HomeMy WebLinkAbout2000-07-31 City Council (12)TO:
FROM:
DATE:
HONORABLE CITY COUNCIL
PLANNING AND TRANSPORTATION COMMISSION
City of Palo Alto
Manager’s Repor
CITY MANAGER DEPARTMENT: PLANNING AND
COMMUNITY ENVIRONMENT
JULY 31, 2000 CMR:352:00
SUBJECT:REVISED FINAL STAFF COMMENTS ON DRAFT
ENVIRONMENTAL IMPACT REPORT (EIR) FOR THE STANFORD
COMMUNITY PLAN AND GENERAL USE PERMIT (GUP)
RECOMMENDATION
Staff recommends that the comments regarding the EIR for the Stanford University
Community Plan and GUP, listed below, and included in memorandums from the Public
Works Department and Transportation Division regarding circulation, parking, and storm
water run-off/flooding, be forwarded to the Santa Clara County Planning Office. The public
review period for the Draft EIR closes on Monday, August 7, 2000; and the County must
receive all comments by this date in order for the comments to be responded to in the Final
EIR.
PROJECT DESCRIPTION
The project is the Draft Environmental Impact Report (EIR) for the Stanford University
Community Plan and General Use Permit (GUP). Together, the PIan/GUP regulate land use
and development for Stanford-owned property in the unincorPorated area of Santa Clara
County; this accounts for 4,017 acres, approximately half of Stanford’s total land ownership.
Stanford-owned land within Santa Clara County consists primarily of the academic campus
and the largely undeveloped foothill property southwest of Junipero Serra Boulevard. The
University also owns land in the Cities of Palo Alto (e.g., Stanford Research Park, Stanford
Shopping Center, Medical Center), Woodside, Menlo Park, the Town of Portola Valley, and
unincorporated portions of San Mateo County. Once approved by the County, the GUP
operates as a broad-based land use entitlement that allows a specified amount and type of
development to occur. Stanford and the County have utilized the GUP as a land use and
development tool since 1962. Presently, development on Stanford lands occurs under the
GUP approved in 1989. The 1989 GUP allowed 2.1 million square feet of b~r[[dirrgarea
CMR:352:00 Page 1 of 11
(including residential construction) to be developed; approximately 140,000 Square feet of
this entitlement remains, leading to Stanford’s request for the approval of a new GUP. As
with the 1989 GUP, the current GUP is anticipated to accommodate development at Stanford
for approximately 10 years. The proposed GUP requests the approval of 2,035,000 square
feet of academic buildings and related facilities and up to 3,018 dwelling units. Assuming
all of the proposed dwelling units are constructed, residential development would likely add
an additional 2 to 3 million square of building area.
Unlike the GUP, the Community Plan is not an entitlement mechanism, but is instead a long-
range policy document that, if adopted, will amend the County general plan concerning
Stanford’s unincorporated Santa Clara County lands. Stanford has not prepared a plan of this
type before. Once in place, the goals, policies, and land use designations contained in the
Community Plan will be effective indefinitely,, until superseded.
DISCUSSION
Planning staff’s comments, which reflect public testimony provided at the July 19, 2000
public hearing and in other written and oral input are included below:
Open Space Preservation
o The EIR and Community Plan/GUP need to analyze mechanisms that will provide
permanent, or long-term (25 years or more) dedication of open space for the foothill
lands southwest ofJunipero Serra Boulevard. The EIR acknowledges that the project
will result in the loss of recognized open space in this area; however, the EIR does not
discuss the inevitable growth that will occur in the foothills as the core campus
approaches build-out. Absolute assurance of conservation of the foothill open space
areas must be linked to the substantial amount of development being proposed.
The proposed land use designation of "Open Space and Academic Reserve" for the
majority of the foothill property is further indication that this area is ultimately
"reserved" for development, though not necessarily within the timeframe of the
proposed GUP. The EIR should identify land to be maintained (as opposed to being
held in reserve) as open space and this land should be designated, accordingly, as "Open
Space" by the Community Plan.
The EIR should be revised to include a discussion of the existing or proposed access to
all open space or conservation areas.
It is not clear from Figure 2-4, "Existing and Proposed Land Use Designations," of the
EIR if the Dish is included within the "Special Conservation" area. The location of the
Dish should be shown on this map to clarify its location either within or outside of the
area designated for "Special Conservation." Additionally, the City strongly believes that
the Dish area should be protected and maintained for open space purposes.
CMR:352:00 Page 2 of 11
While much of Stanford’s land may not be alienable, mechanisms such as open space
easements have been used before by Stanford as a means to achieve long-term open
space protection. Accordingly, the EIR should analyze the use of easements as a means
to protect existing open space on a long-term basis. Further, the EIR should describe
existing open space protection measures used by Santa Clara County for land within its
jurisdiction and by Stanford for other lands under its ownership, such as Jasper Ridge
in San Mateo County.
Project Alternatives
The EIR should analyze an alternative that would avoid impacts to the Stanford Golf
Course, particularly the loss of Hole # 1. This alternative would entail modifying the
Academic Growth Boundary shown in Figure 7-1 so that the area referred to as the
"stable site" would be placed immediately outside of the Academic Growth Boundary.
The City believes that this alternative should not eliminate housing proposed in this
area, but rather, should look at creatively integrating the proposed dwelling units into
or around the existing golf course.
The proposed and altemative Academic Growth Boundaries shown in Figure 7-1 of the
EIR extend to the City of Menlo Park (San Francisquito Creek) to the north, but do not
illustrate where this boundary extends to the south, within the Coyote Hill area in the
City of Palo Alto. Palo Alto’s existing urban growth boundary (i.e., urban service area)
should be included on Figure 7-1 for the purposes of clarification.
The EIR states that the Reduced Project Alternative does not avoid the significant
impacts of the project, so it is, therefore, not an environmentally superior alternative.
The EIR makes this finding even though the Reduced Project Alternative calls for only
50 percent of the total development of the project. This approach treats environmental
impacts like an on/off switch--some impact or no impact at allNand ignores differences
in degree. Moreover, it seems likely that a 50 percent reduction in development would
be environmentally superior given the scale of the project.
Land Use and Development
Table 3-3 of the EIR concludes that the Community Plan/GUP are consistent with all
City of Palo Alto Comprehensive Plan policies. However, Comprehensive Plan Policy
L-l, which is noted in Table 3-3, states, "Continue current City policy limiting future
urban development to currently developed lands within the urban service area. Retain
undeveloped land [south]west of Foothill Expressway [Junipero Serra Boulevard] as
open space, with allowances made for very low-intensity development consistent with
the open space character of the area." Given that the EIR and Community Plan/GUP
identify up to 20,000 square feet of development outside the City’s urban service area,
CMR:352:00 Page 3 of 11
i.e., on the Lathrop property, the conclusion of consistency with the City’s
Comprehensive Plan is not supported.
By continuing to prepare separate environmental documents for on-going development
projects, whose processing overlaps with the Community PlardGUP EIR and approval
process, the County makes it difficult for the public to understand the impacts of all
proposed development for Stanford’s lands. The existing setting has become a "moving
target" that makes it difficult to fully understand the increment of environmental impact
that will result solely from the implementation of the Community Plan/GUP. During
the remaining approval process for the Community Plan/GUP, Stanford should cease
pursuing separate project approvals.
Related to the preceding point, the Carnegie Foundation proposal, for which a separate
draft environmental impact report was recently circulated, should be included as part of
the Comrriunity Plan/GUP proposal. It is recognized that the subject EIR includes the
Carnegie proposal within its cumulative analysis. However, confusion persists that the
20,000 square feet of development proposed in the Community Plan/GUP for the Lathrop
area, southwest of Junipero Serra Boulevard, is describing the Carnegie project, which
is nearly identical in area and is proposed for development on the same parcel. By
including Carnegie in the Community Plan/GUP, this confusion would be avoided.
The Development districts identified in the EIR (Figure 2-6, Tables 2-1 and 2-2) give
the impression that proposed development described in the GUP is not only anticipated
to occur in these districts, but would be specifically limited to these areas. Language in
the Plan/GUP itself indicates otherwise. This inconsistency should be clarified.
Housing and Community Facilities
o The City supports Stanford’s intention to add over 3,000 housing units to the campus
through the GUP, but disagrees with the conclusion reached in the EIR, that the project
will not have a significant impact on existing residential neighborhoods in the City of
Palo Alto. The subject EIR is a program-level document and does not contain a factual
basis for reaching this conclusion. Moreover, should future prqiect-specific
environmental documents find that significant impacts to existing Palo Alto
neighborhoods will occur, a supplemental EIR would need to be prepared providing a
revised analysis.
The EIR should be revised to provide an estimate of the building square footage that will
result from the construction of the proposed dwelling units to indicate the overall scale
of the proposed project.
Given the shortage of housing and the acute shortage of affordable housing identified in
the EIR, it is likely that the project will result in a significantly increased need for
CMR:352:00 Page 4 of 11
additional affordable housing in the vicinity of the project. Also, the EIR estimates that
development under the proposed GUP would generate approximately 1,000 new jobs,
and possibly as many as 1,500 to 2,000, if the standard multiplier is applied. The City
believes the EIR should identify additional housing sites on and off campus in order to
meet regional housing needs or identify other means to address this issue, including
payment of fees to adjacent jurisdictions that may be impacted by Stanford’s proposed
development.
The EIR should include information regarding the existing shortage of on-campus
housing, so that it is clear how the proposed housing will accommodate Stanford’s total
housing need, not just the need that would be created through the build-out of the
proposed GUP.
The EIR does not discuss the extent to which Stanford residents, faculty and students use
community facilities, such as libraries and parks, located in neighboring cities. The City
of Palo Alto conservatively estimates that Stanford residents account for approximately
5 percent of the total usage of City facilities. Given the age of the City’s infrastructure,
the increased usage described in the Community Plan/GUP EIR means an accelerated
deterioration of their physical condition, which is not discussed in the EIR. Moreover,
should the revised EIR find a significant unmitigated impact to Palo Alto community
facilities, a Statement of Overriding Considerations should be adopted by the County
Board of Supervisors. The City of Palo Alto expects that the County of Santa Clara shall
require Stanford to pay City impact fees toward these facilities.
Schools
o The EIR proposes mitigation measures (i.e., payment of impact fees) for school impacts
that appear to be in accordance with pertinent statutory and case law. However, the City
wants to emphasize that these measures will not address the actual impacts to schools
within the Palo Alto Unified School District (PAUSD). Since the actual impacts to
schools wouM remain significant after the payment of fees (i. e., mitigation), the EIR
should note that these impacts would be significant and, therefore, require the adoption
of a Statement of Overriding Considerations by the County Board of Supervisors.
Potential additional options are outlined on pages 4.10-8 and 4.10-9 of the EIR and
include the possibilities of cbnstructing a third middle school on Stanford land, re-
opening closed schools, or modifying existing schools. The City of Palo Alto strongly
believes Stanford needs to be actively involved in the discussion and eventual
implementation of additional options for addressing school impacts.
The EIR should provide a more viable alternative school site than the one shown in
Figure 7-6. Alternate school sites should be more proximately located to the population
they are to serve and should be within the Palo Alto urban service area.
CMR:352:00 Page 5 of 11
Circulation and Parking
, The EIR identifies various transportation measures to mitigate traffic impacts. These
measures need to be placed into a more comprehensive context. Therefore, Stanford
should prepare an integrated transportation plan (see Attachment E for more detail) with
both long- and short-term elements. Long-term elements should include a variety of
solutions to mitigate vehicular congestion and parking demand. The plan should contain
sub-area analyses for the core campus, the Medical Center, the Research Park, and the
Shopping Center; and should be developed in conjunction with Santa Clara County, Santa
Clara County VTA, Palo Alto, Menlo Park, and East Palo Alto. The plan should
emphasize transit, transportation demand management (TDM), bicycling, walking, and
traffic-calming to create a safer environment for alternative modes of use.
The EIR should provide an analysis of the potential traffic impacts to existing Palo Alto
neighborhoods. For instance, the EIR identifies over 1,000 new dwelling units proposed
adjacent to the College Terrace neighborhood, just south of Stanford Avenue. Additional
vehicle trips along these residential streets would be in conflict with the City’s
Comprehensive Plan goal of reducing through-traffic impacts on residential areas.
The EIR list of traffic mitigation measures includes evaluation of several intersection
widenings. While intersection capacity increases may mitigate for peak-hour vehicle
trips in the short-term, they also have the result of inducing greater numbers of vehicle
trips in the future. Evaluation of each proposed intersection widening improvement
should take into account these secondary effects.
With respect to pedestrian travel, all intersection widenings, including those discussed
in the EIR, lengthen pedestrian crossing distance and time. This effect should be
analyzed for each proposed intersection project as well as measures to enhance pedestrian
safety such as median refuges.
Intersection widenings have three potential impacts on bicyclists: 1) Increased complexity
for cyclists navigating intersections; 2) Loss of bike lane space to create turning lanes;
and 3) Lengthening the exposure time of cyclists traveling across the widened
intersection. These effects should be analyzed for each proposed intersection project, as
well as measures to enhance cycling safety.
Roundabouts have had an impressive safety record worldwide. As traffic-calming
measures, roundabouts can help slow vehicle speeds and create safer travel conditions for
pedestrians and bicyclists. Roundabouts should, therefore, be considered in the EIR as
an alternative to such conventional intersection treatments as signalization, new signal
phases and intersection widening.
CMR:352:00 Page 6 of 11
Stanford should consider market-based measures to manage parking demand, such as
implementation of parking prices that reflect the costs of both parking capacity and traffic
congestion.
Trip generation rates are a critical element of the EIR transportation analysis. A
discussion should be provided in the EIR of how the composite trip generation count is
disaggregated to the various categories of trip makers. The EIR should also clearly state
that the trip generation rates used for the project include the present level of
transportation demand management (TDM). Additionally, the trip generation of visitors
and contractors should be included in the analysis. Finally, the off-campus housing units
that will be vacated when the graduate students living off-campus are relocated onto the
campus will be occupied by new residents, resulting in continued trip generation from
these off-campus units, but with a new trip distribution. These backfill trips should be
included in the EIR traffic analysis.
City staff strongly supports the "no net new commute trips" mitigation strategy instead
of the Tier 2 intersection improvements described in the EIR. Many of these
improvements are only minimally feasible from a physical or political perspective and/or
have other negative impacts. For all Tier 2 projects, conceptual-level cost estimates
should be provided, as well as Stanford’s fair share contribution.
As described in the EIR, a coordinated trip reduction effort for the Stanford Research
Park was not used as a credit toward "no net new commute trips" because most of the
Park lies south of Page Mill Road. The boundary of the cooperative trip reduction area
should be extended south to include all or most of the Research Park.
City staff supports traffic-calming mitigation measures. However, the EIR should be
more specific regarding Stanford’s responsibility to determine the amount of cut-through
traffic generated. Specifically, Stanford should be responsible to pay for and conduct a
license plate and/or origin-destination survey to determine which vehicles are travelling
to/from Stanford lands.
CMR:352:00 Page 7 of 11
Storm Water Run-OfffFlooding
o The EIR analyzes run-off impacts based upon a 100-year, 24-hour storm event instead
of the typically used 10-year, 6-hour event. The EIR should be revised to include an
analysis of the 10-year, 6ohour standard, since mitigation measures designed for the 100-
year event d0not necessarily mean that increased run-off will not occur during smaller
storm events.
The EIR cites the use of detention basins as the sole mitigation measure for anticipated
increases in run-off resulting from new development on the campus. While detention
basins are an acceptable means of controlling peak run-off, they should not be used to
the exclusion of alternative features. Therefore, the EIR should be revised to include an
analysis of more innovative measures (e.g., vegetative swales, use of ~
pervious pavement, reduced building footprints)
Biological Resources
Option 2 regarding the California Tiger Salamander should be incorporated into the
project sinceit is superior from an environmental standpoint in that it avoids a significant
impact to the species and its habitat.
The EIR should provide an analysis of the habitat value of the Stanford Golf Course.
Among other things, this analysis should examine impacts to the Western Bluebird and
other species should the golf course, or portions thereof, be lost to development.
Implementation and l;~4,I~lam.em¢ Monitoring
The EIR includes information on the phasing of development (i.e., proportion of
residential development that needs to occur in relation to academic development.), but
is silent on how monitoring of development will occur and by whom it will be done.
The EIR identifies construction noise impacts as significant and not able to be mitigated
to a less than significant level, even though construction would be done in accordance
with Santa Clara County noise regulations. The EIR should analyze construction
standards that take into account the nature of adjacent development or habitat that is more
sensitive to construction noise. The standards would provide greater protection for
sensitive receptors, such as existing residential areas. For instance, the EIR indicates that
construction could occur from 7:00 am to 7:00 pm, Monday through Saturday. Reduction
in construction hours and elimination of Saturday construction may eliminate or lessen
significant construction noise impacts on adjacent residential areas.
PLANNING COMMISSION RE VIE W AND RECOMMENDATIONS
The Planning Commission reviewed and commented on the EIR on July 26, 2000.
comments and recommendations to Council are described, by topic, below.
CMR:352:00 Page 8 of 11
The Commission concurred with staff’s principal conclusion that the EIR does not provide
adequate, long-term protection for recognized open space areas. The Commission
emphasized that the EIR needs to include more discussion regarding publie access to, and
potential intensification of uses in open space areas. The Commission also recommended
that the EIR include a discussion of public access that had historically been allowed on
Stanford lands (e.g., Searsville Lake area) that is no longer permitted. Finally, the
Commission recommended that the EIR examine a means (e.g., conservation easemenO by
which the entire Stanford Golf.Course eouM be permanently protected as recreational open
space and/or habitat area.
Project A ltern atives
The Commission strongly emphasized that the EIR and project shouM examine a
development alternative that intensifies development on under-utilized sites (e.g., surface-
level parking lots, single-story buildings, Arboretum area) in the core campus area,
especially those sites in close proximity to major transportation routes, such as El Camino
Real The Commission recommended that the EIR include a "reduced scale" alternative that
would reduce only the level of proposed academic development, not the number of housing
units," the alternative in the EIR reduces all proposed development, including housing, by 50
percent. The Commission also recommended that the EIR should include a discussion on
how the existing (or under construction) Stanford West housing could be used as a mitigation
measure for the proposedpopulation growth of the University.
Land Use and Development
The Commission recommended that the EIR &elude a discussion and analysis of Stanford
as a single entity, regardless of governmental jurisdiction. The Commission believed that
the EIR should provide clear information describing Stanford’s existing level of development
and foreseeable growth, including the Research Park, Medical Center, and other Stanford-
owned properties outside the GUP boundaries. The Commission noted the confusion
associated with monitoring Stanford development due to the different jurisdictions and
different development entitlement mechanisms involved While not necessarily an
environmental issue, the Commission discussed the concept of creating an inter-
jurisdictional authority that wouM oversee and monitor development on all Stanford lands.
The Commission additionally recommended that the EIR provide clearer definitions of
proposed land use designations described in the Community Plan, and emphasized that the
EIR should specifically define what the proposed Academic Growth Boundary means and by
what process it could be altered in the future.
Housing and Community Facilities
The Commission emphasized that the EIR should discuss Stanford’s existing housing
shortage, not just the antieipated population growth in relation to housing proposed by the
GUP. The Commission also recommended that the EIR provide an explanation of the
CMR:352:00 Page 9 of 11
"standard employment multiplier" regarding the population and job growth that may result
in adjacent communities, such as Palo Alto, due to on-campus growth. Overall, the
Commission recommended that the EIR propose, and that Stanford pursue, creative solutions
(e.g., off-campus housing) to the housing shortage.
Schools
The Commission recommended that the EIR identify a middle school site on Stanford land
that wouM be nearer existing Palo Alto neighborhoods than the site shown in the EIR. The
Commission specifically identified the area along El Camino Real, between Embarcadero
Road and Serra Street, as a viable site. Alternatively, the Commission believed that if this
area along El Camino were deemed too small to accommodate a middle school that an
elementary school should be considered for the location.
Circulation and Parking
The Commission emphasized that the "no net new commute trips" mitigation strategy,
included in the 1989 GUP, shouM be maintained and included in the EIR for the proposed
Community Plan/GUP. Related to its comments on "Project Alternatives," the Commission
recommended that the EIR provide an analysis of proposed land use and development
patterns, and the effect on transportation, including examining the increased use of parking
structures in lieu of surface-level parking lots. The Commission also discussed several other
issues, such as the use of satellite parking facilities and having Stanford contribute to the
funding of the Inter-Modal Transportation Center.
Storm Water Run-Off/Flooding
The Commission recommended that the EIR further discuss potential impacts to water
quality, particularly those brought about by increasing amounts of copper (e.g., copper used
in brake pads which infiltrates run-off, copper used in new buildings, particularly in roofing
material) that could result from the project. The Commission also requested clarification
of the Arboretum’s function as a storm water detention area.
Biological Resources
The Commission recommended that the EIR examine the golf course’s habitat value to all
animal and plant species. The Commission recommended that the EIR analyze an alternative
that wouM provide greater protection for the California Tiger Salamander than "Option 2, "
described in the EIR. This more protective alternative would include a "no building"
limitation on the Lathrop property.
Implementation and Monitoring
The Commission recommended that the EIR discuss the resources (e.g., staffing) that Santa
Clara County has to monitor and enforce the development and phasing of the proposed
GUP.
CMR:352:00 Page 10 of 11
Planning Commission Summary Comments on EIR
The Commission reiterated that Stanford should be looked at as one large landowner with
property in multiple jurisdictions, and that the proposed GUP is the most extensive project
in the north County region within the foreseeable future. The Commission believes it is vital
that the County Board of Supervisors understands the scale of this project and its impact on
the region through the project description in the EIR. The Commission also reiterated that
the proposed development must be off-set by permanent open space protection, where public
access is clearly articulated, and that Palo Alto’s urban service area should not be
expanded. Overall, the Commission believed the Draft EIR was clear but that the Final EIR
could provide more information about future development beyond the timeframe of the
proposed GUP.
ATTACHMENTS
Attachment A: Stanford University Lands (Palo Alto Comprehensive Plan Map L-3)
Attachment B: Academic Growth Boundary Alternatives Map (Figure 7-1 of DEIR)
Attachment C: October 28, 1999 letter from Gary Fazzino, Mayor, City of Palo to Anne
Draper, Santa Clara County Planning Director
Attachment D: Table "S- 1," Impact and Mitigation Summary
Attachment E: Memorandum from Transportation Division, dated July 24, 2000
Attachment F: Memorandum from Public Works Department, dated July 24, 2000
PREPARED BY:Luke Connolly, Senior Planner
DEPARTMENT HEAD REVIEW:
G. EDWARD GAWF
Director of Planning and Community Environment
CITY MANAGER APPROVAL:
Emilv~~ison
Assistant City Manager
Santa Clara County Planning Office
Stanford University Planning Department
CMR:352:00 Page 11 of 11
Attachment A
I
PROPOSED LAND USE DESIGNATIONS
~Open Space and~,cademic Reserve (E-SA) ¯
~SpecialConservati0n (E-SA-SC)
~Academic Campus ~E-SC)
~ Campus Open Space (E-SCO)
~ public School (E-SPS)
, Campus Residential - Low Density (E-SR) ,
~ Campus Residential- Moderate Density (E-SR-~),~i
Alternativb
Academic Growth
Boundary AGB-B
! ~ ~ Alternative
Acad~m_ic Growth
Boundary AGB-A
Community
Sources: Stanford University Draft’Community Plan, 11/15/99, as amende~J 4/1~9/00
Stanford University
CP/GUP Project EIR
ACADEMIC GROWTH
BOUNDARY ALTERNATIVES
Parsons
Harland Bar!~holomew
& Associatesw inc
Figure 7-1
I
Oetober 28, 1999
City Palo Alto
Of$ce of tlm Mcajor ard Ci~j Council
Attachment C
Ms. Anne Draper, Planning Director
Planning Office
County of Santa Clara
?0 W. Hedding Street
San Jose, CA 95110
Subject: Draft Stanford University Community Plan and General Use ]Permit
Dear ~s: Draper:
Thank you for the opportunity to review and comment .on the draft stanford Community
Plan and General Use Permit (GUP). The City of Palo Alto has held three public
meetings this month regarding the Community Plan and GUP, resulting in the City
Council recommendations, des.d..ribed below. As indicated, the City has two overall
recommendations that are, general in nature as well as more focused recommendations
categorized under specific, headings. A major priority of the City is the preservation of
open space areas west ofJunipero Serra Boulevard for a period of 25 years or more. In
addition to rezoning these areas to an "Open Space" land use designation, establishing a
25-year, no-build commitment, long-term open space preservation, should also
incorporate the most protective measures available, such as conservation easements. The
City anticipates making further comments on the Community Plan and GUP as
subsequent drafts of the documents become available. The term "Pian," below, unless
other,vise indicated, refers to both the Community Plan and GUP.
Overall Staff Recommendations
¯ The City of Palo Alto supports Stanford’s efforts to create additional on-campus
housing, and the concept to add new development on lands currently developed or
designated for developrrient within the core campus. However, Palo Alto strongly
shares the County’s concern over the lack of specificity in the Plan regarding land use
and assurances for preservation, especially for open space uses.
The Plan should incorpora{d the generai recommendations of the Santa Clara County
staff report entitled, Stanford University Community Plan and General Use Permit,
P.O. Box 10250
Palo Alto, CA 94303
415.329.2’477
415.328.3631 Fax
Ms. Anne Draper, Plarming Director
October 28, I999
Page 2
dated October 7, 1999, and the direction given to Stanford by the Santa Clara County
Planning Commission on September 2, 1999.
The City supports the Plan’s stipulated gdal of maintaining the existing amount of
open space, but recommend.s that a distinct open space land uge designation be
created. .-...
The Plan is proposed for a period of 10 years, but development is relatively
permanent. The preservation of open space areas, therefore, needs strong long-term
assurances, of at least 25 years, well beyond the life of the Plan.
Santa Clara County Zoning designations that are most reflective of open sp.ace uses,
including the creation of new Zoning designations, should be appIied to lands
intended for long-term open space uses.
The proposed limitation of a 20,000-square-foot maximum (5,00.0-square-foot.
maximum per building) development exception west of Junipero Serra Boulevard
appears reasonable so long as it is subject to further City review wher~ specific
proposals are submitted. This exception, however, should be included in the Plan.
AnY future land use changes that wilI intensify the use of open space areas should
involve the City in a meaningful way in the decision-making process.
Stanford should adopt an Academic Growth Boundary similar to the Urban Growth
Boundaries adopted by several cities in Santa Clara County.
Housing
The City of Palo Alto strongly supports the emphasis on creating additional on-site
housing by establishing goals and identifying potential sites within the core campus.
The unit types ~d development standards for the proposed housing are too general
and should be made more specific to assess its compatibility with existing land uses.
An assessment of needs reIated to the creation of additional housing, such as parks
and schools, should be provided. ,;
Ms. Anne Draper, Planning Director
October 28, 1999
Page 3
Open space areas along E1 Camino Real, north of Escondido Village, should be
maintained. The loss of potential units at this location may be compensated by an
equivalent increase in units elsewhere.in the Escondido Village vicinity.
Any additional development along Stanford Avenue must be consistent and
compatibIe with the existing development located across the street in the City of Palo
Alto.
Housing proposed in the area east of Hoover Pavilion at Quarry Road and El Camino
Real should not be constructed unless a significant open space buffer can be provided
and maintained a~ong E1 Camino Real.
Housing c’onstruction should be phased to occur early in the 10@ear period of the Plan
to keep pace with additional non-residential development, and it is strongly urged that
a more serious effort be made to close the gap between the University’s student
population and on-campuslibusing.
Consideration should be given to the need for providing additional affordable housing
for Stanford support staff.
Circulation and Parking
The goa! of"no new net commute trips" should be retained and the Plan should be
revised to clearly state this goal and how it might be accomplished.
Monitoring of vehicle trips needs to be based on actual counts in and out of the
Stanford campus. These counts need to be performed on a regular basis and the City
should be included in determining at which locations the counts will occur.
The commitment of Stanford regarding regional transportation issues, including
cooperation with other agencies, should be included in the Plan.
Measure the impacts off’no new net commute trips" on adjacent neighborhood streets,
such as in the College TerraCe neighborhood, and mitigate impacts as appropriate.
Ms. Anrte Draper, PIanning Director
October 28, 1999
Page 4
The Plan should include information on Stanford’s trails and pathways and clearly
indicate future intentions for enhancing these facilities and providing linkages from
the foothills to the baylands.
Schools
¯ Provision for a middle schooi of an appropriate size needs to be made in the Plan.
Potential locations for the school should be clearly identified, and ideally these
locations should be west Alma Street and El Camino Real. These locations should not
include any areas presently used for open space purposes.
Elementary school impacts created by additional fatuity and staff family housing
should also be assessed and addressed.
La~d Use
¯ Palo Alto agrees with the generalized land use .designations in the Plan, which include
support for the underlying concept of focusing all significant construction within the
core campus.
Areas presently shown as "Academic Reserve and Open Space" should be further
clarified. A separate ’~Open Space" designation should be provided for areas to be
used as long-term and!or permanent open space and that allows only limited uses and
development.
The total buiIding square fo.o.tage (2,100,000) allowed by the 1989 GUP included all
new structures, regardless of use; housing was included in the total building area. The
current Plan, which Iists allowable numbers of housing units separately from
allowable non-residential building area, should include tota! allowable building square
footage information so an accurate comparison can be made between this Plan and the
1989 GUP.
The Plan should include a section on all of Stanford’s land holdings, since
approximately half of their property is outside the scope of the Plan. This information
should be specific as to use, building area, numbers of dwelling units, and location of
development for botl~ existing and future conditions. The information should be
presented in both map and tabular form to enhance its usefulness.
Ms. Anne Draper, Planning Director
October 28, 1999
Page 5 .... ~.
Plan Implementation
, The Community Plan and GUP need to include provisions for monitoring of
development. Monitoring should be performed by an independent entity on an annual
basis with public hearings held at a location in northern Santa Clara County,
The Community Plan and GUP need to establish thresholds regarding the number of
housing units that must be built prior to the construction of additional academic and
support buildings.
Vision for Long-Term Build-Out of Stanford University
The Community Plan should include a long-term vision, beyond.the lO-year scope of
. theplan, for the ultimate build-out ofth8 University. While it is recognized that this
vision wc~uld not be as detailed as the ten-year Plan r.egarding Stanford’s potential
development, it would be helpful in providing insight into the University’s future
evolution .... ..
Again, th~ you for including the Cify of Palo Alto in the review process for the
Community Plan and GUP. We hope our recommen~tations and comments.are of
assistance.
Very
Mayor
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Attachment D
Impact and Mitigation Summary
Pre-Mitigation
SignificanceImpact Mitigation Measure
1. Land Use
LU-1. Will the project Less than No mitigation is necessary.Less than
increase potential for Significant Significant
conflict as a result of
incompatible land uses?
2. Open Space, Recreation and Visual Resources
No mitigation is necessary.
Post-Mitigation
Significance
OS-!. Will the project be
inconsistent with the
Santa Clara County
General Plan regarding
Scenic Routes, Scenic
Approaches, or Scenic
Highways?
OS-2. Will the project
result in the loss of
recognized open space?
OS-3. Will the project
adversely affect
recreational opportunities
for existing or new
campus residents and
facility users?
OS-4. Will the project
cause an adverse effect on
foreground or middle
ground views l~om a high
volume travel way
(excluding scenic routes
and scenic highways),
recreation use areas, or
other public use areas?
OS-5. Will the project
cause an adverse effect on
foreground views from
one or more private ~
residences or significantly
alter public views?
Less than
Significant
Significant
Significant
Significant
Less than
Significant
OS-2: Cluster Development in Lathrop
Development District
OS-3: Improvement of Parks and
Dedication of Trails
OS-4: Protect Visual Quality Along El
Camino Real
No mitigation is necessary.
Less than
Significant
Significant
Less than
Significant
Less than
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S-4
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Impact
OS-6. Will the project
create a high intensity
light source or glare
affecting private
residences, passing
pedestrians, or motorists?
OS-C 1: Will the project
combined with other
cumulative projects be
inconsistent with the
Santa Clara County
General Plan regarding
Scenic Routes, Scenic
Approaches, or Scenic
Highways?
OS-C2: Will the project
combined with other
cumulative projects result
in the cumulative loss of
recognized open space?
OS-C3: Will the project
combined with other
cumulative projects
adversely affect
recreational opportunities?
OS-C4: Will the project
together with other
cumulative projects cause
an adverse effect on
foreground or middle
ground views from a high
volume travel way
(excluding scenic, routes
and scenic highways),
recreation use areas, or
other public use areas?
Pre-Mitigation
Significance
Significant
Less than
Significant
Significant
Significant
Significant
Mitigation Measure
OS-6: Control Light and Glare
No mitigation is necessary.
OS-2: Cluster Development in Lathrop
Development District
OS-3: Improvement of Parks and
Dedication of Trails
OS-4: Protect Visual Quality Along E1
Camino Real
Post-Mitigation
Significance
Less than
Significant
Less than
Significant
Significant
Less than
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S-5
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Impact
Will the project
Pre.Mitigation
Significance
Less than
Significant
Mitigation Measure
No mitigation is necessary.
Significant
OS-C5:
along with other
cumulative projects cause
an adverse effect on
foreground views from
one or more private
residences or significantly
alter public views?
OS-C6: Will the project
along with other
cumulative projects create
a high intensity light
source or glare affecting
private residences, passing
pedestrians, or motorists?
3. Population and Housing
PH-I: Will the project
result in a net loss,
through conversion or
demolition, of homes
occupied by low- or
moderate-income
households?
OS-6: Control Light and Glare
No Impact No mitigation is necessary.
No mitigation is necessary.
PH-3: Identify Additional Housing Sites
and Condition New Academic Space on
the Construction of Housing
No mitigation is necessary
Post-Mitigation
Significance
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
PH-2: Will the project
result in a net loss,
through conversion or
demolition, of
multifamily rental
housing?
PH-3: Will the project
increase the demand for
housing thereby causing
indirect environmental
impacts?
PH-CI&2: Will the
project have a cumulative
potential to result in a net
loss of homes occupied by
low- or moderate-income
households or a net loss
of multifamily rental
housing?
No Impact
Significant
No Impact
Less than
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S-6
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Impact
PH-C3: Will the project
plus cumulative projects
increase the demand for
housing thereby causing
indirect environmental
impacts?
4. Traffic and Circulation
Pre-Mitigation
Significance
Significant
Mitigation Measure
PH-3: Identify Additional Housing Sites
and Condition New Academic Space on
the Construction of Housing
TR-I: Transit. Will the
project adversely affect
public transit service
levels or accessibility?
TR-2: Bicycle and!or
Pedestrian. Will the
project cause adverse
impacts on the use of
bicycle and/or pedestrian
travel ways?
TR-3: Parking. Will the
project create adverse
impacts to existing
parking or access to
existing parking?
TR-4: Vehicular Impacts
- Freeways. Will the
project create adverse
vehicular impacts on the
freeways?
TR-5: Vehicular Impacts
- Intersections. Will the
project create adverse
vehicular impacts for
intersections in Palo Alto,
Santa Clara County, and
Menlo Park?
TR-6: Residential Streets.
Will the project result in
traffic impacts to
surrounding residential
neighborhoods?
Post.Mitigation
Significance
Less than
Significant
Less than No mitigation is necessary.Less than
Significant Significant
No mitigation is necessary.Less than
Significant
Less than
Significant
Less than
Significant
No mitigation is necessary.
No mitigation is necessary.
TR-SA: Tier 1 Intersection Capacity
Expansion
TR-5B: Trip Reduction and Monitoring
TR-5C: Cooperative Trip Reduction
TR-5D: Intersection Capacity Expansion
TR-6A: Reduce Cut Through Traffic on
Residential Streets
TR-6B: Require Site-Specific Traffic
Studies for Large GUP Projects
Significant
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S-7
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Impact
TR-7: Construction. Will
the project create
additional construction
traffic causing a
substantial reduction in
access to land uses or a
reduction in mobility?
Pre-Mitigation
Significance
Significant
Mitigation Measure
TR-7A: Off-street Parking for
Construction Related Vehicles
TR-7B: Maintenance of Pedestrian
Access
TR-7C: Maintenance of Bicycle Access
TR-7D: Restriction on Construction
Hours
TR-7E: Construction Truck Routes
TR-7F: Protection of Public Roadways
During Construction
TR-7G: Protection and Maintenance of
Public Transit Access and Routes
TR-7H: Construction Impact Mitigation
Plan (Alternate Mitigation)
TR-7I: Construction During Special
Events
5. Hydrology and Water Quality
HWQ-I: Surface Water
Hydrology. Will the
project cause increased
runoff due to creation of
impervious surfaces?
HWQ-2: Groundwater.
Will the project reduce
groundwater quantity?
HWQ-3: Groundwater.
Will the project degrade
groundwater quality?
HWQ-4. Surface Water
Quality. Will the project
result in a degradation of
surface water runoff
quality?
Significant
Significant
Significant
Significant
HWQ-I: Manage Stormwater Runoff
HWQ-I: Manage Stormwater Runoff
HWQ-2: Maintain Groundwater
Recharge
HWQ-3: Protect Water Quality
HWQ-3: Protect Water Quality
HWQ-4: Best Management Practices for
Preventing Post-Construction Urban
Runoff Pollution
Post-Mitigation
Significance
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S.8
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT E R
SUMMARY
Impact and Mitigation Summary
Impact
HWQ-CI: Will the
project have a cumulative
potential to impact
surface water hydrology,
groundwater quantity,.
groundwater quality or
surface water quality?
Pre-Mitigation
Significance
Significant
Mitigation Measure
HWQ-I: Manage Stormwater Runoff
HWQ-2: Maintain Groundwater .
Recharge
HWQ-3: Protect Water Quality
HWQ-4: Best Management Practices for
Preventing Post-Construction Urban
Runoff Pollution
G&S-l: Will project
facilities be damaged by
ground surface rupture?
G&S-2: Will earthquake-
induced strong ground
shaking damage project
facilities?
Geology and Seismicity
Less than
Significant
G&S-3: Will project
facilities be damaged by
co-seismic ground
deformation?
G&S-4: Will project
facilities be damaged by
liquefaction or settlement
during an earthquake?
G&S-5: Will project
facilities be damaged by
unstable slope conditions?
G&S-6: Will project
facilities be exposed to
damage due to expansive
soils or soils with
moderate to high erosion
potential?
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
No mitigation is necessary.
No mitigation is necessary.
No mitigation is necessary.
No mitigation is necessary.
No mitigation is necessary.
No mitigation is necessary.
Post-Mitigation
Significance
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S-9
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Pre-Mitigation Mitigation Measure Post.MitigationImpactSignificanceSignificance
7. Hazardous Materials
PHS-I: Will the Project
provide safeguards to
protect the public from
exposure to hazardous
materials at
concentrations
detrimental to human
health?
PHS-2: Will the Project
provide safeguards to
protect the public from
exposure to hazardous
waste at concentrations
detrimental to human
health?
PHS-CI: Will the project
plus cumulative projects
provide safeguards to
protect the public from
exposure to hazardous
materials and wastes at
concentrations
detrimental to human
health?
Significant
Less than
Significant
PHS-I: Risk Management Plan
No mitigation is necessary.
Less than
Significant
Significant PHS-I: Risk Management Plan
Less than
Significant
Less than
Significant
8. Biological Resources
BIO-I: Will the project Significant;
cause a loss of individuals California Tiger
or occupied habitat of Salamander
BIO-l(a) through (e) - Option 1: CTS
Mitigation Program Proposed by Stanford
Option 1 -
Significant
endangered, threatened, or
rare wildlife or plant
species?
No Impact;
Steelhead and
California red-
legged frog
BIO-l(a) through (e) - Option 2:
Alternative CTS Mitigation Program (not
proposed by project applicant)
No mitigation is necessary.
Option 2 - Less
than Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S-lO
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Impact
BIO-2: Will the project
cause a loss of individuals
of CNPS List 3 or 4 plant
species?
BIO-3: Will the project
cause a loss of active
raptor nests, migratory
bird nests, or native
wildlife nursery sites?
BIO-4: Will the project
cause a permanent net
loss of habitat for
sensitive wildlife species?
BIO-5: Wilt the project
cause a permanent loss of
sensitive native plant
communities?
BIO-6: Will the project
substantially block or
disrupt wildlife migration
or travel corridors?
BIO-7: Will the project
conflict with the County’s
tree preservation
ordinance?
Pre.Mitigation
Significance
Potentially
Significant; Rare,
Threatened, and
Endangered
Plants
Less than
Significant;
American
Peregrine Falcon
and Willow
Flycatcher
Significant
Significant
Less than
Significant
Significant
Significant
Significant
Mitigation Measure
BIO-l(f) through (k): Rare, Threatened,
and Endangered Plant Protection Program
No mitigation is necessary.
BIO-l(f) through (k): Rare, Threatened,
and Endangered Plant Protection Prggram
BIO-3: Pre-Construction Raptor Surveys
No mitigation is necessary.
BIO-5: Replacement of Oak Woodland
and Riparian Oak Woodland
BIO-l(a) through (e) - Option 1: CTS
Mitigation Program proposed by Stanford
BIO-l(a) through (e) - Option 2:
Alternative CTS Mitigation Program (not
proposed by project applicant)
BIO-7: Planting of Replacement Trees
Post.Mitigation
Significance
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S-11
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Impact
BIO-8: Willthe project
conflict with the
provisions of an adopted
Habitat Conservation
Plan, Natural Community
Conservation Plan, or
other approved local,
regional, or state habitat
conservation plan?
BIO-9: Will the project
result in a net loss of
wetlands or other waters
of the U.S.?
BIO-C 1 through BIO-C3,
BIO-C7, and BIO-C8:
Will the project impact
sensitive biological
resources based on
evaluation criteria 1
through 3, 7, and 8?
BIO-C4: Will the project,
combined with other
cumulative projects, cause
a permanent loss of
habitat for sensitive
wildlife species?
BIO-C5: Will the project,
combine~t with other
cumulative projects, cause
a permanent loss of
sensitive native plant
communities?
BIO-C6: Will the project,
combined with other
cumulative projects,
substantially block or
disrupt wildlife migration
or travel corridors?
Pre-Mitigation
Significance
Less than
Significant
Significant
Significant
Less than
Significant
Significant
Significant
Mitigation Measure
No mitigation is necessary.
BIO-9: Wetland Avoidance and
Replacement
BIO-l(a) through (e) - Option 2:
Alternative CTS Mitigation Program (not
proposed by project applicant)
BIO-l(t) through (k): Rare, Threatened,
and Endangered Plant Protection Program
BIO-3: Pre-Construction Raptor Surveys
BIO-7: Planting of Replacement Trees
No mitigation is necessary
BIO-5: Replacement of Oak Woodland
and Riparian Oak Woodland
BIO- l(a) through (e) - Option 2:
Alternative CTS Mitigation Program (not
proposed by project applicant)
Post.Mitigation
Significance
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S.12
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Impact Pre-Mitigation
Significance
BIO-C9: Will the project,Significant
combined with other
cumulative projects, result
in a net loss of wetlands
or other waters of the
U.S.?
9. Historic and Archaeological Resources
HA- l: Will the project Significant
cause a substantial
adverse change in the
significance of a historical
resource as defined in
Section 15064,5?
HA-2: Will the project
cause a substantial
adverse change in the
significance of an
archaeological resource as
defined in Public
Resources Code 21083.2?
HA-3: Will the project
directly or indirectly
destroy a unique
paleontological resource
or site or unique geologic
feature?
HA-4: Will the project
disturb any human
remains, including those
interred outside of formal
cemeteries?
Significan{
Significant
S!gnificant
SignificantHA-CI: Will the project
combined with
cumulative projects have
a potential to disturb
historical resources?
Mitigation Measure
BIO-9: Wetland Avoidance and
Replacement
HA- 1: Protection of Historic Resources
HA-2: Protection of Known and
Previously Undiscovered Archaeological
Resources
HA-3: Protection of Undiscovered
Paleontological Resources
HA-2: Protection of Known and
Undiscovered Archaeological Resources
HA-l: Protection of Historic Resources
Post-Mitigation
Significance
Less than
Significant
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Significant
JUNE 23, 2000 PARSONS PAGE S-13
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Impact
HA-C2-4: Will the
project combined with
cumulative projects have
a potential to disturb
archaeological, unique
geological, or
paleontological resources,
or human remains?
Pre-Mitigation
Significance
Significant
Mitigation Measure
Archaeological Resources
HA-2: Protection of Known and
Undiscovered Archaeological Resources
Unique Geologic, Paleontological
Resources and Human Remains
No mitigation is necessary.
10. Public Services and Utilities
PS-I: Will the project
increase demand for
police, fire, water, power,
sewage treatment and
disposal, or solid waste
removal to such a degree
that accepted service
standards are not
maintained?
PS-2: Will the project
create a demand for
additional school capacity
that cannot be met by
existing or planned
capacity?
PS-CI: Will the project,
combined with other
cumulative projects,
increase demand for
police, fire, water, power,
sewage treatment and
disposal, or solid waste
removal to such a degree
that accepted service
standards are not
maintained?
Significant; Police
Significant; Fire
Significant; Water
Significant;
Wastewater
Less than
Significant; Solid
Waste
Less than
Significant;
Electrical Power
Significant
Significant
PS-1A: Maintain Police Services
PS-1B: Maintain Fire Services
PS-1C: Water Conservation and
Recycling
PS-1D: Improve the Wastewater
Collection System
No mitigation is necessary.
No mitigation is necessary.
PS-2: Payment of Statutory School
Impact Fees
PS-1A: Maintain Police Services
PS-1B: Maintain Fire Services
PS-1C: Water Conservation and
Recycling
PS-1D: Improve the Wastewater
Collection System
Post-Mitigation
Significance
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S. 14
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Impact
PS-C2: Will the project,
together with other
cumulative projects,
create a demand for
additional school capacity
that cannot be met by
existing or planned
capacity?
11. Air Resources
Pre.Mitigation
Significance
Significant
Mitigation Measure
PS-2: Payment of Statutory School
Impact Fees
Post.Mitigation
Significance
Less than
Significant
AQ- 1 : Will there be
inadequate mitigation for
potential construction-
period emissions?
AQ-2: Will the project
produce local CO
concentrations that exceed
federal and state
standards?
AQ-3: Is the project
inconsistent with emission
growth factors contained
in any BAAQMD air
plans or does it result in
an emissions increase
greater than the listed
significance thresholds?
AQ-4: Will the project
create objectionable
odors?
AQ-5: Will the project
significantly alter air
movement, moisture, or
temperature, or change in
climate, either locally or
regionally?
AQ-6: Will the project
expose sensitive receptors
or the general public to
substantial levels of toxic
air contaminants?
Significant AQ-I: Reduce Diesel Emissions Less than
Significant
No mitigation is necessary.Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
No mitigation is necessary.
No mitigation is necessary.
No mitigation is necessary.
No mitigation is necessary,
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S-15
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Impact
AQ-Cl: Will the project
have significant
cumulative air quality
impacts?
12. Noise
Pre.Mitigation
Significance
Less than
Significant
Mitigation Measure
AQ-1 Reduce Diesel Emissions
Post.Mitigation
Significance
Less than
Significant
NOISE-1 : Will Significant NOISE-1 : Reduce Construction Noise Significant
construction of the project
expose the public to high
noise levels?
SignificantNOISE-2: Will operation
of the project expose the
public to high noise
levels?
Less than
Significant
Less than
Significant
Significant
Less than
Significant
NOISE-3: Will operation
of the project expose the
public to high traffic noise
levels?
NOISE-2: Provide for Noise Reduction
Designs
No mitigation is necessary.
No mitigation is necessary.
No mitigation is possible.
NOISE-2: Provide for Noise Reduction
Designs
NOISE-4: Will vibration
from project construction
cause any disturbance?
NOISE-C 1: Will
construction of the project
combined with other
nosie sources expose the
public to high cumulative
noise levels?
NOISE-C2: Will
operation of the project
expose the public to high
cumulative noise levels?
Less than
Significant
Less than
Significant
Less than
Significant
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S-16
STANFORD UNIVERSITY COMMUNITY PLAN/GENERAL USE PERMIT EIR
SUMMARY
Impact and Mitigation Summary
Impact
NOISE-C3: Wilt
operation of the project
expose the public to high
cumulative traffic noise
levels?
NOISE-C4: Will
vibration t~om project
construction plus
cumulative projects cause
any disturbance?
Pre-Mitigation
Significance
Less than
Significant
Less than
Significant
Mitigation Measure
No mitigation is necessary.
No mitigation is necessary.
Source: Parsons, 2000
Post.Mitigation
Significance
Less than
Significant
Less than
Significant
JUNE 23, 2000 PARSONS PAGE S.17
TRANSP OR TA TION
Attachment E
DIVISION
Memorandum
Date:July 24, 2000
To:Luke Connolly
From:Carl Stoffel ~
Subject:GUP Mitigations
The City supports the following transportation mitigations for the GUP:
"No net new commute trips" (DEIR Mitigation TR-5B) and "Cooperative trip
reduction" (Mitigation TR-5C) should be the primary mitigation measures for
intersection impacts on maj or roads.
Tier 1 intersection improvements (Mitigation TR-5A) should be implemented. These
are Arboretum/Palm and Welch/Campus Drive West, both of which are Stanford
campus intersections (Arboretum!Palm signal is operated and maintained by Palo
Alto). For each location, we support giving Stanford the option of implementing a
configuration other than that specified in the DEIR if the altemate improvement is
equal or better. Specifically, we support the option of a modem roundabout at
ArboretmrdPalm, if so desired by Stanford.
3.Generally, Palo Alto does not support Tier 2 intersection projects, with the following
exceptions:
a°E1 Camino Real/Churchill (Palo Alto): This project is already in the Palo Alto
CIP. Stanford’s fair share for this location should be given to the City upon
approval of the GUP, with the proviso that Palo Alto may wish to use the funds
on an alternative project (refer to discussion below).
bo We do not support other Tier 2 intersection projects in Palo Alto or Santa Clara
County for reasons stated elsewhere.
C°For Menlo Park intersections, Menlo Park should determine whether or not it
would like to pursue the improvements and, if so, receive Stanford’s fair share
contribution for them.
GUP Mitigations
July 24, 2000
Page 2 of 6
Palo Alto supports the "Sand Hill Road Widening as Alternative Mitigation"
for the certain intersection impacts in Menlo Park and on Stanford campus.
Palo Alto supports Stanford participation in future neighborhood traffic studies
initiated by Palo Alto and Menlo Park (Mitigation T-6A). Palo Alto suggests that
this mitigation measure be modified to require that Stanford be responsible to pay
for and conduct a license plate and/or origin-destination survey to determine
which vehicles are travelling to/from Stanford lands. Furthermore, the proportion
of through traffic attributable to Stanford should be all traffic generated by the
campus area, whether or not it is related to the new GUP development.
o Palo Alto supports the proposed TDM monitoring program for "no net new commute
trips" described under Mitigation TR-5B. Palo Alto requests that the following
requirements for compliance be added to this monitoring program:
a. Monitoring will be conducted annually.
No Stanford’s failure to meet the "no net new co~mnute trips" requirement by any
amount in either the AM or PM peak hour for any two years (i.e., not
necessarily consecutive) will constitute "triggering" of Stanford’s full
payment of fair share mitigation funds for all Tier 2 intersection
improvements for which Stanford has not already made payment to the
respective jurisdictions.
Co "Fair share" should be based on all Stanford traffic using a particular
intersection (i.e., existing and new traffic)--not just the project component
from the new GUP.
e°
f.
If a third year of failure to meet the TDM requirement occurs, Stanford will
not be permitted to conduct further development projects permitted under
the GUP that have not already been approved for c.onstruction by the
County.
Reinstatement of development rights will occur following two consecutive
years of successfully meeting the "no net new commute trips" requirement.
For Palo Alto and County Tier 2 intersections for which fair share funds are
received per item (b) above, Palo Alto has identified the following possible
"alternative mitigations" for which the funds should be spent and/or for
which Stanford should be responsible. This list may be modified by Palo
Alto or the County.
GUP Mitigations
July 24, 2000
Page 3 of 6
(i)
(ii)
(iii)
(iv)
Increased shuttle service in the Stanford Research Park (all-day bi-
directional service between all major Research Park locations and the
California Avenue Caltrain station).
Establishment of a transit center for Stanford and Palo Alto at the
University Avenue Caltrain station.
Bicycle lane projects on Junipero Serra Boulevard between Foothill
Expressway and Alpine Road and on Deer Creek Road between
Arastradero Road and Page Mill Expressway.
Sidewalk and/or multiuse path along the north side of Stanford Avenue
between E1 Camino Real and Escondido Road.
(v)
(vi)
(vii)
Planned new pedestrian/bicycle undercrossing of Alma and Caltrain
tracks at California Avenue. This undercrossing would be part of the
proposed Stanford/Palo Alto Bay to Foothills trail in which Stanford
may participate as part of the GUP.
Planned new pedestrian/bicycle undercrossing of the Caltrain tracks at
Homer Avenue. This undercrossing would link pedestrian and bicycle
traffic to the Stanford campus via the existing PAM!ECR traffic signal
and a potential new pedestrian/bicycle path through the Stanford
arboretum area to connect to the Medical Center area (see next item).
Construction of a pedestrian/bicycle path in the Stanford arboretum area
between the PAMF/ECR traffic signal and the Arboretum!Palm
intersection.
(viii)
(ix)
Construction of a pedestrian/bicycle path between the new Cancer Center
and the new signalized intersection on Sand Hill Road leading to the
Stanford West apartments and the bike bridge over San Francisquito
Creek. This would include a crossing of Welch Road, which might be
signalized.
Expansion of the Palo Alto/Stanford shuttle integration project hours of
operation.
GUP Mitigations
July 24, 2000
Page 4 of 6
(x)Increased Stanford responsibility for traffic calming projects in Palo Alto
(beyond mitigation measure TR-6A), to include collector streets and
residential arterials.
Note: Some of the above alternative mitigations were also listed for the recently-
approved Cancer Center project.
The impact of the GUP extend~ beyond the peak hour impacts specifically identified
in the DEIR. These. impacts are increased traffic congestion and impacts during
the non-peak hours on maj or streets and, in some cases, on local residential streets.
As mitigation for these impacts, Stanford should be required to implement an
"Integrated Transportation Plan" as described in the attachment to this
memorandum.
CS
Attachment: "An Integrated Transportation Plan for Stanford"
GUP Mitigations
July 24, 2000
Page 5 of 6
ATTACHMENT
An Integrated Transpo.~ation Plan for Stanford
Stanford lands are served by a complex, multimodal transportation system. Elements of this
system are the campus road net, Marguerite shuttle bus routes, bike lanes and paths, sidewalks,
and a travel demand management program. Stanford’s transportation system interconnects with
the roadway, bus and rail transit, bicycle, and pedestrian networks of the surrounding region.
Both Stanford’s and the region’s transportation needs and possibilities are dynamic. Prospective
changes in the region’s transportation system over the next five to ten years include:
Doubling of Caltrain service
Deployment of"articulated" (double capacity) VTA buses to and from the University
Avenue Caltrain station
Creation of a high-speed "baby bullet" passenger train between San Francisco and San Jose
Development of a Palo Alto Intermodal Transit Center
Construction of a new bicycle/pedestrian undercrossing of Caltrain near Stanford lands at
Homer Avenue in Palo Alto
Creation of an east-west "bicycle boulevard" in Palo Alto
Construction of a continuous off-road bicycle path between Churchill and the University
Avenue depot in Palo Alto
Improvements to Palo Ako’s Shuttle and other local transit service
Arterial and local street traffic calming initiatives in Palo Alto
Major upgrades to Palo Alto’s traffic signal system
Successful, citywide travel demand management efforts in Palo Alto
Potential transportation system changes in the ten- to twenty-year horizon include:
Inauguration of high-speed rail passenger service between Los Angeles and San Francisco
Creation of commuter rail service parallel to the Dumbarton bridge, with shuttle service from
an East Palo Alto station to Palo Alto and Stanford
Extension of light rail service from Mountain View to Palo Alto
Continued improvements in bus transit services, bicycle, and pedestrian facilities in the
region
These shorter- and longer-term changes will take place in context of and in response to rising
travel demand, increased levels of roadway congestion, and heightened concerns about air
pollution and quality of life for the region.
An integrated transportation systems or master plan needs to be developed in order for Stanford
to respond effectively to these concerns and the opportunities. This plan should be integrated in
two ways: 1.) developed in cooperation with neighboring jurisdictions: Palo Alto, Menlo Park,
East Palo Alto, and the County of Santa Clara; and 2.) provide for efficient integration and
optimal use of the various transportation modes, including private vehicles, bus and rail public
transport, bicycle and pedestrian transportation. The integrated transportation plan should have
GUP Mitigations
July 24, 2000
Page 6 of 6
shorter-term (perhaps one to ten year) and a longer-term (perhaps ten to twenty year)
components. In addition to addressing each transportation mode, the Plan should include several
ancillary facilities or functions. Plan elements should comprise the following:
Vehicle Circulation and Roadway Network
Public Transit
Bicycle and Pedestrian
Parking
Travel Demand Management
Transportation System Management (including use of Intelligent Transportation Systern
technologies in place of conventional increases in road capacity)
Traffic Calming (including use of innovations such as roundabouts in place of conventional
traffic signals or stop control) elements.
Attachment F
Public Works Department
Engineering Division
MEMORANDUM
Date:July 24, 2000
To:
From:
Luke Connolly, Planning
Joe Teresi (x2129)~-o-
Senior Engineer ~"
Subject:EIR for Stanford University Draft Community Plan
and General Use Permit Application
The Public Works Engineering Division has the following comments on the subject EIR:
Arastradero Creek is a tributary of Matadero Creek (confluence is near intersection of
Arastradero and Page Mill Roads). It is not clear why Arastradero Creek watershed is
separated out from Matadero Creek in the analyses and tables. Data pertaining to Deer
Creek, another tributary of Matadero Creek, is included with the Matadero Creek data.
The 100-Year rainfall total and average intensity appear to be underestimated in the
hydrology section (Page 4.5-9). Using the Santa Clara County Drainage Manual as a
reference, the mean annual precipitation for Stanford University is 16 inches, and the
runoff for a 100-year, 24-hour storm is 4.68 inches (not 4.32 inches), with an average
intensity of 0.19 inches/hour (not 0.17 inches/hour).
It is unusual that the analysis of the impacts of increased runoff resulting from the
proposed new development is based upon a 100-year, 24-hour storm. The 100-year
standard is normally used to analyze the capacity of regional facilities such as creeks or
large flood control facilities. A portion of the developed campus area drains into the city
of Palo Alto’s storm drain system. Storm drain systems are typically designed to convey
the runoff from shorter, more frequent storm events, such as a 10-year, six-hour storm.
Impacts of the proposed development on the 10-year storm peak runoff rate are not
addressed in the EIR. Increases in the 10-year storm peak runoff will have adverse
impacts on the City’s storm drain system. The fact that project mitigations will ensure that
there will be no increase in the peak runoff from a 100-year storm does not necessarily
mean that there will not be an increase in peak runoff during smaller events. Since the
design details of the proposed detention basins are not discussed, it is not clear what, if
any, runoff detention will take place during smaller storms.
The EIR should be amended to include an analysis of the impacts of the proposed
development on the peak runoff rate from the lO-year, six-hour storm event.
Comments on Stanford Use Plan EIR
July 24, 2000
Page 2
4. Runoff from portions of the developed campus area flows through the City of Palo Alto
enroute to Matadero Creek, either through the City’s storm drain system or through the
Stanford Channel, a Santa Clara Valley Water District facility. The Stanford Channel has
less than 100-year flood control capacity. It overflows into a natui:al drainage course and
storm drain system that traverses the College Terrace neighborhood in Palo Alto when it
fills beyond its capacity. This overflow has caused flooding in the neighborhood during
moderate storms (less than 100-year storms) in the past. Any additional runoff may
exacerbate this flooding threat. Portions of the campus drain into a Caltrans/City storm
drain that runs south along E1 Camino Real, east on Page Mill Road, and south along Park
Boulevard before discharging to Matadero Creek. Additional runoff may result in flooding
of this storm drain system. The EIR does not address the impacts of the proposed
development on either of these drainage facilities.
The EIR should be amended to include an analysis of the impacts of the proposed
development on the City of Palo Alto’s storm drain system and the Stanford Channel.
discussed under item 3 above, these impacts may occur during storms smaller than the
100-year, 24-hour storm analyzed in the EIR.
As
Runoff from portions of the developed campus area flow to San Francisquito Creek. The
creek has less than 100-year flood control capacity. The EIR does not analyze the impacts
of increased runoff from new development on San Francisquito Creek during storms
smaller than the 100-year storm event. The fact that project mitigations will ensure that
there will be no increase in the peak runoff from a 100-year storm does not necessarily
mean that there will not be an increase in peak runoff during smaller events.
The EIR should be amended to include an analysis of the impacts of the new development
on the potential for San Francisquito Creek flooding during events smaller than the 100-
year storm.
The EIR cites the use of detention basins as the sole proposed mitigation for expected
increases in runoff resulting from new development on the campus. While detention basins
are an acceptable means of controlling peak runoff, there are other drainage features that
can be incorporated into site designs that will reduce total runoff and improve storm water
quality, as well as control peak runoff rates. These features will also function to reduce
runoff during smaller, more frequent storms, when the proposed detention basins may not
be effective. These design features include the following:
Directing roof and parking lot drainage into vegetated swales
Elimination of "directly connected impervious areas" by breaking up drainage paths
with landscaping or other pervious areas
Retention of native vegetation and minimization of disturbances to natural terrain
Use of pervious pavement materials
Use of underground parking and multi-storied buildings to minimize development
footprints
Clustering of development to minimize land disturbances
Comments on Stanford Use Plan EIR
July 24, 2000
Page 3
These and other design techniques are described more fully in a manual entitled Start at
the Source Design Guidance Manual for Storm Water Quality Protection, published by the
Bay Area Storm Water Management Agencies Association.
The EIR should be amended to require drainage design features in addition to retention
basins as mitigation measures that will control the quantity of storm water runoff.
The EIR sections on groundwater and surface water quality impacts discusses the
preparation of Storm Water Pollution Prevention Plans (SWPPP) and the use of Best
Management Practices as a mitigation measure only in the context of compliance with the
State of California General Permit for Discharges of Storm Water Associated with
Construction Activities. The EIR correctly states that the General Permit applies only to
projects that disturb five or more acres of land. Water quality impacts, both short-term
impacts during construction and permanent post-construction impacts, may, however,
result from projects of any size. In addition, the Municipal Stormwater Permit issued to
Santa Clara County (as one of 15 co-permittees in the County) requires the County to
"implement control measures and best management practices to reduce pollutants in storm
water discharges to the maximum extent practicable" through development and
implementation of an Urban Runoff Management Plan (URMP). One of the required
components of the URMP is a plan to review and control the water quality impacts of new
development.
The EIR discussion and mitigation measures should be clarified to require Stanford to
prepare a SWPPP and implement BMP’s on all new development projects, regardless of
size.
The EIR’s discussion of potential water quality impacts and mitigation measures is rather
limited and should be expanded to address the full range of issues. There should be more
discussion of typical Best Management Practices (BMP’s) that will be incorporated into the
proposed development to minimize both construction and post-construction storm water
quality impacts.
Potential construction-related water quality impacts include erosion of sediment as well as
non-storm water discharges resulting from improper material storage, site housekeeping
practices, and construction vehicle/equipment maintenance, fueling and cleaning. Certain
construction operations (e.g. paving, concrete truck washout, pavement sawcutting,
painting) also have a high potential to release pollutants if not performed properly.
Typical construction-stage BMP’s include stabilized construction entrances, catch basin
protection, silt fencing, berming around material and equipment storage areas, and
designated concrete washout areas.
Potential permanent water quality impacts include increased runoff, and the introduction of
pollutants including sediments, heavy metals, pesticides, fertilizers, and other chemicals
from sources such as parking lots and dumpster areas and activities such as landscape
maintenance, car washing, and tenant use and disposal of cleaning products and other
household chemicals. Typical permanent BMP’s that should be considered include site
planning concepts such as reduced impervious area, clustering of buildings, .infiltration of
Comments on Stanford Use Plan EIR
July 24, 2000
Page 4
storm runoff, and retention of native vegetation. Specific BMP~s may include catch basin
Stenciling (No Dumping! Flows to San Francisquito Creek), routing of parking lot and
building storm runoff to vegetated swales, storm water pollution prevention education for
eventual building user/residents, and the use of catch basin filter inserts, covered dumpster
areas, and pervious paving. Start at the Source, described in comment 6 above, is an
excellent guidance, document for selecting permanent storm water pollution prevention
BMP’s.
cc:Glenn Roberts
Kent Steffens
Jim Harrington