HomeMy WebLinkAboutStaff Report 8474
City of Palo Alto (ID # 8474)
City Council Staff Report
Report Type: Action Items Meeting Date: 12/4/2017
City of Palo Alto Page 1
Summary Title: Stanford GUP 2018: DEIR Comment Letter
Title: Review and Provide Direction to Staff Regarding City Comments on the
Draft Environmental Impact Report for the Stanford General Use Permit
(GUP) Application to Santa Clara County
From: City Manager
Lead Department: Planning and Community Environment
Recommendation
Staff recommends that Council review the draft comment letter in Attachment A and provide
input regarding City comments on the Draft Environmental Impact Report analyzing Stanford
University’s 2018 General Use Permit by Santa Clara County.
Background
In November 2016, Stanford submitted an application to Santa Clara County (County)
requesting an update of its General Use Permit (GUP), as well as minor revisions to the Stanford
Community Plan and changes to some of the on-campus zoning regulations. The Stanford GUP
application sets forth a conceptual development plan in County jurisdiction through a 2035
planning horizon. The project requires the preparation of an Environmental Impact Report (EIR)
and the City submitted a letter in response to the Notice of Preparation earlier this year.
(Attachment B) Santa Clara County as the lead agency released a Draft EIR
(www.scc.org/sites/dpd/Programs/Stanford/Pages/GUP2018_aspx) for a 60-day public review
period on October 6, 2017. The comment period was scheduled to end December 4, 2017,
although the City requested an extension to submit a final comment letter in order to provide
adequate time, not only for the City but community members.
A cross-departmental group of City staff, together with City consultants retained to conduct a
technical review of the Draft EIR, contributed to the preparation of the draft comment letter in
Attachment A. The letter includes a cover letter highlighting some major issues with the GUP
application and the EIR, as well as technical comments developed by City consultants. The
City of Palo Alto Page 2
technical comments are arranged by topic and include a separate technical review of the
transportation analysis. In addition to raising technical comments, which the City expects the
County to respond to and address in the Final EIR, the letter identifies broader community
concerns with respect to a number of issues. Staff expects these concerns to be addressed by
the County either through negotiation among the various parties involved and/or through
conditions of approval.
The County has hosted several meetings to receive community input on the project and DEIR.
The County has made presentations to the City’s Planning and Transportation Commission
(PTC) and City Council. The PTC last discussed and commented on the DEIR on November 8th.
Most of those comments have been incorporated in some form in the attached letter. One
comment that has not been incorporated in the letter thus far relates to an observation that
Stanford appears to be purchasing residential property in the College Terrace neighborhood. A
follow-up comment expressed concern regarding the loss of property tax not only to the school
district, but also to the City when Stanford-owned properties are used to house faculty or
students, which under certain circumstances, can be exempt from paying property tax. Council
can advise staff if the Council desires this discussion point to be included in the comment letter.
Timeline
The City Council is being requested to review the attached letter and provide direction to staff
for transmittal of a final letter to Santa Clara County. The County expects to release a Final
Environmental Impact Report (FEIR) for review by the City and public in the spring of 2018.
They expect that the Board of Supervisors will be reviewing the FEIR and the project application
during the summer of 2018.
Environmental Review
Submittal of comments on a Draft EIR is not a project under CEQA,
Under Section 15381 of the CEQA Guidelines and Section 21069 of the CEQA Statute, the City of
Palo Alto is a ”responsible agency”, which is a public agency, other than the lead agency (Santa
Clara County), responsible for carrying out or approving components of the project. Items
requiring City approval include any physical improvements within the City limits - including
mitigation measures – as well as any agreements or contracts between the City and the
University and/or County related to implementation of the Stanford 2018 GUP.
Attachments:
A: Stanford 2018 GUP Draft EIR Comments (DOCX)
B: Stanford GUP NOP Comment Letter March 2017 (PDF)
Page 1 of 3
November 20, 2017 DRAFT for City Council Review
CITY LETTERHEAD
DATE
Kirk Girard, Director
Department of Planning and Development
Santa Clara County
c/o David Rader & Kavitha Kumar
Santa Clara County Planning Office
70 W. Hedding Street
7th Floor, East Wing
San Jose, CA 95110
RE: Stanford University 2018 General Use Permit Draft Environmental Impact Report
Dear Mr. Girard & Staff,
The City of Palo Alto appreciates the opportunity to comment on the Draft
Environmental Impact Report (EIR) analyzing Stanford University’s proposal to add 2.275M
square feet of academic and academic support (non‐residential) space and 3,150 dwelling
units or beds, and 40,000 square feet of additional building space to their campus between
2018 and 2035. We also want to thank you and other County representatives for attending
meetings of our City Council our Planning & Transportation Commission over the last
couple of months and for convening related community meetings in Palo Alto.
The City of Palo Alto has both technical comments on the Draft EIR and concerns
about the University’s proposal. Both are outlined in the attached list of comments, and we
would appreciate a detailed and substantive response to all of these points. A number of the
City’s comments for the Notice of Preparation (NOP) have not been satisfactorily addressed in
the Draft EIR and remain at issue, and some of the City’s concerns will require the County to
modify or attach meaningful conditions of approval to the ultimate approval action.
The issues of primary concern to the City are briefly highlighted below:
A. Fire Services. As of the date of this letter, Stanford University is not under a going
forward contract with the City of Palo Alto for fire protection and suppression, or
emergency medical services (EMS). Stanford cancelled their contract with the City
as of October 2015 and both parties have been extending the prior contract for
short periods of time (6 to 12 months) while attempting to negotiate a
successor agreement.
Page 2 of 3
November 20, 2017 DRAFT for City Council Review
Stanford has not identified a viable or sustainable fire protection and suppression
and EMS model or provider other than the City of Palo Alto. The University does
not have access to the State of California Master Mutual Aid Agreement for fire
protection and suppression – access is only available via public fire departments
who are participants in the agreement – and would have access to EMS ambulance
transportation services only through Santa Clara County Ambulance unless a new
contract can be executed in short order (which the City is interested in doing).
B. Open Space Protections. While we understand the University is not currently
proposing development outside the Academic Growth Boundary (AGB), we are
concerned that current open space protections (in the form of the requirement for
a super‐majority vote to amend the AGB) will expire in 2025 and are not proposed
for extension or replacement. This is not acceptable to the City of Palo Alto and
undermines both the validity of the Draft EIR and the community’s trust that
the University and the County will be appropriately protective of our collective
open space resources. Please extend existing open space protections or be
explicit where growth and development outside the AGB may be proposed so
that it can be appropriately analyzed in the EIR.
C. Housing. The region’s housing crisis (and affordability crisis) will be exacerbated by
any project that proposes to add more jobs and more housing demand than
housing. We urge the County and University to reconsider parameters of the
current proposal and either reduce housing demand or increase affordable housing
proposed within and proximate to the campus.
Also we call upon the County to commit to a partnership with the City regarding
our Regional Housing Needs Allocations (RHNAs) for the 2023‐2030 Housing
Element cycle. The County and the City were successful in seeking an adjustment
whereby the City’s allocation was decreased and the County’s allocation was
increased by 645 units in the 2007‐2014 cycle based on a recognition that the
University was constructing housing within the City’s Sphere of Influence. We ask
for a commitment to this kind of adjustment again, and ‐‐ if an adjustment is not
acceptable to the regional council of governments – we would ask for a
commitment that the County would seek to form a “subregional entity” with Palo
Alto and one or more other cities for purposes of redistributing the RHNA.
D. Upstream Detention & Flooding. The Biological Resources section (but not the
Hydrology section) of the Draft EIR identifies capacity and flood issues in San
Francisquito Creek (page 5.3‐46) and references one or more on‐ and off‐site
detention basins being considered by the San Francisquito Creek Joint Powers
Page 3 of 3
November 20, 2017 DRAFT for City Council Review
Authority. The City requests a full review of existing flood issues in both
watersheds in which the project is located, as well as documentation of the
change(s) in impervious surfaces and runoff volumes. This review/documentation
should lead to an assessment of potential off‐site flooding impacts for the baseline,
project and cumulative scenarios taking into consideration the likely effects of
climate change.
E. Traffic. Stanford’s “no net new trips” goal is in fact a goal not to increase commute
trips in the peak direction by automobiles during one hour per day at defined
cordon locations around the campus. Once again, the University is also suggesting
it may “meet” this goal by using credits from trip reductions achieved outside the
cordon.
The City does not believe this approach is sustainable for the next 20 years and
urges the County to require explicit and effective mitigation such that the
University is required to make contributions to capital improvements at City
intersections and grade separations, and to specify in advance the specific trip‐
reduction measures and transit capacity enhancements they will implement as
mitigation between 2018 and 2035. Without additional detail regarding impacts
from all auto trips at the cordon (i.e. not just peak direction trips, and not assuming
trip credits), and without specific mitigation measures, the City cannot determine
whether the University is effectively addressing its contribution to cumulative
traffic volumes and congestion in our City.
We would be happy to meet with you, Supervisory Simitian, and representatives of
the University if such a meeting would help resolve any of these issues and concerns. If there
are any questions regarding the specific EIR comments attached, please contact our Planning
Director, Hillary Gitelman at Hillary.Gitelman@cityofpaloalto.org.
Sincerely,
Mayor Greg Scharff
Cc Palo Alto City Council City
Manager James Keene
City Attorney Molly Stump
Planning & Transportation Commission Members
Hillary Gitelman/Meg Monroe/File
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 1
Stanford University 2018 General Use Permit
Draft EIR Comments
Introduction to Environmental Analysis and EIR Assumptions
1. 2018 Baseline Assumptions. The additional development comprising the 2018 Baseline
scenario as described on DEIR pages 5‐6 to 5‐7 is not clearly identified or quantified, and it
is not clear whether the 2018 Baseline includes development under construction in
adjacent jurisdictions. The DEIR indicates that the 2018 Baseline Includes all remaining
academic and support development and housing authorized under 2000 General Use
Permit (GUP) that will be built and occupied at time the County considers approval of
2018 GUP. However, this remaining development is not quantified, and there appears to
be conflicting information where quantification is provided. Table 5.15‐12 (page 5.15‐65)
identify 769,354 square feet of academic space and 416 beds under the 2000 GUP that
will be constructed by Fall 2018. As part of the 2018 Baseline description in each DEIR
topical section, the DEIR states that “nearly all remaining academic and academic support
development and remaining housing authorized under the 2000 General Use Permit will
be built and occupied at the time of approval of the proposed 2018 General Use Permit,”
except for the planned Escondido Village (EV) Graduate Residences, which are currently
under construction, but not expected to be occupied until 2020. But the DEIR also
indicates on page 3‐19 that Stanford may not have received project‐specific approval for
construction of all development authorized under the 2000 GUP when the County
considers the proposed 2018 GUP. As a result, it is not clear what development is included
in the 2018 Baseline and whether all pending and proposed Stanford development is
adequately addressed in the DEIR.
The City asks that the Final EIR provide a table and map that clearly identifies the size,
location and construction timing/status of projects that are assumed for the Baseline 2018
scenario. The EIR should also identify any other projects in adjacent jurisdictions that are
included in the 2018 Baseline and include only those that are under construction or that
have received a building permit.
2. Cumulative Impacts. The Final EIR should identify cumulative projects and whether the
cumulative scenario is based on specific projects or growth projections pursuant to CEQA
Guidelines section 15130(b). The basis for the cumulative scenario as described on page 5‐
8 is not clearly defined, and the reader is unable to discern whether all cumulative
development has been addressed in the cumulative analyses. The Transportation and
Traffic section has the best summary of the scenarios evaluated in the DEIR (page 5.15‐61)
and indicates that the cumulative scenario includes completion of development
authorized under the 2000 General Use Permit, including the EV Graduate Residences,
background growth and reasonably foreseeable projects. Yet neither background growth
nor reasonably foreseeable projects are clearly identified.
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 2
The City requests that the DEIR provide a clear identification of cumulative projects and/or
growth in section 5.0 and that the cumulative scenario include and clearly identify:
a. Projected growth in Palo Alto and surrounding communities, including growth
considered in Palo Alto’s Comprehensive Plan update EIR; and
b. All off‐campus approved or planned cumulative development on other Stanford
University owned lands, including off‐site housing, non‐residential uses in East
Bayshore area, Stanford Research Park, University Medical Center, transit center
site, projects outside the Academic Growth Boundary, and Stanford Golf Course.
Project Description
3. Potential Future Changes in Land Uses or Distribution. The DEIR indicates that additional
housing beyond the proposed limit of 3,150 units and/or changes in distribution of
academic, academic support, and housing may be requested by Stanford as a condition of
the permit, subject to additional environmental review and County approval (pages 1‐4
and 3‐20). As indicated in the City’s letter on the Notice of Preparation (NOP), the City is
concerned that the land use intensity identified by development district not change or
increase unless clear performance standards are identified and included as mitigation
measures or conditions of approval of the project. The Final EIR should identify such
performance standards. Since for example, the Historic Preservation Alternative
emphasizes that new development will be pushed to the peripheral areas around the
central campus with potential resulting impacts upon views and tree loss, the flexibility to
transfer uses within development areas under the 2018 GUP raises similar concerns. The
City requests that the Final EIR provide an assessment of the range and magnitude of
potential future changes in the distribution of land uses and potential related impacts,
especially related to visual considerations, tree removal, parking and traffic.
4. Location of Future Development. Future development locations in the DRAPER district
along El Camino Real between the Arboretum and the new graduate housing are not
defined. Without better definition, some environmental impacts of the proposed 200,000
square feet of academic and academic support development on adjacent Palo Alto
neighborhoods cannot be assessed, such as impacts on views and the visual character of
the area, loss of useable open space, tree removal, traffic and circulation associated with
parking changes.
Visual and Scenic Resources
5. Impacts to Visual Character of Palo Alto. As indicated in Palo Alto’s comments on the NOP,
the City is concerned regarding the lack of information on the location/scale of proposed
development and impacts to the visual character of areas adjacent to the City. While the
DEIR generally references Stanford design guidelines and policies, there is no inclusion or
summary of these standards.
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 3
a. The City asks that Final EIR identify a process for City review/consultation on
projects adjacent to the City, including provision of project photo simulations, and
to identify specific performance standards to ensure that the visual character of
the City is not adversely affected, such as: 1) standards for screening development
and/or maintaining vegetated buffer along roads; and 2) specific reference to
County or Stanford Design Guidelines that would address building siting, height,
scale, architectural features, landscaping, screening, etc.
b. To maintain the aesthetic character along El Camino Real, the City requests that
the County include a mitigation that prohibits re‐distribution of housing or
academic square footage to the Arboretum Development District or lands
designated “Campus Open Space”.
6. Views Along El Camino Real. Of particular concern are impacts to views of the campus
along El Camino Real (State Route 82), which provides a view of open space and is a
significant value to Palo Alto as a vegetated buffer between the City and the higher density
development of the central campus. The proposed development of 200,000 square feet of
academic and/or academic support space in the DRAPER development area is not
specified, and current required setbacks do not provide adequate buffers. Alteration
and/or removal of this open space would substantially alter the visual character of the
surrounding area and should be considered a significant impact. Mitigation should be
provided to insure the preservation and continuation of this open view through the 2018
GUP.
7. Lighting Impacts. The City requests that Mitigation Measure 5.1‐4 be modified to include
specific performance standards to ensure that future Stanford development results in no
offsite illumination into adjacent neighborhoods within Palo Alto.
Air Quality
8. Construction Emissions. The DEIR indicates that Stanford agrees to use final California Air
Resources board Tier 4 standards for all construction equipment, chainsaws and pavers
throughout the life of the 2018 GUP. The City asks whether it is feasible/reasonable to
assume that the campus construction contractors will be able to acquire all Tier 4 Final
equipment (except for chainsaws and pavers), and if not the emissions modeling and
analysis should be revised. Given the amount of development anticipated, construction
activities could be ongoing throughout the period from 2018 to 2035.
Cultural Resources
9. Review of Landscape Elements as Potential Historic Resources. Full historic protection of
the Oval, Palm Drive and the Main Gate were not addressed in the DEIR. The EIR should
evaluate these areas to determine whether they are historic resources and/or should be
considered as part of the Main Quadrangle historic block. If found to be a historical
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 4
resource pursuant to CEQA, the area(s) should be included in Mitigation Measure 5.4.1(a‐
e).
Hydrology and Water Quality
10. Groundwater Impacts and Recharge. The section lacks documentation/references for
assumptions and conclusions. Impact 5.9‐4 does not quantify the amount of increased
groundwater use that is anticipated for the 2018 GUP as requested in the City’s NOP letter
or assess impacts on the groundwater basin and vicinity wells as established in the DEIR’s
Hydrology Significance Criterion “b”. While the impact indicates that project operation
could substantially deplete groundwater supplies, there is no supporting analysis, and the
mitigation measure presented addresses monitoring of recharge, not impacts to
groundwater supplies. Because Palo Alto operates municipal water supply wells in the
vicinity, the FEIR needs to provide a full analysis with technical documentation in order to
make a significance conclusion, including addressing the following.
a. Identify whether the project area is within the Santa Clara Valley groundwater
basin or different sub‐basin.
b. Identify other vicinity groundwater wells. Figure 2 of the City of Palo Alto 2015
Urban Water Management Plan indicates the area adjacent to campus contains
groundwater wells.
c. Provide annual monitoring of groundwater levels to determine an annual average
over a sufficient time to include both wet and dry years.
d. Identify the potential amount of increased groundwater use. It is stated that
irrigation needs would not change substantially (page 5.9‐26) without reference to
an actual estimate, and in contradiction with the increase in non‐potable water
use estimated in Appendix Water Supply Assessment (WSA). The WSA (as
summarized in Section 5.16.5) makes an assumption about groundwater demand
that is not supported by the record provided in the baseline setting, in which
groundwater use is shown to have increased substantially in the last extended
drought, consisting of up to 88% of irrigation water demands in FY14‐15. Section
5.16.5 (pgs. 5.16‐16 and 5.16‐17) assumes no change in groundwater supply, and
does not apportion the water demand in drought scenarios between surface water
and ground water. This lack of information prevents a meaningful analysis of how
much groundwater use could increase, and whether it would exceed significance
thresholds.
e. Section 5.16.5 asserts with no supporting evidence that Stanford’s wells can
withdraw up to 1,700 AFY (1.52 mgd) without adversely affecting groundwater
conditions. Given the wells have a combined capacity of pumping capacity of
approximately 4,450 AFY, additional analysis is required to support the impact
conclusions. The analysis and determination of 1,700 AFY as the sustainable yield
needs to be disclosed and available for public review.
f. Most importantly, the EIR should evaluate impacts to adjacent and nearby wells or
groundwater basin due to increased Stanford pumping. The multiple dry year
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 5
scenario under full buildout needs to be addressed with respect to groundwater,
and whether there could be impacts to adjacent wells or the groundwater basin.
g. It is unclear under what circumstances groundwater could be used to meet
potable demands.
h. Assumption that groundwater recharge can only occur in the unconfined zone is
not adequately explained or justified.
11. Storm Water and Flooding. Some of the storm water from the project area is conveyed
through pipes managed by the City of Palo Alto that discharge into creeks managed by
SCVWD. The Draft EIR does not include an analysis that clearly indicates the estimated
runoff flows with and without the project and cumulatively, so it is not possible to
determine the significance of the impact on these collection facilities. This is of particular
concern since the City of Palo Alto’s storm drain system, downstream from Stanford, has
limited capacity at various locations that can result in localized flooding. Secondly, flows
from Matadero Creek discharge into a flood basin located East of Highway 101. This area
is protected by a levee that will need to be improved in the future to mitigate for Sea Level
Rise. Increasing flows into the flood basin would impact the future levee design. The Final
EIR must provide existing and proposed runoff calculations from the project area for both
the 10‐year and 100‐year storm event.
12. Adequacy of Detention Facilities. The DEIR did not respond adequately to the City of Palo
Alto’s request in the NOP to provide information on the current storm water volumes into
the existing detention facilities generated within the Academic Growth Boundary. Further,
how would the added flow from the 2018 GUP development affect the current detention
capacity in the case of a 10-year and 100‐year storm event? Without this information
it is difficult to determine the adequacy of the capacity of current detention basins and
future needs. The Impact 5.9‐6 analysis asserts “the existing detention facilities are
estimated to have the capacity for accommodating an additional approximate 57.0 acres
(2.48 million square feet) of impervious surfaces in the San Francisquito watershed, and
an additional approximate 194.8 acres (8.52 million square feet) of impervious surfaces
in the Matadero watershed.” However, there is no reference to a specific study, such
as the “annual reporting,” that clearly documents and quantifies changes in detention
capacity as a result of identified flows from constructed projects. This information needs
to be provided in the Final EIR to substantiate the DEIR’s conclusions on capacity and
determination that no significant impact would occur. It is unclear to what degree
activities under the 2000 GUP (including Escondido Village Graduate Residences) or other
development added to establish the 2018 Baseline scenario has already used the
additional available capacity. The Final EIR must provide documentation of the change in
impervious surfaces and runoff volumes for existing development including Escondido
Village and any construction completed as part of the
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 6
2000 General Use Permit, the 2018 GUP Project and cumulative scenarios to adequately
assess the impact of increased runoff and the adequacy of detention facilities and
conclusion of a less‐than‐significant impact.
13. Flood Impacts. The City of Palo Alto’s NOP comments include a request for records of past
runoff volumes for the 10‐ and 100‐year storm flow into Matadero and San Francisquito
Creeks. This information was not provided and is essential to determining the significance
of additional storm water flows with the project. The DEIR Hydrology and Water Quality
section does not identify existing flood problems, but relies on existing detention facilities
to control flows. As indicated above in Comment #12, there is no cited drainage study that
documents existing remaining detention capacity or quantifies additional runoff volumes
added for baseline, project and cumulative conditions to substantiate the conclusion that
no offsite flooding impacts will occur. The Biological Resources section does in fact identify
capacity and flood issues in San Francisquito Creek (page 5.3‐46) with one or more on‐ and
off‐site detention basins being considered by the San Francisquito Creek Joint Powers
Authority. The Final EIR must provide a review of existing flood issues in both watersheds
in which the project is located, and in conjunction with the above comment, clearly
document potential off‐site flooding impacts for the baseline, project and cumulative
scenarios.
Noise
14. Sensitive Receptors. The DEIR reports that residences, schools, hospitals, and nursing
homes are considered to be the most sensitive to noise (page 5.11‐8), and sensitive
receptors are described on page 5.11‐25. The DEIR references Figure 5.2‐1 in the Air
Quality section that shows sensitive receptors, however, specific residential receptors are
not identified. This figure should be revised to clearly identify residential neighborhoods,
which are not shown, since there is potential for construction to occur around campus
edges, and the nearest sensitive receptors in Palo Alto are within 80 feet of project
boundaries.
15. Construction Noise Mitigation. DEIR page 5.11‐25 states Mitigation Measure 5.11‐1, which
implements a performance standard, will reduce construction‐noise impacts, where it is
technically and economically feasible to do so, but also suggests that variances may be
permitted. The mitigation measure should specify:
How “technically or economically infeasible” will be determined;
Who has the authority to grant a variance and the process by which a variance
request would be made and reviewed; and
That City of Palo Alto should have the ability to review and comment on
requests for such variances for projects within 150 feet of their boundaries.
Population and Housing
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 7
16. Existing and Projected Housing. The Final EIR should clearly identify/quantify existing on‐
campus student and faculty/staff housing and 2000 GUP units expected to be constructed
and added to the 2018 Baseline in addition to Escondido Village Residences, expected to
be completed after 2018, and additional units in the proposed 2018 GUP. A full accounting
is needed in order to confirm that Stanford has met its housing linkage/ratio (605 new
beds per 500,000 SF of new academic and academic support) with the project and not just
for the increment of growth permitted under the project. As noted earlier, we also
question whether this ratio should be increased given the region’s housing crisis. Please
clarify whether the total campus units include units constructed outside of the academic
boundaries that are referenced on page 5.12‐3.
17. Population Estimates and Growth. Palo Alto has concerns regarding the
population/household size estimates used in the DEIR and impact conclusions.
a. The DEIR concludes that population induced by the project is consistent with
Stanford’s historic annual growth rate, which is not identified in the DEIR. The Final EIR
should identify the historic annual growth rate and the rate with the proposed project,
including the basis for the “Compound Annual Growth Rate” (CAGR) used in the DEIR
to estimate Stanford growth for each population. Also, why is the University’s historic
annual growth rate the appropriate standards of review? Shouldn’t the growth rate be
calculated from the 2000 General Use Permit approval?
b. It does not appear that the population projections included in the City’s current
Comprehensive Plan update have been used.1 The population numbers included in the
Comprehensive Plan Update EIR should be used for considering impacts of population
growth in Palo Alto. The total population resulting from indirect household growth
(graduate students/faculty and their families) in Palo Alto should be identified and
compared to the City’s projected population growth as part of the impact discussion.
18. Off‐Campus Household Formation and Housing Demand. The DEIR (page 5.12‐17)
estimates the indirect off‐site campus housing demand based on off‐campus household
formation derived from Stanford Commute Survey that is not listed in the DEIR
References. The City believes that the County should use another source of data or an
updated objective and statistically valid survey tool to validate findings of the University’s
commute survey. The FEIR should clearly identify how the estimated 2,425 off‐campus
households was derived. Furthermore, the FEIR should also explain the assumption of a
net decrease in 102 off‐campus faculty households since the project’s faculty housing unit
count (550) is less than the increase in faculty (789).
19. Secondary Impacts of Growth. While, the DEIR estimates the number of new households
that would reside off campus, the Final EIR should also clearly identify the secondary
population growth that would occur in the City of Palo Alto as a result (total number of
people per household), as well as the amount of increased population in the City between
1 The Final Environmental Impact Report for the Palo Alto Comprehensive Plan was circulated on August
30, 2017 and was certified by the City Council with their action on the Comprehensive Plan Update on November
13, 2017.
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 8
2015 and the 2018 baseline. The Final EIR should clearly address the impacts of secondary
population growth on housing demand, public service demand, and public school
capacities. This growth is important to quantify for a variety of reasons and undercuts
reliance on a ‘no net trips’ policy focused only on the peak travel direction in the peak
commute hour.
20. Affordable Housing Demand. In its letter of comment on the NOP, the City requested an
assessment of housing demand, including existing and future demand by employees and
students qualifying for below market rate housing. However, the DEIR does not address
the project’s demand for affordable units off campus in Palo Alto. It is expected that a
significant number of graduate students, postdoctoral researchers and staff would need
affordable housing. Taking the Palo Alto number alone, 367 or 5.6% of the City’s projected
household growth between 2015 and 2040 would be from lower paid Stanford graduate,
post‐doctoral, faculty and staff. The City would need to provide an additional 2.3% of its
housing stock in 2040 for low and moderate income units. This would be in addition to the
low‐ and moderate‐income housing need generated by the rest of the City’s population.
This additional Below Market Rate demand generated by Stanford should be assessed in
the Final EIR with regards to effects on the City’s housing supply and the City’s ability to
meet is Regional Housing Needs Allocation (RHNA).
21. Off‐campus Affordable Housing Fees. Under the 2000 General Use Permit, Stanford is
required to provide one on‐campus affordable housing unit or make an in‐lieu payment to
Santa Clara County for each 11,763 square feet of constructed academic development.
a. The Final EIR should identify how many affordable units have been constructed on
campus and how many have been constructed as a result of payment of in‐lieu
fees with the 2018 GUP in order to document whether Stanford is meeting its
affordable housing requirement. Please indicate projects, number of units and
location of affordable housing that have been constructed under this requirement
and the number of affordable units that have been constructed in Palo Alto under
this program.
b. The DEIR states that Stanford will continue contributions to the County‐
administered off‐campus affordable housing program. However, without the
analysis to identify affordable housing needs as requested in Comment #23, the
extent to which these fees actually meet affordable housing needs is not known
and the finding of a less‐than‐significant impact is not substantiated.
c. The basis for DEIR statement that 900 new graduate student units would equate to
approximately 450 affordable housing units that will be credited toward the
County’s RHNA (page DEIR page 5.12‐20) should be explained and substantiated.
Public Services
22. Fire Protection and Emergency Services.
a. The impact analysis does not identify a specific need for new or physically altered
public fire protection/Emergency Services facilities related to Project growth.
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 9
However, no substantial evidence is provided to support this conclusion. The Final
EIR should assess the effect of on‐ and off‐campus growth on response times and
other performance criteria identified in the EIR and provide a clear discussion of
project impacts – will new or relocated facilities be required at build‐out of the
project? The effects of the project on fire and emergency services related wildland
fires also should be addressed.
b. According to the DEIR, replacement and improved fire stations would allow the
Palo Alto Fire Department to adequately serve growth and buildout in the City.
This is based on Stanford’s continued annual fair share payment to the City of Palo
for fire protection services. Stanford and the City are currently in negotiations for a
multi‐year contract with automatic renewal for fire and EMS services, but
agreement has not yet been reached, and thus, the issue of long‐term fire
protection service in not adequately assessed in the EIR. The Final EIR should
evaluate development alternatives for Stanford if agreement on a fire contract
cannot be reached.
c. The Palo Alto Fire Department requests that the following corrections and
clarifications be provided in the Final EIR.
Page 5.13‐1, Add: The PAFD provides fire protection and suppression, and
emergency medical service (EMS), for all areas within the jurisdictional boundaries
of Palo Alto in addition to some of the unincorporated land surrounding the city
limits, including the project site under a services contract. As of the date of the
City’s response, Stanford University is not under contract with the City of Palo Alto
for fire protection and suppression, and EMS. Stanford cancelled the contract as of
October 2015, and both parties have been extending the contract for short periods
of time (6 to 12 months) while attempting to negotiate a successor agreement.
Stanford does not have a viable or sustainable fire protection and suppression, and
emergency medical service (EMS) model or provider other than the City of Palo
Alto. Stanford does not have access to the State of California Master Mutual Aid
Agreement for fire protection and suppression – access is only available via public
fire departments who are participants in the agreement. Stanford would have
access to EMS ambulance transportation services through Santa Clara County
Ambulance.
23. Police Services Impact. The DEIR analysis of police services concludes that the 2018 GUP
would increase demand for service, but would not result in an adverse physical impact
from construction of additional facilities. No evidence is presented about the effect of on‐
/off‐campus growth on police and emergency dispatch services provided by Palo Alto or
performance criteria for these services. The Final EIR should address impacts of Stanford
population growth and new housing on Police Department police response times, staffing,
facilities, traffic enforcement on City streets, and response in mutual aid situations. The
Final EIR should also address indirect impacts associated with increased calls for mutual
aid assistance and associated impact on the Palo Alto Police Department (PAPD)
performance standards for provision of adequate services. The PAPD has concerns
regarding increased calls for PAPD service especially for parking enforcement, traffic
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 10
enforcement on bordering streets, special sporting and other events, and visiting
dignitaries, which should be addressed in the Final EIR. All additional service requests may
lead to the need for additional facilities and these should be identified and analyzed. If the
University intends to rely on new City facilities, the University should contribute to their
cost.
24. Schools Impacts. The DEIR concludes that the project would increase enrollment in local
schools, but would not result in adverse physical impacts from the construction of
additional school facilities that may be needed in order to maintain acceptable enrollment
standards. Of the new housing provided on‐campus, growth in school‐aged children is
associated only with 550 new units of housing for faculty, staff, postdoctoral scholars, and
medical residents. The Final EIR should also address student growth from undergraduate
and graduate students, and from indirect growth of 367 new households in Palo Alto.
Based on the student generation rates presented in the EIR, the project could result in 183
additional students from new households in Palo Alto.
While enrollment data is not presented, the DEIR states that there will be declining
enrollment in PAUSD schools through 2026/27 and given that, there should be remaining
capacity to accommodate project‐generated students. The 2018 Facilities Master Plan is
being prepared and if school expansion is identified, site‐specific CEQA analysis would be
required. The DEIR indicates that school impacts fees are charged and would be paid by
Stanford for new residential and commercial development under the 2018 GUP. However,
the cumulative analysis states that City of Palo Alto Comprehensive Plan update considers
future growth scenarios that would result in PAUSD enrollment exceeding existing
capacity, but no specific growth scenario has been selected and approved. The Final EIR
should be revised to reflect the City’s adoption of the Comprehensive Plan as part of the
cumulative analysis and resulting effects on school enrollment and facilities.
In addition, the Final EIR should acknowledge that the need for new school facilities is
determine in part by the location of new households with school‐aged children.
Representatives of the School district have suggested that concentrating new units along
Quarry Road may contribute to the need for a new school in that vicinity.
Recreation
25. Additional Parks and Recreation Facilities Impacts.
a. There is no explanation for why the 3‐mile radius was used to identify parks and
recreational facilities that may be used by Stanford’s population. The impact and
mitigation was limited to the four parks in the College Terrace neighborhood,
and Table 5.14‐2 omits Peers Park, Bol Park, Juana Briones Park, John Boulware
Park, Robles Park, Ramos Park, Sarah Wallis Park, Johnson Park, Seale Park, Hoover
Park, and Monroe Mini‐Park. These parks are within the three‐mile radius of
campus and should be considered in the EIR and included in any mitigation
for compensation.
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 11
b. The Final EIR should also consider the impacts on paths through Bol Park that are
used for recreation and transportation by Stanford‐residing adults as well as
Stanford‐residing children attending Terman and Gunn schools. These paths are
used on a daily basis by many folks traveling from the Stanford campus. Increased
daily use of this path should be assessed.
c. The DEIR did not mention the substantial current impactor anticipated future
impact of the EV housing and 2018 GUP by Stanford affiliates and their children on
the College Terrace neighborhood library located in one of these parks.
Transportation / Traffic
26. Traffic Impact Analysis. Palo Alto has a number of concerns with the Traffic/Transportation
section, assumptions and analyses. The City’s primary concerns are listed below and are
fully articulated in the attached Technical Memorandum from Hexagon Transportation
Consultants who reviewed the DEIR as part of the City’s review. The City requests that all
of the comments presented in the Hexagon memo be addressed as part of the City’s
comments on the DEIR. A summary of the City’s concerns include:
a. There are several concerns with the “No Net New Commute Trips” program
wording, methodology and feasibility. The three key areas of concern are with the
definitions of the peak periods to be monitored, the direction of travel to be
monitored, and the unlimited use of trip credits to meet the goal. A particular
concern that underlies the entire model is the feasibility of further reducing single‐
occupant vehicle trips that would be needed in order to meet the goal for the
development in the 2018 GUP.
b. Given the current experience based on the 2000 GUP development, there is
concern about the Trip generation rate being based on traditional peak periods
that potentially underestimate impacts of project trips and traffic impacts given
the existing and growing level of off‐peak University trips.
c. The analysis relies on mass transit support to meet the No Net New Commute
Trips goal, but the assumptions for adequacy of transit capacity and performance
analysis for transit and Caltrain are not entirely accurate.
d. The project proposes to construct all parking for the 2000 GUP plus a 2,000 space
parking reserve, but does not address how this will affect the University’s TDM and
trip reduction goals.
e. Further evaluation is needed for specific intersections, including the Caltrain grade
separations including at Alma and Charleston, regional impacts including freeway
segments, and cumulative impacts, which may affect levels of significance as well
as the need for more mitigation.
f. The EIR does not analyze the effects of City programs to manage on‐street parking
in the vicinity of the campus and on Margarita routes on the current and future
effectiveness of current and future TDM programs relied on to meet the No New
Net Commute Trips goal.
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 12
27. Impacts if No Net New Commute Trips Goal Not Met. As noted earlier, the city believes
that he county should revisit how the No Net New Commute Trips policy is implemented.
Assuming changes are made the EIR should address whether the Air Quality, Greenhouse
Gas Emissions, and Noise analyses will need to be revised.
28. Safe Routes to School. The Final EIR should identify and describe the existing safe routes to
schools activities, which includes crossing guards at busy intersections. The Final EIR
should assess impacts and possible decrease of performance as a result of project traffic in
accordance with the Transportation/Traffic Significance Criterion “f” cited on page 5.25‐54
of the DEIR.
Miscellaneous DEIR Text Corrections
29. EIR Corrections. The Final EIR should make the following corrections.
a. Page xv: "OEM California Office of Emergency Management" should be deleted
(see Cal OES)
b. Page 1‐33: Protection and Maintenance of Emergency Service Access and Routes.
That should be changed to include the Palo Alto Police Department (which runs the
9‐1‐1 center for both Palo Alto and Stanford).
c. Page 5.8‐30, Change "County OEM" to "County OES"
d. Page 5.8‐33, References should also include: City of Palo Alto Emergency
Operations Plan, available on:
http://cityofpaloalto.org/services/public_safety/plans_and_information/ and City
of Palo Alto Threat and Hazard Identification and Risk Assessment (THIRA),
available on: http://cityofpaloalto.org/thira
f. Page 5.13‐2:
Remove: one Rescue truck (at Station 2) for vehicle accidents, hazardous
materials and technical rescues, and search and rescue at fires.
Modify: two advanced life support ambulances (at Stations 1 and 2) that
respond to all medical incidents, and are also included in fire, rescue, and
vehicle accidents and hazardous materials incidents, and one cross‐staffed
ambulance (at Station 4) that responds to medical incidents when the
ambulances from Stations 1 and 2 are not available. (City of Palo Alto, 2015).
g. Page 5.13‐3, Modify the sentence to read: In FY 2016, PAFD arrived at 89 percent
of fire emergencies within eight minutes, 92 percent of EMS calls within eight
minutes, and placed a paramedic at EMS calls within 12 minutes, 99 percent of the
time.
h. In Palo Alto, the Police Department funds 29 crossing guards for the City on school
commute routes. (This fact was left out of the text on page 5.13‐4.)
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 13
Other Issues To Be Addressed
There are other changes that will occur in Palo Alto as a result of the Stanford 2018 GUP project
that will impact our community. The following issues should be a part of Santa Clara County’s
project approval.
1. Long‐Term Stanford Growth and Protection of Foothills. An updated sustainability study
should be prepared by Stanford to define the next ‘phase’ of development and the horizon
of that plan, which should be completed and adopted prior to 2025. While Palo Alto has
recognized and commended Stanford’s commitment to the campus’ Academic Growth
Boundary (AGB), the City has serious concerns regarding the potential change to the AGB
and future protection of foothills from development. Palo Alto prefers and requests that
the commitment to the AGB be renewed as part of the 2018 GUP to ensure protection of
the foothills open space lands.
2. Commitment to Affordable Housing. Stanford is making a real commitment to provide
housing on campus within the AGB to house all undergraduate students, and some faculty,
graduate students, postdoctoral students and some staff. However, it is clear that these
plans will not provide housing for all those in these groups. Stanford should pay a housing
development fee to the County to assist receiver communities with providing housing for
this spillover Stanford population. This would be in addition to fees for affordable housing
Stanford has already agreed to pay if they do not meet their affordable housing need on
campus. Further, based on Stanford’s proximity, the County should share some of the
City’s RHNA allocation in the 2023‐2030 housing cycle.
3. Sharing Costs of Needed Improvements. Because of the close interface with the Central
Campus area, there are a number of facilities provided by the City that will be impacted by
the build‐out of the 2018 GUP. Sharing of the costs arising from campus interface with the
City are focused on:
a. Transportation: In the 2000 GUP there were two intersections that Stanford
committed to improve outside of those shown to also be impacted and addressed
in the No Net New Commute Trips model. The reason for this appeared to be
based on future projects. In the same fashion there are two projects that are
critical to the Palo Alto community based on immediate need and future impact of
the Stanford growth on Caltrain
i. Grade separation at all crossings in Palo Alto. Grade separation will
increase the safety of the intersections, improve through bicycle,
pedestrian and traffic at all intersections and improve Caltrain service
relied on by Stanford for access alternatives to SOV.
ii. Improvement to the Palo Alto Intermodal Transit Center to accommodate
increased bicycle and bus volumes generated by Stanford’s TDM model as
well as facilitating the 8 car trains that the DEIR indicates will be necessary
to meet the Stanford impact on Caltrain ridership demand with the 2018
GUP project.
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 14
b. Recreation. The DEIR indicates that Stanford has offered to pay the City for on‐
campus resident student and faculty use of the four parks in College Terrace. The
city believes that the payment offered ($300,000) is understated because as a one‐
time fee, it will not address the impact and needed future maintenance at these
and other parks caused by Stanford students and faculty and their families over
the 17 years of the 2018 GUP. Second the fee offered fails to address the fact that
in one of the heavily used parks there is a neighborhood library impacted by the
use of families associated with Stanford. The City Librarian indicates that the
renovation costs to expand the current 2,392 square foot building to 4,860 square
feet would be $617,000 to $950,180 this is based on Sunnyvale and Newark
studies of $250‐385/SF and assumes the entire building would need to be used for
library purposes because of the anticipated increase in service resulting from the
2018 GUP when combined with the EV housing project.
c. Bicycle Improvements. Stanford has offered to contribute to one bicycle
improvement in Palo Alto: Bol Park Trail. Despite the figure in the DEIR, the Bol
Park Trail has not been designed. Part of the existing trail will be located on a
shared pathway parallel to the street on Hanover Street. Currently, improvements
on Page Mill Road will result in the installation of a signal at Page Mill and Hanover
Street. However, the improvement to the Bol Park Trail will require modification to
this signal for bicycles and pedestrians. The funding offered by Stanford ($250,000)
will just cover the cost of the modification to the signal. Since this trail is a
connection between Stanford’s main campus and the Stanford Research park and
can be a part of the TDM measures for the No Net New Commute trips, the City
feels that Stanford should make a greater contribution to the project including:
dedication of right of way under the existing separated pathway on Hanover Street
and contribution of funds to make the necessary upgrade of the Hanover pathway
so that it meets current safety standards.
d. Safe Routes to School. Currently Palo Alto, the Palo Alto Unified School District, the
Palo Alto PTA, and Stanford work cooperatively on making necessary
improvements to provide the safe routes to school, particularly for Escondido and
Nixon elementary schools. If an additional school is provided near Sandhill Road
for students living in University housing on that side of campus, this cooperation
should be extended to access to any future school site as well. Currently,
Stanford’s funding for agreed improvements for safe access to schools has not
been fully implemented. The City asks that Stanford create an annual budget
based on the agreed work program for future improvements that benefit Stanford
faculty, employees, staff and graduate students with children.
4. No Net New Commute Trips. The City of Palo Alto requests that Santa Clara County (lead
agency) revise the No Net New Commute Trips policy and monitoring program. Members
of the Palo Alto community experience traffic congestion on a daily basis that can be
attributed to students, faculty and staff of Stanford University. If the County wants
evidence of this, it should collect data when Stanford is in session, and when Stanford is
not in session. The data will show that traffic congestion is noticeably better when
City of Palo Alto Draft Comments – November 20, 2017
Stanford University 2018 GUP DEIR Page 15
Stanford is not in session and validate community members perspective that the current
“no net trips” program is not working.
As a legal matter, if the “no net trips” policy is expected to function as mitigation, it should
be revised to address all vehicle trips entering and exiting the campus during the peak
hours, and Stanford should not be able at apply unlimited credits for trip reductions
outside the cordon. Certainly the cordon Credit Area should not be expanded. The
County should identify specific mitigation measures to reduce vehicle trips and the
University should be required to implement or fund those measures as well as making fair
share payments to operational and capital improvements needed to address its
contribution to regional congestion. The effectiveness of all mitigation should be
quantified.
5. San Francisquito Creek Joint Powers Authority. Stanford should be required to coordinate
and cooperate, including funding, with the San Francisquito Creek Joint Powers Authority
to provide meaningful large‐scale upstream detention facilities to attenuate and manage
flows in San Francisquito Creek.
Technical Memorandum
Date: November 13, 2017
To: Stephanie Strelow, Dudek
From: Gary Black, President, and Jane Clayton, Associate
Subject: Review of Stanford 2018 General Use Permit Draft Environmental Impact Report
on Behalf of the City of Palo Alto
Hexagon Transportation Consultants, Inc. has reviewed the Draft Environmental Impact Report
(DEIR) and the supporting Transportation Impact Analysis prepared for the 2018 General Use
Permit (GUP) application filed by Stanford University with the Santa Clara County Planning Office. In
order to prepare this letter, we have also reviewed the Project Description and Background
Conditions Report included in the 2018 GUP application, the 2015 and 2016 Stanford University
Traffic Monitoring Reports, and comments made at meetings of the Planning and Transportation
Commission (8/30/17 and 11/8/2017) and the City Council (10/16/17). We have conducted this
review at the request of the City of Palo Alto and have paid particular attention to the areas included
in the City’s comment letter for the Notice of Preparation (NOP) related to transportation and
circulation. We have also reviewed all of the transportation-related impact findings and the proposed
mitigation measures for their adequacy.
The development proposed in Stanford’s 2018 GUP application includes 2.275 million square feet of
academic and academic support space, 3,150 dwelling units or beds (of which 550 units may be
used by faculty, staff, post-doctoral fellows, or medical residents), 40,000 square feet of space for
child care centers and facilities for the university’s commute alternatives program, and a parking
supply reserve of 2,000 spaces. Stanford proposes continuation of the “no net new commute trips”
goal included in the 2000 GUP, which is defined as no additional trips above a measured base level
during the peak commute time in the campus commute direction (inbound towards campus in the
AM peak hour and outbound from campus in the PM peak hour).
Key Areas of Concern
The “No Net New Trips” Goal: Methodology and Feasibility
The 2000 GUP Condition G.4 defines the “no net new trips” goal as “no increase in automobile trips
during peak commute times in the peak direction, as counted at a defined cordon location around
the campus.” That condition also states:
“Stanford shall mitigate the transportation impacts of its additional development and
population growth either through a program of ‘no net new commute trips’ or through
proportional funding of mitigation measures for specified impacted intersections.”
Hexagon has concerns about the “no net new trips” policy as it is currently defined. The three key
areas of concern are the definitions of the peak periods to be monitored, the direction of travel to be
monitored, and the unlimited use of trip credits to meet the goal. The DEIR invokes the “no net new
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Review of Stanford 2018 GUP DEIR on Behalf of Palo Alto November 13, 2017
trips” policy as mitigation for potential impacts. However, Hexagon is concerned that the policy
overlooks the following traffic issues.
Lengthening of Peak Period and Definition of Peak Hours: Although AECOM gathers 24-hour
cordon count data for 8 weeks every year, the analysis of data to determine whether Stanford has
met the “no net new trips” standard is currently limited to the hours of 7:00 – 9:00 AM and 4:00 –
6:00 PM. There is abundant evidence throughout the Bay Area that these traditional peak periods
have lengthened, and, in fact, the traffic counts conducted at study intersections for this DEIR were
conducted during the hours of 7:00 – 10:00 AM and 4:00 – 7:00 PM. In its NOP letter, the City
specifically requested that the EIR identify the peak travel periods for the campus using these 24-
hour cordon counts, but this was not done. At a minimum, the peak periods used for monitoring
cordon counts should be consistent with the peak periods used for the intersection counts
conducted for the DEIR (7:00 – 10:00 AM and 4:00 -7:00 PM).
Hexagon’s spot review of the raw cordon count data in the 2015 and 2016 Stanford University
Traffic Monitoring Reports indicates that the AM peak hour frequently occurs after the 7:00 – 9:00
AM period. Similarly, the PM peak hour frequently occurs after the 4:00 – 6:00 PM period.
However, for the purposes of determining whether Stanford has met the goal, any peak hour
volume that does not occur during those defined two-hour periods is ignored. The interpretation of
“peak commute time” in the goal should be modified for the 2018 GUP so that if, for example, the
greatest volume of vehicle trips in the evening occurs between 5:30 - 6:30 PM, then that is the
volume that should be used as the basis for monitoring whether or not Stanford has met the
standard.
One of the likely reasons why there appears to be a disconnect between Stanford’s achievement of
the “no net new trips” standard and the community’s experience of increasing levels of congestion
may be that there are higher levels of Stanford-related trips throughout the day or during much
longer periods during the morning and evening than was true in 2001. Therefore, it is critical that a
fresh analysis of the peak periods of travel to and from the campus be conducted and that
recommendations for future cordon counts be based on that analysis.
Direction of Travel: The “no net new trips” standard currently applies only to the peak direction of
travel: inbound towards campus in the AM peak hour and outbound from campus in the PM peak
hour. As the university constructs more on-campus housing for students, faculty, and staff, the
volume of traffic in the “counter-commute” direction will also increase. Figure 4 of Part 1 of the TIA
shows the change in proportion of resident and non-resident peak hour trips between 2015 and
2035, indicating that resident trips are projected to be a larger percentage of total trips in the future.
Under the 2018 GUP proposal, the volume of “counter-commute” travel could increase substantially,
but Stanford would still be deemed to meet its goal as long as the “commute” direction did
not increase (or was offset by trip credits). In its NOP letter, Palo Alto requested that the DEIR
include an analysis of direction of travel, but this was not done.
Even if Stanford meets the “no net new trips” standard as it is currently written, it would be possible
for the development proposed in the 2018 GUP to have intersection impacts that should be
mitigated. The DEIR overlooks the possibility that intersection impacts may result from vehicle trips
in the other direction (outbound from campus in the morning and inbound in the evening). The EIR
should address this issue and propose a means of mitigating any impacts that may be caused by
increases in traffic leaving campus in the morning and entering campus in the evening.
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Review of Stanford 2018 GUP DEIR on Behalf of Palo Alto November 13, 2017
Trip Credits: The 2000 GUP specifies that the County will recognize participation by Stanford in
off-campus trip reduction efforts and credit reduced trips toward attainment of the goal. Stanford
has not met the PM peak hour 2001 cordon count threshold (3,591 trips) in certain years, but has
been able to meet the “no net new trips” standard by taking credit for its off-campus trip reduction
efforts within a defined geographic boundary (the cordon credit area).
Stanford could continue to increase the number of trip credits it claims in the future as a way of
dealing with rising cordon counts through the life of the 2018 GUP. The fact that in 2015 Stanford
claimed 844 trip credits, equal to 23.5% of the 2001 “trigger” value for the PM peak hour, raises a
question as to whether there should be a limit or cap placed on the percentage of trip credits that
may be taken during the life of the 2018 GUP in order to meet the standard. For example, Stanford
proposes to take trip credits every year after providing funding for bicycle facility improvements in
Palo Alto and neighboring jurisdictions (in Chapter 8 of the DEIR).
This concern is heightened by the large number of potential problems concerning the trip credit
methodology that were raised in the 2016 Stanford University Traffic Monitoring Report. No fewer
than nine issues have been raised by the consultant preparing the report for the County. Hexagon
believes these issues should be addressed and resolved as part of the EIR process since they are
central to the “no net new trips” methodology. Hexagon also believes that trip credits should only
be granted for actual trip reductions, not predicted reductions.
Hexagon notes that the monitoring reports do not provide any information on the various measures
for which credits have been claimed each year, only the total number of credits claimed. In its NOP
letter, Palo Alto requested greater transparency in the cordon count and trip credit reporting.
Feasibility of Mode Split Required to Meet Standard: On page 5.15-156 of the DEIR, the drive-
alone mode share is given as 43.2% in 2015, which would need to be reduced to 36.5% to meet the
“no net new trips” standard for the 2018 GUP development (assuming no trip credits are taken).1
The University has been successful in reducing single-occupant trips to levels much lower than the
County average. However, the TIA (Figure 2 of Part 1) indicates that SOV mode share is
approximately 50% and has been flattening out in recent years, indicating that additional reductions
may be difficult to achieve. Given the environmental characteristics of the commute shed of Stanford
affiliates, such as land use density, transit availability, and other factors, it is likely to be challenging
to reduce that mode share by an additional 6.7%.
The TIA (Part 1, pp. 10-11) includes the following strategies expanding Stanford’s TDM programs in
order to meet the “no net new trips” standard under the 2018 GUP:
Commuter buses
Expand local bus service and first/last mile connections (Marguerite shuttle)
Improve key bike facilities to reduce road stress for cyclists on access routes to campus
Parking fees and policies
Student vehicle prohibitions
However, it is an exceedingly ambitious goal to construct 2.275 million square feet of academic and
academic support space and 3,150 new beds/units and to not increase peak hour vehicle volumes
at all. After many years of a highly successful TDM program, all of the “low-hanging fruit” is gone,
1 The TIA indicates that the drive-alone mode share was approximately 50% in 2015. The Background
Conditions Report also states that the drive-alone rate is 50% (page 4.47) The difference between the two
percentages given for the 2015 drive-alone mode share (43.2% and 50%) should be explained.
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Review of Stanford 2018 GUP DEIR on Behalf of Palo Alto November 13, 2017
and it may prove difficult to persuade many of the remaining SOV drivers to change modes.
Stanford should explore what it will take to achieve a 36.5% SOV mode share (no net new trips)
with real-world examples.
If the “no net new trips” standard is not met under the 2018 GUP, then Stanford has proposed that it
be “given the option of achieving No Net New Commute Trips by funding other entities’ trip reduction
programs before applying such funds to its proportionate share of intersection improvements.”
Ways in which the funding provided could be programmed as consistently over multi-year
periods as possible should be explored, rather than on an annual basis with large dollar amounts
in some years and no funding at all in other years, depending on the preceding year’s monitoring
report. Successful trip reduction programs require consistent funding to be most effective.
2015 Cordon Counts and the 2018 GUP Trip Generation Rate
The trip generation rates for the new development proposed in the 2018 GUP are based entirely on
the 2015 cordon counts conducted as part of the County’s annual monitoring process regarding the
“no net new trips” standard. To the extent that the 2015 cordon counts do not accurately capture
the number of vehicle trips generated by the campus during the AM and PM commute times, the trip
generation estimates for the proposed growth will be correspondingly underestimated, which should
be corrected in the Final EIR.
Identification of “AM peak hour” and “PM peak hour”: As discussed above, the number of peak
hour trips presented in the 2015 Stanford University Traffic Monitoring Reports is the peak hour
volume during the periods of 7:00 – 9:00 AM and 4:00 – 6:00 PM. However, due to the lengthening
of peak commute periods throughout the region and the widespread use of flextime schedules, the
peak traffic volume within that window of time may not actually be the peak traffic volume if a longer
or different peak period were considered. The DEIR did not address the issue of changes in the
peak commute times, even though the City requested such an analysis and it is key to the trip
generation estimates used in the DEIR; this should be considered in the Final EIR.
“Hidden” vehicle trips: The 2015 cordon counts may also underestimate Stanford’s existing trip
generation if there are vehicle trips that are not counted. The City’s NOP letter asked the DEIR to
study the extent to which Stanford commuters are avoiding cordon counts by parking on local
streets in adjacent city neighborhoods. The DEIR addresses this concern on page 5.15-176, and
Figure 5.15-21 shows that there are Residential Parking Permit programs in place in all the Palo
Alto residential neighborhoods adjacent to campus. However, two of these programs did not exist
when the 2015 cordon counts were conducted (Evergreen Park – Mayfield and Southgate). The
DEIR should have included some estimate of off-campus parking.
The DEIR also notes that there is very little on-street parking that is not time-restricted adjacent to
campus, with the exception of approximately 150 parking spaces on the Stanford side of El Camino
Real. The DEIR states that:
“These on-street spaces are essentially filled before the traditional peak hour of 8:00 – 9:00
AM. Thus, drivers using these spaces are not traveling during the peak hour, and therefore
are not parking in this location to avoid cordon counts.”
Since the cordon counts begin at 7:00 AM, the fact that these spaces are filled by 8:00 does not
mean these drivers aren’t avoiding cordon counts. As noted above, Hexagon suggests that the
cordon counts be re-evaluated to determine the actual peak hour, and these spaces should be
included.
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Review of Stanford 2018 GUP DEIR on Behalf of Palo Alto November 13, 2017
Another potential issue with the 2015 cordon counts is related to the exclusion of vehicles that enter
campus and then leave it within 15 minutes, because they are considered cut-through traffic that is
not generated by Stanford. Because of this, if a Stanford affiliate is dropped off or picked up on
campus, the vehicle that enters campus to drop them off in the morning or leaves campus after
picking them up in the evening is excluded from the cordon count, even though that trip is clearly a
Stanford-generated trip. An evaluation of the cordon locations where a vehicle entered and where it
exited campus would help identify some of these trips and distinguish them from actual cut-through
trips. The Final EIR should account for this issue.
Analysis of Transit Capacity and Performance
The City’s NOP letter requested that the DEIR evaluate transit performance and efficiency as it
relates to site design, mobility, and access. A map showing transit priority areas for nearby transit
agencies (Figure 5.15-10) and a map showing areas within a 5-minute walkshed of Marguerite stops
with headways of 15 minutes or less (Figure 5.15-22) were included, but they do not show the
location within the 2018 GUP area of key points of development proposed in the 2018 GUP. The
EIR should include further discussion about optimal land use and site design to support an effective
and efficient transit system on campus.
The City’s NOP letter also requested that the demand, capacity, and utilization of Caltrain,
connecting transit services at the Palo Alto Intermodal Transit Center (PAITC), and the PAITC itself
be studied. The DEIR does not include a capacity assessment of the PAITC at all, including its bus
bays, layover facilities, and the operational impacts of an expanded Marguerite service on other
transit providers, which should be addressed in the Final EIR.
The capacity analysis of Caltrain includes a key assumption that the trains will include eight cars by
2035, rather than the current five cars. The Caltrain electrification/modernization project now
underway does not include funding for extending platforms so that 8-car trains could be utilized. To
make the capacity analysis consistent with the electrification project, it should not be assumed that
the infrastructure improvements necessary to run 8-car trains will be operational by 2035. If train
capacity were constrained by the existing 5-car maximum, then there would be a significant impact
to this transit service. Hexagon suggests that an appropriate mitigation measure would be to make
a fair share contribution to the platform retrofit needed at the PAITC to permit lower level boarding,
which would speed up dwell time.
The DEIR asserts that transit capacity is not a potential impact under CEQA, but we disagree. Since
a project can be found to cause a significant impact to transit if an element of it would conflict with
an adopted policy regarding public transit or decrease the performance or safety of transit facilities,
then operating extremely crowded trains would qualify as conflicting with an adopted policy
and as reducing the performance of the service from the rider’s point of view. Transit services
generally have adopted policies or standards regarding load factor (how many riders they can
accommodate per bus or per car). If a load factor is exceeded by a large amount, then the service is
no longer comfortable or convenient. Such a load factor would clearly also have secondary impacts
on mode choice.
Aside from how the issue is treated under CEQA, there is also a basic operational issue that relates
to Stanford’s ability to achieve the “no net new trips” standard. If achieving the standard would
require an increase in the transit mode share, as conservatively assumed by the DEIR analysis, but
the capacity is simply not available on the trains to handle the increased ridership, then the standard
would probably not be achieved. This could be the case if the assumption regarding 8-car
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trains is changed to 5-car trains. The analysis should be re-assessed in light of these
considerations in the Final EIR.
Requested Parking Reserve of 2,000 Spaces
Stanford has requested approval of a 2,000 space parking supply reserve, for which it does not
seek initial authorization because it seeks to discourage automobile ownership and use. However,
Stanford proposes that it be able to seek Planning Commission approval to construct parking
spaces from that reserve under any of three defined circumstances.
One of the proposed circumstances for increasing the parking supply is meeting the “no net new
trips” standard. There is an obvious contradiction here: if Stanford is meeting the standard, why
would it need up to 2,000 additional parking spaces? Clearly, additional parking supply would make
it increasingly difficult to meet the standard in the future.
There are two obvious ways in which Stanford could meet the “no net new trips” standard and yet
still need 2,000 more parking spaces by 2035. One is that the standard can now be met through an
unlimited use of trip credits. Stanford could meet the standard through services and facilities that
reduce SOV trips off-campus, but still need additional parking for new trips to campus generated by
the development proposed in the 2018 GUP. The second relates to the lengthening of the peak
period. If an increasing number of trips are made outside the peak periods as they are defined (7:00
– 9:00 AM and 4:00 – 6:00 PM) under the 2000 GUP or if the trips made in a single peak hour no
longer represent as large a percentage of daily traffic as has been true historically (because traffic
is more evenly spread over a much longer period of time), then Stanford would need additional
parking to accommodate those trips – even though the standard, as currently monitored, has
been met. The EIR should address this issue directly and define a more stringent qualifying
circumstance for purposes of allowing construction of 2,000 more parking spaces or eliminate this
circumstance from the request.
Review of Impacts and Mitigation Measures
Hexagon evaluated all transportation-related impact findings in the DEIR to determine their
adequacy. The DEIR’s analysis of every study intersection was reviewed carefully, to ensure that
all potential mitigation measures at impacted intersections were included. The following sections
address each impact evaluation about which Hexagon has comments or questions. Impact
discussions – and specific intersection impacts – about which Hexagon has no comments or
questions are not included.
Level of Service Threshold for Unsignalized Intersections
DEIR: The DEIR states on page 5.15-57 that “None of the applicable jurisdictions have an officially
adopted significance criterion for unsignalized intersections. For purposes of this analysis,
significant impacts are defined to occur when the addition of project traffic causes:
The average intersection delay for all-way stop-controlled intersections or the worst
movement for side-street stop-controlled intersections to degrade to LOS F, and
The peak hour traffic signal warrant from the California Manual of Uniform Traffic Control
Devices (CA MUTCD) to be satisfied at an unsignalized intersection already operating at
LOS F.”
Hexagon Comments: The City’s threshold for non-CMP signalized intersections is LOS D, and the
City’s practice has been to apply that threshold to unsignalized intersections as well. The
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significance criteria for impacts at unsignalized intersections have been cited in several TIAs in
recent years as when the project causes a movement to degrade to LOS E or F and the peak hour
signal warrant is met. This Issue concerning Palo Alto’s impact criteria is relevant to the
unsignalized study intersection of Bowdoin Street / Stanford Avenue in the DEIR, which is
discussed further below.
The following section addresses all of the study intersections within Palo Alto where a significant
impact was found and where Hexagon had comments, plus the intersections of I-280 Southbound
Off-Ramp/Page Mill Road, I-280 Northbound Off-Ramp/Page Mill Road, and Bowdoin
Street/Stanford Avenue.
Intersection Impacts (2018 and 2035 Conditions)
I-280 Southbound Off-Ramp and Page Mill Road (#13)
DEIR: Proposed mitigation measure for 2018 impact is “Contribute fair share funding toward the
installation of a traffic signal.” However, on page 5.15-92, the DEIR references the Page Mill
Expressway Corridor Study Report and notes that the improvement concept is for this intersection
is “a roundabout, with traffic signal at the I-280 NB Ramps intersection, and a third eastbound and
westbound through lane on Page Mill Road to the east of the I-280 Northbound Ramps
intersection.” The DEIR says the Project’s fair-share funding towards a traffic signal at this
intersection “may be applied toward a roundabout.”
Hexagon Comments: Stanford should contribute its fair share of the roundabout and other
improvements that have been agreed upon by the three agencies (Santa Clara County, City of Palo
Alto, and Town of Los Altos Hills) for this intersection. Providing fair share funding towards a traffic
signal is insufficient, since that is not the intersection modification that has been agreed upon.
The DEIR does not find an impact at this intersection under 2035 conditions. The LOS calculation
sheets in Appendix F of the TIA indicate that a traffic signal is assumed at this intersection under
2035 conditions, even though Appendix E of the TIA indicates that the lane configuration and traffic
control (all-way stop control) are the same as under 2018 conditions. All changes in roadway
network assumptions should be stated clearly in the text of the report, and all tables and figures
should be consistent with any noted changes.
The intersection should be evaluated under 2035 conditions with all-way stop control and with a
roundabout, not with a traffic signal, since the timing of the roundabout construction is uncertain.
I-280 Northbound Off-Ramp and Page Mill Road (#14)
DEIR: No impact is found at this unsignalized intersection under 2018 or 2035 conditions. Under
2018 conditions, the intersection operates at LOS E both with and without the project, and the
increased delay is one second. Because signal warrant analyses were only conducted for
unsignalized intersections operating at LOS F, no signal warrant analysis is included in Appendix G
of the TIA.
For the 2035 evaluation, Appendix E of the TIA shows no change to the lane configuration or traffic
control at this intersection, although the LOS calculation worksheets indicate that a traffic signal is
assumed under 2035 conditions.
Hexagon Comments: In general, any changes in the roadway network (lane configurations, traffic
controls, signal phasing, etc.) between 2015 and 2018 or between 2018 and 2035 should be clearly
stated in the TIA and the DEIR and all appendices should be consistent.
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Because the intersection is already operating at LOS E during the AM peak hour and the increase in
delay on the stop-controlled approach is only one second, there would not be a significant impact
even if the more stringent LOS D standard were used for unsignalized intersections.
Junipero Serra Blvd – Foothill Expressway and Page Mill Road (#17)
DEIR: The proposed mitigation measure at this intersection for both the 2018 and 2035 impacts is
“Contribute fair share funding toward installation of an overlap signal phase for northbound and
southbound right-turning vehicles and widening of southbound Junipero Serra to two lanes between
Stanford Avenue and Page Mill Road to align with the existing designated right-turn lane.” The text
on page 5.15-92 notes that this would allow southbound right-turning vehicles additional queuing
space so southbound through vehicles do not block the right-turn lane. Under 2018 conditions, there
would still be a significant and unavoidable impact even with this mitigation measure, although under
2035 conditions, this measure was found to reduce the impact to a less-than-significant level.
Hexagon Comments: The mitigation measure proposed is reasonable, but ignores the other
changes that have been proposed for this intersection. The Page Mill Expressway Corridor Study
Report recommends the addition of a third eastbound and westbound through lane on Page Mill
Road between the I-280 interchange and Porter Drive (just east of Page Mill Road), as noted on
Page 5.15-124 of the DEIR. Measure B does not provide sufficient funding for the entire Page Mill
corridor project, including modifications to this intersection, so it would be reasonable for Stanford to
make a fair share contribution to it. Because the DEIR’s proposed mitigation does not fully mitigate
the Project’s impact at this intersection, a fair-share contribution to the Page Mill widening (possibly
HOV lanes) at this intersection should also be included in the mitigation measure, in addition to the
proposed changes to the Junipero Serra approach.
Bowdoin Street and Stanford Avenue (#34)
DEIR: No impact is found at this unsignalized intersection under 2018 or 2035 conditions. Under
2035 conditions, the intersection operates at LOS D without the project and at LOS E with the
project during the PM peak hour. Because signal warrant analyses were only conducted for
unsignalized intersections operating at LOS F, no signal warrant analysis is included in Appendix G
of the TIA.
Hexagon Comments: As noted previously, the City’s practice has been to use LOS D as the
impact threshold for unsignalized intersections, even though there is no formal policy statement
regarding unsignalized intersection impact criteria. If a more stringent LOS D threshold were to be
used and if the peak hour signal warrant were met, then the project would result in a significant
impact at this intersection. The Final EIR should include signal warrant analyses on Palo Alto
unsignalized study intersections operating at LOS E.
If the finding of no significant impact were to be changed to a finding of significant impact (based on
LOS E in the PM peak hour and a signal warrant analysis), installing a traffic signal at this location
would not be recommended as a mitigation measure, due to its fairly close spacing with other
signalized intersections on Stanford Avenue, at Peter Coutts Road and at Hanover Street. The
City’s preferred approach to this intersection would be a roundabout or a treatment other than a
signal at this location.
El Camino Real and Embarcadero Road (#48)
DEIR: Significant impact found in 2035, but not 2018. Proposed mitigation measure is “Contribute
fair-share funding toward the addition of a second northbound left-turn lane.” Page 5.15-131 of the
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DEIR notes that VTA’s Bus Rapid Transit (BRT) project has proposed a separate bus lane on El
Camino Real, but not through this intersection. The DEIR concludes that it is not possible to
determine what, if any, effect this mitigation measure would have on the BRT since there is no final
design available.
Hexagon Comments: As part of the Preferred Scenario selected for Palo Alto’s Comprehensive
Plan Update, queue jump lanes (not exclusive bus lanes) in the curbside lane have been proposed
for transit on El Camino Real. Is there be adequate right-of-way for both an additional northbound
left-turn lane and queue jump lanes? Would it be possible to implement both? The DEIR notes that
the City is “currently designing bicycle improvements at this intersection.”
Alma Street and Charleston Road (#58)
DEIR: Significant impact found under both 2018 and 2035 conditions. Proposed mitigation is
“Contribute fair-share funding toward the addition of a designated northbound right-turn lane and
installation of an overlap phase for the northbound and southbound right-turn movements.” The
impact would remain significant and unavoidable after implementation of this mitigation.
Hexagon Comments: As part of the Preferred Scenario selected for Palo Alto’s Comprehensive
Plan Update, grade separation between Charleston Road and the Caltrain tracks has been
proposed. Because the DEIR’s proposed mitigation does not fully mitigate the Project’s impact at
this intersection, a fair-share contribution to the grade separation project should also be included in
the mitigation measure.
Freeway Impacts (2018 and 2035 Conditions)
DEIR: The DEIR states that the project would result in significant and unavoidable impacts on four
freeway segments under 2018 conditions and on 11 freeway segments under 2035 conditions. The
impacted segments are on SR 85 and I-280. No specific mitigation measure is proposed, although it
is noted that to the extent that vehicle trips are reduced to achieve the “no net new trips” standard
and through applying any fees from exceeding the standard to alternative programs that reduce
vehicle trips, the project’s contribution to freeway congestion would also be reduced.
Hexagon Comments: The freeway segment analysis does not follow the methodology set forth in
VTA’s TIA Guidelines or in C/CAG’s guidelines. According to VTA’s TIA Guidelines (page 44), a
freeway segment is said to have an impact if the level of service falls from LOS E or better to LOS
F. If the segment is already operating at LOS F, then a project has an impact if the number of new
trips added by the project is more than 1% of the freeway capacity.
Instead of referring to the level of service on the study freeway segments, the DEIR uses volume-
to-capacity ratios (v/c) for both the 2018 and 2035 conditions. The TIA states there would be an
impact if a project causes a freeway’s v/c ratio to increase from less than or equal to 1.0 to greater
than 1.0. If the segment is already operating at a v/c ratio greater than 1.0, then there would be an
impact if the number of new trips added by the project is more than 1% of the freeway capacity. If
the freeway evaluation used level of service instead of v/c ratio, there may be more freeway
impacts than have been identified in the DEIR.
A few cities in Santa Clara County have identified contributions to regional freeway and transit
facilities as mitigation measures for significant freeway impacts. VTA has developed a structure for
a program of Voluntary Contributions to Transportation Improvements, which can be used by local
agencies when preparing development agreements. The County has the opportunity to require
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such a contribution to regional facilities in its development agreement as an additional condition if
the “no net new trips” goal is not achieved.
VTP 2040 includes four highway projects that are relevant to the impacted freeway segments on SR
85 and I-280 and could be considered as candidates for a fair-share funding contribution for the
freeway impacts identified in the DEIR. A contribution to improvements at the Palo Alto Intermodal
Transit Station would also be appropriate to consider.
Freeway Ramp Operations
DEIR: The DEIR notes that ramp queuing is not considered an environmental impact, but rather an
operational consideration that is managed over time by Caltrans and local jurisdictions. The ramp
analysis is presented for information purposes only.
In the text following the Existing, 2018, and 2035 off-ramp queuing evaluations, it is noted that the
left-turn queue at the I-280/Page Mill Road southbound off-ramp would exceed the pocket storage
length, but that the queue would be served within the total ramp storage and would not spillback
into the freeway mainline.
Hexagon Comments: Regarding the I-280/Page Mill Road southbound off-ramp, the text is
somewhat misleading. An extremely long exit lane is provided on I-280 for this off-ramp, and the
queue extends a long way into that lane during the AM peak hour. Due to the length of that exit
lane, it is true that through traffic is not blocked on the freeway, but the DEIR implies that there are
no problems at this location since the “queue would be served within the total ramp storage.” A
more detailed description of existing and future conditions at this off-ramp is warranted. This off-
ramp is analyzed as an all-way stop controlled intersection under 2035 conditions, even though the
intersection analysis assumed the intersection would be signalized by 2035. As discussed above,
the proposed improvement at this location is a roundabout.
Construction Impacts
DEIR: The DEIR finds that construction traffic would cause a significant impact and that it would be
reduced to a less-than-significant level with the proposed mitigation measure.
Hexagon Comments: The City has expressed concern about the difficulty that its emergency
responders have in meeting their response time targets when there are frequent lane closures or
roadway detours due to construction. A new system for emergency responders is being
implemented that will identify the best route for responders to take, based on current information
about the roadway network. The mitigation measure should be revised to require the University to
inform the City of all roadway changes immediately, so that the system is kept current at all times.
Transit Impacts
DEIR: The DEIR finds that the project would result in a less-than-significant impact on public transit
based on (a) an analysis of transit delay and (b) the fact that “The proposed 2018 General Use
Permit does not propose infrastructure changes outside the Project site and, thus, would not
interfere with the ability of transit agencies to modify or expand service.”
Hexagon Comments: The DEIR takes a very narrow view of whether the project would conflict
with an adopted policy, plan, or program regarding public transit, or would otherwise decrease the
performance or safety of such facilities. The DEIR does not present the analysis of transit capacity
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as part of the impact analysis, but addresses that topic separately. See comments regarding the
transit capacity analysis of Caltrain under “Key Concerns” above.
The City requested additional transit-related data and analysis in its NOP letter. Although some of
the requested additional information regarding transit has been provided, the following requested
items are not covered in the DEIR:
Boardings, speed, and frequency of individual Marguerite lines;
An evaluation of transit performance and efficiency as it relates to site design, mobility, and
access;
An assessment of the capacity, access, and operations of the Palo Alto Intermodal Transit
Center (PAITC), including a capacity assessment of bus bays, layover facilities, and
potential operating impacts to other transit providers using the PAITC, especially if
Marguerite service is expanded.
The Final EIR should provide this requested additional data and analysis regarding services and
facilities that serve Stanford-affiliated transit patrons.
Residential Streets
DEIR: The DEIR finds that the project would not substantially increase intrusion by traffic in nearby
neighborhoods and that there would be a less-than-significant impact. Traffic impacts on residential
streets were estimated using the Traffic Infusion on Residential Environment (TIRE) methodology.
The threshold for an increase in traffic that would be noticeable to residents is a 0.1 increase in the
index. The analysis was conducted for the College Terrace and Crescent Park neighborhoods, and
the minimum daily volume increase required to increase the Index by 0.1 was calculated for a few
roadway segments.
Hexagon Comments: In general, the TIRE methodology is somewhat problematic in evaluating
traffic diversion impacts for a number of reasons. One reason is that it is based on average daily
traffic (ADT), not peak periods of traffic, and sometimes residents are most sensitive to increases in
traffic during commute hours when diversions are most likely to occur. Hexagon acknowledges,
however, that no other tools have been developed that are widely considered superior to the TIRE
index. The TIRE index uses a logarithmic scale, such that as ADT increases, larger proportional
increases in additional project-related traffic are required in order to result in an increase to the
index.
The DEIR notes that “on a daily basis Hamilton Avenue (just west of Lincoln Avenue) carries about
16% of the combined volume (University Avenue plus Hamilton Avenue); however, between 4:00 –
7:00 PM, it carries about 67%.” This clearly indicates that a large amount of traffic is already being
diverted to Hamilton during the PM peak period. Because of that diversion, ADT is already higher
than it otherwise would be on Hamilton. And, because of that higher ADT, the number of additional
vehicle trips needed to trigger a 0.1 increase in the TIRE index is also much higher than the amount
required to trigger a change on the streets evaluated in the College Terrace neighborhood. For
example, Table 5.15-28, “Crescent Park Neighborhood TIRE Index Results,” shows that 1,025
additional vehicles per day would be needed on Hamilton Avenue (between Hamilton Court and
Lincoln Avenue) to increase the index by 0.1, given that the daily traffic volume is 3,700. In other
words, ADT would have to increase by 28% to trigger a 0.1 increase in the TIRE index.
What this boils down to is that because Hamilton Avenue already experiences a large amount of
diverted traffic, the additional diverted traffic resulting from the 2018 GUP development is
insufficient to cause a significant impact under the TIRE methodology. In fact, even if the estimate
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of 121 project-generated trips on the above-referenced segment of Hamilton Avenue were doubled
or tripled, it would be considered a less-than-significant impact, since it would still be well below the
threshold of 1,025 trips. Although some residents may take issue with this finding, the DEIR applies
the TIRE methodology correctly.
Emergency Access
DEIR: The DEIR finds that the project would not result in inadequate emergency access. This
finding is based on the fact that the proposed 2018 GUP “would not result in any infrastructure
changes outside the project site, and thus would not create fixed physical barriers to, or impede,
emergency access.”
Hexagon Comments: The rationale for this finding refers only to infrastructure changes outside
the project site, but the DEIR should also consider any changes on campus due to the 2018 GUP
development that would impede emergency access. In its NOP letter, the City asked that the DEIR
evaluate impacts to response times for fire, rescue, and emergency medical services. This is not
provided in the transportation (or public service) sections of the DEIR, and should be addressed in
the Final EIR.
Bicycle and Pedestrian Facilities
DEIR: The DEIR states that the 2018 GUP would not result in a significant impact to bicycle and
pedestrian facilities because it “would not result in any infrastructure changes outside the Project
site and would [not] preclude implementation of planned bicycle or pedestrian facilities and, thus,
would not create hazardous conditions where none exist today.”
The DEIR used StreetScore, a proprietary methodology of Fehr & Peers, to evaluate Quality of
Service (QOS) of bicycle and pedestrian facilities. The proposed intersection mitigation measures
are evaluated for secondary impacts to bikes and pedestrians using StreetScore, and none were
found to have a significant secondary impact.
Hexagon Comments: The StreetScore methodology used by Fehr & Peers is a newly developed
tool and is not widely accepted as a standard evaluation tool in the traffic engineering community.
Hexagon notes that the ratings do not seem to be that sensitive to lane geometry changes. In some
cases, the rating given to bicycle or pedestrian facilities does not change at all as a result of the
proposed mitigation measure. In other cases, adding a lane does not affect the Quality of Service
because the intersection is already at the worst rating (4) and the mitigation measure is deemed
to “maintain but not exacerbate current uncomfortable conditions.” This is the equivalent of saying
that if an intersection is already at LOS F that additional trips can’t make it worse – which is clearly
not permitted under the intersection impact criteria. In such cases, the Final EIR should address
ways in which the bicycle and/or pedestrian facilities can be modified to improve conditions for
cyclists and pedestrians as well as motorists.
DEIR: A bicycle capacity analysis of campus gateways was conducted (pp. 5.15-167 – 169), but not
as part of the impact discussion. Peak hour bicycle volumes were converted into cyclists per minute
to provide an indication of how intensely the campus gateways are being utilized. The analysis
concluded that the anticipated growth in bicycle commuters under the 2018 GUP would not exceed
capacity at these gateways.
Hexagon Comments: The City’s NOP letter states that “the DEIR should identify critical
intersections on bicycle routes that currently have inadequate integration of bicycle facilities and
determine needed improvements.” However, the DEIR does not address this. In addition to the
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gateway capacity analysis, the design of bicycle facilities and their integration with routes used by
Stanford commuters should be addressed. For example, Embarcadero Road is a daunting corridor
for cyclists, but the analysis just says there’s adequate capacity at the gateway on Galvez Street
south of Arboretum Road, which is on the campus. Other corridors may also have issues.
The Final EIR should address the access routes used by bicyclists, not just the campus gateways,
and should expand the analysis to include safety, comfort and connectivity, as well as capacity. In
order to meet the “no net new trips” goal, Stanford will need to further increase the bicycle mode
share. One of the strategies put forth in the TIA for expanding the TDM program is to identify key
improvements that would directly reduce the road stress for cyclists on access routes to campus,
which should be included as part of the EIR.
DEIR: Separate from the impact discussion (i.e., not offered as a mitigation measure), The DEIR
notes that Stanford will provide improvements to bike and pedestrian facilities on unincorporated
land near Escondido and Nixon schools.
Hexagon Comments: The list of potential improvements suggested on page 5.15-112 of the DEIR
should be reviewed to confirm that they reflect the most recent ideas regarding needed
improvements for Safe Routes to School for these schools. The University should continue to
coordinate with the City and the Palo Alto Unified School District to define and implement
improvements that reflect the most recent Safe Routes to School recommendations. In addition,
because development on campus can result in large bursts of new school children as residential
projects are completed, it’s important that the University remain responsive when new demands for
school travel are generated by new development. .
DEIR: Stanford also proposes in Chapter 8 of the DEIR to fund specified off-site bicycle
improvements in Palo Alto, East Palo Alto, Menlo Park, and unincorporated San Mateo County.
Stanford would apply for trip credits towards the “no net new trips” goal based on these bicycle
facilities in all future years after the facilities are constructed. The proposal for Palo Alto is to
connect existing facilities at Bol Park and the Stanford Perimeter Trail. “The improvements would
be installed along Hanover Street, which would provide a continuous route through southern Palo
Alto neighborhoods and the Stanford Research Park to the Stanford campus. (DEIR, p. 8-4)”
Stanford would contribute up to $250,000 in funding towards the design and implementation of
bicycle improvements in the Hanover Street corridor, “which is the full estimated cost of these
improvements”.
Hexagon Comments: The proposal to provide better connectivity between the Stanford Perimeter
Trail and the Bol Park Path makes good sense, since the Bol Park Path is a heavily used facility and
provides a route from campus to Terman Middle School and Gunn High School. However, the
specific details of the improvements proposed in the DEIR have not been accepted by the City as
the most critical modifications needed to improve this bike corridor. Further, some of the specific
elements of this project, as listed on page 8-4 of DEIR, may already be covered by the recent
agreement between the City and the County regarding improvements at the intersection of Hanover
Street and Page Mill Road. Stanford representatives should coordinate with Palo Alto staff to better
define this project and ensure that it does not include elements that are already covered by the $3.2
million agreement with the County but does include funding for elements that are still critically
needed for upgrading this bikeway.
On-Campus Parking Supply and Off-Campus Restrictions
See comment under Key Concerns above.
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DEIR: Stanford wants to exclude parking spaces at EV charging stations from the count of parking
spaces allowed under the 2018 GUP. The rationale is that these spaces require turnover, such that
other spaces are needed for the same cars when they are not charging.
Hexagon Comments: Since the number of EV charging stations is likely to increase substantially
by 2035 as EV ownership rates increase, this will not be a trivial number of parking spaces in the
future. Signs at charging stations say that “Vehicles Must Be Actively Charging” to park in these
spaces, but how is that enforced? If someone parks their car at an EV charging station and plugs it
in, do enforcement staff look to see if it is actively charging? How long do people have after their
car is charged to move it? In many public garages, it is common for EV drivers to leave their cars
parked in the space all day long, even if it does not take all day to charge it.
Additional Comments
This section includes additional issues noticed by Hexagon and not addressed in any of the
preceding sections.
2018 GUP, Background Conditions Report, page 4-58: Intersection improvements identified as
mitigation measures for the 2000 GUP were divided into two tiers. A condition of the 2000 GUP
“required Stanford to construct Tier 1 intersection improvements regardless of whether Stanford
achieved the ‘no net new trips’ goal.” A two-tier approach may also make sense for the 2018 GUP,
with a condition of approval that requires a fair-share contribution towards improvements at the Palo
Alto Intermodal Transit Station in order to accommodate 8-car trains for Caltrain service. The
County could require such a contribution regardless of whether Stanford achieves the “no net new
trips” goal because increased Caltrain capacity is so critical to further reductions to the SOV mode
share and the projected increases in Caltrain ridership.
TIA, Part 1, Figure 5 , “Stanford University Employee Mode Share,” provides information about
the modes used by commuters coming from different geographic subareas. The information is
extremely useful, but also raises questions about survey design and validation. For example, the
figure shows a number of people walking from the North Bay (Marin, Napa, and Sonoma Counties).
Stanford should continue to refine its survey process. Also, East Palo Alto is not identified in any of
the geographic subareas. East Palo Alto should be identified on this figure and in Tables 7 and 8.
TIA, Part 1, Table 7, “Percent of Stanford Affiliates (Driving) by Geographic Area”: The table
indicates that Sunnyvale and Santa Clara are north of campus and would use Alpine Road and
Sand Hill Road to access the campus from I-280. Was this error only made on the table or did the
trip distribution and assignment actually incorporate this error?
TIA, Part 2, pages 103-104: The TIA states that “adjustments were made to the survey data to
account for a known bias in the surveys. More detail on how these biases were adjusted for can be
found in the 2018 GUP TIA Part 1.” Part 1 does not include detail on these adjustments. This
information should be added to the TIA.
TIA, Part 2, page 134: A reference is made to “C/CAG’s bus routes.” This should be corrected to
read “SamTrans’s bus routes.”