motor vehicle level of service standard, or deteriorate operations at representative
intersections that already operate at a substandard level of service.
3. Impact TRANS-3: Implementation of the project would cause a freeway segment or ramp to
drop below its level of service standard, or deteriorate operations that already operate at a
substandard level of service.
4. Impact TRANS-6: Implementation of the project would impede the operation of a transit
system as a result of congestion.
All of these significant and unavoidable impacts arise from Palo Alto’s place within a growing
region where traffic increases are projected due to forces well beyond the City’s control.
Evaluations of virtually any long-range plan developed in this region would reach similar
conclusions using the thresholds of significance relied upon in the City’s environmental
documents. And even if the City does not update its Comprehensive Plan (as represented by
EIR Scenario 1), these impacts would remain significant and unavoidable after the City’s best
efforts at mitigation.
In compliance with CEQA, the following findings address whether there are any feasible
alternatives or any additional feasible mitigation measures available that would reduce the
significant and unavoidable impacts identified in the EIR for the proposed project to less than
significant.
Project Alternatives
CEQA requires that an EIR "describe a range of reasonable alternatives to the project, or to the
location of the project, which would feasibly attain most of the basic objectives of the project
..." (CEQA Guidelines Section 15126.6(a)). “If a project alternative will substantially lessen the
significant environmental effects of a proposed project, the decision-maker should not approve
the proposed project unless it determines that specific economic, legal, social, technological, or
other considerations, ... make the project alternative infeasible.” (CEQA Sections 21002 and
21081(a)(3), and CEQA Guidelines Section 15091(a)(3).) The City Council hereby makes these
findings with respect to alternatives. The project objectives are set forth in Chapter 3 of the
Supplement to the Draft EIR.
As explained in Chapter 2 of the Final EIR and referenced sections of the February 2016 Draft
EIR and the Supplement to the Draft EIR, the City has assessed a “range of reasonable
alternatives” throughout the environmental document, in the form of four planning scenarios
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
37
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
(in the Draft EIR), two additional planning scenarios (in the Supplement to the Draft EIR), and a
hybrid “preferred scenario” (in the Final EIR).
In addition, Chapter 6 of the February 2016 Draft EIR and Supplement to the Draft EIR discuss a
“No Growth Scenario” and an “Environmentally Superior Alternative,” and both the Draft EIR
and the Supplement to the Draft EIR discuss alternatives considered and rejected, with an
explanation as to why certain concepts were not carried forward for detailed analysis.
As further set forth below, the City Council has considered all of the possible alternatives
(including the planning scenarios) identified and analyzed in EIR and has elected to adopt the
preferred scenario described in Chapter 2 of the Final EIR. None of the other scenarios and
alternatives would eliminate the significant impacts identified above, and the City finds that
doing so would be infeasible for specific economic, social, or other considerations pursuant to
CEQA Sections 21002 and 21081(a)(3), and CEQA Guidelines Section 15091(a)(3). For CEQA
purposes, “feasible” means capable of being accomplished in a successful manner within a
reasonable period of time, taking into account economic, environmental, social, technological,
and legal factors. (CEQA Section 21061.1, CEQA Guidelines Section 15364.)
1. No Project Alternative (Scenario 1)
CEQA Guidelines Section 15126.6(e) requires that a "No Project Alternative" be evaluated as
part of an EIR. Scenario 1 represents a “Business as Usual” scenario that approximates what is
expected to occur if the 1998 Comprehensive Plan is not updated and the proposed Plan is not
adopted. Thus Scenario 1 represents the “no project alternative” required by CEQA Guidelines
Section 15126.6(e).
Scenario 1 would be expected to result in less residential development than the preferred
scenario, but would result in a higher increase in employment than the preferred scenario. As
shown in Table 1-3 of the Supplement to the Draft EIR, Scenario 1 would not avoid any of the
significant and unavoidable impacts identified for the scenarios. Scenario 1 would also not
include any of the policy adjustments included in the June 30, 2017 Draft of the Comprehensive
Plan Update, new innovations in housing or new approaches to address the high cost of housing
or high jobs-to-employed-residents balance in the city. Under Scenario 1, the Comprehensive
Plan would also not be updated to include new policies related to climate change,
transportation demand management (TDM), and transit-oriented development. Without
policies to address these key issues, Scenario 1 would not fully achieve the City’s objectives to
updates the vision for Palo Alto’s future to reflect current conditions and anticipated trends.
Finding: The City Council considered a No Project Alterative and declines to adopt it because it
does not reduce the project’s significant and unavoidable impacts and is inconsistent with
several of the project objectives including:
Provide a legally adequate Comprehensive Plan that updates the vision for Palo Alto’s future
to reflect current conditions and anticipated trends.
Establish performance standards to ensure that future development contributes to and does
not detract from Palo Alto’s quality of life.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
38
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Identify needed roadway improvements to address congestion related to future
development.
Enable resiliency and adaptation to respond to the consequences of climate change.
Support Palo Alto’s leadership in relationships with neighboring jurisdictions and State and
regional agencies.
A comprehensive plan is intended to be an integrated, internally consistent and compatible
statement of city policies. State law requires that comprehensive plans be periodically reviewed
and revised as necessary (Government Code Sections 65040.5, 65300, 65300.5). Retaining the
current comprehensive plan, last comprehensively updated in 1998, without an update to
reflect changes in the City’s vision for its development and preservation would not be consistent
with State planning law. For all of these reasons, this alternative is infeasible, as supported by
the administrative record for the proposed project.
2. No Growth Scenario
Appendix H of the Supplement to the Draft EIR provides a discussion and analysis of a “No
Growth Scenario,” conducted as a purely hypothetical exercise to highlight the extent to which
the proposed Plan’s significant and unavoidable impacts result from regional growth outside of
Palo Alto. The No Growth Scenario analysis assumes that the proposed Plan is not adopted and
that no growth in population, employment, or square footage would occur in Palo Alto by 2030
beyond the amount of development existing in 2014, plus new growth permitted by fall 2016.
Although the No Growth Scenario would result in less development than the preferred scenario,
as discussed in Appendix H of the Supplement to the Draft EIR, the No Growth Scenario would
not avoid any of the significant and unavoidable impacts identified for the project. This
illustrates that, even if Palo Alto were to put measures in place to halt future growth entirely,
the surrounding region would continue to grow, and as a result many of the impacts identified
in the EIR would still occur.
The No Growth Scenario is purely hypothetical and would not include strategies to address
housing needs, climate change goals, or TDM strategies. Therefore, the No Growth Scenario
would not meet the project objectives. Moreover, it is infeasible to implement, as it would be
impractical and/or illegal for the City to prevent existing residents from adding to their
households or families, and stopping residential growth would violate State housing laws that
require local governments to participate in “accommodat[ing] the housing needs of Californians
of all economic levels” (California Government Code Section 65580 et seq.). In terms of job
growth, while the City could conceivably prevent development of additional non-residential
square footage, it would be very difficult to stop employers from adding new employees to
existing buildings, and such a moratorium would create intense demand for office space in Palo
Alto, increasing commercial rents and creating pressure for non-residential uses such as
retail/service business and lower-rent office uses to convert to high-rent, tech-based office and
research and development (R&D) uses.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
39
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Finding: The City Council considered the No Growth Scenario and declines to adopt it because it
is infeasible, does not reduce the project’s significant and unavoidable impacts, and is
inconsistent with several of the project objectives, including:
Provide a legally adequate Comprehensive Plan that updates the vision for Palo Alto’s future
to reflect current conditions and anticipated trends.
Guide future land use and development decisions and assist staff and decision-makers in
balancing sometimes competing interests.
Address the needs of a changing population and accommodate additional housing.
Establish performance standards to ensure that future development contributes to and does
not detract from Palo Alto’s quality of life.
Reduce the impacts of cars on the environment and improve options for pedestrians,
bicyclists, and transit-users.
Preserve existing single-family neighborhoods while allowing the development of diverse
types of housing affordable to all members of the community.
Identify needed roadway improvements to address congestion related to future
development.
Enable resiliency and adaptation to respond to the consequences of climate change.
Enable the City to deliver top-quality community services to all residents.
Retain existing businesses, maintain vital commercial areas, and attract quality new
businesses.
Support Palo Alto’s leadership in relationships with neighboring jurisdictions and State and
regional agencies.
For all of these reasons, this alternative is infeasible, as supported by the administrative record
for the proposed project.
3. Hybrid Alternative
Chapter 6 of the February 2016 Draft EIR and Supplement to the Draft EIR provide a discussion
of a “Hybrid Alternative.” The discussion of the Hybrid Alternative explains that the scenario
adopted by the City as the Comprehensive Plan Update would not be expected to be identical
to any of the scenarios analyzed in the February 2016 Draft EIR and Supplement to the Draft
EIR, but would rather draw from the scenarios and combine components of various scenarios.
The discussion also explains that the Hybrid Alternative would be developed based, in part, on
the data and analysis that the February 2016 Draft EIR and Supplement to the Draft EIR provide.
Based on the EIR’s conclusions, the Supplement to the Draft EIR states that a Hybrid Alternative
would likely be one that combines the moderate rates of housing growth in Scenarios 3 and 5
with the sustainability initiatives tested in Scenarios 4 through 6. The Supplement to the Draft
EIR did not predict the number of jobs that would be included in the Hybrid Alternative, but did
explain that a lower level of job growth, such as under Scenario 5, would result in fewer GHG
emissions.
Overall, the Hybrid Alternative would have impacts similar to those of Scenarios 1 through 6.
Aesthetics, land use, and population/housing impacts would be similar to Scenarios 3 and 5 if
housing sites along San Antonio and South El Camino are eliminated and replaced by higher
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
40
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
densities on existing sites closer to transit and services, and if growth control measures are
similar to those adopted by the City Council on an interim basis in 2015. The Hybrid Alternative
would also have similar less-than-significant impacts to Scenario 2, 3, or 5 in the topic areas of
biological resources, cultural resources, geology, hazardous materials, hydrology, public services,
and utilities. The Hybrid Alternative could further reduce the transportation, air quality, noise,
and greenhouse gas emission impacts associated with Scenario 3 by incorporating some of the
sustainability features included in Scenarios 4 through 6 to reduce traffic and vehicle miles
traveled.
Although, as with Scenarios 1 through 6, proposed mitigation measures could address some of
the Hybrid Alternative’s impacts related to transportation, air quality, and noise, some impacts
related to transportation and air quality, although reduced, would remain significant even after
mitigation measures are applied. The Hybrid Alternative contemplates lower levels of job
growth than the preferred scenario, but it also includes lower rates of housing growth than the
preferred scenario, so the Hybrid Alternative would be expected to result in a higher jobs-to-
employed-residents ratio than the preferred scenario, and therefore would not meet the City’s
goals to reduce this ratio.
Finding: The City Council considered the Hybrid Alternative and declines to adopt it because it
does not reduce the project’s significant and unavoidable impacts and it does not promote as
well as the preferred scenario the City’s policy goals and objectives of accommodating
anticipated housing growth and improving the City’s jobs to housing (employed resident)
imbalance, all as supported by the administrative record for the proposed project.
4. Planning Scenarios 2 Through 6
Scenarios 2 through 6 in the Draft EIR and the Supplement to the Draft EIR are part of the
reasonable range of alternatives the City has considered because they present different ways
that the City could plan for its future and vary in terms of the housing and employment
projected to occur by the horizon year of 2030. The preferred scenario that has been selected
for adoption shares many characteristics with these other planning scenarios, and was
developed by the City Council based on extensive community input and deliberations. As
described in Chapter 2 of the Final EIR, the preferred scenario is essentially a hybrid of the
other Scenarios, and represents the evolution of a long public planning process.
There are not substantial differences in the number or extent of environmental impacts among
the scenarios evaluated in the February 2016 Draft EIR and Supplement to the Draft EIR. While
the majority of potential impacts could be mitigated to a less-than-significant level, all of the
scenarios would result in the same significant and unavoidable impacts to air quality and
transportation, and the preferred scenario would result in the same significant and unavoidable
impacts. However, there are differences of degree among the scenarios, as described below.
A. Scenario 2
Although similar to the preferred scenario, Scenario 2 would result in slightly lower motor
vehicle trips than the preferred scenario. Scenario 2 would also result in a lower level of
population and jobs growth. Therefore, Scenario 2 would result in lower greenhouse gas and air
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
41
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
quality emissions than the preferred scenario. However, Scenario 2 would result in a greater
jobs/housing imbalance than the preferred scenario and would not meet the City’s goal to
expand housing options as well as the preferred scenario.
B. Scenario 3
Scenario 3 would result in more motor vehicle trips than the preferred scenario. Scenario 3
would result in a level of population growth equal to the lower end of the preferred scenario,
and a higher level of job growth. Therefore, Scenario 3 would result in higher levels of
greenhouse gas and air quality emissions than the preferred scenario. Overall, Scenario 3 would
result in a greater jobs/housing imbalance than the preferred scenario and would not meet the
City’s sustainability goals as well as the preferred scenario.
C. Scenario 4
Scenario 4 would result in lower motor vehicle trips than the preferred scenario. Scenario 4
would result in a level of population growth equal to the higher end of the preferred scenario,
and a higher level of job growth. Overall, due to its lower motor vehicle trips, Scenario 4 would
be expected to result in lower greenhouse gas and air quality emissions than the preferred
scenario. However, Scenario 4 would result in a greater jobs/housing imbalance than the
preferred scenario, which would conflict with City goals.
D. Scenario 5
Scenario 5 would result in the fewest motor vehicle trips of all the scenarios (including the
preferred scenario). Scenario 5 would result in a level of population growth equal to the lower
end of the preferred scenario, and less jobs growth than the preferred scenario. Overall,
Scenario 5 would result in a similar jobs/housing balance as the preferred scenario (slightly
higher than the preferred scenario within the city but lower within the city plus Sphere of
Influence). In addition, Scenario 5 would include the sustainability measures of Scenarios 4 and
6. Overall, due to its lower motor vehicle trips, lower overall growth, and similar jobs/housing
balance, Scenario 5 would be expected to result in lower greenhouse gas and air quality
emissions than the preferred scenario. By combining the rigorous sustainability initiatives of
Scenarios 4 and 6 with the modest housing growth of Scenario 3 and low job growth of Scenario
6, Scenario 5 would be the environmentally preferred scenario. However, Scenario 5 would not
meet the City’s goals to expand housing options.
E. Scenario 6
Scenario 6 would result in lower motor vehicle trips than the preferred scenario. Scenario 6
would result in more population growth and less jobs growth than the preferred scenario and
would achieve the lowest jobs-to-employed-residents ratio of all the scenarios (including the
preferred scenario). In addition, Scenario 6 would include the sustainability measures of
Scenarios 4 and 5. Overall, due to its lower motor vehicle trips and jobs/housing balance,
Scenario 6 would be expected to result in lower greenhouse gas and air quality emissions than
the preferred scenario. Scenario 6 would have the highest population growth of any scenario,
exceeding regional projections and resulting in the greatest demand for schools, parkland, and
services provided to residents. As a result, Scenario 6 would not meet the project objective
regarding service delivery as well as the preferred scenario.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
42
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
Finding: The City Council considered Scenarios 2 through 6 and declines to adopt any of these
scenarios. Scenario 3 would not reduce the project’s significant and unavoidable impacts.
Scenarios 2, 4, 5, and 6 would somewhat lessen, but would not avoid, the project’s significant
and unavoidable impacts, but are less responsive to the project objectives than the preferred
scenario, particularly to the objective to address the needs of a changing population,
accommodating additional housing, and enabling delivery of top-quality community services to
all residents.
IV. STATEMENT OF OVERRIDING CONSIDERATIONS
The City Council of the City of Palo Alto adopts and makes the following Statement of
Overriding Considerations regarding the significant, unavoidable impacts of the Project and the
anticipated benefits of the Project.
General. The City is considering approval of the Comprehensive Plan Update 2030 (“proposed
project”).
CEQA requires decision-makers to balance the economic, legal, social, technological or other
benefits of a proposed project against its unavoidable impacts when determining whether to
approve the project. If the specific benefits of a project outweigh the unavoidable adverse
environmental effects, those effects may be considered acceptable, and the agency must state
the specific reasons to support the action in a “statement of overriding considerations”
supported by substantial evidence in the record. (CEQA Guidelines Section 15903). Pursuant
to CEQA Guidelines Section 15093, the City Council must adopt a Statement of Overriding
Considerations for the significant and unavoidable impacts of the project in connection with
approval of the project. The City Council believes that many of the unavoidable environmental
effects identified in the EIR will be substantially lessened by mitigation measures adopted with
the EIR and implemented with future development and actions taken under the project. Even
with mitigation, the City Council recognizes that the implementation of the project carries
with it significant and unavoidable environmental effects, as identified in the EIR.
Adoption of the June 30, 2017 Draft of the Comprehensive Plan Update 2030, with the specific
changes included in the City Council’s resolution, would result in the following significant and
unavoidable impacts:
5. Impact AIR-2: Implementation of the proposed Plan could violate an air quality standard;
contribute substantially to an existing or project air quality violation; and/or result in a
cumulatively considerable net increase of any criteria pollutant for which the Project region
is nonattainment under an applicable federal or State ambient air quality standard
(including releasing emissions which exceed quantitative thresholds for ozone precursors).
6. Impact TRANS-1: Implementation of the project would cause an intersection to drop below
its motor vehicle level of service standard, or deteriorate operations at representative
intersections that already operate at a substandard level of service.
7. Impact TRANS-3: Implementation of the project would cause a freeway segment or ramp to
drop below its level of service standard, or deteriorate operations that already operate at a
substandard level of service.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
43
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
8. Impact TRANS-6: Implementation of the project would impede the operation of a transit
system as a result of congestion.
Overriding Considerations
The City Council has carefully considered each significant unavoidable project impact in
reaching its decision to approve the project. Even with mitigation, the City Council recognizes
that implementation of the project carries with it unavoidable adverse environmental effects,
as identified in the EIR. The City Council specifically finds that, to the extent that the identified
significant adverse impacts for the project have not been reduced to acceptable levels through
feasible mitigation or alternatives, there are specific economic, legal, social, technological, or
other benefits, including region-wide or statewide environmental benefits that outweigh the
project’s significant unavoidable impacts and support approval of the project. Any one of these
benefits as set forth below is sufficient to justify approval of the project. The substantial
evidence supporting the various benefits is in the record as a whole.
The following statement identifies the reasons why, in the City’s judgment, specific benefits of
the project outweigh the significant and unavoidable effects. The City finds that each of the
project benefits discussed below is a separate and independent basis for these findings. The
reasons set forth below are based on the Final EIR and other information in the administrative
record.
Economic Benefits
1. The proposed Plan strengthens strategies to preserve retail.
2. The proposed Plan includes a cumulative “cap” on the amount of new office/research and
development (R&D) space that would allow up to 1.7 million square feet of new office/R&D
uses over the life of the plan.
3. The proposed Plan allows the City to remain a competitive and innovative business
destination.
Legal Benefits
1. The proposed Plan updates sections of the City’s Comprehensive Plan that are required by
State law, and the State recommends that local jurisdictions update their plans every
10 years.
Social Benefits
1. The proposed Plan was developed to reflect community priorities and concerns, with
extensive input from the general public, a Citizens Advisory Committee, the Planning and
Transportation Commission, and the City Council.
2. The proposed Plan responds to community concerns about housing affordability and
availability.
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
44
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
3. The proposed Plan would allow a balance of development that would help to reduce the
City’s jobs/housing imbalance.
4. The proposed Plan would preserve existing parks, recreational facilities, and open space
areas.
5. The proposed Plan would protect and preserve existing residential neighborhoods.
Technological Benefits
1. The proposed Plan supports Caltrain modernization, including electrification.
Environmental Benefits
1. The proposed Plan updates the City’s policy framework to address important contemporary
environmental issues, including as climate change and greenhouse gas emissions.
2. The proposed Plan includes a program to formalize transportation demand management
(TDM) requirements.
3. The proposed Plan would protect and enhance the urban forest as natural infrastructure.
4. The proposed Plan concentrates growth in existing corridors and nodes, and thereby results
in fewer impacts from the construction of new infrastructure and reduces vehicle miles
traveled per capita, which translates into air quality and greenhouse gas emissions benefits
and increases in resources and energy efficiency.
5. The proposed Plan includes policies that encourage conservation of water and energy
resources in conformance with the City’s sustainability goals.
V. MITIGATION MONITORING AND REPORTING PROGRAM
Attached to this Resolution as Exhibit A and incorporated and adopted as part of this
Resolution herein is the Mitigation Monitoring and Reporting Program (“MMRP”) for the
Project required under Public Resources Code Section 21081.6. The MMRP identifies impacts
of the Project, corresponding mitigation, timing for implementation, and designation for
responsibility for mitigation implementation and monitoring.
//
//
//
//
//
//
//
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
45
171128 SL/PCE PLANNING/COMP PLAN 2017/RESO ADOPTING MMRP
VI. LOCATION AND CUSTODIAN OF RECORDS
The documents and other materials that constitute the record of proceedings on which the City
Council based the foregoing findings and approval of the Project are located at the Department
of Planning and Community Environment, 285 Hamilton Avenue, Palo Alto, CA 94301. The
official custodian of the record is the Planning and Community Environment Director at the
same address.
INTRODUCED AND PASSED: November 13, 2017
AYES: FINE, KNISS, SCHARFF, TANAKA, WOLBACH
NOES: DUBOIS, FILSETH, HOLMAN, KOU
ABSENT:
ABSTENTIONS:
ATTEST: APPROVED:
______________________________ _________________________________
City Clerk Mayor
APPROVED AS TO FORM:
_________________________________
City Manager
_______________________________
Assistant City Attorney
_________________________________
Director of Planning and Community
Environment
DocuSign Envelope ID: FC1D7519-2530-42F5-9EBE-3B6D0199951F
PLACEWORKS 1
Mitigation Monitoring and Reporting Program
This Mitigation Monitoring and Reporting Program (MMRP) for the City of Palo Alto is intended to ensure
the implementation of mitigation measures identified as part of the environmental review for the proposed
project. The proposed project is the adoption and implementation of an updated Comprehensive Plan for
the City of Palo Alto, along with associated amendments to the City of Palo Alto Zoning Code. The MMRP
includes the following information:
A list of mitigation measures.
The timing for implementation of each mitigation measure.
The agency responsible for monitoring implementation.
The monitoring action and frequency.
The City of Palo Alto must adopt this MMRP, or an equally effective program, if it adopts the City of Palo
Alto Comprehensive Plan Update and associated Zoning Code amendments with the mitigation measures
that were adopted or made conditions of project adoption.
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
2 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Aesthetics and Visual
Resources
AES-1: Implementation of
the proposed Plan would
have the potential to
substantially degrade the
existing visual character or
quality of the area and its
surroundings.
AES-1: To ensure that increased residential densities
would not degrade the visual character or quality of
the area, the proposed Plan shall include policies
that achieve the following:
High-quality building and site design.
Compatibility with the neighborhood and
adjacent structures.
Enhancement of existing commercial centers.
Requirements for landscaping and street trees.
Preservation and creation of a safe and inviting
pedestrian environment.
Appropriate building form, massing, and setbacks.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
Planning and
Community
Environment
(PCE)
Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
AES-4: Implementation of
the proposed Plan would
have the potential to
substantially shadow public
open space (other than
public open streets and
adjacent sidewalks) between
9:00 a.m. and 3:00 p.m.
from September 21 to
March 21.
AES-4: The City shall amend its local CEQA guidelines
to require development projects of a certain size or
location to prepare an analysis of potential
shade/shadow impacts. The analysis shall focus on
potential impacts to public open spaces (other than
public streets and adjacent sidewalks) between 9:00
a.m. and 3:00 p.m. from September 21 to March 21.
The analysis shall identify whether the project would
shadow open spaces during these times, explain how
the project meets City design requirements and
other City policy goals, and describe ways to mitigate
substantial shade and shadow impacts through
feasible building and site design features.
City of Palo Alto
PCE Department
Within twelve
months of
proposed
Comprehensive
Plan adoption
City of Palo Alto
PCE Department
Confirm update of CEQA
guidelines.
Once
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 3
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Air Quality
AIR-1: Without inclusion of
air quality policies,
implementation of the
proposed Plan could conflict
with or obstruct
implementation of the
applicable air quality plan.
AIR-1: To ensure consistency with the 2010 Bay Area
Clean Air Plan, the proposed Plan shall include
policies that achieve the following:
Reduction in emissions of particulates from
automobiles, manufacturing, construction
activity, and other sources (e.g., dry cleaning,
wood burning, landscape maintenance).
Support for regional, State, and federal programs
that improve air quality.
Support for transit, bicycling, and walking.
Mix of uses (e.g., housing near employment
centers) and development types (e.g., infill) to
reduce the need to drive.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
AIR-2: Implementation of
the proposed Plan could
violate an air quality
standard; contribute
substantially to an existing
or project air quality
violation; and/or result in a
cumulatively considerable
net increase of any criteria
pollutant for which the
Project region is
nonattainment under an
applicable federal or State
ambient air quality standard
(including releasing
emissions which exceed
quantitative thresholds for
ozone precursors).
AIR-2a: The City shall amend its local CEQA
Guidelines and Municipal Code to require, as part of
the City’s development approval process, that future
development projects comply with the current
BAAQMD basic control measures for reducing
construction emissions of PM10 (Table 8-2, Basic
Construction Mitigation Measures Recommended
for All Proposed Projects, of the BAAQMD CEQA
Guidelines).
City of Palo Alto
PCE Department
Within twelve
months of
proposed
Comprehensive
Plan adoption
City of Palo Alto
PCE Department
Confirm update of CEQA
guidelines and Municipal Code.
Once
AIR-2b: The City shall amend its local CEQA
Guidelines to require that, prior to issuance of
construction permits, development project
City of Palo Alto
PCE Department
Within twelve
months of
proposed
City of Palo Alto
PCE Department
Confirm update of CEQA
guidelines.
Once
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
4 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
applicants that are subject to CEQA and have the
potential to exceed the BAAQMD screening-criteria
listed in the BAAQMD CEQA Guidelines prepare and
submit to the City of Palo Alto a technical
assessment evaluating potential project
construction-related air quality impacts. The
evaluation shall be prepared in conformance with
BAAQMD methodology in assessing air quality
impacts. If construction-related criteria air pollutants
are determined to have the potential to exceed the
BAAQMD thresholds of significance, as identified in
the BAAQMD CEQA Guidelines, the City of Palo Alto
shall require that applicants for new development
projects incorporate mitigation measures (Table 8-3,
Additional Construction Mitigation Measures
Recommended for Projects with Construction
Emissions Above the Threshold, of the BAAQMD
CEQA Guidelines or applicable construction
mitigation measures subsequently approved by
BAAQMD) to reduce air pollutant emissions during
construction activities to below these thresholds.
These identified measures shall be incorporated into
all appropriate construction documents (e.g.,
construction management plans) submitted to the
City.
Comprehensive
Plan adoption
AIR-2c: To ensure that development projects that
have the potential to exceed the BAAQMD screening
criteria air pollutants listed in the BAAQMD CEQA
Guidelines reduce regional air pollutant emissions
below the BAAQMD thresholds of significance, the
proposed Plan shall include policies that require
compliance with BAAQMD requirements, including
BAAQMD CEQA Guidelines.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
AIR-2d: Implement Mitigation Measures TRANS-1a
and TRANS-1b. In addition, to reduce long-term air
quality impacts by emphasizing walkable
neighborhoods and supporting alternative modes of
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 5
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
transportation, the proposed Plan shall include
policies that achieve the following:
Enhanced pedestrian and bicycle connections
between commercial and mixed-use centers.
AIR-3: Implementation of
the proposed Plan would
expose sensitive receptors
to substantial
concentrations of air
pollution.
AIR-3a: The City of Palo Alto shall update its CEQA
Procedures to require that future non-residential
projects within the city that: 1) have the potential to
generate 100 or more diesel truck trips per day or
have 40 or more trucks with operating diesel-
powered TRUs, and 2) are within 1,000 feet of a
sensitive land use (e.g., residential, schools,
hospitals, nursing homes), as measured from the
property line of a proposed project to the property
line of the nearest sensitive use, shall submit a
health risk assessment (HRA) to the City of Palo Alto
prior to future discretionary project approval or shall
comply with best practices recommended for
implementation by the BAAQMD.
The HRA shall be prepared in accordance with
policies and procedures of the State Office of
Environmental Health Hazard Assessment and the
Bay Area Air Quality Management District. If the HRA
shows that the incremental cancer risk exceeds the
BAAQMD significance thresholds, the applicant will
be required to identify and demonstrate that
mitigation measures are capable of reducing
potential cancer and noncancer risks to an
acceptable level, including appropriate enforcement
mechanisms.
Mitigation measures and best practices may include
but are not limited to:
Restricting idling on-site beyond Air Toxic Control
Measures idling restrictions, as feasible.
Electrifying warehousing docks.
Requiring use of newer equipment and/or
vehicles.
City of Palo Alto
PCE Department
Within twelve
months of Plan
adoption
City of Palo Alto
PCE Department
Confirm update of CEQA
Procedures.
Once
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
6 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Restricting off-site truck travel through the
creation of truck routes.
Mitigation measures identified in the project-specific
HRA shall be identified as mitigation measures in the
environmental document and/or incorporated into
the site development plan as a component of a
proposed project.
AIR-3b: To ensure that new industrial and
warehousing projects with the potential to generate
new stationary and mobile sources of air toxics that
exceed the BAAQMD project-level and/or cumulative
significance thresholds for toxic air contaminants
and PM2.5 listed in the BAAQMD CEQA Guidelines
reduce emissions below the BAAQMD thresholds of
significance, amend the City’s CEQA guidelines to
require compliance with BAAQMD requirements.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
AIR-3c: The proposed Plan shall include policies to
mitigate potential sources of toxic air contaminants
through siting or other means to reduce human
health risks and meet the Bay Area Air Quality
Management District’s applicable threshold of
significance. Policies shall also require that new
sensitive land use projects (e.g., residences, schools,
hospitals, nursing homes, parks or playgrounds, and
day care centers) within 1,000 feet of a major
stationary source of TACs and roadways with traffic
volumes over 10,000 vehicles per day consider
potential health risks and incorporate adequate
precautions, such as high-efficiency air filtration, into
project design.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies
continue to mitigate this impact.
Prior to
Comprehensive
Plan policy
amendments
AIR-4: Implementation of
the proposed Plan could
create or expose a
substantial number of
people to objectionable
odors unless policies are
AIR-4: To reduce odor impacts, the proposed Plan
shall include policies requiring:
Buffers, mechanical, and other mitigation
methods to avoid creating a nuisance.
Implementation is complete with the
adoption and implementation of the
policies and programs in the
proposed Comprehensive Plan
Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 7
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
integrated into the proposed
Plan.
Cultural Resources
CULT-1: Implementation of
the proposed Plan could
adversely affect a historic
resource listed or eligible for
listing on the National
and/or California Register, or
listed on the City’s Historic
Inventory.
CULT-1: To ensure the protection of potentially
historic resources, the proposed Plan shall include
policies that achieve the following:
Process for reviewing proposed demolition or
alteration of potentially historic buildings.
Protection of archaeological resources.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
CULT-2: Implementation of
the proposed Plan could
eliminate important
examples of major periods
of California history or
prehistory.
CULT-2: Implement Mitigation Measure CULT-1. See Mitigation Measure CULT-1.
CULT-3: Implementation of
the proposed Plan could
cause damage to an
important archaeological
resource as defined in
Section 15064.5 of the CEQA
Guidelines.
CULT-3: Implement Mitigation Measure CULT-1. In
addition, to ensure that future development would
not damage archaeological resources, the proposed
Plan shall include policies that achieve the following:
Archaeological surveys and mitigation plans for
future development projects.
Developer compliance with applicable regulations
regarding the identification and protection of
archaeological and paleontological deposits, and
unique geologic features.
Appropriate tribal consultation and consideration
of tribal concerns.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
CULT-5: Implementation of
the proposed Plan would
have the potential to directly
or indirectly destroy a
unique paleontological
resource or site or unique
CULT-5: Implement Mitigation Measure CULT-3.
See Mitigation Measure CULT-3.
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
8 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
geologic feature.
CULT-7: Implementation of
the proposed Plan, in
combination with past,
present, and reasonably
foreseeable projects, would
result in significant
cumulative impacts with
respect to cultural
resources.
CULT-7: Implement Mitigation Measures CULT-1 and
CULT-3.
See Mitigation Measures CULT-1 and CULT-3.
Greenhouse Gas Emissions and Climate Change
GHG-3: The proposed Plan
would expose people or
structures to the physical
effects of climate change,
including but not limited to
flooding, extreme
temperatures, public health,
wildfire risk, or other
impacts resulting from
climate change, requiring
mitigation.
GHG-3: To address the potential impacts associated
with exposing people to the effects of climate
change, the proposed Plan shall include policies that
achieve the following:
Monitoring and response to flooding risks caused
by climate change-related changes to
precipitation patterns, groundwater levels, sea
level rise, tides, and storm surges.
Cooperative planning with federal, State,
regional, and local public agencies on issues
related to climate change (including sea level rise
and extreme storms).
Preparation of response strategies to address sea
level rise, increased flooding, landslides, soil
erosion, storm events, and other events related
to climate change.
Implementation of adaptive strategies to address
impacts of sea level rise on Palo Alto’s levee
system.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 9
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Hydrology and Water Quality
HYD-2: The proposed Plan
could substantially degrade
or deplete ground water
resources or interfere
substantially with
groundwater recharge such
that there would be a net
deficit in aquifer volume or a
lowering of the local
groundwater table level.
HYD-2: To reduce potential impacts associated with
construction dewatering the proposed Plan shall
include policies that achieve the following:
Avoidance of the impacts of basement
construction for single-family homes on the
natural environment and safety.
Conservation of subsurface water resources.
Construction techniques and recharge strategies
to reduce subsurface and surface water impacts.
Monitoring of dewatering and excavation
projects.
Cooperation with other jurisdictions and regional
agencies to protect groundwater.
Protection of groundwater as a natural resource.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
Land Use and Planning
LAND-1: The proposed Plan
could adversely change the
type or intensity of existing
or planned land use patterns
in the area.
LAND-1: To ensure that the intensity of future
development would not adversely change the land
use patterns or affect the livability of Palo Alto
neighborhoods, the proposed Plan shall include
policies that achieve the following:
Strengthening of residential neighborhoods.
Vitality of commercial areas and public facilities.
High-quality building and site design.
Architectural compatibility of new development.
Compatible infill development.
Avoidance of abrupt changes in the scale of
development where residential districts abut
more intense uses.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
LAND-2: The proposed Plan
would allow development
that could be incompatible
with adjacent land uses or
with the general character of
LAND-2: Implement Mitigation Measure LAND-1. In
addition, to further reduce potential impacts to
visual character and ensure compatibility with
adjacent land uses, the proposed Plan shall include
policies that achieve the following:
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
10 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
the surrounding area,
including density and
building height.
Use of City procedures, plans, and requirements
to ensure high-quality building design and
architectural compatibility.
LAND-5: The proposed Plan
could physically divide an
established community.
LAND-5: To avoid potential impacts from physically
dividing an established community, the proposed
Plan shall include policies that achieve the following:
Enhanced connections to and from parks, schools,
and community facilities for all users.
Safe and convenient pedestrian, bicycle, and
transit connections between residential areas and
commercial centers.
Cooperation with other agencies to improve
circulation connections.
Grade separation of rail crossings.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
Noise
NOISE-1: Implementation of
the proposed Plan would
have the potential to cause
the average 24-hour noise
level (Ldn) to increase by 5.0
decibels (dB) or more in an
existing residential area,
even if the Ldn would remain
below 60 dB.
NOISE-1a: To ensure that average 24-hour noise
levels associated with long-term operational noise
would not increase by 5.0 decibels (dB) or more in
an existing residential area, the proposed Plan shall
include policies that achieve the following:
Location of land uses in areas with compatible
noise environments.
Use of the guidelines in the “Land Use
Compatibility for Community Noise Environment”
table in the proposed Plan to evaluate the
compatibility of proposed land uses with existing
noise environments.
Clear guidelines for maximum outdoor noise
levels in residential areas.
Adherence to the interior noise requirements of
the State of California Building Standards Code
(Title 24) and the Noise Insulation Standards (Title
25).
Inclusion of a noise contour map in the proposed
Plan.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 11
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Reduction of noise impacts of development on
adjacent properties.
Evaluation of noise impacts on existing
residential, open space, and conservation land.
Requirement for new projects in the Multiple
Family, Commercial, Manufacturing, or Planned
Community districts to demonstrate compliance
with the Noise Ordinance.
NOISE-1b: To reduce potential impacts to new land
uses from aircraft noise, the proposed Plan shall
include policies that achieve the following:
Compliance with the airport-related land use
compatibility standards for community noise
environments.
Prohibition of incompatible land use development
within the 60 dBA CNEL noise contours of the
Palo Alto airport, as established in the adopted
County of Santa Clara Airport Land Use
Commission Comprehensive Land Use Plan
(CLUP) for the Palo Alto Airport.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
NOISE-1c: To reduce potential impacts to new land
uses from railway noise, the proposed Plan shall
include policies that achieve the following:
Minimization of noise spillover from rail-related
activities into adjacent residential or noise-
sensitive areas.
Building design that reduces impacts from noise
and ground borne vibrations associated with rail
operations.
Guidelines for interior noise levels.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
NOISE-2: Implementation of
the proposed Plan would
have the potential to cause
the Ldn to increase by 3 dB or
more in an existing
residential area, thereby
NOISE-2: Implement Mitigation Measures NOISE-1a,
NOISE-1b, and NOISE-1c.
See Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c.
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
12 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
causing the Ldn in the area to
exceed 60 dB.
NOISE-3: Implementation of
the proposed Plan would
have the potential to cause
an increase of 3 dB or more
in an existing residential
area where the Ldn currently
exceeds 60 dB.
NOISE-3: Implement Mitigation Measures NOISE-1a,
NOISE-1b, and NOISE-1c.
See Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c.
NOISE-4: Implementation of
the proposed Plan would
have the potential to result
in indoor noise levels for
residential development to
exceed an Ldn of 45 dB.
NOISE-4a: Implement Mitigation Measure NOISE-1a. See Mitigation Measure NOISE-1a.
NOISE-4b: The Land Use Noise Compatibility
Guidelines established in the 1998 Comprehensive
Plan shall be maintained.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
NOISE-5: Implementation of
the proposed Plan would
have the potential to expose
persons to or generate
excessive ground-borne
vibration or ground-borne
noise levels.
NOISE-5a: To ensure that future development would
not result in significant construction-related
vibration impacts, the proposed Plan shall include
policies that limit the hours of construction around
sensitive receptors, and require formal, ongoing
monitoring and reporting throughout the
construction process for larger development
projects, as well as the use of pertinent industry
standards and City guidelines to avoid significant
vibration impacts during construction or operations.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
NOISE-5b: Implement Mitigation Measure NOISE-1c. See Mitigation Measure NOISE-1c.
NOISE-6: Implementation of
the proposed Plan would
have the potential to expose
people to noise levels in
excess of established State
standards.
NOISE-6: Implement Mitigation Measures NOISE-4a
and NOISE-4b.
See Mitigation Measures NOISE-4a and NOISE-4b.
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 13
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
NOISE-7: Implementation of
the proposed Plan would
have the potential to result
in the exposure of persons
to or generation of noise
levels in excess of standards
established in the local
General Plan or noise
ordinance, or applicable
standards of other agencies.
NOISE-7: Implement Mitigation Measures NOISE-1a,
NOISE-1b, NOISE-1c, NOISE-4a, and NOISE-4b.
See Mitigation Measures NOISE-1a, NOISE-1b, NOISE-1c, NOISE-4a, and NOISE-4b.
NOISE-8: Implementation of
the proposed Plan could
result in a potentially
substantial temporary or
periodic increase in ambient
noise levels in the project
vicinity above levels existing
without the project.
NOISE-8: To ensure that future development would
not result in significant impacts to sensitive
receptors from construction noise, the proposed
Plan shall include policies that achieve the following:
Construction noise limits around sensitive
receptors.
Monitoring and reporting plans for construction
noise levels of larger development projects.
Noise control measures to ensure compliance
with the noise ordinance.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
NOISE-11: Implementation
of the proposed Plan, in
combination with past,
present, and reasonably
foreseeable projects, may
result in significant
cumulative impacts with
respect to noise.
NOISE-11a: Implement Mitigation Measure NOISE-
1c.
See Mitigation Measure NOISE-1c.
NOISE-11b: To address overall community noise
impacts from train noise to the extent such noise is
within the City’s control and in excess of established
State and/or City standards, the proposed Plan shall
include policies that achieve the following:
Efforts to develop and implement technological
methods to reduce train whistle noise from
Caltrain.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
14 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Evaluation of at-grade rail crossings as potential
Quiet Zones based on Federal Railroad
Administration (FRA) rules and guidelines.
Grade separation of rail crossings as a City
priority.
Public Services and
Recreation
PS-7: Implementation of the
proposed Plan would result
in an adverse physical
impact from the
construction of additional
parks and recreation
facilities in order to maintain
acceptable performance
standards.
PS-7: To address the potential physical impacts of
park construction/improvement, the Comprehensive
Plan Update shall include policies that achieve the
following:
Evaluation and mitigation of the construction
impacts associated with park and recreational
facility creation and expansion.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
PS-8: Implementation of the
proposed Plan would have
the potential to result in
substantial cumulative
adverse physical impacts
associated with the
provision of new or
physically altered parks and
recreational facilities, need
for new or physically altered
parks and recreation
facilities, the construction of
which could cause significant
environmental impacts, in
order to maintain acceptable
service ratios or other
performance objectives.
PS-8: Implement Mitigation Measure PS-7. See Mitigation Measure PS-7.
Transportation and Traffic
TRANS-1: Implementation of TRANS-1a: Adopt a programmatic approach to City of Palo Alto Within six City of Palo Alto Confirm program adoption. Once
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 15
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
the project would cause an
intersection to drop below
its motor vehicle level of
service standard, or
deteriorate operations at
representative intersections
that already operate at a
substandard level of service.
reducing motor vehicle traffic, with the goal of
achieving no net increase in peak-hour motor vehicle
trips from new development, with an exception for
uses that directly contribute to the neighborhood
character and diversity of Palo Alto (such as ground-
floor retail and below-market-rate housing). The
program should, at a minimum, require new
development projects above a specific size threshold
to prepare and implement a Transportation Demand
Management (TDM) Plan to achieve the following
reduction in peak-hour motor vehicle trips from the
rates included in the Institute of Transportation
Engineers’ Trip Generation Manual for the
appropriate land use category and size. These
reductions are deemed aggressive, yet feasible, for
the districts indicated.
45 percent reduction in the Downtown district
35 percent reduction in the California Avenue
area
30 percent reduction in the Stanford Research
Park
30 percent reduction in the El Camino Real
Corridor
20 percent reduction in other areas of the city
TDM Plans must be approved by the City and
monitored by the property owner or the project
proponent on an annual basis. The Plans must
contain enforcement mechanisms or penalties that
accrue if targets are not met and may achieve
reductions by contributing to citywide or
employment district shuttles or other proven
transportation programs that are not directly under
the property owner’s control.
PCE Department,
Transportation
Division
(responsible for
program
adoption)
months of
proposed
Comprehensive
Plan adoption
PCE Department
Project
applicants
(responsible for
TDM plans)
Prepare TDM
Plan, if required,
prior to issuance
of occupancy
permits.
City of Palo Alto
PCE Department
Property owner
or project
proponent
Review and approve TDM Plans.
Monitor enforcement of TDM
Plans consistent with Palo Alto
Municipal Code Section
18.34.040(d)(4)
Once
Annually
TRANS-1b: Require new development projects to pay
a Transportation Impact Fee for all those peak-hour
City of Palo Alto
PCE Department
Ongoing
City of Palo Alto
PCE Department
Verify collection of fees. Ongoing
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
16 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
motor vehicle trips that cannot be reduced via TDM
measures. Fees collected would be used for capital
improvements aimed at reducing motor vehicle trips
and motor vehicle traffic congestion.
TRANS-1c: The proposed Plan shall include policies
to ensure collaboration with regional agencies and
neighboring jurisdictions, and identification and
pursuit of funding for rail corridor improvements and
grade separation. Policies shall support grade
separation of rail crossings along the rail corridor as
a City priority, and the undertaking of studies and
outreach necessary to advance grade separation of
Caltrain to become a “shovel ready” project.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
TRANS-1d: Consistent with State requirements, the
City shall adopt a Multimodal Improvement Plan to
address impacts to Congestion Management
Program facilities. In addition, the proposed Plan
shall include policies to engage in regional
transportation planning and advocate for specific
transit improvements and investments, such as
Caltrain service enhancements and grade
separations, Dumbarton Express service, enhanced
bus service on El Camino Real with queue-jump lanes
and curbside platforms, high-occupancy vehicle
(HOV)/high-occupancy toll (HOT) lanes, and
additional VTA bus service.
City of Palo Alto
PCE Department,
Transportation
Division
(responsible for
Multimodal
Improvement
Plan)
See “Monitoring
Action” notes
regarding
Multimodal
Improvement
Plans.
City of Palo Alto
PCE Department
Three CMP intersections would
be affected by this impact.
Intersection #8 (El Camino Real
at San Antonio Road) is located in
Mountain View and Los Altos.
The City of Mountain View is
currently drafting a Multimodal
Improvement Plan that includes
this intersection. The City of Palo
Alto shall participate in
development of this Multimodal
Improvement Plan. The other
two intersections will not require
Multimodal Improvement Plans.
Intersection #9 (Foothill
Expressway/Junipero Serra
Boulevard at Page Mill Road) is
grandfathered in with an
automobile LOS of F and is
therefore exempt from meeting
the CMP standard. For
Intersection #10 (Foothill
Expressway at Arastradero Road),
the City shall make a fair share
Ongoing
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 17
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
contribution toward a full grade
separation project. With the
construction of the grade-
separation project, this
intersection should operate at an
acceptable level of service, and
no longer require the
development of a Multimodal
Improvement Plan. The City shall
monitor the progress of the
grade separation project and
confirm with the County and VTA
that no Multimodal Improvement
Plan is required following its
completion.
Policy implementation is complete
with the adoption and
implementation of the policies in the
proposed Comprehensive Plan
Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
TRANS-1e: The proposed Plan shall include policies
to encourage the PAUSD to analyze decisions
regarding school assignments to reduce peak-period
motor vehicle trips to and from school sites.
City of Palo Alto
PCE Department
Ongoing, as part
of regular
collaboration and
communication
with the Palo
Alto Unified
School District
City of Palo Alto
PCE Department
Confirm communication. Ongoing
TRANS-3: Implementation of
the project would cause a
freeway segment or ramp to
drop below its level of
service standard, or
deteriorate operations that
already operate at a
substandard level of service.
TRANS-3a: The City shall require new development
projects to prepare and implement TDM programs,
as described in TRANS-1a. TDM programs for
worksites may include measures such as private bus
services and free shuttle services to transit stations
geared towards commuters.
See Mitigation Measure TRANS-1a.
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
18 AUGUST 2017
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
TRANS-3b: The proposed Comprehensive Plan shall
include policies that advocate for efforts by Caltrans
and the Valley Transportation Authority to reduce
congestion and improve traffic flow on existing
freeway facilities consistent with Statewide GHG
emissions reduction initiatives.
Policies shall support the application of emerging
freeway information, monitoring, and control
systems that provide non-intrusive driver assistance
and reduce congestion.
Policies shall support, where appropriate, the
conversion of existing traffic lanes to exclusive bus
and high-occupancy vehicle (HOV)/high-occupancy
toll (HOT) lanes on freeways and expressways,
including the Dumbarton Bridge, and the
continuation of an HOV lane from Redwood City to
San Francisco.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
TRANS-6: Implementation of
the project would impede
the operation of a transit
system as a result of
congestion.
TRANS-6: The proposed Comprehensive Plan shall
include policies collaborate with transit agencies in
planning for and implementing convenient, efficient,
coordinated, and effective bus service.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
TRANS-8: Implementation of
the project would create the
potential demand for
through traffic to use local
residential streets.
TRANS-8: The proposed Comprehensive Plan shall
include policies to identify specific improvements
that can be used to discourage drivers from using
local, neighborhood streets to bypass traffic
congestion on arterials.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
TRANS-9: Implementation of
the project would create an
operational safety hazard.
TRANS-9: Implement Mitigation Measure TRANS-8. See Mitigation Measure TRANS-8.
Utilities and Service Systems
UTIL-15: Without the
adoption of policies to
promote recycling and
conservation, the proposed
UTIL-15: To ensure that future development would
comply with applicable solid waste regulations, the
proposed Plan shall include policies that achieve the
following:
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments
COMPREHENSIVE PLAN UPDATE FINAL EIR
CITY OF PALO ALTO
MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 19
Environmental Impact Mitigation Measure
Implementation
Responsibility
Implementation
Timing
Monitoring
Responsibility Monitoring Action
Monitoring
Frequency
Plan could potentially fall
out of compliance with
federal, State, and local
statutes and regulations
related to solid waste.
Ninety-five percent landfill diversion by 2030, and
ultimately zero waste.
Reduced solid waste generation.
Use of reusable, returnable, recyclable, and
repairable goods, through enforcement of the
2016 Plastic Foam Ordinance expansion.
Enhanced recycling and composting programs for
all waste generators.
UTIL-17: The proposed Plan
would not result in a
substantial increase in
natural gas and electrical
service demands that would
require the new
construction of energy
supply facilities and
distribution infrastructure or
capacity enhancing
alterations to existing
facilities. However, without
the adoption of policies in
support of energy efficiency
and conservation, the
proposed Plan would result
in a potentially significant
impact, requiring mitigation.
UTIL-17: To ensure that future development would
maximize energy efficiency and conservation the
proposed Plan shall include policies that achieve the
following:
Maximized conservation and efficient use of
energy.
Continued procurement of carbon-neutral
energy.
Investment in cost-effective energy efficiency and
energy conservation programs.
Provision of public education programs
addressing energy conservation and efficiency.
Use of cost-effective energy conservation
measures in City projects and practices.
Adherence to State and federal energy efficiency
standards and policies.
Consideration of a transition to a carbon-neutral
natural gas supply.
Implementation is complete with the
adoption and implementation of the
policies in the proposed
Comprehensive Plan Update.
City of Palo Alto
PCE Department
Review future Comprehensive
Plan policy amendments to
ensure that relevant policies are
not removed or weakened.
Prior to
Comprehensive
Plan policy
amendments