EAST PALO ALTO
CITY COUNCIL
STAFF REPORT
DATE: May 17, 2022
TO: Honorable Mayor and Members of the City Council
VIA: Patrick Heisinger, Interim City Manager
BY: Elena Lee, Planning Manager
Amy Chen, Community & Economic Development Director
SUBJECT: Willow Village Draft Environmental Impact Report (Facebook/Meta Expansion) Recommendation
It is recommended that the City Council, by motion:
1. Receive the staff report regarding the Willow Village Draft Environmental Impact Report (DEIR);
2. Provide staff with direction regarding any proposed amendments or modifications to the attached DEIR comment letter (Attachment 1); and
3. Direct the Interim City Manager to send the attached DEIR comment letter to the City of Menlo Park to serve as the City’s official comments on the Willow Village DEIR.
Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:
Priority No. 2: Enhance Economic Vitality
Priority No. 4: Improve Public Facilities and Infrastructure Priority No. 6: Create a Healthy and Safe Community
Background
The City of Menlo Park is considering a master plan for a 59-acre industrial site located on Willow Road between Hamilton Avenue and Ivy Drive and has released a Draft Environmental Impact Report (DEIR) as required by the California Environmental Quality Act (CEQA) as the lead agency. In addition to the main campus, the project also includes three parcels west of Willow Road, totaling 3.1 acres, for realignment of Hamilton Avenue for improved access.
The project site is located near the western border of East Palo Alto and Menlo Park, adjacent to the Kavanaugh, University Village and Palo Alto Park single family residential neighborhoods. A location map can be found in the attached Notice of Availability (Attachment 3). The project is a multi-phase, mixed use development proposed by Peninsula Innovation Partners, LLC, a subsidiary of Meta Platforms, Inc. The Willow Village Master Plan Project includes demolition of all buildings and landscaping and construction of new buildings, establishment of various open space areas, and installation of infrastructure within a new Residential/Shopping District, Town Square District, and Campus District. Information on the project, including the DEIR and project plans, can be found on the City of Menlo Park project webpage: https://beta.menlopark.org/Government/Departments/CommunityDevelopment/Projects/Under-review/Willow-Village.
The Notice of Preparation (NOP) for this EIR was released for the on September 18, 2019, for a 30- day public review period and a public scoping meeting was held on October 7, 2019.
The City of East Palo Alto provided a scoping comment letter on October 17, 2019 (Attachment 2). The Notice of Availability (NOA) (Attachment 3) for this Draft EIR was released on April 8, 2022 with a 45-day public comment period set from April 8 through May 23, 2022. A public hearing for the Draft EIR was held before the Menlo Park Planning Commission on April 25, 2022.
The proposed project would consist of the following components:
1. Campus district including 1.6 million square feet of office and accessory uses, including meeting/collaboration space (a maximum of up to 1.25 million square feet of offices with balance for accessory uses, inclusive of meeting and collaboration space);
2. Up to 200,000 square feet of retail/non-office commercial uses, including a grocery store, pharmacy services, entertainment and restaurant uses;
3. A grocery store proximate to Willow Road at the intersection with Hamilton Avenue/Main Street;
4. Up to 1,730 multifamily housing units, including 308 below market rate units (260 inclusionary units or 15 percent, plus 48 units per the city’s commercial linkage fee/unit equivalency requirement);
5. A 193-room hotel and associated retail/dining, proximate to the Town Square;
6. A 3.5-acre publicly accessible park (proximate to Willow Road at Park Street), a dog park (in the southeastern portion of the main project site) and additional public open space;
7. A 1.5-acre publicly accessible town square;
8. A 2-acre publicly accessible elevated park extending over Willow Road providing access at the Hamilton Avenue Parcel North (Belle Haven Shopping Center);
9. A publicly-accessible, below grade tunnel for Meta intercampus trams, bicyclists and pedestrians connecting the project with the West and East campuses.
The approval of the proposed project would require the following actions:
1. Environmental Review to analyze potential environmental impacts and certify the EIR as legally compliant with CEQA;
2. General Plan Circulation Element and Zoning Map amendments to modify the locations of the public rights-of-way, new street connections, and paseos within the main project site;
3. Rezone of entire site from O-B (Office Bonus) and R-MU-B (Residential Mixed-Use, Bonus) to O-B(X) (Office Bonus, Conditional Development) and R-MU-B(X) (Residential Mixed-Use Bonus, Conditional Development) to allow for a conditional development permit (CDP) to develop the main project site through the master plan process and establish the development regulations;
4. Conditional Development Permit to develop the proposed project through the master plan provisions outlined in the Zoning Ordinance, utilize the bonus level development allowances (increased height, density, and intensity) in exchange for community amenities, and outline the performance standards, development regulations (including adjustment requests), and project requirements for the implementation of the master plan;
5. Development Agreement for adequate regulations in exchange for vested rights and the provision of specific community amenities;
6. Architectural Control approval of the design of the individual buildings and associated site improvements;
7. Vesting Tentative Map to create new buildable parcels, dedicate public rights-of-way, identify public access easements, site infrastructure, and realign Hamilton Avenue;
8. Heritage Tree Removal Permits to remove 266 heritage trees on the main project site and 3 heritage trees on the Hamilton Avenue Parcels, and plant heritage tree replacements consistent with the City’s code requirements; and
9. Below Market Rate (BMR) Housing Agreement approval for on-site BMR units (inclusionary units and commercial linkage fee units) in accordance with the City’s BMR Ordinance.
Analysis
Due to the proximity of the project site to East Palo Alto, staff reviewed the EIR to analyze any potential impacts on the City. Staff’s concerns have been compiled and included in a Draft EIR comment letter for Council’s consideration. If directed by Council, staff will transmit the letter as the City’s formal response to the Notice of Availability.
East Palo Alto has severe traffic due to a significant increase in growth regionally because East Palo Alto is located within a commute corridor between the East Bay, the Dumbarton Bridge, US 101, as well as job centers such as Menlo Park and Palo Alto. The proposed project would add significant office, commercial and residential square footage, which likely will increase traffic and congestion and other impacts. The project site is also located near three of East Palo Alto’s predominately single-family neighborhoods: Kavanaugh, University Village and Palo Alto Park.
CEQA Overview
An overview of the EIR process is provided in Table 1 below. EIR preparation begins with initial project review, circulation of a Notice of Preparation (NOP) and scoping. Following the NOP, preparation of a Draft EIR commences. Once completed, the Draft EIR is required under State law to be circulated for public review for a minimum of 45 days. This is followed by preparation of a Final EIR, based on comments received during the public DEIR review. The City of Menlo Park would be required to respond to the City of East Palo Alto’s Draft EIR comments in the Final EIR. The Final and Draft EIR document, along with the required project entitlements, would be reviewed prior to any decision on the project. In this case, the Menlo Park City Council must certify the EIR before taking any action on the application.
Table 1: EIR Process Overview
Activity Purpose Public Participation Opportunity
1 Notice of
Preparation
(NOP)
Communicates to the public,
agencies, and organizations an
EIR is being prepared. Also
serves to solicit input on the
scope and content of the
environmental information to be
Public Meeting(s). A scoping
meeting informs the public that the
City is evaluating a project under
CEQA and allows the City to solicit
public comment and identify possible
impacts.
included in the EIR.
2 Draft EIR
(DEIR)
The DEIR is the first iteration of
environmental analyses
collecting the project description,
identification of impacts,
technical studies, mitigation
measures and alternatives
DEIR includes publication of NOP
public comments.
3 Notice of
Availability
(NOA)
An NOA signals that the DEIR is
available for public review and
comment for no less than 45
days. The NOA also identifies
where the DEIR may be
reviewed and how to submit
comments on the DEIR.
Public Comment. The NOA is
typically circulated to nearby
property owners and occupants,
posted at the site, posted on the
city's project website, and filed with
the State Clearinghouse. The public
may submit comments at any time
during the 45- day public comment
period.
Public Hearing. A public meeting is
held to solicit comments from the
Planning Commission and the public
on the Draft EIR during the public
comment period.
4 Final EIR A Final EIR includes responses
to public comments received
after release of the DEIR and
any additional relevant project
information.
FEIR includes comments and
responses to DEIR public
comments.
5 Certification A certification is an official
position taken by the City
Council indicating that the EIR
has complied with CEQA for the
identified project.
Public Hearing. The decisionmaking body certifies the EIR at a Public Hearing with a portion of the
meeting is dedicated to public
comment.
The Willow Village Draft EIR analyzed the following topics:
• Aesthetics
• Air quality
• Biological resources
• Cultural and Tribal cultural resources
• Energy
• Geology and soils
• Greenhouse Gas emissions
• Hazards and hazardous materials
• Land use and planning
• Noise Population and housing
• Public services
• Transportation
• Utilities and service systems
• Hydrology and water quality
This project level Draft EIR tiers off the ConnectMenlo Program EIR, which was prepared for the Menlo Park General Plan Update. The project level Draft EIR will provide the additional analysis not anticipated in the program EIR.
Staff identified specific concerns regarding the analysis in the Draft EIR. The concerns focused upon the following topics:
• Proximity to East Palo Alto Residential Neighborhoods and potential negative impacts on residents
• Proximity to the Ravenswood Priority Development Area and the Ravenswood/Four Corners Specific Plan Update and potential impacts
• Worsening the Jobs Housing Ratio
• Cumulative Impacts
• Aesthetics
• Construction and Air Quality
• Construction and Noise/Vibration impacts
• Population and Housing
• Public Services
• Transportation
• Utilities and Service Systems
• Hydrology
Staff’s detailed concerns are provided in the draft letter, which is included as Attachment 1 to this staff report.
Project Considerations and Concerns
Since its incorporation in 1983, the City has struggled to achieve economic growth and financial sustainability, especially in comparison to other nearby communities. To address this reality, the City’s leadership has ensured a strong focus on actions that strengthen the City’s economic profile, with the ultimate goal of improving the lives and enhancing the well-being of East Palo Alto residents.
Staff is concerned that the Project may result in unintended financial consequences for the City of East Palo Alto. For example, it is expected that the Project will include a large grocery store, which is a beneficial amenity for the Belle Haven neighborhood and Menlo Park as a whole, but it is unclear how this store will benefit East Palo Alto. If a significant number of residents shop at this new store, the few smaller grocery stores in East Palo Alto may experience negative impacts to their businesses, and the City will receive decreased sales tax revenues.
In addition, increased traffic created by East Palo Alto residents traveling to the new store will only worsen current traffic concerns.
Staff is also concerned that the East Palo Alto Police Department could be impacted by an increase in calls for service, which would require the City of East Palo Alto to fund more police officers during a time when the City has a significant budget deficit.
The Facebook/Meta expansion is located just feet away from the Cesar Chavez Ravenswood Middle School, which already experiences traffic congestion during common drop-off and pickup hours. Staff hopes that Facebook/Meta and the City of Menlo Park will develop strategies to ensure that the Project does not impact the students, staff, and other community members connected to the middle school campus. It is not that long ago a tragic schoolgirl fatality occurred in this area.
The greatest areas of concern for staff are the related issues of traffic and air quality, resulting from increased vehicle travelling through East Palo Alto to access to future Project. Staff hopes that Facebook/Meta and the City of Menlo Park will acknowledge these realities and partner with the City of East Palo Alto to consider necessary infrastructure projects that may be of mutual benefit.
The City of East Palo Alto has a critical need for emergency-access water storage locations.
As such, staff hopes that Facebook/Meta and Menlo Fire will collaborate to determine if water storage may be included in the Project’s design, thus offering support to East Palo Alto residents during a potential emergency.
In conclusion, the City values its relationship with the City of Menlo Park and Facebook/Meta, yet many aspects of the Project raise concerns that may impact the City of East Palo Alto’s goal of achieving financial self-sufficiency and economic growth for our residents. However, an effective partnership between the City of Menlo Park, Facebook/Meta, and the City of East Palo Alto may successfully mitigate these concerns, thus ensuring that all three entities thrive in the future. The City would be eager to engage in these discussions.
Next Steps
If directed, the Interim City Manager will transmit the EIR comment letter to the City of Menlo Park. The City of Menlo Park is required to respond to all EIR comments in the Final EIR. A release date for the Final EIR has not been identified. However, the City will receive a notice of the availability of the Final EIR because it had received the NOA for the Draft EIR. Upon release, staff will review the Final EIR.
Fiscal Impact
There are no fiscal impacts associated with this City Council update regarding the information described in the staff report.
Public Notice
The public was provided notice by making the agenda and report available on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto.
Environmental
Pursuant to California Environmental Quality Act (CEQA) Guidelines section 15378(b)(5), the adoption of an ordinance of general policy does not constitute a “project” in that it is a governmental organizational or administrative activity that will not result in direct or indirect changes in the environment.
Attachments
1. Draft City Letter to Menlo Park
2. EPA NOP Comment Letter
3. Menlo Park NOA Willow Village Draft EIR