Mountain View City Council
April 3, 2023

City of Mountain View
℅ Diana Pancholi, Project Planner
500 Castro St.

Mountain View, CA 94041
February 3, 2022
Dear Mrs. Pancholi,
This document serves as the Mountain View Whisman School District (MVWSD) response to the Amended North Bayshore Precise Plan (NBPP), Dra Environmental Impact Report. We have reviewed the report and provide the following informaon in regard to the adequacy of the findings as related to direct and indirect impacts on the Mountain View Whisman School District. We understand that the passage of SB50 limits the levying of developer fees for direct impacts on school districts. However, nothing precludes the City, Developer and School District from working collaboravely to develop a migaon strategy to address the direct and indirect city growth impacts on the school district.

Student Growth:

The City of Mountain View’s Dra EIR indicates the impact of 1,471 elementary and middle school students would be adequately migated by developer fees. Moreover, the updated Dra EIR indicates:

As discussed in Secon 4.12.1.2, both Monta Loma Elementary School and Crienden Middle School have exisng capacity based on current enrollment numbers and would be able to accommodate the project’s esmated 1,471 elementary and middle school students. Therefore, the addion of new students as the project is gradually built-out would not require the expansion of those schools.

Furthermore, the Dra EIR asserts:

Attachment 3
The project site is located within the Mountain View Whisman School District (MVWSD) and Mountain View-Los Altos Union High School District (MVLASD). The MVWSD serves grades
kindergarten through eighth grade and the MVLAS services high-school age students. Students generated by the project would aend Monta Loma Elementary School located at 460 Thompson Avenue (approximately one mile southwest of the core project site), Crienden Middle School located at 1701 Rock Street (approximately 0.2-mile southwest of the core project site), and Mountain View High School located at 3535 Truman Avenue (approximately four miles south of the core project site).

Table 4.12-1 shows the exisng school capacies at Monta Loma Elementary School, Crienden Middle School, and Mountain View High School. As shown in the table, Monta Loma
Elementary School and Crienden Middle School both have capacity for addional students.

Unfortunately, as highlighted below, the City of Mountain View EIR report does not take into account projects that were already approved in the northern half of the city, some of which are outside of the North Bayshore precise plan area. These projected students will precede the impact of students generated by the North Bayshore Precise Plan (NBPP). While both Monta Loma Elementary School and Crienden Middle School are in the proximity of the NBPP, there will be no capacity

available when the NBPP project is developed. Based on our student generaon rates, which the City used in its own EIR report, Monta Loma will have 117 new students assigned to the school prior to the compleon of these addional units.

Based on MVWSD’s Future Growth Consideraons and Soluons presentaon to the Board of Educaon on March 24, 2022, monitoring the pace of future residenal development was idenfied as a key task to support other District planning acons. The table below was included as a 10-year projecon of future residenal development in the District service area.

Note: 1,682 units listed as “Under Construcon” on table should be revised to 1,050 units due to 632 units in 2580/2590 California Ave. project being outside MVWSD service area.

COST TO HOUSE STUDENTS GENERATED FROM NBPP
Construcon costs in the Bay Area have escalated dramacally in the last 8 years. The State per pupil grant does not reflect this escalaon and therefore the gap between what the State allows and provides for school construcon is significantly less than the actual cost of school construcon.

LAND
In addion to dramac escalaon in construcon costs in the Bay Area, land costs have increased as well. The State of California will provide 50% of the cost of land for eligible school construcon. However, the remaining 50% of the land cost is the responsibility of the local school district. These substanal increases in land costs make it difficult to build schools in accordance with the Department of Educaon school site guidelines. The land cost escalaon issues were ancipated when SB50 was draed and Government Code secon 65998 allows the cies to “reserve or designate” real property for a school site.

Moreover, the Dra EIR inaccurately indicates the distance from North Bayshore to Monta Loma Elementary. As noted in the plan:

Students generated by the project would aend Monta Loma Elementary School located at 460 Thompson Avenue
(approximately one mile southwest of the core project site), Crienden Middle School located at 1701 Rock Street
(approximately 0.2-mile southwest of the core project site), In the following diagrams you will find that almost every elementary school student within the city of Mountain View is approximately 1 to 1.5 miles from school. The placement of these schools helps to facilitate the school as a civic meeng point for the community and reduces commutes. In contrast, while Monta Loma and Crienden reside close to the outer perimeters of the development area, Monta Loma is more than two miles away from the central residenal hub of these developments, thus negang its ability to serve as a community anchor. Because MVWSD cannot provide bussing to an addional 1400 students due to significant cost, not having a school within a 1.5 mile radius would effecvely invalidate the traffic study included as a part of this EIR.

California Department of Educaon’s general guidance for a school site recommends approximately 10 acres of land for an elementary school and 25 acres for a middle school. It is worth nong that MVWSD does have a school (Jose Antonio Vargas Elementary) that resides on less than the minimum recommended land. Vargas Elementary is an extremely ght footprint, which creates logiscal issues as it pertains to growth and meeng student needs.

In contrast, the North Bayshore plan only inmates at the possibility of green space being used for a school. This referenced site in the DEIR, if provided to MVWSD, would have twice the enrollment of Vargas Elementary with less acreage; the site is 3 acres compared to Vargas

Elementary which sits on 4.5 acres and is 7 acres less than the state’s minimum recommendaon. While an urban school design can migate / maximize a small site footprint, this potenal site would be inadequate to serve the needs of the community.

Ergo, as a condion of approval of the NBPP project, and prior to the cerficaon of the DEIR, we request that the City and Developer designate and reserve mulple elementary school sites for MVWSD. The availability of land for school construcon in Mountain View is extremely limited. The District is amenable to creave efforts to ulize all real property opons and is willing to discuss these opons with the Developer.

INDIRECT IMPACTS
Chawanakee Unified School District V. County of Madera
In this appellate court case, the court concluded that the phrase in SB50 “impacts on school facilies” does not cover all possible environmental impacts. While the NBPP does consider noise, emissions, traffic, and other indirect impacts, it does not specifically idenfy those indirect impacts in the operaon of a school district. For example, the eighteen “significant unavoidable impacts” created by transportaon and traffic may have an indirect impact on transporng students to school if the school is not in the proximity of the NBPP project. In addion, the buildout of 9,850 units is in a plan that covers a period through 2030. The approximate 10-year buildout of the NBPP project would mean an absorpon rate of 980 units per year.

This construcon period would require the MVWSD to provide interim housing over a period of me and is considered an “indirect impact.” This issue is not addressed in the DEIR.

Shoreline Community Redevelopment Area Tax Increment
As noted in the EIR report:

Funding for Schools. The Shoreline Community shall work with the Mountain View Whisman School District and the Mountain View Los Altos Union High School District to allocate revenue

related to the growth in assessed value due to new residenal development within the Community pursuant to/in accordance with the annual tax allocaon for each school district, through mutually agreed to and legally binding agreements.

The North Bayshore Precise plan indicates the desire to transform a once blighted area into a thriving mixed development area. The businesses and residences that are being planned are currently planned in a de facto redevelopment district. The Shoreline community, which is managed by the city of Mountain View staff and City Council currently diverts all tax revenue. Currently MVLA, MVWSD and the city of Mountain View have formed a Joint Powers Authority, also known as Share Shoreline, that began releasing part of the tax increment to schools. The current agreement, which not only ends but also ceases to provide any share of the tax increment on July 1st, 2023, currently guarantees approximately $2.8 million. Through a formula that was developed by the City, MVWSD received $5,346,723 dollars this year. Per the county assessor's office, MVWSD normal tax increment would have been $13,926,094.67 last year.

Assessed Value Tax revenue from commercial and residenal is what community funded districts use to address day-to-day operang costs and is not really intended for building schools. As indicated in the EIR, North Bayshore should generate 1471 students. At the MVWSD current per student expenditure rate of $23,000 this would mean that tax revenue would at minimum need to equal $33,833,000 in the near future. An increase of students in this fashion, without the tax increment to cover the cost per pupil expenditures, would reduce our per pupil expenditures from $23,000 to $16,611 dollars. This reducon means that each student in our District would experience a decrease of $6,389 in programs and services annually.

CLOSING COMMENTS
Our comments regarding the DEIR should not be construed to indicate our opposion to the amended NBPP. It is crical that all interested pares understand that the new dwelling units are of such magnitude that school migaon measures for the project exceed the District’s ability to absorb the 1,471 students projected from this project. We look forward to the cooperaon of the City and

proponents of the project to meet with MVWSD and resolve the apparent challenges in this proposed project. We suggest that the District, City, and proponents of the project delay the approval of the North Bayshore Master Plan and the DEIR and meet soon to provide creave viable measures that meet the needs of MVWSD and all stakeholders.

Respecully,
Ayindé Rudolph Ed.D.

Superintendent
CC: Mountain View City Council
Mountain View Whisman Board of Trustees
Mrs. Kimbra McCarthy, City Manager