HomeMy WebLinkAboutStaff Report 8106
City of Palo Alto (ID # 8106)
City Council Staff Report
Report Type: Action Items Meeting Date: 10/23/2017
City of Palo Alto Page 1
Summary Title: Comprehensive Plan EIR Certification and Plan Adoption
Title: Discussion and Consideration of the Planning & Transportation
Commission's Recommendations Regarding the Comprehensive Plan Update
and Adoption of Resolutions Certifying the Final Environmental Impact
Report (EIR) for the Comprehensive Plan Update; Adopting Findings Pursuant
to the California Environmental Quality Act (CEQA), and Adopting the
Updated Comprehensive Plan Dated June 30, 2017 With Desired Corrections
and Amendments, Which Comprehensively Updates and Supersedes the
City's 1998-2010 Comprehensive Plan (Two Public Hearings Will Be Held:
October 23, 2017 and November 13, 2017. On October 23, 2017, the City
Council May Consider Action on the Planning & Transportation Commission’s
Recommendations, Providing Direction to Staff, and Certification of the Final
EIR. Other Actions will be Deferred until the Hearing on November 13,
2017.)
From: City Manager
Lead Department: Planning and Community Environment
Recommendation
Staff recommends that the City Council take the following actions:
1. Receive and consider the Planning & Transportation Commission (PTC) report and
recommendations regarding the Comprehensive Plan Update (Attachment A) and adopt
a motion thanking the PTC and identifying specific changes to the June 30, 2017
Comprehensive Plan Update desired as a result of the Commission’s work;
2. Adopt a resolution (Attachment B) certifying that the Council has reviewed and
considered the Comprehensive Plan Update Final Environmental Impact Report (EIR)
dated August 30, 2017, the Final EIR has been completed in compliance with the
California Environmental Quality Act (CEQA), and the Final EIR reflects the independent
judgment and analysis of the City of Palo Alto;
3. Adopt a resolution (Attachment C) making required CEQA findings, including adoption of
City of Palo Alto Page 2
mitigation measures, findings related to alternatives, findings of overriding
considerations, and a mitigation monitoring and reporting program (MMRP);
4. Adopt a resolution (Attachment D) adopting the updated Comprehensive Plan dated
June 30, 2017 with the specific additional corrections and changes included in
Attachment E, comprehensively updating and superseding the 1998-2010
Comprehensive Plan in its entirety, preserving the Housing Element adopted in 2014;
5. Direct Staff to prepare and disseminate electronic and paper copies of the updated
Comprehensive Plan with appropriate formatting, illustrations, and acknowledgements;
and
6. Direct staff to return to Council for another review of the implementation chapter of the
Comprehensive Plan in 2018 and in the interim, prioritize the following implementing
actions to bring forward to Council on future agendas in the near term:
A. Adoption of an Updated Transportation Impact Fee Ordinance;
B. Adoption of Comprehensive Plan Implementing Ordinance #1 amending Title 18
(Zoning Ordinance) of the Municipal Code to support the production of new
housing and the preservation of existing units;
C. Initiation of a Coordinated Area Plan for the North Ventura area (also referred to
as the Fry’s site); and
D. Initiation of discussions with Stanford University about the potential for
developing housing in the Stanford Research Park, Stanford Shopping Center,
and Stanford University Medical Center vicinity.
Note: This is the first of two hearings planned for consideration of these recommendations.
This evening, staff requests that the Council act on the first two items (PTC Report and EIR
certification) and specify any changes or additions requested to the list of corrections and
changes in Attachment E. The second hearing for plan adoption is currently scheduled for
November 13, 2017.
The August 30, 2017 Final EIR is available at: http://www.paloaltocompplan.org/eir/ and the
June 30, 2017 the Comprehensive Plan Update is available at:
http://www.paloaltocompplan.org/wpcontent/uploads/2017/07/PACompPlan_June30_PTC_we
breduced.pdf. Hard copies of both documents are also available for review at the Planning
Department and at local libraries. The Planning Department is located on the 5th floor of City
Hall at 250 Hamilton Avenue in Palo Alto.
Executive Summary
The City has been working on a comprehensive update to its general plan, the Palo Alto 1998-
2010 Comprehensive Plan, for many years and the City Council will have an opportunity to
complete this effort at tonight’s meeting and a second meeting currently scheduled for
November 13, 2017.
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Overall, the CAC and the Council have crafted a Comprehensive Plan Update that seeks to
preserve the vision and values of the current Comprehensive Plan, while updating its goals,
policies, and programs to reflect the world of today. The updates are aimed at:
Land Use & Community Design
stimulating housing through a host of implementation programs, supplementing policies
and programs in the City’s Housing Element;
making the non-residential development cap apply citywide and focusing it on
office/R&D development only so square footage converted from another use like
warehouse or retail to office/R&D development will count against the cap;
preserving ground floor retail and limiting the displacement of existing retail;
ensuring regular coordination with Palo Alto Unified School District regarding land use
and development;
recognizing and incorporating the goals of other recent planning efforts, such as the
Urban Forest Master Plan and the Parks, Trails, Open Space and Recreation Master Plan;
guiding operation and improvements at the Palo Alto Airport, which was transitioned
from the County to the City in recent years;
Transportation
reducing reliance on single occupant vehicles (SOV), making alternatives to the
automobile more convenient, and addressing the needs of transit-dependent
communities;
establishing specific quantitative goals for trip reduction from new development
prioritizing Caltrain grade separations;
recognizing the State-mandated transition from Level of Service (LOS) to Vehicle Miles
Travelled (VMT)as a methodology for analyzing traffic impacts under CEQA, while
preserving LOS as a methodology for ensuring Comprehensive Plan consistency;
Natural Environment
establishing a new focus on connected ecosystems, consistent with the Parks, Trails,
Open Space and Recreation Master Plan;
recognizing open space, the urban forest, and a healthy natural environment as
contributors to public health;
seeking opportunities for adding open space, including connections between Skyline
Ridge and San Francisco Bay;
addressing climate changes and climate adaption;
ensuring resilient supply and management of water in Palo Alto, including additional
policies to protect groundwater as a resource and to respond to drought;
encouraging energy efficiency, energy conservation, and renewable energy sources;
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Safety
updating policies on natural and man-made threats and hazards, with a focus on
preparedness;
expanding policies on community safety and emergency management;
Community Services & Facilities
perpetuating policies about new and existing parks and public open spaces;
adding new policies and programs specifically tailored to the needs of youth and of
seniors;
sustaining the health and well-being of residents, consistent with the Council’s Heathy
Cities, Healthy Communities resolution;
Business and Economics
promoting a comprehensive approach to fiscal sustainability;
supporting the small local-serving businesses, start-ups, non-profit organizations, and
professional services that make up Palo Alto’s business diversity.
The updated Comprehensive Plan will serve as the City’s “constitution,” with policies that will
inform development and implementation of land use regulations and infrastructure
investments for many years to come. The updated Plan also contains implementation programs
that are intended to advance the goals and policies of the Plan, and that may be reexamined
and reprioritized by the City Council on a regular basis.
Tonight, the City Council will first consider a report and recommendations from the PTC
(Attachment A), as well as a draft resolution that would certify the Final EIR (Attachment B).
Staff is also requesting that the City Council identify any final changes it would like to
incorporate into the June 30, 2017 version of the Draft Plan. This document incorporates City
Council comments and adjustments to the Citizens Advisory Committee’s (CAC’s) work
products. Changes recommended by the PTC to this draft are shown in Table 2 and 3 in this
report which are also included in Attachment A. An errata or list of corrections and
clarifications developed by staff since the June 30th version was published has been provided In
Attachment E.
At the November 13th meeting, staff will be asking the City Council to consider and adopt
required CEQA findings (including a “statement of overriding considerations” and a mitigation
monitoring and reporting program), and adopt the Comprehensive Plan Update with the
desired changes and adjustments specified this evening. Staff will also be asking for direction
to prepare and disseminate electronic and paper copies of the plan, as well as direction to
return to Council for an in depth discussion of the Implementation Chapter and to identify a
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handful of near term implementation priorities.
Background
The City’s current Comprehensive Plan, Embracing the New Century, Palo Alto 1998-2010
Comprehensive Plan, was adopted in 1998 and sets goals, policies, and programs related to
land use and development issues, including transportation, housing, natural resource,
community services, and safety.
The proposed Comprehensive Plan Update contains chapters or “elements” that address topics
required by State law, as well as optional elements and topics. This relationship is shown in
Table 1. The Plan includes a total of seven Elements; two are optional. All of these draft
elements are based on the existing Comprehensive Plan, revised to reflect the City Council’s
direction regarding vision and goals, as well as input from the PTC’s proposed revisions and
public input. The elements included in the June 30, 2017 draft Comprehensive Plan Update are
the product of hundreds of hours of work by the Council, the PTC, the Citizens Advisory
Committee (CAC), CAC subcommittees, staff, and consultants.
Table 1. State-Mandated and Palo Alto Comprehensive Plan Elements
State-Mandated Element Comprehensive Plan Element
Land Use Land Use & Community Design
Circulation Transportation
Housing Housing (adopted 2014 – not part of PTC review)
Open Space
Conservation
Noise
Natural Environment
Safety Safety
Optional Elements
Business & Economics
Community Services & Facilities
Note: The previous Safety Element Goals, Policies and programs were part of the 1998 Natural
Environment Element. The Comprehensive Plan also includes Governance and Implementation
chapters, as well as an introduction and glossary.
Source: Planning & Community Environment, September 2017
The City Council recognized the need to update the Plan and initiated the update in 2006. The
PTC then spent close to six years working on the Comprehensive Plan Update (from 2008 to
2014), ultimately sending its recommendation to the City Council in April of 2014. Upon
receipt of the PTC’s recommendations, the City Council adopted a schedule and strategy for
“reframing” the long-running update to include expanded community engagement and a full
evaluation of alternatives, cumulative impacts and mitigation strategies. A community-wide
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Summit was attended by over 350 people in May 2015, and was followed by creation of the
CAC to engage in further community dialog and inform the Council’s deliberations.
Between July 2015 and May 2017, the full CAC met 23 times to review elements of the
existing Comprehensive Plan, review recommendations advanced by the PTC, and receive and
review community input. The CAC also formed subcommittees to discuss each Element, as
well as a Sustainability subcommittee that considered sustainability-related issues in several
Elements. There were a total of 29 meetings of CAC subcommittees. All CAC meetings were
noticed and open to the public and included time for public comment. The CAC forwarded its
recommended draft Comprehensive Plan Update to the Council on May 16, 2017. All meeting
materials and minutes from CAC meetings are available here:
http://www.paloaltocompplan.org/cac/citizens-advisory-committee/
In addition, the City Council met independently to review elements of the existing
Comprehensive Plan, review recommendations advanced by the PTC and the CAC, and receive
and review community input. The City Council discussed the Comp Plan goals and vision
statements, EIR scenarios, and draft Elements at 24 meetings since 2010. City Council
agendas, staff reports, and other relevant materials for Comp Plan discussion items are
available here: http://www.paloaltocompplan.org/city-council/
On June 12, 2017, the City Council referred the Comprehensive Plan Update Draft to the PTC for
review and a recommendation within 90 days. The draft Plan that was sent to the PTC (referred
to in this report as the “June 30, 2017 Draft Plan”) reflects the Citizens Advisory Committee’s
(CAC) May 16, 2017 recommendations to the Council and incorporates changes based on
Council’s review up to and including the Council meeting on June 12th. At the June 14, 2017
PTC meeting, the PTC passed a motion to focus its 90 day review on the Land Use and
Transportation Elements of the Comprehensive Plan Update. The PTC completed its review and
recommendations on these two Elements on September 27, 2017, within the 90 day period.
The Commission’s report and recommendations are in Attachment A.
The Comprehensive Plan Update cannot be adopted until the City complies with the California
Environmental Quality Act (CEQA), a State law requiring California agencies to identify the
significant environmental impacts of their actions and describe feasible measures that can be
taken to avoid or mitigate those impacts. Concurrent with the preparation of the
Comprehensive Plan Update, the City has prepared what is referred to as a “program-level” EIR
(CEQA Guidelines Section 15168), which assesses the potential cumulative impacts of
development that may occur during the life of the plan, considers potential alternatives, and
identifies mitigation measures that should be adopted to reduce or avoid significant impacts.
This is the same level of environmental analysis that was prepared for the existing 1998-2010
Palo Alto Comprehensive Plan.
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Discussion
With the requested actions, the City Council would accept and consider the PTC’s
recommendations, address CEQA requirements, and adopt a new general plan for the City of
Palo Alto. Once adopted, the plan would constitute a policy framework to guide decisions about
land use and development, transportation, and infrastructure for the next 13 to 15 years. Each
requested action is described briefly below, with a focus on any unresolved issues.
The Planning & Transportation Commission’s Report & Recommendations
At the beginning of July, the PTC was sent a bound copy of the June 30, 2017 draft of the Comp
Plan, which was used throughout the PTC’s review (available at:
http://www.paloaltocompplan.org/wpcontent/uploads/2017/07/PACompPlan_June30_PTC_w
ebreduced.pdf). At the outset of their review, the PTC decided to focus on the Land Use and
Transportation Elements.
The PTC met on July 12, 2017 for an orientation to the Comp Plan document and agreed on a
schedule for review of the Land Use and Transportation Elements. The July 12 PTC staff report
provided an overview of the Comprehensive Plan Update legal requirements and key issues in
the Land Use and Transportation Elements. This is a link to that report:
https://www.cityofpaloalto.org/civicax/filebank/documents/58650.
The objectives of the PTC review were:
To recommend needed high-level adjustments to policies and programs in the Land Use
Element, Transportation Element, and the Implementation Plan, to better address major
policy issues.
To identify any inconsistencies or redundancies between the elements for clarification
or elimination in order to make the document more useable for the PTC and the public.
Over the course of an additional five meetings in July, August, and September, the PTC
reviewed first the Transportation Element, then the Land Use Element, providing comments
and suggestions on background narrative, maps, goals, policies, and programs. After each
meeting, staff organized those comments, identified areas of consensus and returned at the
next PTC meeting with a synthesized list of comments for the commission’s review and further
discussion. At their fourth and fifth meetings, the PTC reviewed a compiled list of comments,
identified those comments that seemed most significant for further discussion, and engaged in
more in-depth discussion and debate on approximately 20 topics. The outcomes of this
discussion are relayed to the Council in Attachment A.
Table 2 lists the nine consensus comments that the Commissioners viewed as non-controversial
comments that had the overall consensus of the PTC. Seven of these general consensus
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comments are related to the Transportation Element. These transportation comments range
from adding more language about pedestrian safety to considering adding policies about High
Speed Rail. The two Land Use Element comments cover making sure the goals, policies and
programs are clear and actionable and placing more emphasis on creating neighborhoods, not
just building housing units.
Table 2: PTC GENERAL CONSENSUS COMMENTS
PTC COMMENT
1. Land Use Element Overall/General
The Element should place more emphasis on creating neighborhoods, not just
building housing units.
2. Land Use Element Overall/General
Goals, policies, and programs throughout should be clear and actionable, and the City
should be able to track progress toward achievement.
3. Transportation Element Overall/General
Don’t build the Plan around specific technologies. The ultimate consequences of new
or emerging trends such as transportation network companies (
TNCs – e.g. Lyft, Uber) or autonomous vehicles may be positive or negative and
cannot be predicted.
4. Transportation Element Narrative and Maps
Geng Road improvement is too specific for the Comp Plan. Re-state more broadly as a
policy to reduce traffic on East Bayshore.”
5. Transportation Element Narrative and Maps
Support for Caltrain grade separation.
6. Transportation Element Goal T-1: Sustainable Transportation
Program T1.2.2: Add reference to stable, sustained funding for the TMA, but don’t be
proscriptive or limit the City’s options for funding.
7. Transportation Element Goal T-4: Neighborhood Impacts
Policy T4.1: Policy should recognize that residential arterials, along with local and
collector streets, are also school commute corridors. Policy should state that safety
on residential arterials is also important.
8. Transportation Element Goal T-6: Road Safety
Policy T-6.6: Policy and related programs discuss education for bicyclists. Language
should be updated to reflect that pedestrian safety is also included.
9. Transportation Element Goal T-8: Regional Collaboration and Coordination
Consider adding a policy statement about a potential future High Speed Rail station
and/or other aspects of High Speed Rail.
Source: Department of Planning & Community Environment; Approved by the Planning Commission on September
27, 2017.
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At their August 30 PTC meeting, the Commission determined that their report to the City
Council would have more impact and be more persuasive if the Commission also identified their
highest priority recommended changes. The Commission created a process to identify these
high priority PTC changes/ comments. At their final two meetings, the PTC reviewed a compiled
list of comments, identified those comments that seemed most significant for further
discussion, and engaged in more in-depth discussion and debate on 21 topics. The outcomes of
this discussion are shown in Table 3.
Table 3 includes 11 PTC high priority recommended changes and indicates the vote associated
with each. Most are changes to the Land Use Element. The PTC recommended unanimously
that support for BMR housing should be strengthened. There are several changes
recommended by a majority of the PTC to support housing. The PTC recommended policies that
support more family oriented housing for all demographics, state a strong preference for
affordable housing and housing that is affordable and commit to increasing the supply of
housing over time consistent with the Housing Element. Another recommendation, supported
unanimously by the PTC, was to strengthen policies supporting walkable neighborhoods to
ensure that space for professional and personal services, as well as retail, is available near
neighborhoods.
Staff expects that the City Council will want to consider these recommendations and provide
direction to incorporate some or all of them as changes to the draft plan. Staff will have to
prepare specific language to implement any of these recommendations that the Council wishes
to implement, and return with that language on November 13th. The PTC recognized that their
recommendations would require changes to the current draft of the Comprehensive Plan
Update and adopted a motion (See Attachment A ) that if the City Council approves any of the
PTC’s recommendations, the PTC recommends and welcomes the City Council to direct that
these changes be returned to the PTC to be worked into the Plan. (This recommendation is not
reflected in the staff recommendation or timeline/next steps discussion at the end of this staff
report.)
Table 3: PTC Highest Priority Changes to the Transportation and the Land Use Elements
PTC COMMENT MOTION* VOTE
1 Land Use Element Goal L-1: Growth Management
We need a strong commitment to creating BMR
housing inventory for purchase and rental. It is too
tentative appearing at a program level. Suggest we
make Program L1.3.1 into a separate policy –
perhaps having a quantifiable goal for ten years in
the future.
The PTC supports a strong
commitment to creating BMR
housing inventory for purchase and
rental. It is too tentative appearing
at a program level. The PTC
recommends that the Council make
Program L1.3.1 into a separate
policy consistent with and in
support of the quantified goals for
7:0
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PTC COMMENT MOTION* VOTE
housing production in the adopted
Housing Element.
2 Land Use Element Narrative and Maps
The distinction between commercial districts and
employment districts is a fundamental linchpin of
the previous comp plan that largely seems lost in the
draft. We need to test the draft commercial district
definition to ensure it still provides space in the
commercial districts for the sort of walkable services
the neighborhoods expect. These include not just
retail, but also services like doctors, dentists,
veterinarians, accountants, lawyers, therapists, auto
repair… Also spaces for not-for-profits, maker
spaces, performance spaces, clubs, dance and music
schools, gymnastics and other uses catering to the
entire age range including families, kids, and seniors.
We need to test that retail includes spaces where
lower margin and more specialized retail businesses
can operate. OR we need to look at some new
definitions for mixed use districts so we don’t
undermine commercial districts. We also need to
discuss whether the land use map contains proper
spaces for neighborhood services.
The PTC recommends that the
Council strengthen policies
supporting walkable
neighborhoods to ensure that
space for professional and personal
services as well as retail uses is
available near neighborhoods,
recognizing that all of these uses
are desirable in thriving
commercial centers. Similar
attention is needed to provide
space to accommodate non-profits
and small medical offices in our
community. (Note: After an
extensive discussion of this item,
the Commission approved a motion
to have staff prepare a statement
that summarized the Commission’s
recommendation. At the
Commission’s request, this
language was developed by staff to
reflect the Commission’s
discussion.)
7:0
3 Land Use Element
Goal L-1: Growth Management
Strengthen Policy L-1.3 about infill development to
indicate not just that infill should be compatible but
that “infill development should be preferred or
promoted.”
Add the following policy: Identify
development opportunities for
BMR and more affordable market
rate housing on city owned
properties, like alleys and parking
lots
5:2
4 Land Use Element Overall/ General
We need to expand our stock of family-oriented
housing. Where do we have spaces to accommodate
this use? How do we ensure new neighborhoods
receive full investment in schools, parks, adjacent
commercial districts and other services we
traditionally offer to neighborhoods. Our current
neighborhoods are built out, and don’t provide
substantial spaces for new family-oriented
development.
In light of Palo Alto’s traditional
family orientation, we need
housing policies that encourage
building more family-oriented
housing for all demographics. The
PTC recommends that the Council
add policies to Goals L-4 and L-5 to
accommodate larger scale family-
oriented housing development in
retail and commercial districts, and
policies to ensure school and other
service impacts are fully mitigated.
5:2
City of Palo Alto Page 11
PTC COMMENT MOTION* VOTE
5 Land Use Element Goal L-4:Commercial Centers &
Hotels
Support for Program L4.6.1 to prepare a
Coordinated Area Plan for Downtown, which is a
huge undertaking. Revise the Program to add that
the Coordinated Area Plan should consider
converting parts of University Avenue to a
pedestrian-only zone.
The PTC supports Program L4.6.1 to
prepare a Coordinated Area Plan
for Downtown, which is a huge
undertaking. The PTC recommends
that the Council revise the Program
to add that the Coordinated Area
Plan should study converting parts
of University Avenue to a
pedestrian-only zone.
5:2
6 Transportation Element Goal T-1: Sustainable
Transportation
PTC members had different views on the offering
incentives for TDM achievements. Some suggested
lowering parking requirements for projects with
successful TDM programs; other felt that permanent
parking reductions are not appropriate for uncertain
future trip reductions.
The PTC recommends that the
Council add language to ensure full
participation among Palo Alto
employers in TMA.
5:2
7 Land Use Element Overall/General
Include stronger emphasis on taking on
responsibility for dramatically increasing housing
supply in Palo Alto. Both BMR housing and “housing
that is affordable,” including housing for the middle
class.
Recommend that the Council
include language that expresses a
strong preference for affordable
housing and housing that is
affordable and a commitment to
increasing Housing supply over
time consistent with the goals set
by the City Council through the
Housing Element Process.
5:1:1
8 Land Use Element
Goal L-1: Growth Management
Comments on Goal L-1:
Concerns
1. Why not put vision statement this section by the
goal (instead of on page 1) so we know what we are
committed to accomplish?
2. Goal does not call for diversity in demographic
groups.
3. Neighborhoods are not prioritized as the most
important.
4. Passive wording and relegation to project level
does not suggest COMMITMENT to future action.
Suggestions for change:
1. Goal L-1 should read “A compact and resilient city
prioritizing diverse and vibrant neighborhoods – and
Recommend the following changes:
1. Goal L-1 should read “A compact
and resilient city prioritizing diverse
and vibrant neighborhoods – and
existing compatibly with shopping
and services, workplaces, public
facilities, parks and open space.”
2. Policies:
Swap L1.1 and L1.2 for emphasis
on neighborhoods – substituting
“prioritize” for “strengthen” in
current 1.2
4:1:2
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PTC COMMENT MOTION* VOTE
existing compatibly with shopping and services,
workplaces, public facilities, parks and open space.”
2. Policies:
Swap L1.1 and L1.2 for emphasis on neighborhoods
– substituting “prioritize” for “strengthen” in current
1.2
9 Land Use Element
Goal L-1: Growth Management
Strengthen Policy L-1.3 about infill development to
indicate not just that infill should be compatible but
that “infill development should be preferred or
promoted.”
Add a sentence at the beginning of
Policy L-1.3 stating that Palo Alto
has a preference for infill housing
4:2:1
10 Land Use Element
Overall/General
The Introduction to the Comp Plan describes a
different city than the land use element. The
introduction describes a walkable suburb oriented
around residential neighborhoods. Land Use
describes a mini-city-office-park and is largely silent
on neighborhoods and neighborhood services.
Either the introduction is wrong or the land use
element is wrong. How do we reconcile the different
views?
Reconcile the narratives,
description and goals with the
policies and programs, where there
appear to be contradictions
4:2:1
11 Land Use Element Goal L-1: Growth Management
Some PTC members felt that the Citywide growth
cap on office/R&D development and annual limit on
office/R&D development (enacted as a separate
ordinance) were appropriate growth management
tools. Others expressed that the consensus at the
2015 Our Palo Alto Summit was that a Citywide cap
is not the right tool, and policies should manage the
impacts of office/R&D growth (such as traffic) rather
than setting a cap on square footage.
The PTC recommends that the
Council keep the growth cap, focus
on offsets and quality of life and
other indication metrics that are
based on the impact of
development, including traffic,
noise, pollution, etc. Set specific
goals for a couple of key quality of
life measures and other indication
metrics.
4:3
12 Land Use Element Narrative and Maps
The distinction between commercial districts and
employment districts is a fundamental linchpin of
the previous comp plan that largely seems lost in the
draft. We need to test the draft commercial district
definition to ensure it still provides space in the
commercial districts for the sort of walkable services
the neighborhoods expect. These include not just
retail, but also services like doctors, dentists,
The PTC recommends that the
Council strengthen policies
supporting walkable
neighborhoods to ensure that
space for professional and personal
services as well as retail uses is
available near neighborhoods,
recognizing that all of these uses
are desirable in thriving
7:0
City of Palo Alto Page 13
PTC COMMENT MOTION* VOTE
veterinarians, accountants, lawyers, therapists, auto
repair… Also spaces for not-for-profits, maker
spaces, performance spaces, clubs, dance and music
schools, gymnastics and other uses catering to the
entire age range including families, kids, and seniors.
We need to test that retail includes spaces where
lower margin and more specialized retail businesses
can operate. OR we need to look at some new
definitions for mixed use districts so we don’t
undermine commercial districts. We also need to
discuss whether the land use map contains proper
spaces for neighborhood services.
commercial centers. Similar
attention is needed to provide
space to accommodate non-profits
and small medical offices in our
community. (Note: After an
extensive discussion of this item,
the Commission approved a motion
to have staff prepare a statement
that summarized the Commission’s
recommendation. At the
Commission’s request, this
language was developed by staff to
reflect the Commission’s
discussion.)
13 Land Use Element
Goal L-1: Growth Management
Strengthen Policy L-1.3 about infill development to
indicate not just that infill should be compatible but
that “infill development should be preferred or
promoted.”
Add the following policy: Identify
development opportunities for
BMR and more affordable market
rate housing on city owned
properties, like alleys and parking
lots
5:2
14 Land Use Element Overall/ General
We need to expand our stock of family-oriented
housing. Where do we have spaces to accommodate
this use? How do we ensure new neighborhoods
receive full investment in schools, parks, adjacent
commercial districts and other services we
traditionally offer to neighborhoods. Our current
neighborhoods are built out, and don’t provide
substantial spaces for new family-oriented
development.
In light of Palo Alto’s traditional
family orientation, we need
housing policies that encourage
building more family-oriented
housing for all demographics. The
PTC recommends that the Council
add policies to Goals L-4 and L-5 to
accommodate larger scale family-
oriented housing development in
retail and commercial districts, and
policies to ensure school and other
service impacts are fully mitigated.
5:2
* Staff will draft specific language for any recommendations that the Council wishes to implement for
consideration at the next hearing on November 13.
Source: Department of Planning & Community Environment Based on Commission actions at their
meetings of September 13 and 27, 2017.
EIR Certification
Preparation of an EIR is a time-consuming process, involving many steps, each of which take
considerable time. In the case of the Comprehensive Plan Update EIR, the process began in
earnest with issuance of a Notice of Preparation in mid-2014. The entire process, including City
City of Palo Alto Page 14
Council sessions to discuss the EIR and EIR scenarios is summarized in Table 4, below.
Table 4. City Council EIR Review – Key Dates
Date Action
July 28, 2008 City Council and Planning & Transportation Commission held a
joint study session on the work program for the Comp Plan and
EIR
May 30, 2014 Notice of Preparation issued for the Draft EIR
August 4, 2014 City Council scoping session on the Draft EIR
August 6, 2014 City Council continued scoping session on the Draft EIR
January 19, 2016 City Council and Citizens Advisory Committee held a joint study
session on the Draft EIR; City Council discussed two new Comp
Plan scenarios (Scenarios 5 & 6) for analysis in the EIR
February 5 to June 8, 2016 124-day Public comment period for the February 2016 Draft EIR
February 8, 2016 City Council continued discussion of Scenarios 5 & 6
May 16, 2016 City Council provided staff with basic parameters for Scenarios
5 & 6
June 6, 2016 City Council public comment hearing on the February 2016
Draft EIR
January 30, 2017 City Council directed staff to develop a preferred scenario for
inclusion in the Final EIR and defined some of its characteristics
(regarding housing sites, non-residential development cap,
transportation investments, etc.)
February 10 to March 31,
2017
49-day Public comment period for the Supplement to the Draft
EIR
March 20, 2017 City Council public comment hearing on the Supplement to the
Draft EIR
August 30, 2017 Final EIR transmitted to the PTC and City Council. Made
available at libraries, City Hall and to commenters.
September 27, 2017 PTC recommended that the City Council certify the Final EIR.
Source: Planning & Community Environment, September 2017
The Final EIR was published in late August 2017 and was available for PTC review in September
along with its review of the Comprehensive Plan Update. The Final EIR responds to comments
on the February 2016 Draft EIR and the Supplement to the Draft EIR, describes the “preferred
scenario” based on the Council’s input on March 27, 2017 and May 1, 2017, and presents
revisions to the February 2016 Draft EIR and the Supplement to the Draft EIR.
For a good summary of the EIR’s conclusions, please see Table 1-3, Summary of Impacts and
Mitigation Measures, in the Final EIR. This table is reprinted from the Supplement to the Draft
City of Palo Alto Page 15
EIR with revisions resulting from the public review process. Where changes have been made,
they are shown in strikethrough and underline. As shown in Table 1-3, several adjustments
have been made to the mitigation measures in the EIR. Most of these revisions are to ensure
that implementation of mitigation measures is consistent with the policy approach arrived at
through the Comprehensive Plan Update process. None of these revisions weaken the
effectiveness of mitigation measures. Chapter 2 of the Final EIR includes a good summary of
the Preferred Alternative and a comparison to other EIR scenarios (See Table 2-4).
The City received 29 comment letters on the February 2016 Draft EIR and 18 letters on the
Supplement to the Draft EIR, as well as oral comments made during public meetings. Chapter 5
of the Final EIR provides responses to every comment received on the EIR. Chapter 5 of the
Final EIR also contains three “master responses” that provide comprehensive responses to
common topics that arose in the comments received:
Master Response 1 addresses comments related to the merits of the Comp Plan Update,
as opposed the EIR analysis. Because CEQA does not require the Final EIR to respond to
comments on the merits of the proposed project, Master Response 1 explains how the
City considers these non-CEQA comments.
Master Response 2 addresses comments that requested that the EIR analysis include
recent cumulative projects and plans in nearby jurisdictions that have been proposed or
approved since the Notice of Preparation (NOP) for the Comprehensive Plan EIR was
issued. The response explains that the EIR analysis is based on regional projections that
are large enough to accommodate planned and approved projects in the region through
the year 2030.
Master Response 3 addresses comments regarding the EIR’s analysis of impacts to
schools. The response corrects and supplements information presented in the
Supplement to the Draft EIR and responds to specific comments from the School District
and others on the scope and conclusions of the analysis.
To ensure that the EIR is responsive to concerns regarding potential impacts to schools, the City
has coordinated with the Palo Alto Unified School District (PAUSD) at various junctures in the
EIR process. Master Response 3 summarizes the information received from the public and
PAUSD during the EIR’s public review period. Since preparing the Final EIR, the City has also
received additional data from the PAUSD regarding school capacity (see Attachment F). The
updated capacity data is intended to capture factors that lower the effective capacity of
schools, and varies from the capacity data presented in the EIR as follows: elementary school
capacity is lower than presented in the EIR by approximately 1,000 students, middle school
capacity is the same as presented in the EIR, and high school capacity is lower by 100 students.
This reduced capacity data is important for planning purposes but does not substantively affect
the conclusions of the EIR, which as required by State statute, concludes that the payment of
City of Palo Alto Page 16
school fees would offset and mitigate potential impacts to schools. Importantly, the City
Council has addressed the issue of school impacts as a policy matter by including a related
policy in the draft Plan:
Policy L-2.11: Ensure regular coordination between the City and PAUSD on land
development activities and trends in Palo Alto, as well as planning for school facilities
and programs. Under State law, impacts on school facilities cannot be the basis for
requiring mitigation beyond the payment of school fees or for denying development
projects or legislative changes that could result in additional housing units. The City will,
however, assess the reasonably foreseeable environmental impacts of development
projects that result in new school construction or enrollment.
Under CEQA, the City Council must consider and “certify” the Final EIR prior to making a
decision on the plan itself. The Resolution in Attachment B would accomplish this and certify
that the EIR: (1) has been completed in compliance with CEQA, (2) was presented to the Council
and reviewed and considered by them prior to making a decision on the project, and (3) reflects
the City’s independent judgement and analysis.
At the PTC’s final meeting, the Commission received a number of comments on the Final EIR
and the Comprehensive Plan Update itself, which have been summarized and responded to in
Attachment G. In addition, at least one commenter seemed to suggest that any plan or EIR
with significant and unavoidable impacts would be unacceptable. As the Council is aware,
CEQA anticipates the potential that agencies will approve projects with significant and
unavoidable impacts, and allows agencies to do so if they adopt findings that the project’s
benefits outweigh the impacts; this is referred to in CEQA as a statement of overriding
considerations.
These findings are included in Attachment C, and are necessitated because the actions and
development contemplated under the Comprehensive Plan Update will have significant and
unmitigable impacts related to: contributions of air pollutants to a region that is in “non-
attainment” for ozone and particulates; contributions to traffic congestion at area
intersections; contributions to traffic congestion at freeway ramps; and transit delays due to
traffic congestion. In all cases, the City is proposing to implement mitigation measures, and is
conservatively concluding that the impact will remain significant even after mitigation. As
noted in the proposed findings, these conclusions would be the same for virtually any plan (and
any planning scenario) proposed in the region if it were analyzed using the same thresholds of
significance. In other words, there is no getting away from the fact that we live in a congested
region and that any programmatic EIR that fairly examines cumulative growth over a period of
time will conclude there are unmitigable impacts.
CEQA Findings
City of Palo Alto Page 17
Under CEQA, the City Council must also make certain “findings” as part of a decision to
undertake a project for which an EIR has been prepared. The Resolution in Attachment C
contains these findings, which include:
Findings concerning significant impacts and mitigation measures,
Findings concerning the infeasibility of alternatives,
A statement of overriding considerations, and
Adoption of a mitigation monitoring and reporting program (MMRP).
The findings concerning significant impacts and mitigation measures summarize each impact
identified in the EIR, describe the applicable mitigation measures, and state the findings on the
significance of each impact after imposition of the mitigation measures.
The findings concerning the infeasibility of alternatives explain that there are no feasible
alternatives that would substantially lessen the significant impacts of the project and the
statement of overriding considerations states that there are specific project benefits that
outweigh the significant and unavoidable impacts.
The MMRP is a program spells out how the City will implement and monitor measures that the
EIR incorporates to mitigate or avoid significant environmental effects. In many cases, these
mitigation measures are being implemented by adopting Comprehensive Plan policies that
specifically address the impact identified. For example, policies in the plan regarding land use
compatibility ensure that future developments -- and future capital projects -- are designed to
ensure compatibility and these policies will be implemented as these future projects are
reviewed for conformance with the adopted Comprehensive Plan. In some cases, the
mitigation measures are implemented by making changes to the City’s CEQA procedures or
sections of the Municipal Code and the MMRP provides a timeline for these actions.
The June 30, 2017 Comprehensive Plan Update
On June 12, 2017, City Council referred the current draft of the Comprehensive Plan Update to
the PTC for review and a recommendation. The June 30, 2017 draft Plan reflects the Citizens
Advisory Committee (CAC) May 16, 2017 recommendations to the Council and incorporates
changes based on Council review.
Following Council adoption of the Comprehensive Plan, staff and consultants will create the
final Comprehensive Plan by making any substantive changes to Plan that are directed by
Council motion, including the corrections and changes listed in Attachment E if or as directed by
the City Council. As noted in the recommendation section, above, staff also recommends non-
content (formatting) revisions to create the final Plan. These non-content revisions include:
City of Palo Alto Page 18
A graphically rich cover
An Acknowledgement section
An index
Formatting clean-ups, such as updating the footer on each page to say “Adopted [date]”
Agency Consultation
A key part of any general plan update consists of consultation with State and regional agencies
and Native American tribes, as required by various sections of the California Government Code.
Consistent with these requirements, staff provided notice to Native American Tribes in early
February, and copies of the Safety and Natural Environment Elements to State agencies in early
August 2017. Notice to adjacent cities, LACFO, PAUSD, and other agencies were provided in
late-September.
All periods for agency comments (45-days in some cases and 90 days in others) will close prior
to the Council’s second hearing on November 13, 2017. In staff’s experience, the City may
receive last minute comments from one or more agency that require immediate responses or
revisions. If this is the case, staff will provide a recommendation for the Council’s
consideration.
The List of Corrections and Amendments
Attachment E includes a list of corrections to the June 30, 2017 Comprehensive Plan that have
been identified by staff since its publication in June 2017. These changes correct mistakes,
clarify wording, and shift some programs to policies, primarily to be consistent with the Final
EIR mitigation measures. None of these revisions would affect the intent or effect of a policy or
program. Some notable corrections and clarifications listed in Attachment E include:
Rewording the Regional/Community Commercial designation to more accurately reflect
Council’s motion on May 1, 2017 that software development is an allowed use
Downtown, rather than allowed throughout the Regional/Community Commercial
designation, which also includes Stanford Shopping Center and Town and Country
Village.
Revising Policy L-5.4 to remove reference to East Meadow Circle Concept Plan because
some of its policies are not consistent with the draft Comprehensive Plan Update, while
keeping policy wording to maintain the East Bayshore and San Antonio Road/Bayshore
Corridor areas as diverse business and light industrial districts.
Rewording Policy L-6.5 to clarify that the policy is intended to preserve views up City
streets to the hills, not from a street across private property.
Rewording Program T2.3.1 to clarify that maintaining City standards for both VMT and
LOS analysis of proposed projects is consistent with new State CEQA requirements
under SB 743.
City of Palo Alto Page 19
Attachment E also includes a small mapping errata in the Comp Plan and Final EIR.
Implementation Priorities
The Implementation Chapter of the Comprehensive Plan repeats implementation programs
included in all Elements of the Plan and the City Council has reviewed the programs in that
context. The implementation table also identifies the lead department or agency for each
program, as well as each item’s relative priority and level of effort. These notations
(department, relative priority, level of effort) have not been previously reviewed by the City
Council and currently reflect relative priorities as they were identified by the CAC. While the
City Council’s input on this Chapter is welcome as part of plan adoption, the Chapter is intended
to be reviewed and revised on an annual basis. Staff’s recommendation is to (1) schedule a
separate, in depth discussion of the table in 2018, and (2) identify a few key priorities that the
City Council would like to prioritize in the interim. The Implementation Chapter is a key
mechanism to link the Comprehensive Plan to Palo Alto’s budget process. The priorities, timing
and resource estimates in this chapter are intended to be modified depending on the city’s
budget, available staff resources and other changes over time and do not require a
Comprehensive Plan Amendment.
The PTC is scheduled to review and provide a report on this chapter before the end of the year
and the Council will have an opportunity for in depth review upon receipt of the PTC’s annual
report.
The specific interim actions that staff are recommending that the City Council prioritize include:
1. consideration of an updated nexus study and Transportation Impact Fee ordinance by
the Finance Committee and the Council;
2. consideration of the first of several implementing ordinances to amend the Zoning
Ordinance to address Comprehensive Plan programs, prioritizing programs related to
housing production and preservation (for example, incentives for small units, preserving
cottage clusters, minimum densities in multifamily zoning districts, etc.);
3. consideration of actions necessary to initiate a Coordinated Area Plan for the North
Ventura (aka Fry’s) area; and
4. initiation of discussions with Stanford University about the potential for developing
housing in the Stanford Research Park, Stanford Shopping Center, and Stanford
University Medical Center vicinity.
These items are recommended for prioritization based on individual Councilmember
statements during hearings on the Comprehensive Plan and the EIR, and the Council as a whole
may alter these immediate priorities or defer discussion on them if desired. Many communities
City of Palo Alto Page 20
follow adoption of a new general plan with an update of their zoning ordinance. Staff
recommends Palo Alto address necessary changes with a series of ordinances addressing
different subjects, with the first one focusing on housing. If Council wishes to take an alternate
approach, staff will need to return with a detailed scope and cost estimate.
Policy Implications
The Comprehensive Plan is the City’s “constitution” when it comes to land use and
development issues, including transportation and the protection of the environment. The
Comprehensive Plan Update has been crafted by the Citizens Advisory Committee, Planning and
Transportation Commission, and the City Council to perpetuate the overall vision and values of
the current plan, while updating some of its goals, policies, and implementation programs.
Resource Impact
The Comprehensive Plan Update has been a time consuming and costly project for the City.
Current contracts are sufficient to complete the project in accordance with the current
schedule, which envisions plan adoption before Thanksgiving and publication (searchable pdf
and hard copies) thereafter. Additional budgetary resources – and a contract amendment --
would be required if the City Council wishes staff to work with the consultants to develop an
interactive, on-line “users guide” as originally envisioned.
Timeline/Next Steps
Tonight’s hearing is the first of two hearings scheduled for plan adoption. It is expected that
the City Council will use this first hearing to review and discuss the PTC’s report and
recommendations, discuss any additional changes or corrections that should be included in
Attachment E, and take action on EIR certification. A second hearing has been scheduled for
November 13 to allow the City Council to consider adoption of the CEQA findings and the
Comprehensive Plan Update itself. If the Comprehensive Plan Update is not adopted before
the end of the year, a new State requirement will take effect requiring revisions to the Draft
Plan to address Environmental Justice (SB 1000), which will further delay adoption of the
Comprehensive Plan Update.
Staff has also requested the City Council’s direction to prioritize a short list of priority
implementation tasks. (See implementation discussion above.) The current schedule for
related activities is provided in Table 5 below:
Table 5: Schedule of Upcoming Events (Subject to Modification)
Priority Actions Next Steps
Accept grant and initiate North Ventura (aka “Fry’s”)
Coordinated Area Plan process
City Council Grant Acceptance
Scheduled for November 6.
City of Palo Alto Page 21
City Council Initiation/Scope
Discussion to Follow (Date TBD).
City participation in "On the Table” Community Conversation
about Housing sponsored by Silicon Valley Community
Foundation (SVCF)
November 15
Transportation Nexus Study & Updated Impact Fee Ordinance Finance Committee hearing
tentatively scheduled for
November 28.
City Council housing “retreat” to discuss housing issues and
implementation actions.
Date TBD at the end of November
or early December.
Comp Plan Implementing Ordinance #1 (Housing Unit
Production & Preservation)
PTC and City Council Hearing
schedule TBD
Initiate Discussions with Stanford University about Housing in
the Research Park, Shopping Center, and SUMC vicinity
Steps and schedule TBD
Source: Planning & Community Environment, October 2017
Environmental Review
A Final Environmental Impact Report (EIR) has been prepared and is proposed for certification.
The Final EIR responds to substantive comments on the Draft EIR and the Supplement to the
Draft EIR and describes the “preferred scenario” based on the Council’s input this spring.
Following certification of the Final EIR, the City Council will consider adoption of CEQA findings,
including adoption of mitigation measures, a statement of overriding considerations, and a
mitigation monitoring and reporting program (MMRP).
Attachments:
Attachment A: PTC Report to the City Council on Comprehensive Plan Update Adoption
(PDF)
Attachment B: RESO Certifying EIR for Comp Plan Update (PDF)
Attachment C: RESO Adopting CEQA Findings for Comp Plan Update (PDF)
Attachemnt D: RESO Adopting Comp Plan Update (PDF)
Attachment E: CompPlan_Errata_20171002 (PDF)
Attachment F: Updated School Capacities (PDF)
Attachment G: Responses to Comments Received at the PTC Meeting of September 27, 2017
(DOCX)
PTC Report to Council
September 27, 2017 Page 1
Planning and Transportation Commission Report to the City Council on the
Comprehensive Plan Update Adoption, September 27, 2017
On June 12, 2017, the City Council referred the draft of the Comprehensive Plan Update to the
Planning and Transportation Commission for a report on the proposed plan. The City Council
referenced the 90 day timeframe contained in Section 19.04.080 of the Palo Alto Municipal
Code for the PTC review, with the 90 days beginning on June 30, 2017.
The PTC held six public hearings and focused its 90 day review on the Land Use and
Transportation Elements of the June 30th version of draft Comprehensive Plan Update. The PTC
completed its review and recommendation on September 27, 2017, within the 90 day period.
At the September 27, 2017 PTC meeting, the PTC adopted a series of motions approving the
transmittal of this report to the City Council and:
• Recommending the PTC’s highest priority changes to the Transportation and Land Use
Elements and the Comprehensive Plan Update as shown in Table 1 below;
• Transmitting the PTC General Consensus Comments as shown in Table 2 below;
• Transmitting the Minutes from the six PTC hearings on the Comprehensive Plan Update per
Table 3 below;
• Recommending certification of the Comprehensive Plan Update Final Environmental Impact
Report (EIR) dated August 30, 2017 as completed in compliance with the California
Environmental Quality Act (CEQA), and reflecting the lead agency’s independent judgment
and analysis;
• Deferring the PTC’s review of the Transportation and Land Use Sections of the
Implementation Plan Table; and
• If and when any of the PTC’s 11 Highest Priority recommendations are approved by the
Council, recommending and welcoming the City Council to direct that these changes be
returned to the PTC to be worked appropriately into the Comp Plan.
PTC Report to Council
September 27, 2017 Page 2
Table 1: PTC Highest Priority Changes to Transportation and Land Use Elements and the June
30, 2017 Draft Comprehensive Plan Update
ORIGINAL PTC COMMENT MOTION VOTE
1 Land Use Element Goal L-1: Growth
Management
We need a strong commitment to creating
BMR housing inventory for purchase and
rental. It is too tentative appearing at a
program level. Suggest we make Program
L1.3.1 into a separate policy – perhaps having
a quantifiable goal for ten years in the future.
The PTC supports a strong commitment
to creating BMR housing inventory for
purchase and rental. It is too tentative
appearing at a program level. The PTC
recommends that the Council make
Program L1.3.1 into a separate policy
consistent with and in support of the
quantified goals for housing production
in the adopted Housing Element.
7:0
2 Land Use Element Narrative and Maps
The distinction between commercial districts
and employment districts is a fundamental
linchpin of the previous comp plan that largely
seems lost in the draft. We need to test the
draft commercial district definition to ensure it
still provides space in the commercial districts
for the sort of walkable services the
neighborhoods expect. These include not just
retail, but also services like doctors, dentists,
veterinarians, accountants, lawyers,
therapists, auto repair… Also spaces for not-
for-profits, maker spaces, performance
spaces, clubs, dance and music schools,
gymnastics and other uses catering to the
entire age range including families, kids, and
seniors.
We need to test that retail includes spaces
where lower margin and more specialized
retail businesses can operate. OR we need to
look at some new definitions for mixed use
districts so we don’t undermine commercial
districts. We also need to discuss whether the
land use map contains proper spaces for
neighborhood services.
The PTC recommends that the Council
strengthen policies supporting walkable
neighborhoods to ensure that space for
professional and personal services as
well as retail uses is available near
neighborhoods, recognizing that all of
these uses are desirable in thriving
commercial centers. Similar attention is
needed to provide space to
accommodate non-profits and small
medical offices in our community.
7:0
3 Land Use Element
Goal L-1: Growth Management
Strengthen Policy L-1.3 about infill
development to indicate not just that infill
should be compatible but that “infill
development should be preferred or
promoted.”
Add the following policy: Identify
development opportunities for BMR and
more affordable market rate housing on
city owned properties, like alleys and
parking lots
5:2
4 Land Use Element Overall/ General
We need to expand our stock of family-
oriented housing. Where do we have spaces to
In light of Palo Alto’s traditional family
orientation, we need housing policies
that encourage building more family-
5:2
PTC Report to Council
September 27, 2017 Page 3
ORIGINAL PTC COMMENT MOTION VOTE
accommodate this use? How do we ensure
new neighborhoods receive full investment in
schools, parks, adjacent commercial districts
and other services we traditionally offer to
neighborhoods. Our current neighborhoods
are built out, and don’t provide substantial
spaces for new family-oriented development.
oriented housing for all demographics.
The PTC recommends that the Council
add policies to Goals L-4 and L-5 to
accommodate larger scale family-
oriented housing development in retail
and commercial districts, and policies to
ensure school and other service impacts
are fully mitigated.
5 Land Use Element Goal L-4: Commercial
Centers & Hotels
Support for Program L4.6.1 to prepare a
Coordinated Area Plan for Downtown, which is
a huge undertaking. Revise the Program to
add that the Coordinated Area Plan should
consider converting parts of University Avenue
to a pedestrian-only zone.
The PTC supports Program L4.6.1 to
prepare a Coordinated Area Plan for
Downtown, which is a huge undertaking.
The PTC recommends that the Council
revise the Program to add that the
Coordinated Area Plan should study
converting parts of University Avenue to
a pedestrian-only zone.
5:2
6 Transportation Element Goal T-1: Sustainable
Transportation
PTC members had different views on the
offering incentives for TDM achievements.
Some suggested lowering parking
requirements for projects with successful TDM
programs; other felt that permanent parking
reductions are not appropriate for uncertain
future trip reductions.
The PTC recommends that the Council
add language to ensure full participation
among Palo Alto employers in TMA.
5:2
7 Land Use Element Overall/General
Include stronger emphasis on taking on
responsibility for dramatically increasing
housing supply in Palo Alto. Both BMR housing
and “housing that is affordable,” including
housing for the middle class.
Recommend that the Council include
language that expresses a strong
preference for affordable housing and
housing that is affordable and a
commitment to increasing Housing
supply over time consistent with the
goals set by the City Council through the
Housing Element Process.
5:1:1
8 Land Use Element
Goal L-1: Growth Management
Comments on Goal L-1:
Concerns:
1. Why not put vision statement this section
by the goal (instead of on page 1) so we know
what we are committed to accomplish?
2. Goal does not call for diversity in
demographic groups.
3. Neighborhoods are not prioritized as the
most important.
4. Passive wording and relegation to project
Recommend the following changes:
1. Goal L-1 should read “A compact and
resilient city prioritizing diverse and
vibrant neighborhoods – and existing
compatibly with shopping and services,
workplaces, public facilities, parks and
open space.”
2. Policies:
Swap L1.1 and L1.2 for emphasis on
neighborhoods – substituting
“prioritize” for “strengthen” in current
1.2
4:1:2
PTC Report to Council
September 27, 2017 Page 4
ORIGINAL PTC COMMENT MOTION VOTE
level does not suggest COMMITMENT to
future action.
Suggestions for change:
1. Goal L-1 should read “A compact and
resilient city prioritizing diverse and vibrant
neighborhoods – and existing compatibly with
shopping and services, workplaces, public
facilities, parks and open space.”
2. Policies:
Swap L1.1 and L1.2 for emphasis on
neighborhoods – substituting “prioritize” for
“strengthen” in current 1.2
9 Land Use Element
Goal L-1: Growth Management
Strengthen Policy L-1.3 about infill
development to indicate not just that infill
should be compatible but that “infill
development should be preferred or
promoted.”
Add a sentence at the beginning of
Policy L-1.3 stating that Palo Alto has a
preference for infill housing
4:2:1
10 Land Use Element
Overall/General
The Introduction to the Comp Plan describes a
different city than the land use element. The
introduction describes a walkable suburb
oriented around residential neighborhoods.
Land Use describes a mini-city-office-park and
is largely silent on neighborhoods and
neighborhood services. Either the introduction
is wrong or the land use element is wrong.
How do we reconcile the different views?
Reconcile the narratives, description and
goals with the policies and programs,
where there appear to be contradictions
4:2:1
11 Land Use Element Goal L-1: Growth
Management
Some PTC members felt that the Citywide
growth cap on office/R&D development and
annual limit on office/R&D development
(enacted as a separate ordinance) were
appropriate growth management tools.
Others expressed that the consensus at the
2015 Our Palo Alto Summit was that a
Citywide cap is not the right tool, and policies
should manage the impacts of office/R&D
growth (such as traffic) rather than setting a
cap on square footage.
The PTC recommends that the Council
keep the growth cap, focus on offsets
and quality of life and other indication
metrics that are based on the impact of
development, including traffic, noise,
pollution, etc. Set specific goals for a
couple of key quality of life measures
and other indication metrics.
4:3
Source: Department of Planning & Community Environment Based on Commission actions at their meetings of
September 13 and 27, 2017.
PTC Report to Council
September 27, 2017 Page 5
Table 2: PTC General Consensus Comments
PTC GENERAL CONSENSUS COMMENTS
1. Land Use Element Overall/General
The Element should place more emphasis on creating neighborhoods, not just building
housing units.
2. Land Use Element Overall/General
Goals, policies, and programs throughout should be clear and actionable, and the City
should be able to track progress toward achievement.
3. Transportation Element Overall/General
Don’t build the Plan around specific technologies. The ultimate consequences of new or
emerging trends such as transportation network companies (
TNCs – e.g. Lyft, Uber) or autonomous vehicles may be positive or negative and cannot be
predicted.
4. Transportation Element Narrative and Maps
Geng Road improvement is too specific for the Comp Plan. Re-state more broadly as an
improvement or a policy to reduce traffic on East Bayshore.”
5. Transportation Element Narrative and Maps
Support for Caltrain grade separation.
6. Transportation Element Goal T-1: Sustainable Transportation
Program T1.2.2: Add reference to stable, sustained funding for the TMA, but don’t be
proscriptive or limit the City’s options for funding.
7. Transportation Element Goal T-4: Neighborhood Impacts
Policy T4.1: Policy should recognize that residential arterials, along with local and
collector streets, are also school commute corridors. Policy should state that safety on
residential arterials is also important.
8. Transportation Element Goal T-6: Road Safety
Policy T-6.6: Policy and related programs discuss education for bicyclists. Language
should be updated to reflect that pedestrian safety is also included.
9. Transportation Element Goal T-8: Regional Collaboration and Coordination
Consider adding a policy statement about a potential future High Speed Rail station
and/or other aspects of High Speed Rail.
Source: Department of Planning & Community Environment; Approved by the Planning Commission on September
27, 2017.
Due to the volume of the PTC minutes for the six meetings (around 600 pages total), the minutes
have not been attached in a hard copy. Electronic copies are available at the following links:
Table 3: PTC Minutes
PTC Hearing Date Link
July 12, 2017 (Approved) http://www.cityofpaloalto.org/civicax/filebank/documents/59548
July 26, 2017 (Approved) http://www.cityofpaloalto.org/civicax/filebank/documents/59549
August 9, 2017 (Approved) http://www.cityofpaloalto.org/civicax/filebank/documents/59550
August 30, 2017 (Approved) http://www.cityofpaloalto.org/civicax/filebank/documents/59731
PTC Report to Council
September 27, 2017 Page 6
September 13, 2017 (Draft) http://www.paloaltocompplan.org/wp-content/uploads/2017/10/PTC-
09.13.17-Item-3-Excerpt-Minutes.pdf
September 27, 2017 (Draft) www.paloaltocompplan.org/planning-and-transportation-commission/
Not Yet Approved
170901 jb Lee/Planning/LongRange/Comp Plan
Resolution No _____
Resolution of the Council of the City of Palo Alto Certifying Adequacy of the Final
Environmental Impact Report for the City of Palo Alto Comprehensive Plan Update in
Accordance with the California Environmental Quality Act
RECITALS
A. The City of Palo Alto, a chartered 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, 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. The
environmental review process under CEQA commenced and was undertaken concurrently with the
preparation and consideration of the Comprehensive Plan Update.
D. 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, and was circulated for public review from February 5, 2016 to June 8, 2016. The City held
several public hearings to receive comments on the Draft EIR.
E. 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.
F. Through its review of the Citizens Advisory Committee’s recommendations over
several duly noticed public hearings, the City Council identified the parameters of the preferred
alternative for the Comprehensive Plan Update.
G. 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 “Final EIR”).
H. Prior to the adoption of this Resolution, the Planning and Transportation
Commission of the City of Palo Alto, on September 27, 2017, reviewed the Final 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.
Not Yet Approved
170901 jb Lee/Planning/LongRange/Comp Plan
I. Public notice was duly given that on October 23, 2017 at 5:00 p.m. in the Council
Chambers at City Hall, 285 Hamilton Avenue, Palo Alto, California, the Council would hold a public
hearing where interested persons could appear, be heard, and present their views with respect to
the proposed Comprehensive Plan Update and the Final EIR, and at the noticed date and time, the
Council gave all persons full opportunity to be heard and to present their views with respect to the
proposed Comprehensive Plan Update and the Final EIR.
J. The Council is the decision-making body for adoption of the proposed
Comprehensive Plan Update.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PALO ALTO AS
FOLLOWS:
The City Council (hereinafter the “Council”), in the exercise of its independent judgment as
the decision-making body for the City of Palo Alto as Lead Agency, makes and adopts the following
findings and certifications in compliance with the requirements of CEQA:
1. The Council has independently reviewed and considered the Final EIR.
2. The Council does hereby find and certify that the Final EIR has been prepared and
completed in compliance with CEQA.
3. The Council does hereby find and certify that the Final EIR reflects the City of Palo Alto’s
independent judgment and analysis.
INTRODUCED AND 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
Not Yet Approved
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 1
Resolution No _____
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 2
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.
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. On ___________, the Council held a duly noticed public hearing on the
Comprehensive Plan Update and EIR, and certified the EIR in accordance with CEQA by
adoption of Resolution No. _______.
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 3
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 4
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 5
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
improving safe access for bicyclists and pedestrians and increasing the amount of bicycle
parking.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 6
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
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 7
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
types, such as studios, cohousing, cottages, clustered housing, accessory dwelling units and
senior housing.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 8
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).
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).
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 9
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.
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 10
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:
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 11
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
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:
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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.
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
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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.
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.
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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
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:
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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.
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.
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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.
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,
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 17
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.
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.
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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.
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.
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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.
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
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 20
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:
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
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 21
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.
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
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 22
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.
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 23
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
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 24
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
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 25
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
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 26
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.
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 27
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.
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
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 28
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
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
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 29
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:
- 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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 30
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.
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
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 31
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
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 32
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
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
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 33
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
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
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 34
(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.
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 35
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
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 36
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
(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).
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 37
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.
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,
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 38
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.
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 39
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
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
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 40
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
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
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 41
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.
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 42
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.
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
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 43
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.
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.
171003 JB SL/PLANNING/LONGRANGE/COMP PLAN 44
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.
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:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST: APPROVED:
______________________________ _________________________________
City Clerk Mayor
APPROVED AS TO FORM: _________________________________
City Manager
_______________________________
Assistant City Attorney _________________________________
Director of Planning and Community
Environment
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.
EXHIBIT A
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
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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
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Implementation
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Timing
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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
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Timing
Monitoring
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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
Not Yet Approved
170901 jb Lee/Planning/LongRange
Resolution No _____
Resolution of the Council of the City of Palo Alto Adopting the City of Palo Alto
Comprehensive Plan Update
RECITALS
A. The City Council is authorized by Title 19 of the Palo Alto Municipal Code and state
law to adopt and, from time to time, amend the general plan (known as the Comprehensive
Plan in the City of Palo Alto) governing the physical development of the City of Palo Alto.
B. In 1998, the City Council adopted the Comprehensive Plan entitled, “Embracing the
New Century, Palo Alto 1998-2010 Comprehensive Plan,” which Plan has since been amended
by the Council. This Plan is referred to herein as the “1998 Comprehensive Plan”.
C. Through an extensive and lengthy public process including the convening of a
Citizens Advisory Committee (“CAC”) and numerous public hearings held by the CAC, the
Planning and Transportation Commission and the City Council, the City of Palo Alto has
prepared that certain comprehensive update to the 1998 Comprehensive Plan entitled “Our
Palo Alto 2030,” proposed for approval and adoption by the City Council.
D. In accordance with Title 19 of the Palo Alto Municipal Code, all Comprehensive Plan
amendment proposals are referred to the Planning and Transportation Commission of the City
of Palo Alto for review and recommendation prior to City Council consideration of the
amendments. On June 12, 2017, after receiving the CAC recommendation and holding
additional public hearings, the City Council identified a preferred planning scenario and
forwarded the draft Comprehensive Plan Update to the Planning and Transportation
Commission. The draft Comprehensive Plan Update is referred to herein as the “June 30, 2017
Draft of the Comprehensive Plan Update” which reflects the date that the Plan was transmitted
to the Planning and Transportation Commission.
E. From July 12, 2017 to September 27, 2017, the Planning and Transportation
Commission held five public hearings to consider the draft Comprehensive Plan Update, at
which interested persons were given the opportunity to appear and present their views with
respect to the Comprehensive Plan Update.
F. At the conclusion of the final public hearing on September 27, 2017, the Planning
and Transportation Commission transmitted its recommendations to the City Council on the
proposed Comprehensive Plan Update.
G. Concurrently with the Planning and Transportation Commission review, City staff
prepared a list of minor corrections and clarifications to June 30, 2017 Draft of the
Comprehensive Plan Update (the “Errata”).
H. An original of the proposed Comprehensive Plan Update is on file in the office of the
Director of Planning and Community Environment of the City, with a copy submitted to the City
Council for its consideration.
Not Yet Approved
170901 jb Lee/Planning/LongRange
I. Pursuant to Title 19 of the Palo Alto Municipal Code, public notice was given that on
October 23, 2017, at 5:00 p.m. and November 13, 2017, at 6:00 p.m. in the Council Chambers at
City Hall, 285 Hamilton Avenue, Palo Alto, California, the Council would hold a public hearing
where interested persons could appear, be heard, and present their views with respect to the
proposed Comprehensive Plan Update.
J. The Council held a duly noticed public hearing at the dates and times in Recital I
above and gave all persons full opportunity to be heard and to present their views with respect
to the proposed Comprehensive Plan Update.
K. On __________, the Council reviewed, considered and certified that certain Final
Environmental Impact Report for the proposed Comprehensive Plan Update by Resolution No.
________, and on ___________, the Council adopted adopted related findings by Resolution
No. _________, all in accordance with the California Environmental Quality Act. Both actions
were taken prior to the Council making its determination on the proposed Comprehensive Plan
Update.
L. The Council is the decision-making body for adoption of the proposed
Comprehensive Plan Update.
The Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. The Public Hearing Draft of the Comprehensive Plan Update dated June
30, 2017 (referred to herein as the “June 30, 2017 Draft of the Comprehensive Plan Update”) is
hereby adopted, subject to the modifications set forth in the Errata document, the
modifications recommended by the Planning and Transportation Commission, and the
additional modifications approved by the Council, all of which modifications are attached
hereto and incorporated herein as Exhibit A. [Exhibit A to be prepared upon Council action on
the Errata, PTC recommendations, and further Council direction at the plan adoption
hearings.]
The Council finds and determines that the Final Environmental Impact Report
adequately evaluated and provides a sufficient basis to approve the Comprehensive Plan
Update including these modifications, and that the modifications, individually and collectively,
do not change any of the conclusions of the Final Environmental Impact Report. The Council
further finds that the modifications, individually and collectively, do not constitute significant
new information under the California Environmental Quality Act (“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
Not Yet Approved
170901 jb Lee/Planning/LongRange
of the Project has been proposed and would not be implemented.
SECTION 2. The Implementation Table attached to the Comprehensive Plan Update
restates the programs in the Comprehensive Plan and identifies the lead department or agency,
the relative prioritization and planned timeframe, and the anticipated level of resources and
effort for their implementation. While the programs are substantive parts of the Comprehensive
Plan Update, the other information in the Implementation Table, including the prioritization of
the programs are not intended to be incorporated as substantive elements and may be modified
by the City Council without a formal amendment to the Comprehensive Plan.
SECTION 3. City staff may perform minor, non-substantive edits to the Comprehensive
Plan Update without additional Council review. These include such things as formatting,
illustrations, and acknowledgements.
SECTION 4. This Comprehensive Plan Update supersedes the adopted 1998
Comprehensive Plan, except for the Housing Element of the Comprehensive Plan adopted by the
Council in November 2014 (“Housing Element”), which remains in full force and effect and is
incorporated into the Comprehensive Plan Update.
INTRODUCED AND 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
October 2, 2017 1
ERRATA TABLE /COMP PLAN CORRECTIONS AND CLARIFICATIONS
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1 Inside front cover Add City Hall contact information General City Information: (650) 329-2100
Planning & Community Environment Department: (650) 329-2442
http://www.cityofpaloalto.org/iwantto/
http://www.cityofpaloalto.org/services/paloalto311/
2 Table of Contents Inclusion of Housing as Number 4 on table of contents A foot note shall be added: “The Housing Element is incorporated
into the Comprehensive Plan and can be found at:
http://www.cityofpaloalto.org/civicax/filebank/documents/37935.
3 Regional Commercial
Designation
Fix reference to software development to accurately reflect
Council motion that it should be allowed Downtown only; not in
other shopping areas.
Regional/Community Commercial: Larger shopping centers and
districts that have a wider variety of goods and services than the
neighborhood shopping areas. They rely on larger trade areas and
include such uses as department stores, bookstores, furniture
stores, toy stores, apparel shops, restaurants, theaters and non-
retail services such as banks. Examples include Stanford Shopping
Center, Town and Country Village and University
Avenue/Downtown. Non-retail uses such as medical and dental
offices and software development may also locate in this
designation; office uses including software development are
appropriate Downtown. Examples include Stanford Shopping
Center, Town and Country Village and University
Avenue/Downtown. In some locations, residential and mixed use
projects may also locate in this category. Non-residential FARs
range from 0.35 to 2.0.
4 Map L-3: City Structure Show road lines See revised map L-3
5 Map L-6: Land Use
Designations
Correct map for consistency with actual land use Modify the land use designation for the former Hyatt Rickey’s site
to remove the Hotel Overlay (see attached map), so that the
property is designated only Multifamily Residential.
October 2, 2017 2
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6 Programs L-2.4.2 and
L-2.4.3 Focus Program L2.4.2 on housing in Stanford Shopping Center
to reduce confusion.
Put all the language about housing in Stanford Research Park
in one policy-L-2.4.3.
Key language about housing at Stanford Research Park
inadvertently left out of 6.30.17 version of L-2.4.3.
1. Reword L-2.4.2 to read: Allow housing on the El Camino Real
frontage of the Stanford Research Park and at Stanford Shopping
Center, provided that adequate parking and vibrant retail is
maintained and no reduction of retail square footage results from
the new housing.
2. Reword L-2.4.3 to read: Allow housing on the El Camino Real
frontage of the Stanford Research Park. Explore multi-family
housing elsewhere in the Stanford Research Park and near Stanford
University Medical Center (SUMC).
7 Policy L-2.9 Move policy to Goal L-4 Commercial Centers to be with other
retail-related policies.
1. Move Policy L-2.9 to become Policy L-4.2 Preserve ground-floor
retail, limit the displacement of existing retail from neighborhood
centers and explore opportunities to expand retail.
2. Put programs L4.1.1 and L4.1.2 under this policy and renumber
them program LL4.2.1 and L4.2.2
8 Program L4.8.1 Remove reference to “Fry’s site” as the current tenant may not
be in this site for the life of the Comp Plan. Reword to “North
Ventura area.”
Prepare a coordinated area plan for the Fry's site North Ventura
area and surrounding California Avenue area. The plan should
describe a vision for the future of the Fry's site North Ventura area
as a walkable neighborhood with multi-family housing, ground floor
retail, a public park, creek improvements and an interconnected
street grid. It should guide the development of the California
Avenue area as a well-designed mixed use district with diverse land
uses and a network of pedestrian-oriented streets.
9 Policy L-5.4 Reword to remove reference to East Meadow Circle Concept
Plan because the policies of this concept plan encourage the
attraction and expansion of high end technology companies that
is not consistent with Comp Plan growth management policies.
Maintain the East Bayshore and San Antonio Road/Bayshore
Corridor areas as diverse business and light industrial districts with
the approved East Meadow Circle Concept Plan (Appendix Y of this
Comprehensive Plan).
10 Policy L-6.5 Clarify that policy is about views up City streets, not from a street
across private property to the hills
Guide development to respect views of the foothills and East Bay
hills from along public streets corridors in the developed portions of
the City.
11 Program L-6.6.1 Correct wording – City does not have design standards
specifically for mixed use developments.
Modify design standards for mixed use projects to ensure that
mixed use development promotes a pedestrian-friendly
relationship to the street, including elements such as screened
parking or underground parking, street-facing windows and
entries, and porches, windows, bays and balconies along public
ways, and landscaping, and trees along the street. Avoid blank
or solid walls at street level.
October 2, 2017 3
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12 Policy L-7.17 Revise wording to be consistent with EIR mitigation measure.
Add ",and unique geologic features."
Require project proponents to meet State codes and regulations
regarding the identification and
protection of archaeological and
paleontological deposits, and unique geologic features.
13 Policy L-9.10 Redundant with Policy N-2.1. Delete.
Policy N-2.1: Recognize the importance of the urban forest as a
vital part of the city’s natural and green infrastructure network
that contributes to public health, resiliency, habitat values,
appreciation of natural systems and an attractive visual character
which must be protected and enhanced.
L-9.10 Recognize the urban forest as City infrastructure to be
maintained in accordance with applicable guidelines and
requirements. [NEW POLICY] [L138]
14 Program T1.2.2 Revise wording in the last two bullets to be consistent with EIR
Mitigation Measure TRANS-1a.
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
and size:
- 50 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
Require new development projects to pay a
Transportation Impact Fee for all those daily 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.
October 2, 2017 4
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15 Program T1.12.3 Revise to start “Work with VTA to…” to clarify that collaboration
is needed on any study regarding bus service.
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.
16 Program T2.3.1 Clarify that VMT/LOS program is not inconsistent with SB 743
requirements.
When adopting new CEQA significance thresholds for VMT for
compliance with SB 743 (2013), adopt standards for vehicular LOS
analysis for use in evaluating the consistency of a proposed project
with the Comprehensive Plan, and also explore desired standards
for MMLOS, which includes motor vehicle LOS, at signalized
intersections for use in evaluating the consistency of a proposed
project with the Comprehensive Plan.
17 Program T4.2.1 Change to a Policy to be consistent with EIR mitigation measure
TRANS-8.
Program T4.2.1 Policy T4.3: Identify specific improvements that can
be used to discourage drivers from using local, neighborhood
streets to bypass traffic congestion on arterials.
18 Policy T-5.12 Reword to reference diverse bike types, not just trailers. 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 bicycle 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.
19 Policies and Programs
under Goal T-8,
Regional Collaboration
and Coordination
Revise to eliminate redundancy and improve readability and
usability.
Policy T-8.1: Engage in regional transportation planning to reduce
congestion and reduce single-occupant vehicle trips, 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.
Program T8.6.21.2.2: Advocate for improved connectivity to
transit to serve workers who live in the South Bay and work in
Palo Alto.
Policy T-8.2 Participate in regional planning initiatives for
the rail corridor and provide a strong guiding voice.
Policy T-8.3 Collaborate effectively with and engage in
October 2, 2017 5
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regional partnerships and solutions with a range of stakeholders,
including regional agencies, neighboring jurisdictions and major
employers, on issues of regional importance such as traffic
congestion, reduced reliance on single-occupant vehicles and
sustainable transportation.
Program T8.3.1: Continue to participate in regional efforts to
develop technological solutions that make alternatives to the
automobile more convenient and thereby contribute to reducing
congestion.
Policy T-8.4: Coordinate with local and regional agencies and
Caltrans to support regional efforts to maintain and improve
transportation infrastructure in Palo Alto, including the Multi-Modal
Transit Center.
Policy T-8.5 Support the efforts of MTC to coordinate
transportation planning and services for the Mid-Peninsula and the
Bay Area that emphasize alternatives to the automobile.
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. (Comp Plan Draft EIR Mitigation
Measure Trans-3b)]
Program T8.6.1: Advocate for provision of a new southbound
entrance ramp to Highway 101 from San Antonio Road, in
conjunction with the closure of the southbound Charleston Road
on-ramp at the Rengstorff Avenue interchange in Mountain
View.
Policy T-8.7: Support the application of emerging freeway
information, monitoring and control systems that provide non-
intrusive driver assistance and reduce congestion. (Comp Plan Draft
EIR Mitigation Measure Trans-3b)]
Policy T-8.8: Where appropriate, support the conversion of existing
October 2, 2017 6
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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. (Comp Plan Draft EIR Mitigation Measure Trans-3b)]
Policy T-8.9: Support State and federal legislation to reduce motor
vehicle emissions, noise and fuel consumption.
Policy T-8.10: Support plans for intra-county and transbay transit
systems that link Palo Alto to the rest of Santa Clara County and
adjoining counties. Ensure that these systems and enhancements
do not adversely impact the bay.
Program T8.10.1: Work with regional transportation providers,
including BART and Caltrain, to improve connections between
Palo Alto and the San Francisco International Airport and
Norman Y. Mineta San Jose International Airport.
Policy T-8.11: Support regional bicycle and pedestrian plans, to
complete including development of the Bay Trail, and the Bay-to-
Ridge Trail, and the Santa Clara County Countywide Bicycle System.
Policy T-8.12 Support the development of the Santa Clara
County Countywide Bicycle System, and other regional bicycle
plans.
20 Program N4.7.2 Change to a policy for consistency; insert new policy
number and renumber subsequent policies and programs under
Goal N-4.
Program N4.7.2 Policy N-4.9: Work with neighboring jurisdictions
and regional agencies to protect groundwater.
21 Program N5.1.2 Change to a Policy to be consistent with EIR mitigation measure
AIR-2c.
Program N5.1.2 Policy N-5.5: 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.
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22 Policy N-5.5 Add for consistency with EIR mitigation measure AIR-3c. NEW POLICY: 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.
23 Program N6.12.1 Add an “also” to separate two ideas in this program. Program N6.12.1: Continue working to reduce noise associated with
operations of the Palo Alto Airport. Also, eEnsure compliance with
the 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
airport.
24 Program N6.11.1 Revise to reference pertinent industry standards for consistency
with EIR mitigation measure NOISE-5a.
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.
[(NEW PROGRAM)(Comp Plan Draft EIR Mitigation Measure NOISE-
1c, 5a)] [N152]
October 2, 2017 8
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25 Safety narrative Add description on location and extent of utilities to narrative UTILITIES
In Palo Alto, utility services are provided by The City of Palo Alto
Utilities (CPAU), a city-owned utility. Today, CPAU provides six
services that include electric, fiber optic, natural gas, water and
wastewater services. Initially formed in 1896 with the installation of
a water supply system, CPAU expanded between the years 1898
and 1917 to include wastewater, electric, and natural gas
distribution services; in 1996 it began to provide fiber optic
services. Through its mission to provide safe, reliable,
environmentally sustainable and cost effective services to Palo Alto
residents, CPAU offers cost-effective service rates to residents and
re-invests proceeds to support other City community services and
facilities. For example, CPAU provides financial support to the Palo
Alto library and parks system, as well as to support police and fire
protection services.
26 Program S-1.10.3 Reword for clarity to: “…including those that address evolving…” Implement the mitigation strategies and guidelines provided by the
LHMP, including those that address evolving hazards resulting from
climate change.
27 Program S- 2.8.3 Change to Policy since this is a “specific statement of guiding
action that implies clear commitment.”
Program S-2.8.3 Policy S-2.9: Partner with appropriate agencies to
expand flood zones as appropriate due to sea level rise, changes in
creek channels, street flooding or storm drain overload due to
increased likelihood of extreme storm events caused by climate
change.
28 Glossary Update the definition of Infill to cover various types of possible
sites, not only vacant land.
Infill: Development of vacant or underused lots in built up sites or
areas.
ERRATA TABLE /EIR CORRECTIONS AND CLARIFICATIONS
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ID Figure Error to Be Corrected Recommended Change
1 Figure 2-2
(Same as Map L-6)
Revise for consistency with Map L-6 in the Comprehensive Plan
Update
Modify the land use designation for the Hyatt Rickey’s site to
remove the Hotel Overlay.
RESPONSES TO COMMENT S RECEIVED SEPTEMBER 29, 2017
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There were a number of comments made at the Planning and Transportation Commission (PTC)
meeting on September 29, 2017 that staff did not have an opportunity to respond to on the
record. This attachment provides a brief summary of the comments and staff’s responses.
Comment 1: One or more commenters suggested that the proposed Comp Plan
would allow a significant increase (or “double”) the rate of office growth and that
proposed growth management strategies are inadequate.
The proposed Comprehensive Plan lowers the non-residential growth cap in the current
Comprehensive Plan to reflect past development and improves on that cap by focusing
on Office/R&D rather than uses the City wants, like retail. The Plan does not propose or
allow more rapid office growth than the current Comprehensive Plan and includes
policies and programs to focus on housing growth, rather than job-generating office
uses. More detail is provided below.
Currently, the City tracks non-residential square footage under Policy L-8 of the 1998
Comp Plan, which contains a city-wide cap on non-residential development in nine
“monitored areas.” Based on the data collected under Policy L-8, there were 24,886,880
square feet of non-residential development in Palo Alto in May 1987. From May 1987
through September 2015, a total of 3,805,020 square feet of non-residential space was
added, including both square footage subject to the growth monitoring provisions under
Policy L-8 and square footage that was not subject to monitoring, such as the SUMC
expansion, which was approved in 2012 under the 1998 Comp Plan and is exempt from
Policy L-8. The average rate over the 28 years was about 117,000 sf per year.
The proposed Comp Plan would replace Policy L-8 with a new non-residential growth
management policy, Policy L-1.9. This policy would establish a Citywide cap of 1.7
million new square feet of office/R&D development, using January 1, 2015 as the
baseline. This cap is based on the allowed square footage remaining under the existing
Policy L-8 cap; it does not increase the Policy L-8 cap currently in place. The Final EIR
Preferred Scenario talks about 3M square feet because it adds the 1.3 M sq. ft. of
approved space that is still being built out at SUMC to the new 1.7M cap. Over the 15-
year horizon of the Comp Plan (January 2015 to 2030), an allowance of 1.7 million
square feet equates to an average of 113,333 sf per year, which is lower than the annual
average over 28 years described above.
RESPONSES TO COMMENT S RECEIVED SEPTEMBER 29, 2017
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Actually seeing this much square footage in a year is unlikely because the City Council is
also proposing to perpetuate (by ordinance) a 50,000 sq. ft. annual limit on new
office/R&D development in parts of the City. In both cases – with the cap in Policy L-1.9
and the annual limit -- the focus is on net new office/R&D space, so any conversion of
space from warehouse or retail to office/R&D will count towards the cap/limit, which
has not been true in the past.
Table 1. Non-Residential Growth Comparison
1998 COMP PLAN
(POLICY L-8)
PROPOSED COMP PLAN
(POLICY L-1.9)
Non-residential square footage 3,270,000 1,700,000
Number of years 28 (1987-2015) 15 (2015-2030)
Average rate of increase per year 116,786 113,333
Source: Planning & Community Environment, September 2018
There are four important differences between the way growth is monitored under Policy L-8
and how it would be monitored under Policy L-1.9 in the proposed Comp Plan. Specifically:
Policy L-8 monitors all types of non-residential development, including uses that
might be desirable for the community, such as retail. Policy L-1.9 focuses specifically
on office/R&D development as the use the City is most concerned to monitor.
Policy L-8 only counts net new non-residential square footage towards the cap. So a
project that removes 5,000 square feet of retail and adds 10,000 square feet of
office is recorded as an addition of only 5,000 square feet. Policy L-1.9 would count
the full 10,000 square feet of office towards the cap.
Policy L-8 only applies to the “monitored areas” identified on Map L-6, so the data
does not present a full picture of non-residential development in the City. Policy L-
1.9 covers the entire City (but continues the exemption of medical offices associated
with SUMC).
Policy L-8 is silent on what to do as the growth cap is neared or reached. Policy L-1.9
is supported by a new Program, L1.9.1, to re-evaluate the cap when entitled
office/R&D square footage reaches 67% of the allowed increase.
Please also see Response to Comment PUB14-02 in the Final EIR (p. 5-93). The commenter
suggests a long-term historical average of 94K square feet per year between 1989 and 2015,
illustrating that it’s possible to get different annual averages depending on the years used
for the analysis.
These various calculations does not change the value or effectiveness of Policy L-1.9 in the
proposed Comp Plan carries forward the existing non-residential growth cap in Policy L-8
with no increase, while expanding the coverage of the cap Citywide, targeting it to
office/R&D development, and making it more restrictive by counting all new square footage
rather than only net change. Staff believes the cumulative effect of these policy refinements
RESPONSES TO COMMENT S RECEIVED SEPTEMBER 29, 2017
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will be more aggressive, rather than less aggressive, management of non-residential growth
in Palo Alto – particularly when combined with a new annual limit ordinance and with
policies and programs aimed at supporting the development of housing. For example,
proposed Program L2.4.5 proposes zoning changes to support mixed use with retail and
residential -- not office, and Program L2.4.4 proposes converting commercial development
potential (floor area ratio or FAR) to residential FAR.
Comment 2: One or more commenters suggested that the Comp Plan does not
identify funding mechanism to mitigate the traffic impacts of future growth.
The proposed Plan (and the EIR) present policies (and mitigation) to require new
development to adopt and implement TDM plans aimed at meeting aggressive performance
standards specifically targeted to geographic areas of the City. Consistent with Program T-
1.2.2, new development projects would be required 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.
As noted in the staff report, City staff is recommending that the Council direct staff to
prioritize implementation of the updated impact fee program (called for in Program T-
1.25.1), and is hoping to bring a draft nexus study forward for review by the Council’s
Finance Committee at the end of November.
In addition, the proposed Comp Plan includes an entirely new section on funding
transportation improvements. Policies T-1.25, T-1.26, and T-1.27 guide the City to pursue a
range of funding opportunities; to collaborate with adjacent communities to ensure that
Palo Alto and its immediate neighbors receive their fair share of regional transportation
funds; and to advocate for transportation regulatory changes, such as an increase in the
gasoline tax.
The Comp Plan is long-range policy guidance document; the City also does many things
outside of the Comp Plan to manage its budget and plan for capital improvements, and
transportation funding also comes to the City from federal, State, regional, and County
sources. For example, Palo Alto will receive funds from Measure B, a countywide sales tax
approved by voters in November 2016 that are anticipated to be used to fund Caltrain
grade separation and other transportation projects and programs.
Comment 3: One or more commenters suggested that the EIR does not assume an
increase in water use, even though it assumes more housing and office development.
The EIR shows an increase in water use in the City and Sphere of Influence under all 6
scenarios. However, for the City limits only, the EIR anticipates a decrease in demand from
existing conditions by 2030. The EIR analyzes future water use in Chapter 4.14, Utilities and
RESPONSES TO COMMENT S RECEIVED SEPTEMBER 29, 2017
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Service Systems, in both the February 2016 Draft EIR and the February 2017 Supplement to
the Draft EIR. The Final EIR includes Table 2-4, which shows future water demand under all
6 scenarios, as well as the Preferred Scenario, at the bottom of page 2-17. Table 2 below is
an excerpt of that table.
Table 2. Existing and Projected Future Water Use
Utilities Impacts 2014 Existing Conditions
Preferred Scenario
Low End of Range High End of Range
City Water Demand (GPD) 3,706,077,880 3,647,353,578 3,647,621,801
City & SOI Water Demand
(GPD) 4,230,635,205 4,485,665,218 4,485,933,441
City Water Demand
Acre-Feet/Year (AFY) 11,374 11,193 11,194
City & SOI Water Demand AFY 12,983 13,766 13,767
Source: Final EIR, August 2017
Table 2 from the EIR shows an increase in water use in the City and SOI under all 6
scenarios. However, for the City limits only, the EIR anticipates a decrease in demand
from existing conditions by 2030. This conclusion may be non-intuitive, but, as is
required by law, the projections in the EIR were developed in consultation with City of
Palo Alto Utilities staff and are based on the projections of the City’s 2015 Urban Water
Management Plan (UWMP), adopted unanimously by Council in June 2016 (Resolution
9589).
The 2015 UWMP includes data showing the City’s potable water use since 1988 and a
projection of water supplies through 2040. Present water consumption at its lowest
level in the more than 25-year history covered in the UWMP. The reduction in water
consumption is the result of state mandated water reductions and permanent water
conservation measures implemented during the past 25 years, and these trends are
expected to continue. The 2015 UWMP cites the following reasons for its projections
that future water use will remain flat and that per capita water use will continue to
decline over time:
Many permanent water use changes, including landscape conversion, occurred
as a result of rebate programs and public outreach,
Public attitudes regarding water use are shifting
New construction in every sector is subject to increasingly stringent regulations
regarding water‐using appliances and fixtures.
Based on these factors, the UWMP anticipates total water demand decreasing from
10,177 acre-feet/year (AFY) in 2015 to 10,108 AFY in 2040. See pages 39 through 42 of
the 2015 UWMP for a detailed discussion of future water demand.
RESPONSES TO COMMENT S RECEIVED SEPTEMBER 29, 2017
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Comment 4: In noting that the Comprehensive Plan should support additional
affordable housing, one commenter stated that the Council recently lowered housing
impact fees.
The Council updated housing impact fees earlier this year, adding a fee on market rate
rental apartments and increasing the fee on office/R&D from around $20/ft to $35/ft.
The earlier fees and the new fees are summarized in Table 3, below.
Table 3A: Housing In Lieu and Housing Impact Fees for Residential Uses
Table 3B: Non-Residential Housing Impact Fees
Prior to 6/19/2017
(per sq. ft.)
As of 6/19/2017
(per sq. ft.)
Hotel
$20.37 $20.37
Retail, Restaurants and Other Non-
Residential Uses $20.37 $20.37
Office, Medical Office and
Research and Development $20.37 $35
Source: Planning & Community Environment, September 2017
In Lieu Fees
(For Residential Ownership Projects)
Prior to 6/19/2017
As of 6/19/2017
(per sq ft)
Single Family Detached Home 7.5% of the sales price $75
Single Family Attached Home 7.5% of the sales price $50
Condominiums 7.5% of the sales price $50
Impact Fees
(For Residential Rental Projects) None $20