CITY OF EAST PALO ALTO
Office of the City Manager
May 20, 2022
Kyle Perata, Acting Planning Manager
Community Development Department
City of Menlo Park
701 Lauren Street
Menlo Park, CA 94025
Subject: Notice of Availability for the Facebook Willow Master Plan Project Dear Mr. Perata:
This letter is provided in response to the Notice of Availability (NOA) for the Facebook Willow Master Plan Project. Thank you for providing an opportunity to comment. East Palo Alto values its relationship with Menlo Park and we hope to continue to work cooperatively on the many issues common to both of our communities.
The City commented on the Notice of Preparation on October 17, 2019, and incorporates those comments by reference.
Proximity to East Palo Alto Residential Neighborhoods
The project site is in very close proximity to East Palo Alto residences, specifically three single family residential neighborhoods: Kavanaugh, University Village and Palo Alto Park. In some instances, the residences are within 300 feet of the site. Given the size of the project and the five-year construction time period, the City requests that equal consideration be given to these neighborhoods as Menlo Park neighborhoods. In some cases, these East Palo Alto neighborhoods would be more impacted by this project. The City has concerns about various impacts (described below) as well as air quality, biological resources, energy, geology and soils, greenhouse gas emissions, hazards and hazardous materials, and hydrology and water quality.
Proximity to the Ravenswood Priority Development Area and the Ravenswood/Four Corners Specific Plan Update
The project site is located less than 2,000 feet from the Ravenswood Business District (RBD), which is a priority development area and an important jobs center for East Palo Alto. The City is in the process of updating the Specific Plan, which may include increasing the amount of both nonresidential and residential square footage. The Notice of Preparation for the update was released on May 9, 2022; however, the update has been in process, including multiple public hearings, since mid-2020. While the Draft EIR includes the four projects proposed for the RBD area, the text does not acknowledge or discuss the RBD Specific Plan update. The Draft EIR should explicitly include in its analysis the RBD Specific Plan Update. Given the importance of the RBD area for East Palo Alto, that it is a designated priority development area and the pending update, the City is very concerned about the potential impact of the Willow Village project on the ability to develop the RBD area. Specifically, traffic impacts from the Willow Village would directly impact the RBD area.
Jobs Housing Ratio
The City of East Palo Alto provides a significant amount of housing stock in Silicon Valley. East Palo Alto has more housing units than jobs, the lowest market rate prices in the region, and approximately 30% (or 2,405 of 7,759 units) of the total housing units are currently registered (non-exempt) in the Rent Stabilization Program. The City is concerned that the proposed development of a significant amount of nonresidential square footage would exacerbate the existing housing crisis in East Palo Alto.
Cumulative Impacts
The Draft EIR tiers off the ConnectMenlo EIR prepared for the General Plan update.
ConnectMenlo did not include East Palo Alto projects in the cumulative scenario due to a water moratorium that paused projects in East Palo Alto during the preparation of the DEIR. This DEIR includes a list-based approach for the cumulative analysis. The list used for the cumulative analysis is incomplete. It does not include two projects that were approved but not yet constructed (Clarum University and Sobrato Phase II) nor the RBD Specific Plan Update. Clarum University, located at 2331 University, was approved for the construction of a 47,594 square foot four-story mixed-use building with retail space and parking on the ground level and 33 residential dwelling units on the levels above the ground floor. The Sobrato Phase II project was approved for the demolition of two existing buildings and construction of an eight-story structure with approximately 231,883 square feet of office space and a five-story, 284,094-square-foot parking structure. The City respectfully requests that the DEIR analyze these three projects for cumulative and traffic impacts.
Aesthetics
The Aesthetics analysis included the viewsheds from two locations within the City of East Palo Alto. The DEIR included a photosimulation which simulated potential views from the Kavanaugh View shed, one of three single family neighborhoods located within 300 feet of the project site. The photosimulation clearly shows the project will significantly alter middle ground views. Buildings over 70 feet in height would clearly be visible from the neighborhood. Although there are no identified scenic vistas, the project would change the character of the area with a significantly taller structures both for the project and cumulatively. The Draft EIR should be revised to incorporate mitigation to reduce the impacts on the viewshed to a less than significant impact.
Construction and Air Quality
The DEIR identifies three significant unavoidable impacts for air quality. There are a significant number of sensitive receptors within the three East Palo Alto single-family neighborhoods near the perimeter of the project site. The DEIR states that extended construction hours are proposed over the five-year construction period. Work is proposed between 7:00 a.m. to 10:00 p.m. Monday through Saturday. Construction is also proposed on Sunday from 8:00 a.m. to 6:00 p.m. Although it is recognized that air quality issues are beyond the control of any one jurisdiction, the City is significantly concerned about the extended construction hours and five-year time period and the potential impact on East Palo Alto residents and sensitive receptors.
Mitigation Measures AQ 1.1, AQ 2b2 require that prior to the issuance of a building permit that the applicant provide a supplemental analysis by a qualified air quality specialist that the construction would not create air quality impacts that exceed Bay Area Air Quality Management District regulations and CEQA guidelines. Due to the potential direct impacts on East Palo Alto residents, the City requests that the mitigation measure also require submittal of the construction air quality analysis that includes analysis for East Palo Alto impacts be submitted for East Palo Alto review.
Construction and Noise/Vibration impacts
The DEIR identifies three significant unavoidable impacts related to noise and vibration. As described above, there are three neighborhoods in the City of East Palo Alto that will be directly impacted. The City is significantly concerned due to the proximity of East Palo neighborhoods to the project.
Noise 1.1 and 2a require a construction noise control plan and a noise and vibration analysis to assess and mitigate potential noise and vibration impacts. The plan and analysis should be evaluated to prevent noise impacts on East Palo Alto neighborhoods. Activities that cannot comply with the noise limit of 60dBA at the residential or noise sensitive land use or exceed maximum level of 0.2 in/sec for vibrations should not be permitted. The City also requests to review the noise control plan and noise/vibration analysis prior to the issuance of a building permit.
Settlement Agreement
Pursuant to Section 2.6 of the Menlo Park General Plan Settlement Agreement, when the preparation of an EIR is required, concurrent with the preparation of the EIR, Menlo Park will conduct a Housing Needs Assessment (HNA). The scope of the HNA, to the extent possible, shall include an analysis of the multiplier effect for indirect and induced employment by the development project and its relationship to the regional housing needs market and displacement. The DEIR includes a HNA in the appendix. The discussion in the DEIR should be consistent with all relevant terms of the Settlement Agreement. The City requests that a summary of the required analysis be incorporated into the DEIR
Population and Housing
According to the DEIR main report and Housing Needs Assessment Appendix, the growth in units from the Proposed Project is estimated to result in a housing unit deficit of 815 regionally. The DEIR notes that because ABAG and MTC Plan Bay Area Projections 2040 incorporate growth under ConnectMenlo, cumulative impacts related to population and housing are less than significant. The ABAG/MTC housing projections are based on all future housing development, not concurrent development (to the Proposed Project), within Menlo Park and in the region. The regional balancing of jobs and housing from the Proposed Project and other similar projects will only occur if neighboring jurisdictions, including East Palo Alto, but also Palo Alto, Redwood City, and other cities within the commute area keep up with planned housing production, the evidence for which is lacking.
Of particular concern in the Housing Needs Assessment is the estimated number of Extremely-Low, Very-Low, and Low-Income units included in the net decrease in available housing in the region as a result of the Proposed Project: 127 Extremely Low, 270 Very Low, and 727 Low. Given that lower-income housing units have been, and continue to be, produced at much lower levels than above-moderate housing, with most jurisdictions in the region not meeting their lower-income Regional Housing Needs Allocations (RHNA), the deficit from this Proposed Project deserves particular attention.
Since not all new employees will seek housing in Menlo Park, it is estimated that induced employment from the Proposed Project will lead to employees seeking housing elsewhere, with an additional 26 employee households ultimately living in East Palo Alto.
This very low number, particularly in combination with findings of the HNA that, “on balance, the analysis suggests the proposed Project would likely, at most, represent a minor contributing factor to the substantial pre-existing displacement pressures in East Palo Alto and Belle Haven,” should be viewed with scrutiny to ensure that it is accurate.
Public Services
East Palo Alto has significant concerns regarding the ability to provide public safety services. Traffic is already having an impact for public safety services post pandemic.
Since returning to “normal” following the pandemic, and people returning to work, traffic has increased during commute hours, thus creating congestion throughout the city with traffic coming from Highway 84 to SR 101 in the morning and from SR 101 to Highway 84 in the afternoon. The traffic typically lasts for approximately 3 hours during the morning and afternoon. However, commuter traffic doesn’t remain on University Avenue. The traffic spills into our neighborhoods which isn’t fair to our residents who live and work in this area, as they must negotiate and navigate through traffic just to get home, pick up children from school or just conduct their daily lives.
During the afternoon, commuters use Pulgas Avenue, Clarke Avenue and Cooley Avenue as a cut through to Bay Road. They also use Euclid Avenue, to Glen Way via Runnymede Street to Bay Road as a cut through, and Dumbarton Avenue to Bay Road during the afternoon. The City already have narrow streets due to a high volume of parked vehicles and it is already difficult to navigate through these streets during peak commute times while performing normal patrol duties. When an emergency occurs during commute times, getting the necessary emergency apparatus to the scene when time is of the essence always is a difficult task because of heavy traffic. There have been at least two occasions when a life flight (helicopter) had to be requested to transport trauma patients to Stanford Hospital (less than 5 miles away), because the commute traffic was so congested an ambulance couldn’t get to the scene soon enough. Willow Village Project will add to the traffic congestion and traffic issues we already have with our existing commute traffic. With the potential of increased traffic resulting from this project, this will negatively impact our ability to provide efficient public safety services in a timely manner and thus negatively impact the safety and security of our residents.
TDM and TMA
The City understands that the project will be required to prepare and implement a Transportation Demand Management program designed to reduce the number of vehicular trips. As noted above, traffic impacts are a regional issue that extend beyond individual city borders. The City of East Palo Alto recently adopted a TDM ordinance requiring that average daily trips be reduced by 40% and has been exploring the formation of a Transportation Management Association (TMA). There is an economy of scale for TDM measures and TMAs. The City requests that the project applicant be required to consult with the City of East Palo Alto to find opportunities to pool resources where feasible to reduce vehicular trips. This can include the formation of a TMA or measures such as coordinating or sharing shuttles or rideshare programs. This would benefit both the City of East Palo Alto and Menlo Park.
Transportation
East Palo Alto’s General Plan identifies a vision for University Avenue which is to transform it from a regional cut-through corridor to a mixed-use boulevard with high density housing and multi-model transportation options. The goal is to reduce traffic volumes, reduce traffic speeds, make the area desirable for pedestrians with wide sidewalks, streetscape improvements such as signage and street trees, and add multimodal transportation options. The proposed Willow Village project will add a significant amount of traffic onto University Avenue - intersections will be beyond acceptable levels of service; there will be congestion during AM/PM peak hour, significant impacts at interchanges. These issues can be mitigated by design and construction of the University Avenue Improvements project (Grand Corridor) in East Palo Alto. Improvements along University Avenue will be vital and should be constructed alongside the Willow Village project.
Impacts at Kavanaugh Drive/O’Brien Drive should be studied further and a traffic signal/roundabout analysis should be performed. Any necessary improvements to this intersection should be a part of the Willow Village project.
Modification of existing dead-end cul-de-sacs into through streets will increase cut through traffic onto University Avenue. This will impact both O'Brien Drive, Kavanaugh Drive, Gloria Way, and Bay Road. Traffic safety and traffic calming improvements along these roads should be a part of the Willow Village project. These improvements may include roundabouts at intersections, radar speed feedback signs, lighting, ADA improvements, signage and striping, and bulb-outs.
In order to enforce traffic related impacts in the City of East Palo Alto, a traffic enforcement officer should be budgeted for the City of East Palo Alto for a few years upon project completion to ensure effectiveness of traffic controls.
The EIR should clearly identify show all of the fair-share calculation formulas for affected East Palo intersections.
Because several Menlo Park streets adjacent to the proposed project have restricted parking and Kavanaugh street in East Palo Alto does not, there is concern that overflow parking will spill into East Palo Alto streets. The applicant shall work with the City of East Palo Alto to address potential solutions to prohibit overflow parking onto City of East Palo Alto city-streets, primarily within the Kavanagh Drive/Gloria Way neighborhoods.
In order to ensure bike trail connectivity from the proposed project onto the Bay Trail as well as other trails in East Palo Alto, an analysis of bike trail connectivity should be performed and bike trails should be striped as a part of this project.
Cut through traffic along City of East Palo Alto city streets is a major potential concern with the implementation of this project. A cut-through traffic analysis should be performed and measures should be implemented to discourage cut through traffic within City of East Palo Alto neighborhood streets. Measures can include signage in both cities of Menlo Park as well as East Palo Alto.
Utilities and Service Systems
Because the Kavanaugh Drive/Gloria Way neighborhoods in East Palo Alto are adjacent to the proposed project site, these streets should be improved aesthetically.
Undergrounding of power lines in these neighborhoods can significantly improve aesthetics in and around the proposed project site.
There are drainage issues in the vicinity of the proposed project site that can be improved.
Primarily, at the north end of Ralmar Avenue to 1170 O’Brien Drive, Menlo Park. There is occasional flooding of Ralmar street in East Palo Alto due to an inadequate drainage system. Collaboration is needed between Menlo Park and East Palo Alto to ensure a storm drain system can be constructed through 1170 O’Brien Drive to avoid flooding in the City of East Palo Alto.
Hydrology
A detailed hydrology plan would show existing and proposed storm drain systems and drainage areas around the vicinity of the proposed project. This information would be useful to verify whether any of the storm drain systems in the City of East Palo Alto would be impacted. This information should be shared with the City of East Palo Alto when available.
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 pick-up 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.
Sincerely,
Patrick Heisinger
Interim City Manager