HomeMy WebLinkAbout2000-10-16 City Council (7)TO:
FROM:
DATE:
SUBJECT:
City of Palo Alto
C ty Manager’s Report
HONORABLE CITY COUNCIL
PLANNING AND TRANSPORTATION COMMISSION
CITY MANAGER DEPARTMENT: PLANNING AND
COMMUNITY ENVIRONMENT
OCTOBER 16, 2000 CMR:394:00
STANFORD UNIVERSITY COMMUNITY PLAN AND GENERAL USE
PERMIT (GUP)
RECOMMENDATION
Staff recommends that the City Council and Planning and Transportation Commission
reaffirm their prior positions on the Stanford Community Plan/GUP, recognizing the
changes made by Santa Clara County staff.
Staff recommends that in furtherance of the Stanford Community Plan, the City
Council direct staff to draft an amendment to the Sand Hill Road Development
Agreement that reflects Stanford’s recent proposal to allow housing development on
the approximately 13-acre area west of the Stable Site in exchange for the retention of
open space and recreational uses on Hole # 1 of the Stanford Golf Course
o Staff recommends that the City Council direct staff to meet with Stanford to proceed
with the development of a community-serving facility on the Stanford-owned
Mayfield Site, located at the northwest comer of E1 Camino Real and Page Mill Road.
BACKGROUND
On Tuesday, October 10, the County released the final draft of the Stanford University
Community Plan and General Use Permit and Final Environmental Impact Report. Staff
has reviewed these documents, within the brief timeframe provided, and is appreciative
that many of the City’s concerns raised in previous correspondence to the County have
been addressed. Given the limited time for its preparation, this report highlights only the
major issues regarding the Community Plan and the General Use Permit that will be the
focus of the City Council and Planning Commission deliberations over the next week. A
more detailed staff report will be available for the final City Council meeting on the
Community PlardGUP, scheduled for October 23. All previous City responses on the
Community Plan!GUP are included in this staff report as Attachments A, B and C.
CMR:394:00 Page 1 of 6
Attachment A is the staff letter commenting on the Community Plan sent to the County in
late September. Attachments B and C are earlier letters from the City to the County
regarding the EIR and the Community Plan/GUP.
The Community Plan/GUP regulate land use and development for Stanford’s land in the
unincorporated portion of Santa Clara County. This accounts for over 4,000 acres,
approximately half of Stanford’s total land ownership. With the exception of an
established residential area located north of Junipero Serra Boulevard and west of Page
Mill Road, Stanford-owned land within Santa Clara County consists primarily of the
academic campus and the foothill-open space property south of Junipero Serra.
Stanford’s ownership includes land in the cities of Palo Alto, Menlo Park, Woodside, the
Town of Portola Valley and unincorporated San Mateo County. Stanford-owned
property in Palo Alto includes the Stanford Research Park, Stanford Shopping Center and
the Medical Center.
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 used the GUP as a land
use and development tool since 1962. Presently, development on Stanford’s
unincorporated land occurs under a GUP approved by the County in 1989. The 1989
GUP allowed 2.1 million square feet of building area, including residential structures, to
be developed; approximately 100,000 square feet of this entitlement remains, leading to
Stanford’s request for County approval of the proposed GUP. As with the 1989 GUP, the
proposed 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 dwellings for students, faculty and staff.
Residential building square footage is exclusive from the 2,035,000 square feet of
building area that is requested.
The Community Plan, unlike the GUP, is not an entitlement mechanism, but is instead a
long-range policy document that, if adopted, will amend the Santa Clara County General
Plan concerning Stanford’s land. 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 guide development indefinitely, unless superseded.
SUMMARY OF SIGNIFICANT ISSUES
Academic Growth Boundary/Open Space Preservation
The establishment of mechanisms that would enable the long-term preservation of
Stanford’s foothill area south of Junipero Serra Boulevard has been, and remains, the
primary concern of the City of Palo Alto throughout the over year-long Community,
Plan/GUP review process. The City supports development within an Academic Growth
Boundary (AGB) as an initial step in establishing such preservation mechanisms, but is
concerned that the AGB alone results in only medium-term preservation. The
CMR:394:00 Page 2 of 6
Community Plan includes an AGB, and as proposed, there are three major issues
associated with the boundary and its effectiveness at open space preservation: 1) Once
established, what assurances would there be that the AGB Would be kept firmly in place?
2) How long would the AGB be kept in place, without modification? 3) Where would the
AGB be located?
AGB: Modification and Duration of the Boundars,
In the. City’g initial response (Attachment C, letter dated October 28, 1999) to the draft
Community Plan, the Council recommended the establishment of an AGB, since one was
not proposed by Stanford at that time, that would define the area where academic
development would occur under the proposed and future GUPs. The Council also
recommended to the County that Stanford’s open space lands should not be considered
for development for a period of 25 years or more, with their permanent preservation
being the objective. The Council maintained this position in its subsequent comments on
the Community Plan/GUP and its EIR.
The Stanford-prepared draft Community Plan, dated November 15, 1999, included the
AGB concept. The more recent August 2000 draft Community Plan, prepared by the
County Planning staff, expanded on the concept by including provisions intended to keep
the AGB in place for 25 years or until an additional5 million square feet of development
occurred on the Stanford campus. In the City’s most recent comments (Attachment A,
letter dated September 25, 2000), staff recommended that the AGB remain in place,
without modification, for a minimum period of 50 years and that the AGB not have an
alternative "trigger" allowing it to be modified when development had reached a
specified level. The staff recommendation of 50 years was an attempt to quantify what
the City had earlier meant by "permanent" open space preservation.
The final draft of the Community Plan, dated October 9, 2000, still recommends that the
AGB remain in place, without modification, for 25 years but eliminates the alternative "5
million square feet of development" trigger, in accordance with the City’s most recent
recommendation. This "’firming up" of the duration of the AGB is an improvement;
however, staff does not consider this to provide long-term preservation of the open space
south of Junipero Serra and prevention of the potential sprawl of the campus. Staff is still
reviewing this issue and potential alternatives.
Location of the AGB: Lathrop and Stanford Golf Course Hole # 1
The City’s principal goal concerning the location of the proposed AGB is to have it be
coterminous with the City’s existing Urban Growth Boundary (UGB). At present there
remain two areas where the City’s UGB and the proposed AGB are inconsistent: 1) the
Lathrop Property and 2) Stanford Golf Course Hole # 1.
When Stanford first proposed an AGB in November 1999, it was coterminous with the
City’s UGB along Junipero Serra Boulevard, from approximately Lake Lagunita
eastward to the Palo Alto-County border, east of Page Mill Road. However, the initial
CMR:394:00 Page 3 of 6
Stanford AGB proposal also included the entire 154-acre Lathrop property, located south
of Junipero Serra Boulevard, within the AGB, despite the City’s strong recommendation
that the AGB exclude all of Stanford’s open space land south of Junipero Serra. The
County’s August 2000 draft Community Plan revised the AGB so that only a portion of
Lathrop was included in the AGB, but, like Stanford’s earlier iteration, it also included
the southern portion of the Stable Site (Stanford Golf Course Hole # 1) within the AGB.
At present, both a portion of Lathrop, which appears to be reconfigured from the August
2000 Community Plan, and Hole #1 remain within the proposed AGB. Staff still believes
that the proposed Stanford AGB should be re-positioned so that it is coterminous with the
City’s Urban Growth Boundary and Urban Service Area, thus placing both Lathrop, in its
entirety, and Hole # 1 outside Of the boundary. Lathrop contains a low level of existing
development, but the site is overwhelmingly "undeveloped" in nature. And, like the rest
of Stanford’s lands south of Junipero Serra, the City believes it is essential that these
open space lands be preserved. Therefore, staff considers that the earlier City
recommendation that the AGB exclude the entire Lathrop property should be reiterated.
Even. though the Hole # 1 site is immediately north of Junipero Serra Boulevard, the site is
designated as "Campus Open Space", in the latest draft of the Community Plan. The
Com.munity Plan has been modified to pursue housing construction nearby in order to
preserve Hole #1. Moreover, Hole #1 is located within the California Tiger Salamander
(CTS) Management Zone. Given that Hole #1 is to be preserved as a key element of a
larger recreational, open space resource (the golf course), and given its sensitive location
within the CTS Management Zone, staff still believes that the proposed AGB should be
adjusted to exclude the Hole # 1 site.
Preserving Stanford Golf Course Hole #1 and Providing Housing
The most recent draft of the Community Plan contained a significant change from the
earlier drafts: the elimination of Stanford Golf Course as a potential housing site. As
noted above, the previous drafts of the Community Plan intended to develop faculty and
staff housing on the Hole #1 site. Stanford is now proposing that Hole #1 will be
preserved and that faculty and staff housing will be developed on the existing Driving
Range property instead. Graduate student housing that was earlier proposed for the
Driving Range will be relocated to other sites on-campus. As a result, Stanford
anticipates that it will need to develop additional faculty and staff housing in the vicinity
of Hole #1. Accordingly, it has identified a 13-acre site north of the golf course and
immediately west of the Stable Site where this future housing development could occur.
This 13-acre alternative housing site, however, is affected by the 1997 Sand Hill Road
Development Agreement, which does not allow development on the site until 2021 and
would therefore need to be modified for development to occur.
The City’s recommendation regarding the Hole #i/housing issue has been that Stanford
should seek a solution that would accommodate much-needed on-campus housing but
also maintain Hole #1. Staff believes that Stanford has complied with the City’s
CMR:394:00 Page 4 of 6
recommendation and has found an appropriate solution to both providing housing and
preserving Hole #1. Staff, therefore, recommends that Council direct staff to modify the
Sand Hill Road Development Agreement so that housing could be developed on the
alternative housing site immediately west of the Stable Site.
Housing
As stated in previous correspondence to the County, the City supports the development of
3,000 new housing units within the Academic Growth.Boundary and a linkage policy that
ensures that as academic and other non-residential uses are developed, a proportional
amount of the planned housing is concurrently developed. The City continues to have
concerns regarding the housing development planned for sites along E1 Camino Real and
Stanford Avenue. Any future housing development along E1 Camino Real should be
designed to provide substantial setbacks in order that the existing view corridor will not
be impacted. Housing development along Stanford Avenue should be compatible with
the scale, type and intensity of existing adjacent housing.
Transportation
The City supports the "no net new commute trips" compliance requirement currently
proposed in the Community Plan including monitoring based on actual counts, and
Stanford’s payment of fees for Tier 2 intersection improvements, whether cities use the
fees for intersection improvements or not. If, as development proceeds, these measures
fail to achieve "no net new commute trips", the City recommends an inter-jurisdictional
approach to resolving these traffic problems. Stanford should work with the Cities of
Palo Alto, Menlo Park and East Palo Alto to identify additional mitigation measures to
offset the impacts from any increases in project traffic.
Community Facilities
The City’s consistent stance on the issue of community facilities has been that Stanford
address the impact to jurisdictions affected by Stanford’s anticipated growth and
development as part of the approval of the Community Plan/GUP. In light of the recent
proposal by Stanford to. provide a City community center at the presently undeveloped,
Stanford-owned Mayfield Site, located at the northwest comer of E1 Carnino Real and
Page Mill Road, staff requests that Council provide direction to staff to work with
Stanford to proceed with this proposal to address the City’s community facility needs.
TIMELINE
October 17:
October 18:
October 23:
October 30:
Special Palo Alto Planning and Transportation Commission meeting (if
needed, the meeting will be continued to October 19)
Santa Clara County Planning Commission meeting (evening meeting held
in Palo Alto City Hall).
Palo Alto City Council meeting to finalize the City’s recommendation
Santa Clara County Board of Supervisors meeting (evening meeting held at
County Government Center, 70 W. Hedding Street, San Jose)
CMR:394:00 Page 5 of 6
ATTACHMENTS
Attachment A:
Attachment B:
Attachment C:
Letter dated September 25, 2000, to Anne Draper, Planning Director,
Santa Clara County Planning Office
Letter dated August 7, 2000, to Anne Draper, Planning Director,
Santa Clara County Planning Office
Letter dated October 28, 1999, to Anne Draper, Planning Director,
Santa Clara County Planning Office
Prepared By:Luke Connolly, Senior Planner
DEPARTMENT HEAD REVIEW:
G. EDWARD
Director of Planning and Community Environment
CITY MANAGER APPROVAL:
3ENEST
City Manager
Santa Clara County Planning Office
Stanford University Planning Department
CMR:394:00 Page 6 of 6
City of Palo Alto
Department of Planning and
Community Environment
Attachment A
September 25, 2000
Divisions
Inspection Services
Planning
Transportation
Ms. Anne Draper, Planning Director
Planning Office
County of Santa Clara
70 W. Hedding Street
San Jose, CA 95110
Subject:Stanford Community Plan, Santa Clara County Staff
Recommendation
Dear Ms. Draper:
Thank you for providing the Planning and Community Environment
Department with the opportunity to review the Preliminary Staff
Recommendation for the Stanford University Community Plan (Community
Plan), prepared by your office. The comments in this letter are based on
direction previously given by the City Council and advisory Commissions and
Boards. The Community Plan and the proposed GUP, as well as the Final EIR,.
will again be on the Council agenda in October.
Overall, the City staffis pleased with the Community Plan’s core concepts and
principles and considers this draft a positive step towards the effective planning
of Stanford University’s future development. Importantly, the present City staff
comments are.based on the current draft of the Community Plan and could
change, depending on the contents of the final document. Also, we have not
had the opportunity to review either the proposed conditions for the General
Use Permit (GUP) or the Final EIR for the Community PlardGUP, which will
include a response to the City’s comments on the draft EIR. The City,
therefore, wants to note that its previous comments and recommendations on
the GUP and EIR are not superseded by any contained in this letter. The City’s
latest comments on the Community Plan are described below in relation to the
plan’s individual elements.
250 Hamilton Avenue
P.O. Box 10250
Palo Alto, CA 94303
650.329.2404
650.329.2154 fax
Ms. Anne Draper, Planning Director
September 25, 2000
Page 2
Growth and Development
As indicated through our prior comments, the City strongly supports the
establishment of an Academic Growth Boundary (AGB) for Stanford
University. Additionally, the City is pleased to see that the Community Plan
includes an AGB that is more in accordance with Palo Alto’s existing urban
service area/urban growth boundary (UGB). It is our belief that the AGB, in
conjunction with other land use tools, will foster compact academic
development on the campus and prevent future sprawl into Stanford’s foothill
area south of Junipero Serra Boulevard. Accordingly, the City supports the
inclusion of the AGB described in the Community Plan, but has the following
reservations regarding its location and effectiveness:
The City recommends that the AGB remain in place, without boundary
modifications, for a minimum of 50 years, regardless of the amount of
building square footage that is developed on the Stanfdrd campus. The City
agrees with the stated purposes of the AGB: "to direct all new development
to in-fill sites rather than expansion areas," with "lands outside the AGB
remaining in open space." (Community Plan, page 10). As it stands, the
Community Plan indicates that the AGB is intended to remain in place for
25 years. Given the importance of these objectives, we urge the County to
extend this period to a minimum of 50 years. Fifty years is a reasonable
time frame given the additional development potential of the core campus
area and Stanford’s lands within the City of Palo Alto, because some of
these lands within Palo Alto are currently developed with uses that Stanford
defines as "interim."
The City also believes that it is unwise for the Community Plan to include
provisions that allow the minimum period--whether it is 25 years or 50
years--to be shortened based on the amount of growth occurring at
Stanford. Thus, although the Community Plan states that "It]he County
intends that the AGB will remain in the established location for a period of
at least 25 years," it also expressly allows for adjustment of this boundary
when the building area of academic and support facilities and student
housing reaches 17,300,000 square feet--or, approximately 5,000,000
additional square feet within these categories. (Community Plan, page 12).
Although the Community Plan projects that 25 years will be Sufficient to
accommodate this amount of additional space at historic growth rates, it also
acknowledges that in just the next 10 of those 25 years Stanford has
requested authority through the GUP to develop 70% of this added space.
Ms. Anne Draper, Planning Director
September 25, 2000
Page 3
The City believes that so long as there is a square footage threshold for
adjustments, the observance of a minimum time period for the AGB will be
illusory. It is vital to the integrity of the AGB that it be de-coupled from
any square footage threshold or "trigger’; for modification. Otherwise,
Stanford will have little incentive to plan development in conformity with
the AGB, but will operate, rather, on the principle that the AGB can be
adjusted when it reaches a certain square footage, regardless of how much
sooner that may occur than the projections in the Community Plan.
The City believes that additional levels of protection should be incorporated
into the AGB concept. As described in the Community Plan, the AGB is
intended to provide long-term protection for Stanford’s foothill areas.
However, even if the minimum period of time that the AGB is intended to
remain in place is extended from 25 to 50 years and square footage
thresholds are eliminated, as Palo Alto has proposed, the Community Plan
would still lack assurances that the AGB would remain intact for this period
of time, since the AGB would still be subject to modification at any time.
The use of open space preservation mechanisms, such as preservation
easements, would strengthen the effectiveness of the AGB in precluding
development in the foothills. This is crucial, because of their importance as
a viewshed, habitat, and open space.
The City believes that Stanford’s AGB and Palo Alto’s UGB should be
coterminous; therefore, both parties should agree to reconcile discrepancies
along these boundaries. Community Plan, Figure 1.3 depicts a proposed
AGB for Stanford that expands Palo Alto’s UGB in two adjacent areas: 1)
the northem portion of the "Lathrop" site south of Junipero Serra Boulevard
and, 2) the southern portion of the stable site north of Junipero Serra
Boulevard (including Stanford Golf Course Hole # 1). The City does not
support an expansion of its UGB at this time. Also, as consistently
indicated by our previous comments, the City does not support
academic/urban-type growth on any portion of Stanford’s lands south of
Junipero Serra Boulevard, including "Lathrop." In addition, the City does
not support changing the AGB to include the stable site at this time.
However, the City understands the desire to use a portion of the stable site
to provide housing in the future, but encourages further study, prior to any
boundary change, that shows how housing can be integrated into the site
while preserving Hole # 1 of the Golf Course. The further study should also
Ms. Anne Draper, Planning Director
September 25, 2000
Page 4
identify and take into consideration the environmental and wildlife value of
the existing golf course.
It is important that the Community Nan recognize the desirability that these
two growth boundaries remain coterminous. Palo Alto requests that an
additional policy be added to the "Growth and Development" element of the
Community Plan to this effect. This could be done with language similar to
the following: "It is the intent of this Community Plan, that to the
maximum extent practicable, the AGB be coterminous with the Urban
Growth Boundary (UGB) identified in the City of Palo Alto’s Community
Plan. Therefore, Stanford should coordinate with Palo Alto any proposals
for changes in the AGB or UGB to that end."
As noted in the preceding comments, the City does not support the
designating of a portion of the Lathrop area as appropriate for academic or
urban-type development. Page 31 of the Community Plan states that the
positioning of the AGB is based on the location of"existing developed
areas." However, the proposed AGB includes a portion of the "Lathrop"
property, which is located on the southerly side of Junipero Serra
Boulevard. Given the entire 154-acre area of the Lathrop property, the.
approximately 45,000 square feet of existing development on the property
results in a very low floor-area-ratio (FAR) of .007, not indicative of a
"developed area." The existing FAR for the academic campus is .21, thirty
times greater than the "Lathrop" area and more typical of a developed area.
Moreover, Junipero Serra creates an easily identifiable boundary between
Stanford’s campus and the foothill area, and adjusting the AGB to reflect
this would not impact the development that already exists on the "Lathrop"
property since it could be maintained but not expanded through language in
the Community Plan.
In conjunction with the proposed AGB concept, the "Growth and
Development" element should include development policies that explain
how compact, transit-oriented development would be achieved within the
AGB. While the City agrees that the AGB will be a principal mechanism
in preventing the sprawl of Stanford’s academic development, it alone
cannot ensure that what gets built within the core campus area will adhere
to compact development principles that maximize the use of a site and
allow for a promotion of transit, pedestrian and bicycle usage. At present,
the Stanford campus has a significant number of under-utilized sites (e.g.,
Ms. Anne Draperl Planning Director
September 25, 2000
Page 5
surface-level parking lots, single-story buildings) that should be
redeveloped and intensified through the pending GUP. The Community
Plan should, therefore, include policies that promote the most efficient use
of Stanford land within the AGB and the County should create zoning
districts in accordance with these policies that will implement them. One
possibility would be the development, in the future, of a zoning district
more suited to this use than the existing County "AI" zOning.
The Community Plan should be revised to include development standards
that preserve the existing landscape buffer along E1 Camino Real.
Presently all of Stanford’s land along E1 Camino Real, between the
Shopping Center and Stanford Avenue, is included in Special Limitation
Area A. Area A was established by the 1985 Three-Party Land Use Policy
Agreement (Agreement)and associated Protocol between Stanford, Santa
Clara County and the City of Palo Alto. Pages 6 and 7 of the Community
Plan acknowledge that the Agreement will be maintained and enhanced,
but the Plan fails to point out that the Agreement does not allow
development in Area A, except through the approval of a separate use
permit that is distinct from the GUP entitlement. The Community Plan
proposes two housing sites ("D" and "I") within Area A and also
designates over half of E1 Camino Real’s frontage as "Academic Campus."
These designations would allow for a significant level of development in
this area that the City cannot support given the Community Plan’s absence
of development standards that would maintain this area as a landscaped
setback and buffer between Stanford University and the City of Palo Alto.
Land Use
The City is generally supportive of the proposed land use designations
described in the "Land Use" element of the Community Plan and shown in
Figure 2.2. In particular, the City supports the proposed re-designation of the
majority of Stanford’s foothill property, located southwest of Junipero Serra
Boulevard, from the existing "Academic Reserve and Open Space" to the
newly-created "Open Space and Field Research" and "Special Conservation"
designations. We do, however, have additional comments and
recommendations. They are as follows:
In accordance with our comments concerning the AGB, the City believes
that the portion of the Lathrop property proposed for designation as
"Academic Campus" in Figure 2.2 (page 23) of the Community Plan,
Ms. Anne Draper, Planning Director
September 25, 2000
Page 6
should be re-designated to either "Open Space/Field Research" or "Special
Conservation." At a minimum, the area should be designated as "Open
Space and Field Research." As noted, Stanford’s property south of
Junipero Serra Boulevard is predominately undeveloped and is
characterized by open space and foothills worthy of long-term, or
permanent, preservation. By designating even a portion of"Lathrop" as
"Academic Campus," the Community Plan would expand the recognized
area of Stanford’s campus, potentially .intensify the allowable use of the
site, and undermine the intent of the AGB to "promote compact
development" on the academic campus. Moreover, it would be appropriate
to consider to designation of this area as "Special Conservation." This
portion of the "Lathrop" property is proximately located to Lake Lagunita,
which is the area’s primary California Tiger Salamander habitat, and is,
accordingly, included in the California Tiger Salamander Management
Zone shown in Figure 6.1 of the Community Plan.
The City supports the proposed Community Plan Development Policy
"SCP-LU 28," that would allow the use, maintenance and preservation of
the existing portion (11 holes) of the Stanford Golf Course south of
Junipero Serra Boulevard. The City would not, however, support an
expansion of the golf course, or any other use that is not consistent with the
proposed "Open Space and Field Research" or "Special Conservation
Area" designations, in this vicinity.
The City believes that the Community Plan should be specifically amended
to require. Stanford to pay impact fees for impacts to community facilities,
such as libraries, parks and recreation centers, located in adjacent cities that
are used by Stanford residents. The City of Palo Alto conservatively
estimates that Stanford residents account for five-percent (higher for
libraries) of its community facilities usage. The new development
authorized through the GUP process will increase these burdens and
directly impact the quality of the environment of the City of Palo Alto and
other neighboring cities. The Community Plan should require that
development authorized through the GUP will be required to mitigate these
impacts through mitigation fee programs, provided that the affected
jurisdictions establish programs and standards for applying such fees. In
return, the staff would recommend that Palo Alto reciprocate appropriately,
for example, by treating Stanford residents in a like manner as Palo Alto
Ms. Anne Draper, Planning Director
September 25, 2000
Page 7
residents in that "non-resident" fees that presently exist, and are paid by
Stanford residents, would be waived.
Housing
The City has consistently expressed its support for Stanford’s intent to add over
3,000 housing units to its campus through the proposed GUP/Community Plan
and wishes to reiterate its support again. Additionally, the City has the
following specific comments based on the current draft of the Community Plan:
The discussion of Stanford’s jobs/housing balance on pages 34 and 35 of the
Community Plan should be revised to include all Stanford land that is
subject to the 1985 Three-Party Land Use Policy Agreement. Under the
Agreement, Stanford locates its profit-making, non-academic uses in Palo
Alto, and its academic, open space and agricultural uses in unincorporated
Santa Clara County. Therefore, any meaningful analysis of Stanford’s
provision of jobs and housing in the area must look at Stanford lands in the
County and the City of Palo Alto. For example, immediately adjacent to
Stanford’s campus, within Palo Alto, are the Stanford Research Park and the
Stanford Shopping Center. The Research Park contains approximately 150
employers in over 10 million square feet of office-research and development
buildings, and the Shopping Center over 1.3 million square feet of retail
floor space. Combined, these two Stanford-owned sites are major
employers and the Community Plan text should acknowledge their
relationship to the area’s jobs/housing balance.
The "linkage policy," described in the "Housing Element" of the proposed
Community Plan, must be maintained and strengthened as part of the
approval of the proposed GUP. Given Stanford’s existing housing
shortage, it is vital that the Community Plan and GUP require construction
of needed housing prior to, or concurrently with, approval for increases in
academic space as proposed in staff’s recommended Policy "SCP-H 7" on
page 46 of the Community Plan. The City also agrees that at a minimum
Stanford should be required to construct 1,510 dwelling units available to
students, staff and faculty within the first six years of GUP approval as
proposed in Policy "SCP-H(i) 4." This is only half of the total housing that
Stanford is proposing through the GUP and is a reasonable requirement that
is fully supported by the City. However, the City believes that it is
important that the requirement of linkage in "SCP-H 7" be carried forward
fully in the implementation so that it is not limited to this initial six-year
Ms. Anne Draper, Planning Director
September 25, 2000
Page 8
commitment. Rather, Policy "SCP-H(i) 5" should be reworded as follows:
"Require through the General Use Permit that approvals for development
(based on building square footage) be conditioned on the prior or
concurrent construction of residential development (based on number of
dwelling units) at the same rate of development as the academic space".
The City recognizes the need for some flexibility in this determination, and
the County could alter the suggested language to provide that the rate of
development of the residential space be "roughly proportional" to the rate
of development of the academic space.
The City supports the Community Plan’s emphasis on providing and
maintaining rental housing’ for faculty and staff as a means of increasing
affordable housing opportunities. Additionally, the City recommends that
Policy "SCP-LU 2" be revised to expressly allow the inclusion of faculty
and staffhousing within the "Academic Campus" land use designation.
The City recommends that on-campus housing eligibility and affordable
housing assistance be extended to service workers and support staff who
will be directly attracted to the Stanford campus through its anticipated
growth. The City supports the intent of proposed Community Plan Policy
"SCP-H 12(b)," which states that housing assistance and on-campus
residence eligibility would be extended to "populations which have
previously not been served." In order to achieve this, the City believes that
the County should require Stanford to institute an affordable housing
(below market rate) program to assist service workers and others who
would be attracted to the University through the approval of the GUP and
its resulting development. As an alternative or supplement to an on-campus
housing program, the County should ’require Stanford to pay such fees to
adjacent cities, such as Palo Alto and Menlo Park, which have existing
programs. This would ensure the provision of affordable housing in close
proximity to Stanford for those attracted directly to the University by its
growth.
The City supports the proposed Community Plan goal (page 50) of adopting
zoning consistent with Santa Clara County General Plan designations for
campus residential areas. The City believes this should be a high priority
for Stanford and the County so that development standards could be built-in
to the zoning ensuring compatibility with existing residentia!
neighborhoods within and adjacent to the campus. Moreover, the City
Ms. Anne Draper, Planning Director
September 25, 2000
Page 9
suggests that the Community Plan allow for the consideration of future
development of zoning for Stanford’s academic campus and open space
areas that is reflective of the land use designations proposed in the
Community Plan.
The City does not support the development of housing for Housing Sites
"D" and "I," shown in Figure 3.1 of the Community Plan. While the City
fully supports the construction of the amount of proposed housing under the
Community Plan/GUP, these sites, located in Special Limitation Area A,
along E1 Camino Real, are not appropriate to accommodate the significant
levels of dwellings that are proposed. This is especially true of the four-
acre site "D," which is located along a very narrow strip of property located
at the northwest corner of El Camino Real and Stanford Avenue and,
according to the Community Plan, would contain dwellings for 250
graduate students.
Circulation
The City has already provided extensive comments to the County on the issues
of Stanford’s circulation and parking, particularly through its comments on the
draft EIR (see July 24, 2000 Transportation Division Memorandum, entitled
"GUP Mitigations") for the Community Plan and GUP. Accordingly, the City
is pleased to see that the latest draft of the Community Plan recommends that
the "no net new commute trips" policy, initiated through the 1989 GUP, be
maintained. Moreover, the City is in complete concurrence with proposed
Community Plan Policy "SCP-C 1," which states that the no net new commute
trips standard should be applied to the "fullest extent allowed by law." The
City has the following additional comments regarding circulation:
Regarding the no net new commute trips standard, the City wants to
reiterate its earlier concern that independent monitoring and enforcement
of the standard are vital to its effectiveness. While the Community Plan
acknowledges the importance of monitoring, it is not clear what, if
anything, would occur if Stanford failed to meet the policy, other than
"system expansion" (i.e., intersection and street widenings). The City
recognizes that roadway modifications are anticipated as one measure to
accommodate the extensive level of growth proposed by Stanford.
However, such measures should be considered only where absolutely
necessary and should not be undertaken in lieu of complying with the no
net new commute trips standard.
Ms. Anne Draper, Planning Director
September 25, 2000
Page 10
The City supports the proposed TDM monitoring for no net new commute
trips with the inclusion of three compliance requirements. One, all
potentially impacted intersections will be monitored annually. Two, if the
no net new commute trips threshold is exceeded in either the AM or PM
peak commute period for any two years (not necessarily consecutive),
Stanford will make payment of fair-share mitigation for all Tier 2
intersection improvements (these were identified in the draft EIR) not
already funded. Three, should a third year of failure to meet the no-net new
commute trips goal requirement occur, no additional development
permitted under the GUP will be granted approvals by the County.
Reinstatement of development rights would be established once successful
compliance with the no net new commute trips standard had been achieved
in two consecutive years.
Stanford should develop and implement ~an Integrated Transportation
Management Plan, for all of its land holdings, as a component of the
currently proposed Community Plan/GUP to address impacts on City streets
from increased traffic congestion during the non-peak commute hours. As
described in the Community Plan, Stanford is a unique entity, in that it owns
nearly 13 square miles of contiguous land in six jurisdictions that is devoted
to a wide range of land uses (i.e., academic campus, office-research park,
shopping center, medical center). As a result, Stanford has an opportunity
to employ unique transportation management methods, such as the
development and implementation of an Integrated Transportation
Management Plan, to address the transportation impacts resulting from the
Community Plan. The Integrated Transportation Management Plan should
be developed in cooperation with neighboring jurisdictions and provide for
efficient integration and optimal use of various transportation modes,
including private vehicles, bus and rail transport, and bicycle and pedestrian
transportation. In particular, a joint City-Stanford Marguerite shuttle
program should developed that would allow an expanded service throughout
the area. The specifics of such a plan were conveyed by the City to Santa
Clara County through Palo Alto’s August 7, 2000 letter (and accompanying
Transportation Division Memorandum) on the draft EIR. The City also
wants to state that it is encouraged by the Community Plan’s emphasis on
TDM measures and its recognition that Stanford’s campus is not
autonomous from its other operations (i.e., housing adjacent to the medical
center will reduce vehicle trips).
Ms. Anne Draper, Planning Director
September 25, 2000
Page 11
Open Space
Many of the City’s concerns regarding open space preservation are discussed
under the "Growth and Development" and "Land Use" sections, above. The
City also has the following comments regarding the "Open Space" element of
the Community Plan:
The City recognizes that Stanford is the steward of its open space areas and
should be the entity in control of access to such areas. As noted in the
Community Plan, Stanford’s vast, undeveloped areas southwest of Junipero
Serra Boulevard provide critical open space resources to both Stanford
residents and students as well as to residents of surrounding communities.
The Community Plan proposes to re-designate Stanford’s open space lands
to more clearly identify them as such (i.e., "Open Space and Field
Research," "Special Conservation"), but it does not clarify how access to
these lands would be affected. As with most open space areas, there is the
obvious need for Stanford and the County to balance long-term preservation
with on-going recreational use. The City recommends that when limiting
access to certain open space areas, the Community Plan explain why access
is being limited.
The Community Plan should designate all geologically hazardous,
sensitive habitat, and ecological restoration areas as "Special
Conservation" and provide a map describing the significance of all areas so
designated.
As a condition of approval of the Community Plan/GUP, the City
recommends that all derelict, obsolete structures/facilities located in open
space areas south of Junipero Serra Boulevard be identified and, where
appropriate, removed.
The Community Plan should include policies that specifically target
reducing run-off to San Francisquito Creek. The upstream portion of San
Francisquito Creek is on Stanford lands, but as the Community Plan notes,
the cities of Palo Alto, Menlo Park and East Palo Alto are also affected by
development within this watershed. Policies promoting the use of
vegetative swales and pervious materials (particularly along open space area
trails) to limit the amount of run-off should be included in the Community
Plan. Additionally, Stanford should continue to participate with the adjacent
Ms. Anne Draper, Planning Director
September 25, 2000
Page 12
jurisdictions through the Joint Powers Agency to improve habitat quality,
flood control and overall management of the San Francisquito Creek
watershed.
The Planning and Community Environment Department would again like to
thank you for including us in the review process for the Community Plan and
look forward to seeing additional information as it becomes available. We hope
that our comments and recommendations will contribute to the refinement of
the plan and we anticipate making future comments in October in addition to
the staff recommendations made in this letter.
Sincerely,
G. EDWARD GAWF
Director of Planning and
Community Environment
Joe Simitian, Supervisor, Santa Clara County
Palo Alto City Council
Palo Alto Planning and Transportation Commission
Frank Benest, City Manager
Kris Schenk, Community Development, Menlo Park
Cityof Palo Alto
Office of the Mmjor and City Coundl
Attachment B
August 7, 2000
Ms. Anne Draper, Planning Director
Planning Office
County of Santa Clara
70 W. Hedding Street
San Jose, CA 95110
Subject:Comments on the Draft Environmental Impact Report (EIR) for the
Stanford University Community Plan and General Use Permit (GUP)
Dear Ms. Draper:
Thank you for the opportunity to review and comment on the Draft EIR for the Stanford
University Community Plan/GUP. Overall, the City believes the EIR is a well-prepared,
informative document. However, the City hopes that through the inclusion of its
comments, the Final EIR will better enable decision-makers to fully understand the scope
of the proposal not only for Stanford but also for surrounding communities, like Palo
Alto.
In the month of July, the City of Palo Alto held three public meetings regarding the EIR,
resulting in the City Council recommendations and comments that are described, by topic,
below. In addition to these recommendations, memorandums from the City’s Public
Works Department and .Transportation Division are attached with more detailed
comments in their respective areas. ~-
Open Space Preservation
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 of Junipero Serra Boulevard. The EIR should specifically address
what the impacts to open space would be if it is not permanently protected, as well as
what the benefits would be if open space is permanently preserved. 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
P.O. Box 10250
Palo Alto, CA 9’4303
415.329.24/7
415.328.3631 Fax
Ms. Anne Draper, Planning Director
August 7, 2000
Page 2
conservation of the foothiil open space areas must be linked to the substantial amount
of development being proposed.
As described in the EIR, the proposed Stanford University Community Plan/GUP are
inconsistent with the City ofPalo Alto’s adopted Urban Growth Boundary; the City’s
Urban Growth Boundary is discussed in Policy L-1 and shown in Map L-2 of the
Palo Alto Comprehensive Plan. Additionally, the proposed Community Plan/GUP
are inconsistent with existing Santa Clara County General Plan Policies C-GD-19
through C-G-22, which pertain to Urban Growth Boundaries within the County of
Santa Clara.
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. Further, the "Open Space" designation
should include a description of allowable uses and intensities of development that
would be allowed.
The EIR should include a discussion of the existing or proposed access to all open
space or conservation areas on Stanford lands. Analysis of open space access should
focus on how intensification of use could impact open space, and should also address
how implementation of the project could lead to further exclusion of public access to
areas that have historically been used for open space purposes.
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.
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
Ms. Anne Draper, Planning Director
August 7, 2000
Page 3
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 the Jasper Ridge Biological Preserve in San Mateo County.
Since the Community Plan is long-term in nature, the EIR should discuss open space
protection methods and development ideals that are equally .long-term in viewpoint.
For instance, the EIR should examine the placement of a"’green belt" around the
campus that would identify the University’s long-term vision of academic build-out.
Project Alternatives
The EIR should provide and discuss an alternative development plan showing an
Academic Growth Boundary (Figure 7-1 of the DEIR) that is coterminous with the
City ofPalo Alto’s urban growth boundary/urban service area. In revising Figure 7-
1, Palo Alto’s existing urban growth boundary/urban service area should be
illustrated on the southern portion of the map (Coyote Hill area) as well as on the
northern portion (San Francisquito Creek).
The EIR should analyze an alternative that would avoid impacts to, and preserve,
intact, the Stanford Golf Course. The EIR should also include a discussion of the
golf course’s value as a cultural resource, recreational open space and habitat for a
variety of native fauna and flora. It also seems likely that the housing proposed in
the area of Hole # 1 could be constructed in a manner that would integrate it into the
existing fabric of the golf course rather than supplanting portions of the existing
course.
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 all--and
ignores differences in degree. Moreover~ it seems likely that a 50 percent reduction
in development would be environmentall.y s__u_per__zig_Lgiven the scale_o_f_th_e__pr_o_j_e_c_t.
The EIR should include a Reduced Project Alternative that reduces the amount of
proposed academic development (i.e., 1 million square feet instead of 2 million
square feet) but does not reduce the amount of proposed housing. Given the housing
Ms. Anne Draper, Planning Director
August 7, 2000
Page 4
deficit that Stanford presently has, it appears that a significant portion of the
proposed 3,000 dwelling units is needed to address the existing shortfall.
The EIR should provide an alternative that focuses on reducing the impact of the
proposed development, while not necessarily reducing the amount of square footage
or number dwelling units being sought. This alternative should discuss the benefits
and/or lessened environmental impacts that would occur through the implementation
of more compact development patterns (i.e., "clustering") and the intensification of
under-utilized (i.e., surface parking lots, single-story buildings) sites in the core
campus. Additionally, a discussion of more compact development patterns should
include information regarding lessened impacts to the area’s transportation system
since this development pattern would be more transit-, pedestrian- and bicycle-
friendly.
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-1, 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. The boundary of the urban service area is otherwise known as the
urban growth boundary [see comments under "Open Space Preservation"]. 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, i.e., on the Lathrop property, the conclusion of consistency with the
Cityls Comprehensive Plan is not supported.
By continuing to prepare separate environmental documents for on-going
development projects, whose processing overlaps with the Community Plan/GUP
EIR and approval process, the County makes it difficult for the public to understand
-the3mpa-ctg-ofall-pfo)og~d-d~velo)-merit fof Stanfo~d’s-l~rfds. 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
Ms. Anne Draper, Planning Director
August 7, 2000
Page 5
Community Plan/GLIP, the City strongly believes that 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 Community PlargGUP proposal. Or, if not included, the Community PlargGUP
EIR should clearly specify that the 20,000 square feet of development proposed on the
Lathrop property, located southwest of Junipero Serra Boulevard, is not describing the
Carnegie Foundation project. The City recognizes 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 PlargGUP for the
Lathrop area is in fact describing the Carnegie project, which is nearly identical in
area and would be developed on the same parcel.
The EIR should include information and a discussion regarding all of Stanford’s
extensive land holdings. Even though the EIR is focused on Stanford’s
unincorporated Santa Clara County land, Stanford’s property is contiguous and it is,
therefore, vital that it be treated as a single entity. The EIR should, accordingly,
provide more detailed information about Stanford’s levels of existing and proposed
development for all its property, regardless of jurisdiction.
The EIR should include more detailed definitions of the proposed land use
designations included in the Community PlargGUP and indicated in Figures 4.2-4 and
4.2-5. It should be clear what uses and levels of development would be allowed under
each land use designation. Also, it is ~ritical that the EIR describe what is meant by
the term "Academic. Growth Boundary" and by what process such a boundary could
be altered in the future. It is the City’s view that the Academic Growth Boundary
should define the area in which urban levels of development could occur, and that
such a boundary should not merely be a "line on a map," that is easily changed to
accommodate future development. The City further believes that the Academic
Growth Boundary should be kept in place, coterminous with the City’s urban growth
boundary, for the maximum period of time permitted by County regulations.
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.
Ms. Anne Draper, Planning Director
August 7, 2000
Page 6
Language in the Plan/GUP itself indicates otherwise.
clarified.
This inconsistency should be
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 project-specific
environmental documents fred 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 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.
The EIR should further discuss the "standard employment multiplier," referred to on
pages 5.4 and 5.5, and how it is used to determine the overall growth-induced impact
of the Community Plan/GUP.
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 siguificantly increased need for
additional affordable housing, especially in regard to service personnel who would be
attracted to the area by the additional growth but would have limited affordable
housing opportunities in the Stanford-Palo Alto-Menlo Park area. 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 employment
multiplier" is used. 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 discuss the lessened environmental impacts or potential benefit that
would result through assurances of affordable housing being provided either on-
campus or in the immediate vicinity of the campus. These lessened impacts would
include reduced vehicle trips to/from the campus from outside areas.
Ms. Anne Draper, Planning Director
August 7, 2000
Page 7
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 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
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 would 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.
The EIR should provide information regarding Stanford’s existing impacts to the
PAUSD school system. At a minimum, the EIR should state how many students
Stanford contributes to the District at present and how many would be added through
the proposed build-out of the project.
Potential additional options are outlined on pages 4.10-8 and 4. I0-9 oftheEIR and
include the possibilities of constructing a third middle school on Stanford land, re-
opening closed schools, or modifying existing schools. The City of Palo Alto strongly
Ms. Anne Draper, Planning Director
August 7, 2000
Page 8
believes Stanford must be involved in the discussion and eventuaI implementation of
additional options for addressing school impacts.
The EIR: should provide a more viable alternative school site--one more proximately
located to existing Palo Alto neighborhoods--than the one shown in Figure 7-6. The
EIR also needs to address the impacts of the alternatives described on pages 4-10-8
and 4-10-9 that would lead to reclaiming school sites and displacing existing City
community centers. The recommendation from Stanford that PAUSD could use
property now devoted to Terman and Cubberley Community Centers would
potentially reduce the amount of land devoted to City community centers, services and
facilities. The City believes this reduction in land devoted to community facilities
constitutes a direct environmental impact that should be addressed in the EIR.
Moreover, the potential loss of community facilities is inconsistent with several Palo
Alto Comprehensive Plan policies and goals described in its "Community Services
and Facilities" element, particularly Policy C-29: "Strategically locate public
facilities...to serve all neighborhoods in the City."
Related to the preceding recommendation, if a viable school site within the City of
Palo Alto’s urban service area/urban growth boundary is not included in the EIR, and
the City must surrender existing community center facilities for the purpose of a new
school in order to accommodate Stanford growth, Stanford must pay their fair share of
acquisition costs to mitigate the direct impact of their growth on Palo Alto community
centers. Stanford’s contribution should close the gap between the fair market value of
a new community center site and the unmet cost after City and School contributions
have been made.
The cumulative impacts to schools and community services facilities from the
anticipated 10-year residential and employment growth of both City of Palo Alto and
Stanford, using the latest available demographic information, has not been provided
in the EIR. The impacts from the recommended PAUSD/Stanford conversion of
community facilities to schools are in addition, and therefore cumulative, to the
impacts created from Stanford’s proposed growth, the City’s proposed growth, and
overall demographic turnover. Previously-prepared EIRs for the City’s
Comprehensive Plan and the Sand Hill Road projects used lower demographic
projections and growth assumptions than what actually occurred. In light of this, the
EIR needs to provide up-to-date, realistic information that better reflects the level of
population growth that is anticipated.
Ms. Anne Draper, Planning Director
August 7, 2000
Page 9
Circulation and Parking
The EIR identifies various transportation measures to mitigate traffic impacts. These
measure~ need to be placed into a more comprehensive context. Therefore, Stanford
should prepare an integrated transportation plan (see attached memorandum from the
City’s Transportation Division for more detailed EIR and project recommendations)
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 altemative
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 City believes it is imperative that proposed GUP maintain the "no new net
commute trips" standard included in the 1989 GUP. Additionally, the EIR must
discuss how independent monitoring of Stanford’s vehicle trip contribution to the Palo
Alto street system would be done; and, importantly, if monitoring determines that
traffic levels have exceeded identified thresholds the EIR must describe what
mechanisms would then be used to reduce vehicle trips or their impacts to acceptable
levels.
In conjunction with comments made above under "Land Use and Development," the
EIR should discuss the lessened transportation impacts, or potential benefits, that
could~e derived from more compact development patterns on the core campus, such
as increased use of parking structures in lieu of surface-level parking facilities.
The EIR must address the impacts to the Palo Alto street network that would occur
due to increased truck-traffic related to construction activities that would result from
Ms. Anne Draper, Planning Director
August 7, 2000
Page 10
the significant amount of development proposed under the GUP/Community Plan.
The EIR list of traffic mitigation measures includes evaluation of several intersection
widenirigs. 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 poter~tial 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.
Stanford should consider market-based measures to manage parking demand, such as
implementation of parking prices that reflect the costs of b.oth 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
Ms. Anne Draper, Planning Director
August 7, 2000
Page 11
trip generation from these off-campus units, but with a new trip distribution. These
backfill trips should be included in the EIR traffic analysis.
As prevlously stated, the 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 standpoint 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.
Storm Water Run-Off/Flooding
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, 6-hour standard, since mitigation measures
designed for the 100-year event would not necessarily mean that increased run-off
would 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, perviouspavement, reduced building footprints).
The EIR should include an expanded discussion of water quality impacts. For
instance, copper is a significant contributor to water quality impacts and much of this
Ms. Anne Draper, Planning Director
August 7, 2000
Page 12
is a result of copper’s use in brake pads and building materials (i.e., roofing). Since
the project would involve both increased vehicle trips (more brake pad wear) and
new building construction, the EIR should address the potential water quality
impactg that could occur.
Biological Resources
Option 2 regarding the California Tiger Salamander should be incorporated into the
project since it is superior from an environmental standpoint in that it avoids a
significant impact to the species and its habitat. Moreover, the EIR should examine a
"no-build" option on the Lathrop property that could potentially reduce impacts to the
California Tiger Salamander to an even greater extent.
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.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 existing 1989 GUP includes a provision that annual development reports should
be prepared documenting the development that has occurred during the year. The
City supports a continuation of the reporting process under the proposed GUP and
believes that the EIR should indicate whether the annual reporting process would
continue under the proposed GUP.
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 pro,
Monday through Saturday. Reduction in construction hours and elimination of
Ms. Anne Draper, Planning Director
August 7, 2000
Page 13
Saturday construction may eliminate or lessen significant construction noise impacts
on adjacent residential areas.
Given the considerable scale and complexstaging oftheGUP/Community Plan, the
EIR should discuss the resources (i.e., staffing) Santa Clara County would have in
place to adequately monitor and enforce the all of the proposed development.
Thank you again for providing us with the opportunity to comment on this EIR and we
look forward to working with you on the finalization of this document in the coming
months.
Sincerely,
[SS
Mayor
Attachments:
Public Works memorandum, dated July 24, 2000
Transportation Division memorandum, dated July 24, 2000
Public Works Department
Engineering Division
Date:July 24, 2000
To:
From:
Luke Connolly, Planning
Joe Teresi (x2129)~v<e-- ~ "
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 atributary 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-yea.r rainfall total arid 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).
3.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 de.veloped campus area dra.ins 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 runoffwill have adverse
impacts on the City’s storm drain system. The fact that project mitigations will ensure that
.....tl~r.e-_~ --lab_e_~ ~ ~ ~ ~ tlll:~ ~kruzao -If~-~~year-ste rm_g~ -tan.e_e_eis a r_it y
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 smalIer storms.
The EIR should be amended to include an analysis of the impacts of the proposed
¯ development on the peak runoff rate from the 10-year, six-hour storm event.
Comments on Stanford Use Plan
July 24, 2000
Page 2
4. Runoff from portiois of the deveIoped 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 nature1 drainage course and
storm drain system that traverses the College Terrace neighborhood in PaIo 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 mnnff may
exacerbate this. flooding threat. Portions of the campus drain into a Caltrans/City storm
drain th£t rum south along E1 cam~no 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 Charmel,
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 dr.ainage 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 d.esign features include the following:
Directing roof and parking lot drainage into vegetated swales
Elimination of "directly connected impervious areas" by breaking up drainage paths
wi~a-tandscaping-or-other-p-erv~us-are a s
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
foot-prints
Clustering of development to minimize 1and 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 ErR 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 ErR sections on groundwater and surface water quality impacts discusses the
preparation of Storm Water Pollution Prevention Plans (SW-PPP) and the use of Best
Management Practices as a mitigation measure only in the context of compliance with the
State of California GeneraPermit for Discharges of Storm Water Associated with
Construction Activities. The ErR 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 controI 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 UP, MP is a plan to review and control the water quality impacts of new
development.
The ErR 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 ErR’ 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 (’131VfP’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 resuIting 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
de-si-gnated-concrete-washout-areas.
Potential permanent water quaIity 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
plarming 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
gtenciling (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
13MP’so
cc:Glenn Roberts
Kent Steffens
Jim Harrington
TRANSPOR TA TION DIVISION
Memorandum
Date:July 24, 2000
To:Luke Connolly
From:CarI Stoffel (.,5
Subject:GUP Mitigations
The City supports the following transportation mitigations for the GUP:
"No net new colmnute trips" (DEIR Mitigation TR-5B) and "Cooperative trip
reduction" (Mitigation TK-5C) should be the primary mitigation measures for
intersection impacts on major rohds.
Tier I intersection improvements (Mitigation TR-5A) should be implemented. These
are Arboretun’KPalm and Welch/Campus Drive West, both of which are Stanford
cmnpus 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 alternate improvement is
equal or better. Specifically, we support the option of a modem roundabout at
ArboretumYPalm, if so desired by Stanford.
Generally, Palo Alto does not support Tid~ 2 .intersection projects, with the following
exceptions:
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
approvai 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-r --ea~ns-atat e d-e ls e-w-her-e.
For Menlo Park intersections, Menlo Park should determine whether or not it
would like to pursue the improvements and, if so, receive Stanford’s f~ir 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 aI1 traffic generated by the
campus area, whether or not it is related to the new GUP development.
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 armually.
Stanford’s failure to meet the "no net new commute trips" requirement by any
amount in either the AM or PM peak hour for any two years (i.e., not
necessarily consecutive) wil! 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.
"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.
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 construction 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 Pa!o
Alto or the County.
GUP Mitigations
July 24, 2000
Page 3 of 6
(i)
(ti)
(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).
Establigh.ment of a transit center for Stanford and Pato 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 MiI1 Expressway.
Sidewalk and/or multiuse path along the north side of Stanford Avenue
between E1 Camino Real and Escondido Road.
(v)planned new pedestr.ian]bicycte undercrossing of Alma and Caltrain
tracks at California Avenue. This undercrossing would be part of the
proposed StanfordiPalo Alto Bay to Foothills trail in which Stanford
may participate as part of the GUP.
(vi)Planned new pedestrian/bicycle undercrossing of the Caltrain tracks at
Homer Avenue. This undercrossing would link pedestrian and bicycle
traffic to the Stanford campus ~,ia 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).
(vii)Construction of a pedestrian/bicycle path in the Stanford arboretum area
between the PAMF/ECR traffic signal and the ArboretutrFPalm
intersection.
(viii) 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.
(ix) 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 proj ect.
The impact of the GUP extends beyond the peak hour impacts specifically identified
in the DEIR. These impacts are increased traffic congestion and impacts during
the non-peak hours on major 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"
OUP Mitigations
July 24, 2000
Page 5 of 6
ATTACHMENT
An Integrated Transpo.rtation 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 dynmnic. Prospective
changes in the region’s transportation system over the next five to ten years include:
Doubling of Caitrain 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 Pal0 Alto’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 m.anagement efforts in Palo Alto
Potentia! transportation system changes in the ten- to twenty-year horizon include:
Inauguration of high-speed railpassenger 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 ~nd 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 punic
transport, bicycle and pedestrian transportation. The integrated transportation plan should have
GUP Mitigations
7uly 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 System
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,
City of Palo Alto
Office of the Mayor and City Co,moil
October 28, 1999 Attachment C
Ms. Anne Draper, Planning Director
Planning Office
County of Santa Clara
70 W. Hedding Street
San Jose, CA 95110
Subject:Draft Stanford University Community Plan and General Use Permit
Dear Ms: 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, desd.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 of Junipero 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 "Plan," below, unless
otherwise 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 development 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~~ the general 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
415.329.2477
415.328.3631 Fax
Ms. Anne Draper, Planning Director
October 28, 1999
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 g0al of maintaining the existing amount of
open space, but recommend.s that a distinct open space land use 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 applied to lands
intended for long-term open space uses.
The proposed limitation of a 20,000-square-foot maximum (5,000-square-foot
maximum per building) development exception west of Junipero Serra Boulevard
appears reasonable so long as it is subject to further City review when specific
proposals are submitted. This exception, however, should be included in the Plan.
Any future land use changes that will 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 and 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 related to the creation of additional housing, such as parks
and schools, should be provided. ~,:
Ms. Anne Draper, Planning Director
October 28, ;. 999
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
compatible 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 E1 Camino
Real should not be constructed unless a significant open space buffer can be provided
and maintained along E1 Camino Real.
Housing c’onstruction should be phased to occur early in the 10-year 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-campus lii~using.
Consideration should be given to the need for providing additional affordable housing
for Stanford support staff.
Circulation and Parking
The goal 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 of "no new net commute trips" on adjacent neighborhood streets,
such as in the College Terr~de neighborhood, and mitigate impacts as appropriate.
Ms. Anne Draper, Planning 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
o Provision for a middle school 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 Aii:na Street and E1 Camino Real. These locations should not
include any areas presently used for open space purposes.
Elementary school impacts created by additional faculty and staff family housing
should also be assessed and addressed.
Land 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 building square fo.otage (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 lists allowable numbers of housing units separately ~om
allowable non-residential building area, should include total allowable building square
footage informa~tion 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 both 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 Co .mmunity 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
¯ the Plan, for the ultimate build-out of the University. While it is recognized that this
vision would not be as detailed as the ten-year Plan regarding Stanford’s potential
development, it would be helpful in providing insight into the University’s future
evolution.
Again, thank you for including the City of Palo Alto in the review process for the
Community Plan and GUP. We hope our recommendations and comments are of
assistance.
Mayor