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Staff Report 3496
City of Palo Alto (ID # 3496) City Council Staff Report Report Type: Study Session Meeting Date: 2/11/2013 City of Palo Alto Page 1 Summary Title: Study Session: Prescreening Development of Lot at Page Mill Road and El Camino Real Title: Preliminary Review of a Planned Community Zoning Proposed on the Former VTA Lot at El Camino Real and Page Mill Road (2755 El Camino Real) From: City Manager Lead Department: Planning and Community Environment Recommendation Staff recommends that City Council conduct a preliminary review (pre-screening) of the proposed project and provide comments on the proposal to staff and the applicant, particularly focused on the proposed land uses and intensities and on the adequacy of proposed public benefits. No formal action may be taken at a pre-screening. Comments made on preliminary plans are not binding on the City or the applicant. Executive Summary The applicant, Pollack Financial Group, requests that Council conduct a Preliminary Review of the proposed rezoning of a 19,563 square foot, Public Facilities (PF) zoned site at 2755 El Camino Real, the former Valley Transportation Authority’s park and ride lot on the northerly corner of Page Mill Road and El Camino Real. The site is proposed for rezoning to a Planned Community (PC) zoning to allow development of a four-story commercial building with associated parking facilities both at grade and in three levels below grade. The project would also include a request for a Comprehensive Plan Amendment to change the site’s Land Use Designation, which is currently Major Institution/Special Facilities. The Application Narrative, report Attachment B, is also included in the packet prepared by the applicant for Councilmembers. Proposed community benefits include: land dedication and widening of Page Mill Road, upgrade of the pedestrian tunnel beneath El Camino Real, providing new lighting for California Avenue, transit passes, and design features along the El Camino Real frontage. The packet provided to Councilmembers is available on the City’s website at: http://www.cityofpaloalto.org/civicax/filebank/documents/32974. City of Palo Alto Page 2 Background On December 17, 2012, the applicant submitted an application for Preliminary Review by City Council of a commercial land use concept for the 19,563 square foot site, involving rezoning the site from Public Facilities (PF) to Planned Community (PC), to construct a four-story commercial building with structured and below grade parking. Prescreening Process Palo Alto Municipal Code (PAMC) Section 18.79.030(b) states that concurrence of the City Council is necessary to conduct a preliminary review. The purposes of a preliminary review, as stated in PAMC Section 18.79.010, are: a) To maximize opportunities for meaningful public discussion of development projects, at the earliest feasible time, for the guidance of the public, project proponents, and City decision makers. b) To focus public and environmental review of development projects on the issues of greatest significance to the community, including but not limited to: planning concerns; neighborhood compatibility; Comprehensive Plan consistency; economics; social costs and benefits; fiscal costs and benefits; technological factors; and legal issues. These procedures are not intended to permit or foreclose debate on the merits of approval or disapproval of any given development project. c) To provide members of the public with the opportunity to obtain early information about development projects in which they may have an interest. d) To provide project proponents with the opportunity to obtain early, non-binding preliminary comments on development projects to encourage sound and efficient private decisions about how to proceed. e) To encourage early communication between elected and appointed public officials and staff with respect to the implementation of City policies, standards, and regulations on particular development projects. f) To facilitate orderly and consistent implementation of the City’s Comprehensive Plan and development regulations. Planned Community Zone Change and Comprehensive Plan Amendment Processes Rezoning to a Planned Community (PC) district follows a unique set of procedures and standards, which are described in Chapter 18.38 of the Palo Alto Municipal Code (PAMC). After this prescreening, the applicant intends to submit an application for rezoning the site to Planned Community and for a Comprehensive Plan Amendment. The Planning and Transportation Commission (P&TC) would review the preliminary plans, a development City of Palo Alto Page 3 program statement and a draft development schedule. With favorable feedback and initiation by the P&TC, the development plan, site plan, landscape plan and design plans would be submitted for review by the Architectural Review Board (ARB) in the same manner as any commercial or mixed-use project. An environmental document would be prepared and circulated prior to ARB consideration, although a preliminary ARB review or reviews may be recommended and conducted. The development plan recommended for approval by the ARB is then returned to the P&TC, together with a draft zoning ordinance and environmental document, for its final review and recommendation to the City Council. As a part of the formal PC Zoning process, the PT&C and City Council would be required to make all of the following findings with respect to the rezoning application: (a) The site is so situated, and the use or uses proposed for the site are of such characteristics that the application of general districts or combining districts will not provide sufficient flexibility to allow the proposed development. (b) Development of the site under the provisions of the PC planned community district will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts. In making the findings required by this section, the planning commission and city council, as appropriate, shall specifically cite the public benefits expected to result from use of the planned community district. (c) The use or uses permitted, and the site development regulations applicable within the district shall be consistent with the Palo Alto Comprehensive Plan, and shall be compatible with existing and potential uses on adjoining sites or within the general vicinity. Amending a site’s Comprehensive Plan land use designation would also require P&TC initiation, followed by preparation of an environmental document and resolution for P&TC review and recommendation for final Council decision. Comprehensive Plan Map designation amendments are not subject to ARB review and recommendation. Site Description The site is located on the northeast corner of El Camino Real and Page Mill Road (see Location Map Attachment A). The project site is a 19,563 square foot parcel located at 2755 El Camino Real on the northerly corner of El Camino Real and Page Mill Road. The subject site is a parking lot deemed surplus property by the Valley Transportation Authority (VTA) and recently sold to the applicant. Surrounding Sites The southerly corner (3000 Page Mill Road) of the Page Mill/El Camino intersection is the ten- story Palo Alto Square commercial complex (PC 4637), which includes at-grade landscaped City of Palo Alto Page 4 parking facilities located adjacent to the two street frontages. The four-story Sunrise Assisted Living Facility (PC 4831), with below grade parking facilities on one level, is located adjacent to and northwest of the subject property. Adjacent to and northeast of the subject site is PC-4463, a three-story residential condominium complex (The Silverwood), which includes one level of underground parking. The southeast corner of Page Mill Road and El Camino Real is developed with the two-story AT&T retail building and associated surface parking lot. The site adjacent to the AT&T store on Page Mill Road (423-451 Page Mill Road) was recently amended from single family residential zoning and land use designation to the Commercial Service (CS) zone and land use designation. The AT&T building is adjacent to the three-story mixed-use building at 2825 El Camino Real, which is next to a vacant lot approved for development of a one-story commercial building. The westerly corner of the intersection is the Mayfield Soccer Complex, on a 5.9 acre site zoned PF (AS3). Project Description The applicant proposes rezoning of the site to Planned Community, to construct a four-story, 33,500 square feet commercial building with three levels of underground parking. A 1.71 Floor Area Ratio (FAR) is proposed for the project. The components included in the applicant’s “2755 El Camino Project Narrative Application” (Attachment B) include a project description, public benefits proposal, the applicant’s analysis of the project’s compliance with the PC Ordinance (PAMC Chapter 18.38), with development standards of the CS Zone District, with Comprehensive Plan policies, and comparison of the urban design features to goals of other City land use policy documents. The submittal also suggests a hearing schedule that includes a Preliminary Architectural Review Board (ARB) meeting in early February and concludes with a Council final hearing in July 2013. No Preliminary ARB application has been submitted or accepted, due to Council policy for processing Planned Community applications. The building envisioned by the applicant would include a concrete frame, cut stone, plaster finishes and window glazing system. Vehicular ingress to the site and garage would be provided via right turn only from El Camino Real, with right turn only egress onto EL Camino Real. The project concept is a modern design with an elliptical wall shape and a “curtain” with structural glazing that presents a full height glass wall without apparent structural frames and without visible structural elements for the horizontal spaces between each floor. Discussion The applicant’s project description for the proposed Planned Community (PC) District is detailed in Attachment B. Staff has identified the following key issues for the Council’s specific consideration and comment: City of Palo Alto Page 5 A. Zoning compliance, uses, and intensity of land use; B. Comprehensive Plan Amendment and Planned Community Rezoning; C. Adequacy of the proposed public benefits; D. Parking Reduction; E. Relationship to the El Camino Real; F. Conformance with Bicycle and Pedestrian Transportation Plan; G. Relationship to and impacts on surrounding neighborhoods; and H. Environmental review. Conformance with Zoning Designations and Comprehensive Plan The project site is located in the Public Facilities (PF) Zoning District. The PF district is designed to accommodate governmental, public utility, educational, and community service or recreational facilities. The applicant is proposing to rezone the site to a Planned Community (PC) district, intended to accommodate developments for residential, commercial, professional, research, administrative, industrial or other activities, including combination of uses appropriately requiring flexibility under controlled conditions not otherwise attainable in other districts. Another standard zoning district that would accommodate a commercial building would be the Service Commercial (CS) district; however, the project as described would not meet the CS district development standards for Floor Area Ratio and Height. The PC zone would allow the flexibility for the larger floor area, expanded use and increased height. The project site is designated ‘Major Institutions/Special Facilities’ in the Comprehensive Plan. The project would require a new Comprehensive Plan land use designation, such as Service Commercial or Regional Community Commercial. The project site is located within a “Multi-Neighborhood Center” in the Cal-Ventura Mixed Use Area noted in the Comprehensive Plan. Policy L-31 states, “Develop the Cal-Ventura area as a well-designed mixed use district with diverse land uses, two to three story buildings, and a network of pedestrian-oriented streets providing links to California Avenue.” Program L-30 calls for the preparation of a Coordinated Area Plan for the area, using the one-day community workshop diagram on page L-24 as a starting point; the diagram shows the project site as suitable for Mixed Use. Program L-31 contains five bulleted “unranked priorities” for redevelopment within the area (and these refer to sites to the north and south of the subject site, but make no mention of the site in particular). The site is shown on the diagram from the one-day community workshop referenced in Program L-30 as desirable for mixed uses, as are the sites to the west (now the Sunrise Assisted Living PC) and north (now the Silverwood Residential PC). City of Palo Alto Page 6 The VTA project site is not on the City’s list of housing inventory sites in the draft Housing Element currently under review. Public Benefits The second of the three required PC approval findings is that: “Development of the site under the provisions of the PC planned community district will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts. In making the findings required by this section, the P&TC and City Council at a later formal hearing shall specifically cite the public benefits expected to result from use of the planned community district.” The applicant’s project description includes a “List of Public Benefits”, the highlights of which are summarized below. 1. Widening of Page Mill Road. The applicant proposes to dedicate land so that Page Mill Road can be widened to provide a dedicated right turn lane onto El Camino Real. The applicant has determined that 856.3 square feet would be dedicated for public use. The cost of land is represented by the applicant at approximately $248,327. The applicant would be required to construct new curb, gutter, sidewalk and other design and utility features. The applicant estimates the dedication and improvements and value at $600,000. 2. Land Dedication. The applicant proposes to dedicate the widened portion of Page Mill Road. The applicant proposes to go through the title document efforts to grant land for the widening of Page Mill Road. The applicant is proposing to transfer fee interest of the land to allow the City full legal right of the land (though Page Mill Road is a County road). The applicant estimates the fee dedication to have a value of $150,000. 3. Upgrade Pedestrian Tunnel. The applicant proposes to reopen and improve the abandoned pedestrian tunnel under El Camino Real between Chipotle and the Mayfield Soccer Complex. The applicant proposes to improve the tunnel for pedestrians and bicyclists and would make the tunnel accessible per building code requirements. The applicant estimates the tunnel upgrade to have a value of $352,459. 4. Installation of Pedestrian Light Poles on California Avenue. The applicant proposes to contribute $750,000 for the installation of pedestrian lights on California Avenue. The lights are similar to the lights currently in Downtown Palo Alto. City of Palo Alto Page 7 5. Urban Design Features. The applicant identifies the following additional features as public benefits to have a value of $150,000: 1. Tree canopy upgrades, including irrigation on the El Camino Real median near 2755 El Camino Real and north of Page Mill Road; 2. Installation of four vehicle charging stations, two open to the public in the surface parking lot and two in the private garage; 3. Provide wider sidewalks than the minimum standards for the El Camino Real Design Guidelines; and 4. The project will be in compliance with Palo Alto’s Green Building Code and meet LEED Silver standards. 6. Ten-Year Eco pass and CALTrain pass. The applicant proposes to purchase Eco and CALTrain passes for the employees of the project site for 10 years. The applicant estimates that this feature has a public value of $225,000. 7. Quality and Character of 2755 El Camino Real. The applicant believes the project would serve as a Gateway project to the Stanford Research Park, and that the height, mass and quality of architecture would provide a prominent building and serve as a public benefit. The applicant summarized proposed costs and benefits in Attachment B. Staff has not conducted a preliminary analyses of these initial costs and has not formally peer reviewed them nor attempted to estimate operating costs for any of these facilities. Staff has particular concerns about the value of item #2 (the dedication of existing Page Mill Road area), the feasibility of item #3 (the tunnel), and the benefits of the design and green building components of items #5 and #7. The City Manager has directed that for significant PC projects such as this, the City should commission an independent third party analysis of the potential scale and adequacy of the public benefits being proposed for the project with a consideration for the “public benefit” and the provision of full value to the City in exchange for the land use changes being requested. Such analysis would be required as the project moves forward to the Planning and Transportation Commission for review. Development Standards and Relation to Public Benefits As discussed below and shown in the attached zoning comparison table (Attachment D), staff has analyzed the concept with respect to both the existing PF Zone and alternative CS zone development standards. City of Palo Alto Page 8 Floor Area Ratio The proposed FAR increase is the applicant’s primary reason for requesting a Planned Community Rezoning. As shown below in Table 1, the requested FAR at 2755 El Camino Real is 1.71:1.0, whereas the maximum floor area ratio in the PF district is 1:1. The CS District would allow a 0.4:1 FAR for commercial development and 1.0:1 FAR for a mixed use development. Table 1: Floor Area Ratio (FAR) COMPARISON Project Allowed FAR in PF Allowed FAR in CS Proposed FAR 2755 El Camino Real 1:1 * 0.4:1 commercial 1.71:1 – non-conforming * allowed FAR for public facilities Relationship to Public Benefits The amount of excess square footage requested for 2755 El Camino Real amounts to 13,937 square feet above what would be allowed in the PF district, albeit for a different land use, and would result in 25,675 square feet above the commercial development allowed in the CS zoning district. This would yield a “public benefit” of $210 per square foot of increased development compared to the PF zoning and $114 per square foot based on increased commercial above the CS zone FAR, assuming the applicant’s cost estimates for the proposed public benefits. For comparison, the City’s last approved PC project at Lytton Gateway provided $134 per square feet (without parking in lieu fees) in community benefits and the 395 Page Mill Road/3045 Park Boulevard PC project includes a proposal for community benefits currently estimated to have a value of $95 per square foot. The independent third party analysis of the potential scale and adequacy of the public benefits being proposed for the project would provide more specific estimates and comparisons for future deliberations. As a preliminary matter, staff believes that some of the applicants’ community benefits may be required mitigations rather than benefits. However, further environmental analysis will be required to assess that. The Council is requested to comment as to whether the scope of the community benefits is adequate, and whether public benefits should be more closely aligned to the purpose and intent of the proposed project. City of Palo Alto Page 9 Traffic/Parking Fehr & Peers (the applicant’s consultant) has prepared a focused transportation impact analysis (TIA) and site plan evaluation for the project. The trip generation estimates were based on the proposed office square footage, assuming general office use. Based on the Institute of Transportation Engineers (ITE) Trip Generation manual, the project would produce fewer than 100 peak hour trips in the morning or evening peak hour. According to the VTA TIA guidelines, Congestion Management Program (CMP) analysis would not be required due to the project generating fewer than 100 peak hour trips. However, since the applicant is proposing a financial service use which is a more intensive use than general office, the applicant would need to provide additional analysis. Based on the results, a full TIA may be necessary for the project. As a next step, if a TIA is necessary, the City’s Transportation staff will have a discussion with the applicant’s traffic consultant and a scope of work will be prepared for a traffic study. This Traffic Impact Analysis (TIA) would be evaluated by staff in conjunction with the environmental review document. Zoning Code Chapter 18.52 requires an automobile parking ratio of 1 space per 250 square feet of gross floor area for general office. Under this requirement, the project would need to provide 134 parking spaces. However, if the applicant is proposing a financial services use (bank, savings and loan office with more than 7,500 square feet of floor area), this area would require 1 space per 310 square feet of floor area. Based on this use, the project would need to provide 108 parking spaces. The applicant is proposing 121 parking spaces. Depending on the type of office proposed, the project would either meet the parking standard or have a deficit of 13 parking spaces. The project could be eligible for a parking adjustment of up to 20 percent reduction, if deemed appropriate by the Director of Planning and Community Environment and, in this case, the City Council. Assuming a 10% reduction for transportation demand management (TDM) features, the project would need to provide 121 spaces if all office use is proposed. Neighborhood Compatibility The project concept proposes a maximum height of 50 feet above grade, generally consistent with PF, CS and PC zoning. The proposed roof screen would extend an additional eight feet above the roof. There are, however, special height and daylight plane requirements for PC zoned sites that abut residential PC property. Specifically, PC zoning (PAMC 18.38.150) requires sites sharing any lot line with one or more sites in any RE, R-1, R-2, RM or any residential PC district to comply with a specific daylight plane. The maximum height is established by a daylight plane beginning at a height of ten feet at the applicable side or rear site lines and increasing at a slope of three feet for each six feet of distance from the side or rear site lines until intersecting the height limit otherwise established for the PC district. The project’s preliminary plans indicate the top of the parapet and roof screen would encroach in the day City of Palo Alto Page 10 light plane related to the adjacency of the Silverwood Residential PC (Attachment G, Exhibits 6.1 and 6.2 in Section 6 of the spiral bound document). The plans do not indicate the daylight plane related to the Sunrise Assisted Living property, but the building setback measured to the property line shared with the Sunrise property is estimated at 27 feet. Given that the proposed building is over 35 feet in height and within 40 feet of a residential zone, height/daylight plane exceptions would be requested. These types of exceptions may be granted as a part of a PC Ordinance, rather than requiring a variance, and such actions are within the authority of the Council. Therefore, the issue is more of a policy one for Council, regarding precedence and extent of the exceptions. Staff believes that, if the request were for a height in excess of 50 feet for building areas comprising floor area, an undesirable precedent could be set through a PC process, though again the Council may have discretion to make such a determination. The applicant would be required to submit visual studies, including solar impact/shade studies, to assist in the environmental review and allow staff to determine whether there would be impacts from the proposed building height on the residential neighbors. Correspondence was received on February 4, 2013 (Attachment E) from the owner of the adjacent property to the west, the Sunrise Assisted Living Planned Community project. The property owner states that he is not in favor of this property being up-zoned for office, given the adjacency of the Sunrise Assisted Living facility and residential property next door. He states that he had made a proposal for an office project on the Sunrise site (before the Sunrise PC was submitted and approved) and was turned down by the City of Palo Alto, as he was told this was not an area where the City wanted more office space. He does not want to see office space on the VTA lot, with its difficult access, and had earlier stated he would check with Sunrise to see if the company had interest to expand to the corner site, noting that Sunrise would be sending a separate letter regarding the project. In addition to concern about the office use, his two other primary concerns are the density and blockage of views from the assisted living facility. The height of the Sunrise Assisted Living building, approved as a Planned Community by Council, is approximately 44’8” above grade; the analysis of the Sunrise Assisted Living PC compared the project with the RM-40 Zone development standards, as follows: RM-40 Proposed Project Front Setback 25 feet 20 feet Side Setback 10 feet 20 feet Rear Setback 10 feet 30 feet City of Palo Alto Page 11 Height 40 feet 44 ’-8” Lot Coverage 18,425.7 square feet 17,047square feet FAR 40,946 square feet 63,347 square feet Common Open space 8,189.2 square feet 16,000 square feet Private Open Space 4,500 square feet 0 square feet Density 37 units 81 units Parking 127 spaces 40 spaces El Camino Real Development Three guidelines are applicable to this site: (1) El Camino Real Design Guidelines (ECR Guidelines), (2) South El Camino Real Guidelines, recommended by ARB in 2002 (South ECR Guidelines), and (3) El Camino Real Master Schematic Design Plan, 2003 Draft (Design Plan). South ECR Guidelines: The project site is located within the California Avenue Strategic Site Pedestrian-Oriented Node, “the properties at the intersection of Page Mill Road and El Camino Real need to be architecturally prominent with a strong street presence so that they serve as anchors, for the southern end of the district”. As defined on page 14, the “VTA center at the corner of Page Mill Road and El Camino Real”- where a more intensive use of the site should be designed “to take advantage of the prominent location” and supports pedestrian activities. The project would provide three levels of subsurface parking, which is desirable. Buildings should face El Camino Real parallel to the El Camino Real right-of-way to create a cohesive well- defined streetscape. The building would face the El Camino Real right-of-way but would need to provide a prominent entry to reflect a human scale. Also as noted, “The El Camino frontage should feature extensive windows.” The project does provide extensive glazing on the façade, providing a strong street presence, but the ARB should consider the massing at the corner, which may dominate close to the street. Step-backs or landscape softening may be desirable to mitigate the size of the building frontage. ECR Guidelines: The project is subject to the 1979 guidelines with respect to street trees, signage, architecture and building colors. Trees: The ECR Guidelines call for street tree spacing every 25 feet (Page 2, top) or 30 feet (page 2, bottom); whereas the ECR Design Plan calls for London Plane street trees in this segment of El Camino Real, planted 22 to 23 feet at center in 4’ x 6’ tree wells, and pruned to provide 14’ feet of clearance below to allow for truck and bus traffic. The concept plan does indicate London Plane street trees. Preliminary review of the Landscape Plan by the City’s arborist City of Palo Alto Page 12 suggests removal of the proposed street tree adjacent to the underground parking garage for site visibility reasons. Signage: There are a few relevant statements, such as –“Signs on ECR are limited to ½ to 2/3 the maximum size permitted by the sign ordinance’; “Wall signs should appear as though the building and the sign were designed together. The sign should not appear as if it were attached as an afterthought”; “Three signs one on each elevation, are usually not approved!” The location of signage would be shown on the formal ARB plans to ensure integration. Architecture: “Buildings should not be overdesigned or decorated with superfluous details or imitations of structural materials.” Also, “when possible buildings should be set back from the front property line, with landscaping or a people oriented plaza in front.” This is something to keep in mind when comparing guidelines. Again, the massing of the building near the corner needs to be addressed by ARB, PTC, and Council with these concepts in mind. Colors: “More than three colors on a structure will make it incompatible with the surroundings. Using bright colors, such as reds, yellows and purples and greens as predominant color on a structure may it incompatible with the surroundings. The ARB usually feels these colors are used to attract attention.” Aesthetics/Landscape As this review is only a prescreening, limited information regarding trees and landscaping has been provided. An assessment of aesthetics due to intensity of development would be provided within the required environmental review document. Achievement of urban forestry goals on a densely designed site of this nature would require creative and technological consideration. Staff would work with the applicant to explore urban and pedestrian design features that would help improve the site connections to services and create a greater sense of place for this area. Following submittal of a PC application, staff would meet with the applicant team to discuss the areas that need to be addressed and set next steps for the design review. Community Outreach A notice of the public hearing was distributed to the owners and tenants of all properties located within 600 feet of the project site, and the notice was posted on the City website. This staff report is also posted on the City’s website. Signage has been posted at the site to inform the public about the proposed change. Staff has been available to discuss the proposal with interested members of the public. City of Palo Alto Page 13 Timeline/Next Steps 1. Applicant revises project concept in response to Council comments 2. P&TC (or Council) initiation of Planned Community zoning/Comp Plan redesignation 3. Coordination with California Avenue Concept Plan 4. Initiate Environmental Review process (scoping meeting for an EIR if necessary) 5. ARB preliminary review hearing 6. ARB formal hearing(s) and recommendation 7. P&TC hearing and recommendation to Council 8. City Council hearing and action Resource Impact Applicants for any preliminary review are required to submit a fee deposit, against which staff time to process the application is charged, as a part of the City’s cost recovery program. As part of the formal process, the applicant will submit a fiscal impact analysis to provide information on the valuation of benefits of the project to the City. The City expects to retain consultant assistance to peer review the costs and benefits. The proposed development would also result in one-time development impact fee payments to the City. Policy Implications As noted, a Comprehensive Plan Amendment would be required in addition to a rezoning of the site to allow other than public facilities use. The Discussion section of this report describes policies in the Comprehensive Plan, Housing Element and El Camino Real guidelines regarding development of this site. While the site was shown as a housing opportunity site in the 1998 Comprehensive Plan Housing Element, it is not listed as a housing opportunity site in the draft 2007-2014 Housing Element. Environmental Assessment Environmental review is not required for a prescreening, as no formal action will be taken on the project. If the project proceeds, staff will work with the applicant to obtain and review all the environmental documents associated with the site. A complete environmental assessment (and potentially an Environmental Impact Report (EIR)), including a traffic report, air quality and greenhouse gas analysis, arborist report, hazard and hazardous materials report and noise report would be prepared in compliance with the California Environmental Quality Act (CEQA) guidelines prior to the ARB’s and Planning and Transportation Commission (PTC) review of the City of Palo Alto Page 14 PC zone request, and PTC and Council consideration of the Comprehensive Plan Land Use Re- designation and PC ordinance. Attachments: Attachment A: Location Map for 2755 El Camino Real (PDF) Attachment B: Applicant's Project Narrative (Section I through IX) (PDF) Attachment C: Comprehensive Plan Analysis (DOC) Attachment D: 2755 ECR Zoning Comparison Table 1-25-13 (DOC) Attachment E: Letter from Morris Page Mill, LLC (PDF) PF (AS3) PF CN CN PC-2293 PC-4 3 5 4 PC-44 6 3 GM PC-4831 This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend abc Zone District Labels Zone Districts Assessment Parcel (AP) 2755 El Camino Real 0'99' Sit e 2 7 5 5 E l C a m i n o R e a l CITYOF PALO ALTOINCORPORATED CALI FORNIA P a l o A l t oT h e C i t y o f APRIL 16 1 894 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2013 City of Palo Alto cmoitra, 2013-02-04 17:45:29 (\\cc-maps\gis$\gis\admin\Personal\Planning.mdb) 2755 EL CAMINO PROJECT NARRATIVE APPLICATION TABLE OF CONTENTS. I. INTRODUCTION. II. EXISTING CONDITIONS. III. PROPOSED PROJECT. IV. PROJECT PUBLIC BENEFITS. V. CITY IMPACT FEES AND FUTURE PROJECT REVENUE. VI. LAND USE PLANNING LEADERSHIP. VII. COMPLIANCE WITH PC ORDINANCE 18.38. VIII. COMPLIANCE WITH COMPREHENSIVE PLAN POLICIES AND PROGRAMS. IX. PROCESS AND PUBLIC OUTREACH. 2 .1 I : I q i I I. I SECTION I. INTRODUCTION. The purpose of this Application is to provide extensive narrative and planning materials for a STUDY SESSION to enable the City Council to conduct a comprehensive initial review of the building and site plan for and public benefits related to a PC Zone for development of 2755 EI Camino. We have been advised that complex projects for PC Zone approvals have been adopted in 2011 and 2012. Several of these projects involved complex PTC and City Council hearings with the City Council reversing some recommendations made by the ARB and PTC. These projects would have benefited from an early Study Session with City Council so that the size and style and use of a proposed building could be offered guidance from the City Council. The Council could also describe most preferred public benefits and the necessary value for such public benefits. We plan on a well-managed, thoughtful City Council Study Session. This lengthy narrative and the accompanying building plans and site plans should enable City Council Members to provide strong early guidance for a fine building and public benefits suitable for this important comer site. We seek City Council guidance at the Study Session for (1) approval of the proposed 2275 EI Camino Project as an office building of 33,500 square feet: (2) approval of 10% parking reduction for a comprehensive TOM plan; (3) discussion of adequacy of the proposed public benefits (fully described in Section IV) that we identify as having a value $2,929,000 value. Public Benefits for the 2755 EI Camino Project compare very favorably to other PC Zone projects and, in particular, for the 101 Lytton Project. Public Benefits valued at $2,929,000 consist of (i) land dedication for widening Page Mill Road to allow a right tum lane from westbound Page Mill onto northbound EI Camino but with reservation of subsurface rights of parking area dimensions for safety and parking yield and for shoring of the garage as it will required for best engineering safety; (ii) upgrading the abandoned pedestrian and bicycle tunnel under EI Camino between Chipotle on the east side of EI Camino and the soccer fields on the west side of EI Camino; (iii) dedicating fee interest in the roadway area between the 2755 EI Camino Project and the center of Page Mill road $750,000 to the City for the installation of pedestrian light poles on the portion of California Avenue to be upgraded by the City; (v) canopy improvements for the EI Camino median; sidewalk, pedestrian and planting upgrades; two Electrical Vehicle Charging Stations available for the public to be located at the surface public parking area and two for private use in the underground garage; LEED and other energy and environmental management programs; transportation benefits such as a Cal Train Pass and VT A Eco Pass for all employees that constitute public benefits and not transportation mitigations because there is no CEQA Traffic impact from the 2755 EI Camino Project. There are also impact fees of $918,503 that are greater by $704,000 than the fees that would be charged were it not for the larger PC Zone project of 33,500 square feet. We treat 3 , I I I : I ; I , I : I this $~04,OOO as an element of Public Benefit in Section IV because only because of the 33,500 sf building size allowed by a PC Zone District are there such exorbitant impact fees. The 2755 EI Camino Project will serve to further advance Palo Alto as a regional and national leader. In Section VI of this Document under discussion of the Proposed Project, we provide an extensive discussion of four general land use principles advanced by the 2755 EI Camino Project: (i) Urban Design Guidelines for El Camino; (ii) Iconic Gateway Architecture; (iii) Progressive Transportation Policies; (iv) Transportation Demand Management; and (v) Enviroumental and Energy Management. SECTION II. EXISTING CONDITIONS. 1. RFP AND SALE OF SURPLUS PARKING SITE BYVTA. The Applicant has entered into a contract to purchase from the Valley Transportation Authority ("VTA") the parcel located at the Northeast (logical northeast) comer of Page Mill Road and EI Camino Real. This location of 19,653 square feet serves as a surplus parking lot for VTA bus commuters. VTA has determined that 2755 El Camino has not been used by a significant number of VT A commuters. As a result of a high level of disuse, VTA has declared 2755 EI Camino to be a "Surplus Site", By having become a "Surplus Site" VTA widely distributed an RFP for the sale of 2755 EI Camino. After several rounds of offers in 2012 and 2013, the Pollock Financial Group has been chosen as the qualified purchaser of 2755 EI Camino. 2. CURRENT ZONING. Current Zoning for 2755 EI Camino is (PF) Public Facilities under PAMC 18.28.060. As a Public Facility only the existing surface parking lot is a permitted use. Accordingly, the Applicant requests a PC Zone District that will allow a larger and better-suited building for 2755 El Camino. Were the Applicant not seeking a PC Zone District, the CS Zone District would be the most likely zoning for 2755 El Camino. Staff and the Applicant compare the proposed PC Zone District with the Site Development Standards of both the CS Zone District since there are few site Development Standards for comparison under the PF Zone District and because the PF Zone District must evaluate the site as if it were only a parking lot as now used by VTA. 3. NO EXISTING BUILDING & NO HISTORIC SIGNIFICANCE. There is no building and has been no building at 2755 EI Camino for over fifty years. As a result, there is no historic characteristic of the site with no existing building that is an historic resource. 4 4. NEIGHBORHOOD CONTEXT SUPPORTS THE 2755 EL CAMINO PROJECT. The 2755 EI Camino Project is amidst a well-developed and consistently occupied set of mixed-used buildings. Directly North of and adjacent to 2755 El Camino is 2701 EI Camino, the Sunrise Assisted Living Facility that was approved as a PC Zone District in 2004 for the specific development of the now existing building and its landscaping and parking to be used only for Senior Assisted Living. Sunrise Assisted Living provides 81 dwelling units for Assisted Senior Living. The Sunrise Assisted Living Project is 4-stories and 50 feet tall with one level of underground parking. Directly Eastof2755 El Camino is 435 Sheridan Avenue that is a PC Zone District developed in 2000. 435 Sheridan consists of 35 residential condominium units on a parcel of 57,400 square feet. 435 Sheridan is 3 stories tall over a partially elevate parking garage that provides adequate parking. 435 Sheridan is about 40 feet tall. South across Page Mill along the entire EI Camino frontage is a well-developed block consisting of 3 projects all under the CS Zone District. a) 2805 El Camino is a major retail center for AT&T cell pbone sales and service. b) 2825 El Camino is a three-story mixed-use building with quality office uses for the first two floors and with the third floor consisting of two, fine 2 & 3 bedroom residences that are leased and have not been schedule as "for sale" units. c) 2875 El Camino is a vacant lot, formerly Stanford Dry Cleaners. 2875 El Camino has received City approval for a new one-story commercial building ofless than 5,000 square feet. Jim Baer has been involved with all three of these projects. Hayes Group Architects is the architect for 2805 El Camino and 2875 El Camino. West of the site across El Camino are the City of Palo Alto soccer fields of about 5 acres that is a PF Zone District. Southwest of the site across EI Camino and across Page Mill is the Palo Alto Square office center with the tallest office buildings located along EI Camino with very large surface parking areas. Palo Alto Square is a PC Zone District. Palo Alto Square is occupied by non medical, professional service users. Existing Conditions are well demonstrated in an attached aerial photo and a zoning map. We anticipate receiving endorsement letters from neighboring owners because of the high quality of construction and sensitive site and building design for the 2755 EI Camino Project. 5. HAZARDOUS MATERIALS 5 I J 'f I I I I J I I I I I I I I The following infonnation is provided by our Environmental Engineer and well describes the existing conditions of contamination from the HP COE Superfund site and the mitigation measures we will undertake to ensure that we solve hazardous material problems to the highest possible standards: "The Site is located within the Hewlett Packard-Varian plume where residual contaminant levels are very low. The detectable contaminants in the groundwater within the Site include diesel, motor oil, cis-1,2-dichloroethene, and trichloroethene. TIlese low contaminant levels were confirmed by a recent site investigation that was conducted in June 2012. Results of the site investigation also indicated that contaminants in the underlying soil and soil vapor were below regulatory acceptable levels. Construction of the underground parking garage and building foundation will require lowering the groundwater table and removal of soil to a depth of approximately 35 feet within the Site. We have initiated discussions regarding the project, and plan to work with the Regional Water Quality Control Board (RWQCB), Santa Clara Valley Water District (SCVWD), Hewlett Packard, the Environmental Compliance Division ofthe City of Palo Alto Public Works Department, and possibly the U.S. Environmental Protection Agency (USEPA), to develop acceptable protocols during excavation and pnmping of the groundwater to mininlize disruption to the existing plume and maintain public and worker safety. Additionally, the groundwater will be treated to lower residual contaminant concentrations to levels that are acceptable to the Regional Water Quality Control Plant prior to discharge into the sanitary sewer. It is not anticipated that vapor intrusion into the building workspace will be an enviromnental or human health issue due to the low contaminant levels. However, vapor mitigation measures will be incorporated into the design of the building as a precautionary measure to minimize, if not prevent, vapor intrusion into the building workspace. 111e vapor mitigation alternatives that are being considered include the installation of vapor barriers, subslab depressurization, or proper venting of the underground garage airspace to eliminate a pathway for vapors to migrate into the building works. A Site Management Plan (SMP) describing the proposed dewatering, treatment and discharge, shoring, soil excavation and disposal, vapor mitigation measures, monitoring, and implementation schedule, will be prepared. Additionally, the SMP will describe the precautionary measures that will be implemented to preserve the integrity of the shallow aquifers and araa groundwater extraction, treatment and contaimnent systems during installation of the perimeter shoring for the excavation of the foundation and underground parking garage, the installation and removal of dewatering wells and related equipment, and the dewatering operation itself. The SMP will be submitted to RWQCB, SCVWD, and, as necessary, USEPA, for review and approval prior to initiation of construction activities. Approved procedures identified in the SMP will be implemented during construction of the underground portion of the structure. The recorded field observations; sampling results for the dewatering and treatment system, soil excavation activities, and post-excavation monitoring program, along with waste manifests, will be presented in the Site Management 6 I , I ;1 I I 'I I I I I ! Report (SMR). The SMR will be submitted to RWQCB, SCVWD, and, as necessary, USEPA, for review and acceptance." 6. IMPACTS The 2755 EI Camino Project complies with Daylight Plane requirements relative to its neighboring properties except for a small portion of the building that is the stair tower.. The 2755 E1 Camino Building is twenty-eight feet away from the Sunrise Assisted living project at 270 I EI Camino and is ten feet away from the 435 Sheridan condominiums. Among the mitigations are the following features: a) Providing a setback on the Eastern property line of mostly 23 feet greatly exceeds the setback of 10 feet required for a property in the CS Zone District abutting a residential property; b) Providing a setback on the Northern property line of approximately 25 feet greatly exceeds the setback required for a property in the CS Zone District abutting a PC Zone property. c) With the great depth of the setbacks, the 2755 EI Camino Building, complies with the 10 foot at property line and 45 degree daylight plane as required in the CS Zone District d) The 2755 EI Camino Project reduces noise impacts because of elimination of the all hours parking that brings cars to the current parking lot site early mornings. e) TIle 2755 El Camino Project greatly mitigates traffic impacts for neighboring properties by directing all traffic to enter its site only from EI Camino and not from Page Mill. SECTION III. PROPOSED PROJECT. The Applicant proposes a strong Urban Design leadership commercial, only, project for this crucial site as the primary entry to the Stanford Research Park of 11,000,000 square feet and that has been both an historic and current internationally renowned technology and professional office and rcsearch and development center that has been world renowned and has been one of the earliest office R&D parks in the United States since it inception in the late 1950s. TIle 2755 EI Camino Project fulfills City of Palo Alto Comprehensive Plan Programs, Policies and Goals and enhanccs the EI Camino Real Design Guidelines and thc rcgional principles now being promoted by the Grand Boulevard Multimodal Transportation Corridor Plan. Before gencrally describing the character of the 2755 EI Camino Project as an urban design gateway, employment centerpiece, and a progressive transportation and 7 I " '] : I I I -I , I t i I i I I I I , I : I 11 I environmental model and leader, we first summarize the broadest features ofthe 2755 EI Camino Project. 1. SITE AND ZONING. The Property consists of a single parcel that is currently a vacant surplus parking lot owned by VTA that carries a PF Public Facilities Zone District designation that allows use only as a parking lot. We evaluate the parcel as if it were subject to CS Zone District Site Development Standards. PAMF 1816 CS ZONE FAR • 1;« •••••• )'.<, ••. .> PF •• ·'·····.·.'.··,·> orcS .. •• ..•. Total:!· Parcel Size 19,563 sf 19,563 sf 19563 sf Commercial FAR NA 0.4:1 7,861 sf Residential FAR NA 0.6:1 11,792 sf Total NA 1.0:1 19,563 sf The 2755 EI Camino Project described below is a very modest PC Zone application seeking only 33,500 square feet for the new commercial building with only an FAR ofl.71:1.0 at this strong corner intersection. 2. PROPOSED COMMERCIAL BUILDING PROJECT We propose to demolish and recycle, in accordance with Palo Alto's waste and recycling requirements, the existing parking facility and rezone the property to a Planned Community (PC) zoning designation. A new four story, 33,500 SF, connnercial building with three levels of underground parking is proposed for the 19,563 SF, corner site. A square footage analysis and supporting parking facility calculations are provided in the submittal documents. At only 1.71 FAR, The FAR for the Project is modest for a PC Zone District. With Stanford Research Park and the original Hewlett Packard facility up the street from the project site, the northeast corner of Page Mill Road and EI Camino Real serves as an entrance to the world-renowned Stanford Research Park of nearly 11,000 square feet, Silicon Valley and to the California Avenue neighborhood of Palo Alto. As a Gateway, the mass of the building rises to the corner. The building uses sustainable materials, including a concrete frame, high efficiency glazing systems, high recycled content metal skin systems, cut stone, plaster finishes, abundant day-lighting and sun-shading systems as well as an energy efficient cool roof. 8 . Floor 1 5,275 square feet • Floor 2 9,562 square feet Floor 3 9,761 square feet Floor 4 8,902 square feet 3. ELIPTICAL GLASS FACADE WITH PEDESTRIAN SCALE As one approaches Page Mill from El Camino Real, the floor layers form arcs in the fayade culminating in a large sweeping curve at the comer responding to the energy generated by the vehicular traffic. When one approaches the building from the foothills or Hwy 101 toward EI Camino, the building fayade draws inspiration from the landmark saw-tooth HP building as arc segments form a repetitive pattern in the fayade, providing sun shading on this southeast fayade. Additional curved sun-shading fins wrap the building's comer providing visual interest and depth as well as necessary sun control on this fayade. The new building reinforces the comer of the block with increased height and creates a welcoming ground floor pedestrian experience with integral planters forming a building base with clear, frameless glass windows above allowing visual access into the ground floor like the AT&T building across the street. A horizontal metal canopy further reinforces the first floor and pedestrian friendly scale by wrapping the entire window line, grounding the building and providing sun control. 4. PARKING COMPLIANCE are no attendant spaces and we have not areas for areas, hazardous materials storage, resource conservation or ADA upgrades as are allowed under PAMC 18.04.030(65)(B) See Section VI, below, for other Land Use Leadership Policies advanced by the 2755 EI Camino Project. 9 5. PRELIMINARY TRAFIC ANALYSIS INDICATES NO SIGNIFICANT TRAFFIC IMPACTS, BUT ONLY SIGNIFICANT PERFORMANCE IMPROVEMENTS FROM THE NEW PROJECT The Preliminary Traffic Analysis provided by from Fehr & Peers (November 22, 2012) indicates that the 2275 EI Camino Project will produce fewer than 100 peak hour trips in either the morning or evening peak hour. Therefore, a Congestion Management Program (CPM) traffic analysis is not required. The preliminary analysis also indicates that the El Camino ReallPage Mill/Oregon Expressway intersection operates at acceptable service levels (LOS E or better). Fehr & Peers determines that there are no significam traffic impacts under analysis of both (i) the existing 2012 site and (ii) the existing 2012 condition plus the proposed new 2275 EI Camino Project of33,5oo square feet. In addition, the preliminary analysis shows that the intersections will operate more efficiently with the addition of a dedicated westbound right tum lane from Page Mill Road onto El Camino Real northbound. This means that the dedicated land from the 2275 EI Camino Project for this dedicated right tum lane is a very significant public benefit for the entire community transportation system. Because development of the 2275 El Camino Project has no immediate traffic impacts, benefits offered by the 2275 EI Camino Project shall be public benefits rather than mitigations or conditions of approval that could in any way be compelled. We will discuss these transportation public benefits in Section IV. SECTION IV. PROJECT PUBLIC BENEFITS P AMC 18.38.060 provides this required determination concerning public benefits for a PC Zone. "Development of the site under the provisions of the PC planned community district will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts. In making the findings required by this section, the planning commission and city council, as appropriate, shall specifically cite the public benefits expected to result .from use of the planned community district. " A. EXTENSIVE PUBLIC BENEFITS $2,929,000 Value The 2755 EI Camino Project has planned many site development outcomes and use outcomes that benefit the City and that cannot otherwise be compelled under the CS zone 10 : I J , [ , J , J I , t , I I J I , ! I I I district or any other "c" Zone district. The 2755 EI Camino Project provides extraordinary urban design features, progressive transportation features and parking features (including electric charging stations), and many energy and envirorunental management benefits. All of these features, and more, are elements of public benefit not only by their inherent nature, but also because they carmot otherwise be compelled by the City as a condition of approval. In this section we present the public benefits for the 2755 EI Camino Project with all of the items committed to by the Applicant and of the type of improvement or use that carmot be compelled by underlying zoning. The specific public benefits that are not an element ofthe 2755 El Camino Project but that are offered separately and entirely as a public benefit under PAMC 18.38 consist of the following compelling and valuable benefits. 1. DEDICATE LAND, WIDENING PAGE MILL ROAD FOR A RIGHT TURN LANE WHEN HEADING WEST ON PAGE MILL ONTO NORTHBOUND EL CAMINO. $600,000 Value. This intersection contains Page Mill Road operated by Santa Clara County. Page Mill is the only Palo Alto transportation corridor that connects Freeways 101 and 280. El Camino carries the most vehicles of any corridor in Palo Alto with over 5,000 daily trips. The Page Mill and El Camino intersection is the business and most severely impacted in Palo Alto. For peak hour trips, vehicles heading west on Page Mill back as far east as Waverley and further. Traffic onto Page Mill headed west backs up so that it creates a dangerous situation for high speed traffic exiting from Alma onto westbound Page Mill. There is no right tum lane from Page Mill westbound onto EI Camino northbound. At peak hours traffic crossing El Camino at Page Mill is also an arduous, failing transportation metric. By making a substantial land dedication, Page Mill can be widened to provide a dedicated right tum lane and possible further widening of Page Mill to correct other deficiencies. Neither the City nor the County conld compel a land dedication from the 2755 El Camino Project and it is even unlikely that either the City or the County could successfully pursue eminent domain for land to widen Page Mill because of mandatory findings to support a resolution of necessity when Page Mill has existed at its current width for 50 years or so. We have determined with the City and the County transportation departments that 856.3 square feet will be dedicated. The cost of this land for the Applicant on a per foot basis is $290.00; 856.3 SF @$290/SF = $248,327. In addition, the Applicant must build a new curb, gutter, sidewalk, and street edge conditions with scraping existing street speed and reflective bumps, and other desigu and utility features for $205,960. These improvements would not otherwise be required of the Applicant for occupancy oftbe 2755 EI Camino Project. We are assuming that the city would be involved in redoing any signal work and will do the additional paving in Oregon Expressway at their expense. We value the land 11 I I ( , I I I ~ 1 , I : i r I , I I I I : I dedication for the purposes of widening Page Mill as $600,000 because widening Page Mill has much greater community and transportation value to the City than does the Applicant's cost for this land and its sidewalk and roadway improvements. As stated in the Fehr & Peers Preliminary Report: "The intersection will operate more efficiently than existing conditions with the addition of a dedicated westbound turn lane on Page Mill Road. " This land dedication will consist of part fee simple interest and part beneficial use easement for the City because the 2755 El Camino Project will need to reserve some subsuiface rights for the construction of underground parking garage stalls with necessary shoring and safety deigns, These details will be worked out with the City following the Study SessiolJ,. 2. DEDICATE LAND IN FEE INTEREST TO THE CITY FROM THE EDGE OF 2755 EL CAMINO TO THE CENTER OF PAGE MILL ROAD. $150,000 VALUE. Under California Law (Civil Code Section 831) the City owns only a surface beneficial easement without fee ownership from the previous dedication of sidewalk and roadway by a predecessor of the Applicant. With only a beneficial easement and not with fee ownership, technically the City must ask the Applicant as continuing owner of the fee interest under Page Mill for permission for subsurface construction work or utility installation. We value the dedication of a fee interest under Page Mill Road as $150,000. Code Section 831 provides: " An owner of Land bounded by a road or street is presumed to own to the center of the way but the contrary may be shown." The series of cases and Attorney General opinions under Code Section 831 provides that a property owner grants only a surface, beneficial use easement to a City when dedicating a right of way> Since the 2755 E1 Camino Project will be going through title documentation efforts to grant to the City land dedicated to allow the City to create a dedicated right run lane from westbound Page Mill onto northbound El Camino, it will be technically easy and possible for the 2755 El Carnion Project to transfer a fee interest to the City under any portion of Page Mill Road for which the 2755 El Carnion Project may still own fee interest. This will allow the City greater value in its fee ownership of the land, and in its free use of subsurface areas of the surface easement that might not currently be fully legal, even if the City has installed some underground utilities, Such utility installations may not have been accomplished with full legal rights as if the City were to own a full fee simple interest. We value the upgraded ownership of the City in Page Mill Road from a beneficial use easement 0 a fee simple interest as having a value of $150,000. 3. UPGRADE THE ABANDONED PEDESTRIAN TUNNEL UNDER EL CAMINO REAL BETWEEN CHIPOLTE AND THE SOCCER FIELD. $350,000 VALUE. 12 The tunnel has been closed for nearly fifty years. It was originally installed to provide a pedestrian tunnel for school children attending Hoover Elementary School located where the City soccer fields are now located. It will be necessary to install pedestrian elevator/lifts in order to make the tunnel ADA compliant. The tunnel may be well used for both pedestrians and bicyclists walking their bicycles under El Camino. The tunnel may not be wide enough to handle two-lanes of bicycle traffic. We will comply with whatever use and planning is determined most needed and safe for non-vehicular transportation. This is another opportunity for City of Palo Alto to demonstrate transportation leadership at this busy location. We are working with the City of Palo Alto, with CaiTrans and with our construction and engineering team to determine the best upgrade conditions for highest public use. We value the upgrade of the tunnel at $352,459 and we provide an exhibit of the construction line item costs considered as necessary for upgrading the tunnel. 4. MAJOR FINANCIAL CONTRIBUTION FOR INSTALLATION OF PEDESTRIAN POLE LIGHTS ALONG CALIFORNIA AVENUE TO SUPPLEMENT CITY'S UPGRADE FO THE CALIFORNIA A VENUE SHOPPING DISTRICT. $750,000 VALUE. The 2755 El Camino Project will contribute $750,000 that is the cost estimated by the City for installation of most of the pedestrian light standards along Califomia Avenue for the area planned for redevelopment by the City in its efforts to greatly upgrade the Califomia Avenue Area Shopping District. The City has not included these pedestrian lights for installation at the City's cost or within the City's allocated budget for Califomia Avenue. These lights are comparable to those in the Downtown Palo Alto area that add to its success as a regional pedestrian and retail center. These lights are on large anchored poles and are not small, impermanent twinkly tree lights. We include, as exhibits, pedestrian light pole standards and a budget estimate for contribution by the 2755 El Camion Project. Contributing $750,000 toward the upgrade of pedestrian light standards for Califomia Avenue as tit becomes an upgraded Downtown for the Stanford Research Park and the 2755 El Camino Project and that the Califomia Avenue District will become more suitable for serving customers and pedestrians. 5. URBAN DESIGN FEATURES THAT CANNOT BE COMPELLED BY THE CITY AS CONDITIONS OF APPROVAL. $150,000 VALUE. There are 3 seminal cases regarding the requirement that there be a nexus between an imposition made by a local govemment and the impact of the project on the community. These are the U.S. Supreme Court cases Nollan (1987) and Dolan (1994), and the California Supreme Court's Ehrlich case. (1986) 13 r '1 . I f I ~ I I I I : I . I , ! I The features we describe as public benefits in this Subsection 5 are of the type discussed in these court cases that could not be compelled by the City. Therefore, we identify these features as public benefits. 1. Canopy upgrades, including irrigation in the EI Camino median near 2755 EI Camino and north of Page Mill Road. We will work with Canopy and the City to complete this important section of the Betty Meltzer roadway. 2. We will install 4 Electric Vehicle Charging Stations two of which will be on the surface parking available for use by the public. These two EV Charging Stations are pubic benefits. There will also be two private Electrical Vehicle Charging Stations in the private garage. 3. We will provide widened sidewalks greater than the minimum standards for the El Camino Real Design Guidelines. 4. We will complete several energy and environmental management programs including compliance with Palo Alto's Green Building Code ad compliance with a LEED Silver standard and other features described in Section III 6. EXTRAORDINARY IMPACT FEES ONLY BECAUSE OF PC ZONE PROJECT SIZE. $704,000 VALUE. We identify the Impact Fees and increased fees of about $704,000 allocable tc Public Benefits because these increased impact fees are related entirely to the increased commercial area for the 2755 El Camino Project. 7. TEN-YEAR VALUE OF ECO-PASS AND CALTRAIN PASS. $225,OOOV ALUE. We identify a Public Benefits value of the Beo-Pass and Caltrain Pass for employees for ten years as $225,000. We are using 110 employees as the basis for determining the annual cost of transit passes. These transit passes require purchasing passes for 100% of all employees even if some employees are unable to make use of the transit passes. The VTA Eco Pass costs $36 per year and the CaItrain Go Pass $165 per year for a total of $201 per 14 r J '1 I , J I , 1 'I I I I I I I I I , ! I year per employee of$22,I10 per year for 110 employees. For ten years the value is $225,000 including very minor future inflationary costs. We identifY the cost of these passes as a Public Benefit because nnder CEQA there are no traffic impacts from development of the 2755 El Camino Project. We commit to purchase these passes for ten years -it may be that tenants will be required to purchase passes for its employees rather than the Landlord purchasing passes but the same benefits accrue to the 2755 El Camino Project. 8. QUALITY AND CHARACTER OF THE 2755 EL CAMINO PROJECT CONSTITUTES FINE PUBILC BENEIT FOR WHICH WE ASSIGN NO VALUE. In order to serve as a Gateway project leading into the world renowned Stanford Research Park business and technology epicenter, a building larger than allowed through underlying the CS Zone District at a 1.71 FARis a best mass and design and land use for the site. There is no true Gateway for the Stanford Research Park at the present time and only with this height, mass, and quality of architecture can the site serve to be that Gateway that the Stanford Research Park and the City so rightfully deserves. We hope you will consider the character and quality of the 2755 El Camino Project and building for its location has a major component of community benefits. In the Downtown. The City has identified strong buildings and their site plans as substantial public benefits, including Plaza Ramona at 250 University, 531 Covvper, 529 Bryant. 251 University, the Byxbee Historic House, 260 Ramon, 819 Ramona, 101 Lytton, 820 Ramona, 250 Emerson, 737 Bryant, 400 Emerson, 250 Ramona, 820 Ramon, 499 University, and others that greatly contribute to the fabric of the Downtown and that have succeeded as Public Benefit projects. SECTION V. IMPACT FEES AND PROJECT REVENUES. Impact Fees: $918,503 for the 2755 EI Camino Project that is $704,000 in excess of the Impact Fees that would be charged were the Project developed under the CS Zone District. We treat this excess PC Zone Impact Fee as an element of Public Benefit. 15 , r , I 1 I , I I : I I I I I I I I 1. IMPACT FEES The 2755 EL Camino Project is a commercial project that will have only office, financial service, and retail service uses. The commercial building will be 33,500 square feet on a site that has not existing building. Accordingly, we calculate Impact Fees based entirely on the commercial use and the size of the building all as net new uses and areas. The "new gross square footage" for the 2275 EI Camino Project is 33,500 square feet. The Impact Fees will be as described below in two columns: the first column identifies the impact fees that would be payable if only 7,825 square feet of commercial building area were built in acqordance with the CS Zone District. The second column identifies the impact fees that will be payable for the proposed 2755 EI Camino Project. with its "new gross square footage" of 33,500. a) PAUSD Fee. The amount of the PAUSD fee for the 2755 EI Camino Project will be $0.47 per square foot for 33,500 square feet or $15,745. b) Parks, Community Center and Libraries. The amount of the Park fee shall be $4.908 per square foot for 33,500 square feet or $164,418. c) Citywide Transportation Impact Fee. The amount of the Citywide Transportation fee shall be $4.45 per square foot for 33,500 square feet or $149,075. d) Quimby Fee. There is no parkland dedication fee known as a Quimby fee for the 101 Project because there is no subdivision for the 101 Project. The Parkland Dedication Fee is $0.00. e) Housing Impact Fee. The amount of the Housing Impact fee is $17.59 per square feet for 33,500 square feet or $589,265. Total Impact Fees: $918,503 for 33,500 square feet under the PC Zone rather than $214,546 for 7,825 square feet under the CS Zone, or $704,000 additional impact fees for the 2755 EI Camino Project. 16 J : I 'I I i'l , t , 1 J , f l I ,I I 1 I I I I 2. FUTURE PROJECT REVENUES FROM PROPERTY TAXES: $211,196 SHARED BY PAUSD AND CITY a) ANNUAL STABILIZED PROPERTY TAX: CITY $32.120; b) ANNUAL STABILIZED PROERPTY TAX; PAUSD $164.016 c) PROPERTY TAX CALCULATION: COMMERCIAL BUILDING of 33,500 SQUARE FEET @ $850 psf= $28,475 012% TAX RATE = $341,700 0.48% of TAX to PAUSD = $164,016. 0.94% of TAX to CITY= 32,120 3. ANNUAL PROJECT REVENUES FROM SALES TAXES: $15,060 a) FROM OFFICE TENANT CORPORATE USER: $3,000 PER WEEK ($156,000 SALES PER YEAR; CITY = 1% = $1,560 PER YEAR) b) FROM 110 EMPLOYEES = $14,000 PER EMPLOYEE PER YEAR ($1,400,000 PER YEAR; CITY = 1 % =$14,000 PER YEAR) SECTION VI. PLANNING POLICY LEADERSHIP. There are five components of the Planning Policy Leadership of the 2755 EI Camino Project: (A) Urban Design; (8) Gateway Architecture for entry to the Stanford Research Park; (C) Progressive Transportation Programs; (D) Transportation Demand Management; and (E) energy and environmental management features. A. URBAN DESIGN LEADERSHIP FOR EL CAMINO. The 2755 EI Camino Project beckons as a uniquely successful urban design project for central Palo Alto at the entry to the World-renowned and innovative Stanford Research Park. 17 I I I We refer to and seek guidance from significant urban design principles found in Palo Alto's South El Camino Real Design Guidelines as adopted by the ARB in 2002, and the Grand Boulevard Multimodal Transportation Corridor Plan of 20 I 0 as well as urban design policies of Palo Alto's Comprehensive Plan. 1. SAN MATEO/SANTA CLARA COUNTIES GRAND BOULEVARD MULTIMODALTRANSPORTATION CORRIDOR PRINCIPLES ADOPTED IN 2010: Of the ten Guiding Principles, one principle relates to encouraging compact mixed-use development. We have successfully achieved housing and mixed-use developments along this portion ofEI Camino with 2825 El Camino, and 270] El Camino. With the severe traffic and acoustic challenges of the 2755 EI Camino site that are the worst in the City of Palo Alto, housing development as a mixed-use for this site would not be achievable for attracting happy residents. The remaining Guiding Principles are well achieved with considerable effort and investment by the 2755 EI Camino Project. a. Target job growth in strategic areas along the corridor. We will attract employment and likely financial services for employees with the 2755 El Camino Project commercial building. b. Encourage high-quality urban design and construction. We are confident that the design by the Hayes Group Architects and Ken Hayes will continue their award wining modern design concept for much of EJ Camino. c. Create a pedestrian-oriented environment ensuring access between public areas and private development. The 2755 El Camino Project will implement the City's goals for greatly widened sidewalks along El Camino and we will make the interface between our commercial building and public areas open and inviting. d. Develop a balanced multimodal corridor. The 2755 El Camino Project is located at Palo Alto's busiest intersection with Page Mill and El Camino design and transportation features provided by VTA, the City, the County and some private shuttle operators such as StanJord. The 2755 El Camino Project will provide a small private shuttle for assisting tenants and employees make maximum, best use CalTrain. e. Manage Parking Assets. The Guidelines encourage a developer to "consider trip reduction when designing parking requirements. The 2755 El Camino Project reduces parking by 10% with a TDM Planfor trip reduction. The Guidelines encourage preserving street frontage by placing parking behind buildings or below grade as is accomplished by the 2755 El Camino Project. 18 I I I I I I . I , I , I , 1 . J ,I I I I I I I , I \ I f. Provide vibrant public spaces and gathering places. The entry area plaza and garden area is a vibrant public space for gathering. g. Preserve the existing quality of life in adjacent neighborhoods. By limiting vehicular ingress and egress to the site from El Camino, the 2755 El Camino Project preserves the residential character of Sheridan Avenue. b. Improve safety and public healtb. By dedicating land to widen Page Mill in order to add a right-turn lane onto El Camino, public safety will be greatly improved since vehicles currently back up on Page Mill to Waverleyandfurther, and in particular with negative impacts on high speed Alma and its exiting onto Page Mill. The 2755 El CamillO Project will also participate with pedestrian safety imprOVements at the El Camino and Page Mill intersection I. Strengtben pedestrian and bicycle connections. The 2755 El Camino Project enhances pedestrian and bicycle connections in two ways: (I) by upgrading and . making safe and ADA compliant the abandoned tunnel under El Camino, pedestrian and bicycle connections near Page Mill will be greatly improved; (U) by widening the sidewalks along both El Camino and Page Mill to meet City standards, the movement of pedestrians will be greatly enhanced as will the connectivity of sites north and south of the 2755 El Camino Project. j. Pursue environmentally sustainable and economically viable development patterns. The 2755 El Camino Project will become a stellar role model for LEED and sustainable design for a new commercial building. A strong commercial building with community service users enhances the economic viability for El Camino north, south and east of our project. 2. CITY OF PAW ALTO SOUTH EL CAMINO REAL DESIGN GUIDELINES ADOPTED IN 2002: Given the foregoing local and regional policy studies, we identify the following most successful urban design features of the 2755 EI Camino Project adopted May 2002 with updated reviews as recently as November 2010: a) Locate higher density development adjacent to transit nodes. The proposed 2755 EI Camino Project with a 1.71 FAR adds strength and identity to this important corner as a gateway component for the world renowned Stanford Research Park. Although larger than the CS Zone District would allow, at 1.7 1 FAR the 2755 EI Camino Project is not a massive building too large for the site or its neighborhood context. b) Create an identity that is specific to South Palo Alto. The modern glass fayade and elliptical shape of the 2755 EI Camino Project and with its wide sidewalks, consistent with the South EI Camino Design Guidelines, the 2755 EI Camino 19 , I , I I I I I :1 : I : I ~ I , I ,\ I I I I I I I , I , I Project of appropriate larger size and scale suitable for and specific to EI Camino. The 2755 EI Camino Project is highly compatible as a leader for vehicular visual access at this most busy intersection. This design motif of the 2755 EI Camino Project is not reminiscent of successful buildings in Downtown Palo Alto. The 2755 EI Camino Project is specific to South Palo Alto and EI Camino with its high vehicular traffic counts, c) Encourage design that compliments the streetscape concept. The 2755 EI Camino Project will work to enhance canopy for medians and sidewalk areas and will create wide sidewalks for pedestrian enjoyment with great connectivity to the crosswalks at this intersection and with an safe, upgraded tunnel under EI Caruino to greatly improve public use ofthe existing streetscape and buildings along EI Camino near Page Mill. d) Ensure a healthy and vibrant market for new development projects. We have entered into a Letter ofIntent to lease the entire 2755 EI Camino building (if we are approved and able to deliver a completed building in accordance with the LOT terms) to a fine and current tenant in this part of Palo Alto. Attrscting such a user will ensure a healthy and vibrant market for future development projects. We know that Jim Baer is working on the vacant site at 2875 El Camino and renovation of the large, old building at 2600 E1 Camino. These kinds of projects will follow soon aided by the City's approval of the 2755 EI Caruino Project. 3. SUMMARY URBAN DESIGN FEATURES OF THE 2755 EL CAMINO PROJECT. We identify the most notable of many successful Urban Design features of the 2755 EI Camino Project. Gateway Architecture is reflective in the prominent and contemporary design that is consistent with neighboring buildings with an appropriate building mass of 1. 71 FAR and with 4 full stories. At 50' height. a) Iconic architectural features will purposely can attention to this prominent location and confirm its gateway nature as an entry site for the world renowned Stanford Research Park. b) Pedestrian continuity created by eliminating several curb cuts currently in place, bringing the building to the urban edge, and disguising surface parking by placing it behind the building. c) Pedestrian-scaled features span the EI Camino and Page Mill property line. d) Highly visible financial services and retail services along the Page Mill and E1 Camino corridors. 20 r I I I , I , I : I : I : J : I : I : 1 I I I I I I I I e) Widening the walkable area for sidewalks on both Page Mill and E! Camino, f) Recessed door and window features of the building to further the walkable area of the sidewalks along Page Mill and El Camino. g) Bulb-out at Page Mill and E! Camino N/E intersection to increase sidewalk area at corner. h) Decrease the crosswalk distance for El Camino to enhance the safety of the intersection and encourage more pedestrian use. i) Median and sidewalk trees will be coordinated with the City, the County, CalTrans and Canopy to enhance this portion ofE! Camino. j) Vehicular entry along El Camino to preserve the pedestrian connectivity at the corner and on Page Mill. B. GATEWAY ARCHITECTURE FOR THE STANFORD RESEARCH PARK. 1. PROMINENCE FOR STANFORD RESEARCH PARK WITH GATEWAY ARCHITECTURE. Appropriate height and mass are required for a building to become a Gateway as an important landmark location for the Stanford Research Park. The 2755 EI Camino Project provides the appropriate height of 50' and mass at 1.71 FAR for this gateway location directly opposite the Stanford Soccer fields and near Palo Alto Square. Palo Alto Square is far too recessed and is not interactive with the street so that is dos not serve as a successful Gateway for the Stanford Research Park. 2. FINE GATHERING PLACE FEATURES WITH GROUND FLOOR PLAZA AND LANDSCAPING. There is afine plaza and landscaped area to serve visitors and passersby at the entry to the building, Along El Camino and Page Mill there will be "in ground" plantings in addition to sidewalk, median and street canopy. 3. ROOF TOP DECKS FOR BUILDING OFFICE TENANTS. The Applicant has included rooftop deck areas for the commercial tenants. The commercial roof deck will be at the 4th level. In order to provide such substantial rooftop space, the Applicant has endeavored to relocate considerable mechanical eqUipment into and around the building edges, 4. GATEWAY SIGNAGE AT THIS GATEWAY CORNER LOCATION. Signage will be appropriate and highly prominent for this strong corner location. 5. GROUND FLOOR FINANCIAL SERVICES THAT MAY INCLUDE BRANCH BANKING THAT IS NEEDED FOR STANFORD 21 , I , I 'I I :1 I I :I : I . I , I I I .1 I I I RESEARCH PARK EMPLOYEES AND FOR VEHICULAR TRIP REDUCTIONS. The 2755 EI Camino Project combines ground floor financial services with a likely branch bank to serve employees of the Sanford Research Park without the need for vehicular trips to manage personal hanking matters, superior office, with spectacular integration and extremely low school, traffic, acoustic or other impacts. 6. MODERN ELLIPTICAL DESIGN WIm A FULLY GLAZED "CURTAIN" WALL. The modem design for the 2755 El Camino relies on a unique elliptical wall shape and a "Curtain" with structural glazing that presents a full-height glass wall without apparent structural frames holding the glazing erect. and without visible structural elements for the horizontal spaces between each of the four floors. C. PROGRESSIVE TRANSPORTATION POLICY LEADERSIDP. The City's Comprehensive Plan has emphasized progressive transportation policies and leadership. Without identifying specific Comprehensive Plan provisions, the following City transportation goals have been captured by the 2755 El Camino Project. a) Pedestrian amenities and connectivity to the train and other public transportation and to vehicular and pedestrian opportunities are emphasized with new features to be developed by the 2755 El Camino Project that will encourage alternative means of transportation other than single occupancy automobiles. b) Surface parking is located behind the building and in three-levels below grade to enhance the urban design of the 2755 El Camino Project while providing safe and adequate parking thereby avoiding parking in the neighborhoods. Other than with on c) Site parking and effective Transportation Management Planning, there areftw parking alternatives to adequately parking the building for 2755 El Camino Project. d) The 2755 El Camino Project will provide, at the Applicant's expense, 2 electric vehicle (EV) charging stations each of the two locations (including one Class Three EV station), available to the public on the surface public parking area. There will be one EV station providedfor tenants of the 2755 EI Camino Project in the underground parking garage. The Applicant will pay for installation of the EV stations and will help coordinate with EV station operators the billing of EV users directly for electric utility costs of charging. e) The 2755 El Camino Project provides 121 parking spaces including 15 parking spaces at grade with 7 of these spaces located on the surfoce in an area that is visually and practically open to the public. In addition there are 39 spaces on level 3 of the below grade parking garage and 34 spaces on level 2 of the below grade parking garage and 33 spaces provided on the level 1 of the below grade parking garage. 121 parking spaces is consistent with the number of parking spaces required 22 , I : I , I ·1 I I I .1 I I I I I I by P AMC Managing on-site parking has been determined to be the most effictive factor for reducing Single-use occupancy vehicles. f) The 2755 EI Camino Project will provide a Transportation Demand Management (I'DM) Plan that can result in 30%+ reduction of single use automobiles that are near a central train depot and other public transportation. We seek only a 10% reduction in parking, rather than seeking the 20% parking reduction encouraged under PAMC 18.52. The 2755 EI Camino Project respects the conservative 10% parking acfjustment as most suitable for this site. g) VTA and Bus transit subsidy program for tenants of the 2755 EI Camino Project The Applicant will provide or will require its tenants to provide Cal Train passes and ECO-Pass bus passes for 70% of the employees within the 2755 EI Camino Project. The cost per employee for a VTA ECO Pass is $36 per year and/or a Cal Train Go Pass will be $18,150 per year. We estimate that with 110 employees the VTA Eco Pass will cost $3,960 per year. The combined two transit passes will cost the project $22,100 per year that we further extrapolate as $225,000 for over a tell year period thereby ensuring implementation of a successful, operation of vehicle passes for all employees. The cost of passes are Public Benefits because the transit passes could not be compelled as part of the CEQA analysis that has determined that existing condition plus the proposed 2755 EI Camino Project do not generate any significant traffic impacts requiring any transit pass mitigations or other transportation conditions on for approval of the Proposed 2755 Project. The Project commits for 110 employee annual passes for the VTA ECO Pass of$3,960 per year, and for the Cal Train Pass will be $18,150 per year for a total of $22,1 10 per year or $225,000 estimated with an inflator for a 10-year program commitment. D. TRANSPORTATION DEMAND MANAGEMENT. The trip reduction activities of the 2755 EI Camino Project and transportation mode-use rate will be monitored annually, with the first employee commute survey to be conducted one year after the occupancy of the completed 2755 EI Camino Project. An alternative transportation mode-use survey report will be submitted to the City's Director of Planning and the Community Environment following the completion of the annual employee commute survey. The measures and elements contained in this plan are consistent with other well performing employee TOM commute programs in the Greater San Francisco Bay Area. TOM measures specifically developed for the 2755 EI Camino Project have a variety of infrastructure and incentive-based measures, which encourage all forms of alternative transportation modes such as carpool, vanpool, public transit, bicycling, walking, and telecommuting. The applicant is committed to encouraging tenant and employee participation and strongly supports employee commute programs. In addition to the existing transportation infrastructnre in the immediate area (free shuttles, CalTrain depot and VTA bus stations, bicycle "pods", and VeloCity Bicycle Taxicab), the TOM measures of the 2755 El Camino Project include: 1. INFRASTRUCTURE MEASURES 23 , I I t 1 I I I I a) Comnllmity Connectivity -Mixed-use, Pedestrian and Transit Oriented Design (LEED Neighborhood highest standards); b) Rail Station Proximity within 1000 feet walking distance of the CalTrain station; and with shuttle van operated by the Applicant exclusively for the 2755 El Camino Project. c) Reduce Parking Supply by 10% under locai policies and codes; d) Provide Four Clean Fuel Electric Vehicle Charging Stations Two for Public Access; e) Provide Carpool and Vanpool Parking Spaces; 1) Provide a Passenger Loading Zone; g) Provide Motorcycle and Scooter Parking Placement; h) Provide Bicycle Parking -Long-Term and Short-Term; i) Provide Showers and Clothes Lockers for Employees; j) Instali Transportation Kiosk(s); k) Abundant Significant nearby amenities (e.g., retail, cafe, vending, ATM, etc.); 1) Incorporate Alternative WorklTelework Infrastructure. 2. PROGRAMMA TIC TDM MEASURES a) TDMTenant Lease Language and Tenant to designate a TDM administrator; b) EmployerlTenant TDM Training (provided by Applicant as building owner); c) Project Transportation Coordinator -Commuter Assistance, Employee Outreach, Transit; d) Planning and Rideshare Matching by TDM administrator. e) Project Commute Flier and TDM Site Plan; 1) Kick-off and Recurring Commuter Event (at 75% occupancy); g) Promotional Programs (Bike to Work Day, CAL-train Day, Spare the Air Days, etc.) h) Employee newsletters, and updates; i) Carpool Promotions; j) Bicycle Resources; k) Transit Resources; I) Annual Onshe Transportation/Commute Spare the Air Fair. m) On Site shuttle service to provide regular pick up and delivery trips to California Avenue and the California Avenue train station at well-coordinated hours of service. 3. TDM MONITORING AND REPORTING a) Notice of TDM Program Implementation following b) tenant occupancy of the completed new building; c) Annual Employee Commute Survey and Summary Report; d) Greenhouse Gas Reduction Assessment. (See the "Draft" TDM Program. Elizabeth Hughes ofTDM Specialists prepared the TDM Program. Elizabeth has been a leading TDM consultant throughout Northern California with recent, successful programs in Palo Alto). 24 I , r I I , I I I I [ I I I I I I 4. EMPLOYMENT TRANSPORTATION MANAGEMENT IS SUCCESSFUL. The vast majority of the growth that has occurred in the United States over the last century has occurred in the suburbs with the expansion of the freeway system and the reliance on the automobile. This has created significant problems that have reached catastrophic levels. Carbon emissions are increasing by upwards of20% every 10 years, our freeways and bridges and roads are congested and well over capacity, and access to employment and amenities is growing increasingly difficult, especially for the low income and the elderly. It is imperative that cities focus their development near transit and near downtown locations to address these seemingly insurmountable obstacle The Association of Bay Area Govemments ("ABAG") has implemented policies such as SB375 and AB 32. These policies specifically call for significant reductions in carbon emissions and GHGs by focusing on compact development and locating these developments near transit. ABAG's decision and local municipalities' decision to focus development near transit is due to the results of multiple studics that have been done looking at automobile usage, alr quality, and congestion, as it relates to housing and employment near transit. Many studies demonstrate conclusively that locating employment near transit is of great importance for Transportation Planning and Progressive Leadership. In California, those working in office buildings near rail stations and along well-established bus lines like VTA on El Camino are nearly three times as likely to regularly commute by transit compared to those working away from rail stations and bus lines. Studies have determined that "employment densities at trip ends have more influence on ridership than population densities at trip origins." Bay Area "office densities around suburban transit stations had a significant positive influence on ridership". Furthermore, the office buildings within 500 feet of transit had double and triple the ridership than those office buildings more than 500 feet away from transit that were still considered within walking distance. The 2755 EI Camino Project is committed to the goals and policies of ABAG and goals and policies of Palo Alto to create a eJean and pedestrian friendly environment and reduce the reliance on the automobile by focusing employment near transit. E. ENVIRONMENTAL & ENERY MANAGEMENT LEADERSHIP. The 2755 EI Camino Project greatly benefits the environment by its important environmental design leadership. These environmental design features include: a) Achieving LEED Silver standards for the new site and building by complying with the Palo Alto Green Building Code. Compliance with LEED Standards does not necessarily include receiving a LEED certification of compliance. 25 J , I I t I , J 1 : t I I r I I I I I I I , I b) c) d) e) j) g) Highly efficient design of irrigation for landscaping and street trees. Planting many new trees (both onsite and offiite) that will provide climate temperature control and C02 absorption. RefUse and perishable efficiencies with progressive purchasing policies for building tenants, comprehensive recycling, and proper treatment of disposable products. Goal of35% reduction of indoor energy and water use relative to similar businesses and buildings as measured by federal Energy Star standards, Superb management and remediation of the on site underground water contaminated as part of the EPA superfUnd sites contaminated by HP & Varian at the CaE Plume under 2755 El Camino. Support of City of Palo Alto conservation and environmental goals for the Including support of ACTERRA and the City's Utility Department that have, as their mission, the advancement of Palo Alto and its residents and businesses as the most successful environmental, energy and water management citizens in the United States. 26 [ . I SECTION VII. COMPLIANCE WITH PC ORDINANCE 18.38. Under P AMC 18.38, the Planning and Transportation Commission, prior to recommending approval of any PC Zone District application to the City Council, and prior to approval of any PC Zone District by the City Council the relevant governing board shall make all of the following required fmdings with respect to the 2755 EI Camino Project. 1. The site is so situated, and the use or uses proposed for the site are of such characteristics thatthe application of general districts or combining districts will not provide sufficient flexibility to allow the proposed development. 2755 EI Camino under a PF Zone District is allowed no commercial development, Under a likely CS Zone District change, the commercial portion of a building would be limited tol,O FAR of 19,563 square feet consisting of 0.4 FAR for commercial area and 0.6 FAR for residential area .. The Applicant proposes a commercial building of33,500 square feet and with an FAR of 1.7 that requires adoption of PC Zone District. A suitably strong commercial building of 1. 7 FAR at this most important intersection of EI Camino Real and Page MiU Road requires a PC Zone District. Also, under the CS Zone District PAMC 18.16 there is no limit on ground floor office use for a property facing El Camino that has been previously unoccupied. However there is a limit on the total area of Office Users of 5,000 square feet per parcel. Accordingly, a PC Zone District is also necessary so that the 2755 EI Camino Project can be occupied by one or more Office Users for a total area that will be greater than 5,000 square feet. In a CS Zone District there is no limit on the size ofa Financial Service User. The Applicant hopes that the initial user of the entire 2755 EI Camino Project shall be a Financial Service User. However, a PC Zone is necessary to allow an Office Use of greater than 5,000 square feet as is a likely requirement during the lifetime of the 2755 EI Camino Project 2. Development of the site under the provisions of the PC planned community district will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts. 2755 EI Camino provides extensive public and community benefits that are described in Section IVabove and valued at over $2,929,000. 3. The use or uses permitted, and the site development regulations applicable within the district shall be consistent with the Palo Alto Comprehensive Plan and shall be 27 J J I I I I 1 I I I r I I I I I I I compatible with existing and potential uses on adjoining sites or within the general vicinity. As described in Section VIII below, The 2755 EI Camino Project powerfully exemplifies the goals of the 1998-2010 Comprehensive Plan and land use policies including Comprehensive Plan amendments now being considered by PTC and Council. SECTION VIII. COMPLIANCE WITH COMPREHENSIVE PLAN POLICIES AND PROGRAMS. PAMC 18,38.060(c) requires that the following findings must be made: "The use or uses permitted, and the site development regulations within the district shall be consistent with the Palo Alto Comprehensive Plan." The 2755 EI Camino Project powerfully exemplifies the goals of the 1998-2010 Comprehensive Plan and land use policies discussed below, including Comprehensive Plan amendments being considered by PTC and Council in 2009-2010 and 2011-2012. The 2755 El Camino Project addresses the following elements of The Comprehensive Plan. 1. LAND USE AND COMMUNITY DESIGN ELEMENT. Land Use and Community Design components of the Comprehensive Plan provide, Goals, Programs and Policies that deal primarily with physical and design characteristics such as: a) Establish links with the train station; b) Support pedestrian and bicycle use -a walkable community; c) Provide underground parking and parking located behind the building; d) Strengthen the identity of important community gateways; e) Enhance EI Camino; with a mix of commercial, civic and residential uses f) Promote high quality, creative design and site planning; g) With aesthetic design identify the building as a Gateway to the Stanford Research Park. The 2755 EI Camino Project advances and enhances each of the Comprehensive Plan goals set forth above and below and is consistent with creating the 2755 El Camino Project as an important gateway for the Stanford Research Park, with a shuttle link to CalTrain, with a pedestrian and bicycle tunnel under EI Camino mixed, financial services and office uses enhancing community character and reducing vehicular trips for tenants within the Stanford Research Park who seek financial service supports. The 2755 EI 28 I I I , I 1 '{ I t I I t I I I I Camino Project will create a landmark project at the gateway to the Stanford Research Park that rightfully represents the City of Palo Alto as the epicenter of technology, financial and investment analysis, retail services and culture for Silicon Valley. Policy L·42: Encourage Employment Districts to develop in a way that encourages transit, pedestrian and bicycle travel and reduces the number of auto trips for daily errands. Policy L· 75: Minimize the negative physical impacts of parking lots. Locate parking behind buildings or underground wherever possible. Policy L-71: Strengthen the identity of important community gateways. Policy L·9: Enhance desirable eharacteristics in mixed-use areas. Use the planning and zoning process to ereate opportunities for new mixed-use development. Goal L-9: Attractive, inviting public spaces and streets that enhance the image and character of the City. Program L-33: D Study ways to make South EI Camino Real more pedestrian-friendly, inviting streetscapes -including redesigning the street to provide wider sidewalks, safe pedestrian crossings at key intersections, street trees, and streetscape improvements. Policy L-36: 0 Allow a full range of office and retail uses on shallow parcels along South El Camino Real, subject to adequate buffering from adjacent residential uses. Policy L-35:D Establish the South El Camino Real area as a well-designed, compact, vital, Multi-neighborhood Center with diverse uses, a mix of one-, two and three-story buildings, and a network of pedestrian-oriented streets and ways, PolicyL-42: 0 Encourage Employment Districts to develop in a way that encourages transit, pedestrian and bicycle travel and reduces the number of auto rips for daily errands. Program L-43:0ModifY existing zoning regulations and create incentives for employers to pro-vide employee services in their existing buildings-for example, office support services, restaurants, convenience stores, public gathering places, and child care facilities-to reduce the need for employees to drive to these services. Policy L-43:DProvide sidewalks, pedestrian paths, and connections to the citywide bikeway system within Employment Districts. Pursue opportunities to build sidewalks and paths in renovation and expansion projects Program L-44: D Design the paths and sidewalks to be attractive and comfortable and consistent with the character of the area where they are located, 29 i I I I J : I I Policy L-44: 0 Develop the Stanford Research Park as a compact employment center served by a variety of transportation modes. Policy L-66: 0 Maintain an aesthetically pleasing street network that helps frame and define the community while meeting the needs of pedestrians, bicyclists, and motorists. Policy L-750: Minimize the negative physical impacts of parking lots. Locate parking behind buildings or underground wherever possible. 2. TRANSPORTATION ELEMENT. The Transportation elements of the Comprehensive Plan are enhanced by the 2755 EI Camino Project. The Transportation element discourages the use of single-occupant vehicles, and encourages pedestrian and bicycles uses along with public transportation. The 2755 EI Camino Project embraces Transportation Programs and Policies. The 2755 EI Camino Project honors the CalTrain station and its use with extensive public amenities and services that will also support use of jitneys and buses that operate from Cal Train station to Stanford and employment centers in Palo Alto and throughout Santa Clara and San Mateo counties. The 2755 EI Camino Project will develop and implement a Transportation Demand Management System. The 2755 EI Camino Project physically improves, widens, and enhances the sidewalks and pedestrian connections along Page Mill and EI Camion and under EI Camino by upgrading for ADA and seismic safety the abandoned tunnel nnder EI Camino that use to serve Hoover Elementary School where the Soccer Fields are now located. There will be secure bicycle parking for employees and the public. Parking does not intrude into neighborhoods. The 2755 EI Camino Project dedicates extensive land to the City along Page Mill Road to enable the City to create a dedicated right turn lane from Page Mill headed west onto EI Camino headed north and with possible other widening of Page Mill for other improved turn lanes and aligrnnent with Page Mill on the west side ofEI Camino! Only the 2755 EI Camino Project can provide these kinds of transportation opportunities for this most important and most severely impacted intersection under current traffic conditions. Goal T-1: Less Reliance on Single-Occupant Vehicles Policy T-1: Make land use decisions that encourage walking, bicycling, and public transit use. Transit stations and bus routes present opportunities for higher density development. Program T-3: Locate higher density development along transit corridors and near multimodal transit stations. Policy T -23: Encourage pedestrian-friendly design features such as sidewalks, street trees, on-street parking, public spaces, gardens, outdoor furniture, art, and interesting architectural details. 30 I 1 r 1 I t t I I I I J I J Program T ·32: Improve pedestrian crossings with bulb outs, small curb radii, street trees near comers, bollards, and landscaping to create protected areas. Policy T -37: Where sidewalks are directly adjacent to curbs and no planting strip exists, explore ways to add planting pockets with strect trces to increase shade and reduce the apparent width of wide streets. Policy T ·3: 0 Support the development and expansion of comprehensive, effective programs to reduce auto use at both local and regional levels. Policy T·14:D Improve pedestrian and bicycle access to and between local destinations, including public facilities, schools, parks, open space, employment districts, shopping centers, and multi-modal transit station Locations of Proposed Intersection Improvements Additional turning lanes and other related changes are proposed at the follawing major intersections in Palo Alto: * EI Camino RealI Page Mill Road Program T-I: DEncourage infill, redevelopment, and reuse of vacant or underutilized parcels employing minimum density requirements that are appropriate to support transit, bicycling, and walking. Policy T·28:D Make effective use of the traffic·carrying ability of Palo Alto's major street network without compromising the needs of pedestrians and bicyclists also using this network. ProgramT -23: 0 Develop public sidewalks and bicycle facilities in Stanford Research Park and other employment areas. 3. NATURAL ENVIRONMENT. The 2755 EI Camino Project fulfills nearly all relevant aspects of the Natural Environment element ofthe Comprehensive Plan. These aspects include: replacing and improving street tree planting and irrigation. Meeting a LEED Silver Standard, the 2755 EI Camino Project will provide leadership for: (a) water conservation both of landscaping and of interior plumbing, such as bathrooms, faucets kitchens and other devices; (b) state-of-the-art solid waste management by extensive use of purchasing and recycling practices; (c) appropriate and responsible renewable energy; (d) sophisticated controls of the use of electricity other than for lighting such as equipment, plug loads, timers, sensors, and equipment purchases (e) low voltage lighting with extensive use of motion sensors, time clocks and task lighting; (f) noise impacts reduction with prescribed purchases and practices; (g) permeability with paving landscaping and other surface 31 I 1 I I J I 1 ! I I features; (h) reduction of single use of automobiles through a TDM program, proximity to CalTrain, shared parking arrangements with parking at lower than maximum levels; (i) reduction of emissions with electric charging stations for automobiles for use by employees and the public; (j) reduction of emissions by providing great bicycle and pedestrian amenities. It is the goal of the 2755 El Camino Project to serve as a role model for TOD and LEED development projects throughout Northern California. Goal N·3: A thriving "Urban Forest" that provides ecological, economic, and aesthetic benefits for Palo Alto. Program N·l6: Continue to require replacement of trees, including street trees lost to new development, and establish a program to have replacement trees planted offsite when it is impractical to locate them onsite. Program N·40: Expand the use of alternative fuels for City vehicles and establish a program to encourage expanded use of such fuels in private vehicles. To support this program, encourage the development of alternative fuel infrastructure (for instance, electric plug-ins) in parking facilities and other key locations around the City. Policy N·28: Encourage developers of new projects in Palo Alto, including City projects, to provide improvements that reduce the necessity of driving alone. 4. BUSINESS AND ECONOMICS. The 2755 EI Camino Project enhances the Business and Economics element of the Comprehensive Plan. The primacy of this Stanford Research Park area as one of the world's most distinct technology, legal, financial and business centers is enhanced with our new iconic building. The 2755 EI Camino Project isolates the nearby residential community from impacts of business growth. Business diversity will be ensured with one or more new employer(s) occupying the office and financial service portions of the 2755 EI Camino Project -this will be the largest new office development in nearly ten years along central El Camino. The Gateway Design of the 2755 El Camino Project will further enhance the distinctive characteristics of central El Camino in Palo Alto that is one of the most successful suburban business districts in California. 2755 EI Camino Project is a spectacular and unique business and economic opportunity fur Palo Alto. Goal B-l: A thriving business environment that is compatible with Palo Alto's residential character and natural environment. Policy B-2: Support a strong interdependence between existing commercial centers and the surrounding neighborhoods as a way of encouraging economic vitality. Policy B·5: Maintain distinct business districts within Palo Alto as a means of retaining local services and diversifying the City's economic base. 32 Goal B-3: New businesses that provide needed local services and municipal revenues, contribute to economic vitality, and enhance the City's physical environment. SECTION IX. PROCESS AND PUBLIC OUTREACH. The Applicant has reached out to the immediate residential and commercial neighbors and has kept in regular contact with them .. We anticipate endorsements for neighboring property oWllers and operators In order to facilitate local community involvement beyond our immediate neighbors, regular mailings will be sent out, we will conduct study sessions with local residents and business owners, and we will have a website for the public and nearby residents to provide feedback and stay informed of the Project's progress. The Applicant looks forward to having the local community involved and engaged in the Public Hearing Process to help make the project a success for local residents, businesses, and the City. We anticipate participating in the following schedule of comprehensive public hearings for the PC Zone District project that will ensure a well-publicized project with great public input and commentary to ensure project success. a) City Council Study Session is to provide guidance with no motions for formal action. January 28 to Feb 11 b) Preliminary ARB Hearing also with no motions for approval. Purpose is to familiarize the ARB. Feb 7 to Feb 14 c) Formal Planning & Transportation Commission frrst hearing. This is a full CEQA analysis of the project and requires a formal set of studies and documents with published public notices for commentary. March 23 to Apri117. d) Formal ARB hearing with a motion to recommend City Council approval of the Project. April 25 to May 16. e) if (3) and (4) are strong, positive hearings we proceed to City Council June 3 to June 17. If we need one more meeting with Planning Commission we return to Planning Commission but with only minor changes to the submitted materials related to specific changes recommended by ARB or PTC f) City Council Second Hearing July 8 33 Attachment C Planned Community Prescreening 2755 El Camino Real 12PLN-00527 Applicable Comprehensive Plan Policies Land Use and Community Design Element Goal L-1: A well-designed, compact city, providing residents and visitors with attractive neighborhoods, work places, shopping district, public facilities and open spaces. Policy L-5: Maintain the scale and character of the City. Avoid land uses that are overwhelming and unacceptable due to their size and scale. Policy L-6: Where possible, avoid abrupt changes in scale and density between residential and non-residential areas and between residential areas of different densities. Policy L-7: Evaluate changes in land use in the context of regional needs, overall City welfare and objectives, as well as the desires of surrounding neighborhoods. Goal L-5: High quality employment districts, each with their own distinctive character and each contributing to the character of the City as a whole . POLICY L-42: Encourage Employment Districts to develop in a way that encourages transit, pedestrian and bicycle travel and reduces the number of auto trips for daily errands. POLICY L-43: Provide sidewalks, pedestrian paths, and connections to the citywide bikeway system within Employment Districts. Pursue opportunities to build sidewalks and paths in renovation and expansion projects. Goal L-6: Well-designed buildings that create coherent development patterns and enhance city streets and public spaces. Policy L-48: Promote high quality, creative design and site planning that is compatible with surrounding development and public spaces. Program L-48: Use the Zoning Ordinance, design review process, design guidelines and Coordinated Area Plans to ensure high quality residential and commercial design. POLICY L-75: Minimize the negative physical impacts of parking lots. Locate parking behind buildings or underground wherever possible Transportation Element POLICY T-1: Make land use decisions that encourage walking, bicycling, and public transit use. PROGRAM T-1: Encourage infill, redevelopment, and reuse of vacant or underutilized parcels employing minimum density requirements that are appropriate to support transit, bicycling, and walking. POLICY T-22: Improve amenities such as seating, lighting, bicycle parking, street trees, and interpretive stations along bicycle and pedestrian paths and in City parks to encourage walking and cycling and enhance the feeling of safety. POLICY T-23: Encourage pedestrian-friendly design features such as sidewalks, street trees, on-street parking, public spaces, gardens, outdoor furniture, art, and interesting architectural details. GOAL T-8: Attractive, Convenient Public and Private Parking Facilities ATTACHMENT D ZONING COMPARISON TABLE 2755 El Camino Real 12PLN-00527 Table 1: COMPARISON WITH CHAPTER 18.28 (PF DISTRICT) Regulation Proposed Existing PF (Public Facilities) Minimum Site Area 19,563 sq ft 19,563 sq ft None Min. Front Setback (El Camino Real) 10 ft NA Equal to the setback of the most restrictive abutting district Rear Yard Setback 10 ft min. NA 20 ft, same if abutting or opposite residential zone Side Yard Setback (Page Mill Road and Interior) 10 ft / 4 ft NA 20 ft, same if abutting or opposite residential zone Max. Total Floor Area 33,500 1:7 NA 1:1 Max. Site Coverage 100% 100% 30% Max. Building Height 58 ft (with additional 8ft for mechanical) NA 50 ft, 35 ft within 150 ft of residential district Daylight Plane 45 degrees @ project rear property line, 10 ft @ mechanical equipment NA 1:2 with initial height of 10 ft when abutting residential zone Table 1: CONFORMANCE WITH CHAPTER 18.52 (Off-Street Parking and Loading) Use Required Proposed Conformance Admin Offices, 1 per 250 sf of gross floor area (134 spaces)* 121spaces Non-conforming – 13 spaces deficient Financial Services 1 per 180 sf with 7500 sf floor area or less (5,275 sf proposed of financial services/28,225 sf office) 29 spaces/113 spaces 142 total 121 spaces Nonconforming- 21 * 20% reduction is given for TDM Table 2: COMPARISON WITH CHAPTER 18.20 (ROLM DISTRICT) FOR 3045 PARK BLVD SITE Regulation Proposed Existing GM (AD) General Manufacturing (Automobile Dealership) Minimum Site Area 1.41 acres 1.41 acres none Min. Front Setback 20 ft 30 ft 10 ft if abutting or opposite residential zone Rear Yard Setback 10 ft 50 ft none Interior Yard Setback 10 ft 30 ft min. none Max. Total Floor Area Ratio 0.71:1 (44,420 sf public safety bldg) 0.29:1 (17,957 sf) 0.5:1 Max. Site Coverage 82% (50,228 sf) 29% (17,957 sf) none Max. Building Height 60.5 ft Approx. 25 ft 35 ft, 25 ft within 40 ft of residential zone Table 2: CONFORMANCE WITH CHAPTER 18.52 (Off-Street Parking and Loading) Use Required Proposed Conformance Admin Offices 1 per 300 sf of gross floor area (149 spaces)* 732 spaces (191 spaces dedicated for public safety) Conforming – 191 spaces dedicated to Public Safety Bldg., 541 spaces available for off-site parking * In accordance with the Public Safety Building (PSB) Program, prepared for the City by RossDrulisCusenbery, Architecture Inc. in 2007, the PSB requires 191 parking spaces. February 4,2013 Via Email and Fed Ex Ms. Margaret Netto City of Palo Alto 285 Hamilton A venue Palo Alto, CA 94301 MORRIS PAGE MILL, LLC 2500 Sand Hill Road, Suite 240 Menlo Park, CA 94025 (650) 854-1040 Re: Planned Community Development Application for redevelopment of Real Property located at 2755 EI Camino Real-APN 132-36-084 ("VTA Parcel"); Obiections to Proposed Development by Adjacent Landowner Dear Margaret: As a property owner and developer in Palo Alto, I am writing this letter as a follow up of our discussion today concerning the pending application by Pollock Realty Corporation. Please include this letter in your packet to the members of the City Council and the City Attorney for the February 11,2013 Study Session. It is my understanding that Pollock Realty Corporation is the recent purchaser of the VT A Parcel and is seeking to obtain development approvals for development of a four-story commercial building of approximately 33,500 square feet and 1.71: I FAR (the "Pending Project"). As you know, Morris Page Mill, LLC ("MPM") is the owner of the adjacent parcel at 2701 EI Camino Real (the "Sunrise Parcel"), the site of the existing Sunrise Assisted Living Facility (the "Sunrise Facility"), the owners of which ("Sunrise") entered into a long term ground lease with MPM and developed the Sunrise Facility in 2004/2005. On behalf ofMPM I am writing to express MPM's strong objections to the Pending Project and to inform the City that both MPM and Sunrise oppose the Pending Project. The Pending Project is Incompatible with Existing Area Development. Based on the information you have provided to me concerning the Pending Project, MPM asserts that the use, size and scope of the commercial office building proposed as the Pending Project is incompatible with uses in the immediate vicinity. Sunrise is also concerned about how the views of the residents will be negatively impacted by the construction of a four-story office building on the property. The Pending Project is Incompatible with Nearby "CN" Zone Uses and Compatibility Standards: Nearby commercial parcels fronting the Northeast side of EI Camino Real are zoned "CN" (Neighborhood Commercial) to the Northwest of the VT A and Sunrise Parcels. All areas to the Northeast of these parcels are within various high-density residential zones. Uses contemplated by the CN Zone are intended to consist primarily of retail uses serving nearby neighborhoods, with all uses having "maximum compatibility with surrounding residential areas" (Palo Alto Zoning Ordinance §18.16.1 Ora)~. Furthermore, any office uses within the CN Zone shall be "moderately sized" and although we await more details on the exact design of the Pending Project it appears that it would exceed the FAR and other site restrictions that would otherwise apply in the CN Zone. The Pending Project is Incompatible with Nearby "CS" Zone Uses and Compatibility Standards: I developed the property at 2825 EI Camino Real and was limited to 40% coverage for office space. If the same limitation for office space were applied to the Pending Project the allowable square footage for office use would be 7,836 square feet. This would be a decrease of 25,164 square feet from what is being requested. Another way to look at the request is that the CS zoning standard for office space would pennit construction of office space equal to only 23.75% of the request being made for the Pending Project. The density of the Pending Project is too great for the area. The Pending Project is Incompatible with Standards for Planned Community Developments: The Pending Project does not meet the requirements of a Planned Community Development under the Palo Alto Zoning Code (Palo Alto Zoning Ordinance §18.38.010 et.seq.). Specifically, existing nearby districts such as high-density residential or CN uses within the limits of the CN Zone already provide sufficient flexibility to allow development of the VT A Parcel in a manner compatible with the adjacent properties (See Palo Alto Zoning Ordinance §18.38.060(a)}. In addition, based on the information provided thus far it appears the Pending Project would violate other requirements for a Planned Community Development, such as height restrictions, minimum yard requirements, etc. (See Palo Alto Zoning Ordinance §18.38.150). A large, commercial office-only project like the Pending Project would not meet the compatibility standards under the Palo Alto Zoning Ordinance, and would overburden the residential and CN uses in the immediate vicinity of the VT A Parcel. Approval of the Pending Project as part of a planned development would therefore circumvent the various requirements for "CN" use, which is more appropriate for this location. The Pending Project Would Unreasonably Burden Adjacent Landowners and Users. Traffic Impact: The Pending Project will increase traffic congestion in an already-congested area by substantially increasing the number of automobiles and daily traffic in and out of the VT A Parcel. Currently the VT A Parcel is limited to approximately 35 existing surface parking spaces and is typically used by drivers who leave their vehicle in place all day. The Pending Project with a three-level underground parking garage would more significantly increase the number of parking spaces and would result in constant auto entry and exit throughout the day. The increased traffic will not be offset by the new right tum lane off Oregon Expressly proposed as part of the Pending Project. Density Impact/View Corridor: The MPM Parcel and the residents of the Sunrise Facility currently enjoy a density level in the immediate vicinity that is reasonably compatible with the residential uses immediately Northeast of the Sunrise and VT A Parcels and the CN parcels fronting EI Camino Real to the Northwest. A large office building on the VT A Parcel will impede natural light into the Sunrise Facility, substantially diminish the view corridor from the MPM Parcel, and the added density and auto/foot traffic reSUlting from the Pending Project will impose an unreasonable burden on the residents of the Sunrise Facility. Approval of the Pending Project would be Ineguitable. Previous Office Projects Disapproved: MPM originally applied for approval of an office project on the Sunrise Parcel and was denied. The City's reasoning at the time was that the immediate area is for high-density residential use and for "CN" uses to serve the neighborhood. As the principal of MPM, with James E. Baer as a consultant, we were both told in 2004 that the City would never pennit any additional office uses in this area, as it is incompatible with existing uses and the immediate vicinity. Accordingly, MPM was forced to abandon efforts to construct an office building and found a user, Sunrise, whose use is compatible with the neighborhood. Sunrise Objections: Sunrise and its residents understand there has always been a possibility that the VT A parcel would be redeveloped, but they have nevertheless become accustomed to the VT A Parcel's current use. Regardless, Sunrise and its residents have a reasonable expectation that any redevelopment of the VT A Parcel will be compatible with the neighborhood, and like MPM they have strong objections to an oversized commercial office project that is wholly incompatible and imposes substantial burdens on their use and occupancy. The City can expect to receive separate communications from Sunrise and its counsel expressing opposition to the Pending Project. MPM, Sunrise and their respective counsel will await submission of more detailed plans for the Pending Project, and I expect we will update our fonnal objections as more details of the Pending Project are publicly disclosed. Regardless, however, MPM would like to make a record of its objections to the Pending Project prior to the initial application now that we know some of the basic infonnation, and we are in hopes that Pollock Realty Corporation will revise its plans and apply for a compatible development on this site. JAM:aes cc: Palo Alto City Council members Office of the City Attorney, Palo Alto Very Truly Yours,