Commenter: Cedric (via Zoom)
Hello, good early afternoon. Thanks to the staff for working on this plan and thanks to the ARB for your prior comments. I was happy to see that in your comments there was a lot of support and encouragement for rooftop gardens, as well as good access to the to the creek, the renaturalized creek. I'm really looking forward to that creek being renaturalized to a hundred-foot channel that would allow the maximum winding of the creek. I hope that the zoning areas and stuff will be preventing or dissuading any development through the area that the creek would expand into, so that we don't block the ability to widen the creek.
I saw that in the comments that there were desires to incentivize more rooftop gardens and I saw that they're kind of supported by the green building standards, but not necessarily incentivized. I wonder if there’s additional ways to incentivize them.
And I guess this will come later when we actually go to design the naturalization of the creek. My understanding is, from the past, from the prior, feasibility study that, there is a plume of ground pollution and so there would be, underneath the naturalized creek, some sort of impermeable barrier to prevent those pollutants from spreading into the creek. And I wonder if there's some way to actually fix up that ground pollution so that the creek can have full contact with the Earth. There's a lot of information out now or you know, I don't know how new this information is, but basically underneath every creek and river there's a underground parallel river that helps to support the life of the creek in the soil, and I forget the exactly the details, but I think it was like 1 h of water moving through the ground-based creek would remove like 90% of pollutants from about 78% of the types of pollutants. So it's really valuable for cleaning our waters and promoting a healthy ecosystem. So hopefully we'll find a way to clean up that pollution and get the creek fully in contact with the earth.
Thank you.
“Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 4
OFFICE OF REGIONAL AND COMMUNITY PLANNING
P.O. BOX 23660, MS–10D | OAKLAND, CA 94623-0660
www.dot.ca.gov
April 22, 2024 SCH #: 2023020691
GTS #: 04-SCL-2023-01266
GTS ID: 29299
Co/Rt/Pm: SCL/82/24.037
Kelly Cha, Senior Planner
City of Palo Alto
250 Hamilton Avenue, 6th Floor
Palo Alto, CA 94301
Re: North Ventura Coordinated Area Plan ─ Draft Environmental Impact Report (DEIR) Dear Kelly Cha:
Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the North Ventura Coordinated Area Plan. The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities. The following comments are based on our review of the March 2024 DEIR.
Please note this correspondence does not indicate an official position by Caltrans on this project and is for informational purpose only.
Project Understanding
The proposed project will adopt land use policies and programs that would allow for additional 530 residential units and would incorporate two acres of new public open space within the North Ventura Coordinated Area. Residential densities would range from low to high. The plan would additionally result in a net reduction of up to 278,000 square feet of office space and up to 7,500 square feet of retail space.
The project site is located at the intersection State Route (SR)-82 and Page Mill Rd in Palo Alto and is approximately 60 acres with three proposed intersection improvement sites located within Caltrans’ Right of Way (ROW).
Travel Demand Analysis
With the enactment of Senate Bill (SB) 743, Caltrans is focused on maximizing efficient development patterns, innovative travel demand reduction strategies, and multimodal improvements. For more information on how Caltrans assesses Vehicle Kelly Cha, Senior Planner
April 22, 2024
“Provide a safe and reliable transportation network that serves all people and respects the environment” Miles Traveled (VMT) analysis for land use projects, please review Caltrans’ Transportation Impact Study Guide (link). The project VMT analysis and significance determination are undertaken in a manner consistent with the City of Palo Alto VMT policy. Per DEIR, this project is found to have a less than significant VMT impact.
However, since the additional trips generated from this project would impact several intersections along El Camino Real within Caltrans’ jurisdiction, we request an in-depth traffic safety impact analysis including Intersection Safety Operational Assessment Process (ISOAP).
Fair Share Contributions
As the Lead Agency, the City is responsible for all project mitigation, including any needed improvements to the State Transportation Network (STN). The project’s fair share contribution, financing, scheduling, implementation responsibilities and lead agency monitoring should be fully discussed for all proposed mitigation measures.
The DEIR has identified that the additional trips generated from this project could have an adverse effect on the operation of three Caltrans intersections under horizon plus project conditions. Please consider the following Projects for fair share contributions to mitigate the impact of this project to the State Transportation Network:
• Metropolitan Transportation Commission (MTC)’s Plan Bay Area 2050: Bus Rapid Transit (BRT) Modernization with SamTrans on El Camino Real (RTP ID 21-T10-078).
This program includes funding to implement BRT improvements to existing bus service along El Camino Real from Daly City Bay Area Rapid Transit (BART) to Palo Alto Caltrain Station. Improvements include frequency upgrades (15- minute peak headways), dedicated lanes (45% of route), transit priority infrastructure and transit signal priority.
• Active transportation projects in support of building a multimodal transportation system to accommodate users of all ages and abilities:
o Caltrans District 4 Bike Plan: Class IV separated buffered bike lanes on El Camino Real from Sand Hill Rd to San Antonio Rd.
Hydrology
There would be significant impact from storm runoff due to proposed development.
Please ensure that any increase in storm water runoff from the development do not encroach on Caltrans’ ROW but be efficiently intercepted by drainage inlets.
The
existing storm drain system in Caltrans’ ROW might need to be upgraded in size to allow increased runoff. A detailed Drainage report will be required to be submitted to our office for review and approval.
Kelly Cha, Senior Planner
April 22, 2024
“Provide a safe and reliable transportation network that serves all people and respects the environment”
Freight
SR-82 is identified as a Terminal Access Route by the Freight Network Designation. Lane widths and turning movements should be considered during development.
Construction-Related Impacts
Project work that requires movement of oversized or excessive load vehicles on State roadways requires a transportation permit that is issued by Caltrans. To apply, please visit Caltrans Transportation Permits (link). Prior to construction, coordination may be required with Caltrans to develop a Transportation Management Plan (TMP) to reduce construction traffic impacts to the STN.
Encroachment Permit
This project would result in a significant increase in usage for El Camino Real. Please identify whether any projects will be required on SR-82 in the immediate vicinity as a result of this area plan to accommodate the residential and mixed use. In the event of such projects, please provide information if there would be dedications for additional ROW required as a condition of future development.
Please be advised that any permanent work or temporary traffic control that encroaches onto Caltrans’ ROW requires a Caltrans-issued encroachment permit. As part of the encroachment permit submittal process, you may be asked by the Office of Encroachment Permits to submit a completed encroachment permit application package, digital set of plans clearly delineating Caltrans’ ROW, digital copy of signed, dated and stamped (include stamp expiration date) traffic control plans, this comment letter, your response to the comment letter, and where applicable, the following items: new or amended Maintenance Agreement (MA), approved Design Standard Decision Document (DSDD), approved encroachment exception request, and/or airspace lease agreement.
The checklist TR-0416 (link
) is used to determine the appropriate Caltrans review
process for encroachment projects. The Office of Encroachment Permit requires 100% complete design plans and supporting documents to review and circulate the permit application package. To obtain more information and download the permit application, please visit Caltrans Encroachment Permits (link). Your application package may be emailed to [email protected].
Equity
We will achieve equity when everyone has access to what they need to thrive no matter their race, socioeconomic status, identity, where they live, or how they travel.
Caltrans is committed to advancing equity and livability in all communities. We look Kelly Cha, Senior Planner
April 22, 2024
“Provide a safe and reliable transportation network that serves all people and respects the environment” forward to collaborating with the City to prioritize projects that are equitable and provide meaningful benefits to historically underserved communities.
If any Caltrans facilities are impacted by the project, those facilities must meet American Disabilities Act (ADA) Standards after project completion. As well, the project must maintain bicycle and pedestrian access during construction. These access considerations support Caltrans’ equity mission to provide a safe, sustainable, and equitable transportation network for all users.
Thank you again for including Caltrans in the environmental review process. Should you have any questions regarding this letter, please contact Marley Mathews, Transportation Planner, via [email protected]. For future early coordination opportunities or project referrals, please contact [email protected].
Sincerely,
YUNSHENG LUO
Branch Chief, Local Development Review
Office of Regional and Community Planning
c: State Clearinghouse
April 22, 2024
City of Palo Alto City Hall
250 Hamilton Avenue, 5th floor
Palo Alto, CA 94301
Attn: Kelly Cha, Senior Planner
By Email: [email protected]
Dear Kelly,
VTA appreciates the opportunity to comment on the Draft North Ventura Coordinated Area Plan (NVCAP) and its Draft Supplemental EIR. VTA has reviewed the documents and has the following comments.
Countywide Plans
The Draft NVCAP and its Draft Supplemental EIR should include relevant countywide plans with the listed local, regional, and state plans. VTA recommends including VTA’s Visionary Network and Bike Superhighway Implementation Plan and specifically recommends highlighting El Camino Real’s improvements identified in the two plans.
Caltrain Crossing
VTA recommends exploring adding a bicycle and pedestrian crossing across the Caltrain tracks within the plan’s area. Currently, there is no crossing along the plan’s frontage. With the plan’s increased density, the lack of crossing may cause more users to trespass onto the tracks and thereby increase the risk of incidents.
Transportation Mitigation Measures
VTA would like more information on the TRANS-1b Mitigation Measures: “Fees collected would be used for capital improvements aimed at reducing motor vehicle trips and motor vehicle traffic congestion” (page vii).
If Transit Signal Priority (TSP) improvements are applicable to this mitigation measure area, VTA recommends including a fair share contribution to upgrade the traffic signal controller cabinets on El Camino Real to comply with VTA’s Enhance Traffic Signal Controller guidance document (see attached). The existing equipment in the traffic signal controller cabinets is reaching its end of useful life and the traffic signal controllers do not have the capabilities to work with more modern forms of TSP.
Future Coordination
VTA appreciates the multimodal transportation improvement and connections to Caltrain and VTA identified in the plan. VTA would like to review future development applications. Please send applications to [email protected].
City of Palo Alto
April 22, 2024
Thank you again for the opportunity to review this project. If you have any questions, please do not hesitate to contact me at 408-321-5804 or [email protected].
Sincerely,
Larissa Sanderfer
Transportation Planner II
PA2401
From: Cha, Kelly
To: Natalie Noyes
Cc: Raybould, Claire
Subject: Fw: VW File 33840 - NVCAP SEIR Review at Matadero Creek Date: Tuesday, April 23, 2024 8:07:24 AM
Attachments: image001.png
Outlook-xppccy5s.png
Forwarding 3 of 3
KELLY CHA
Senior Planner
Planning and Development Department
(650) 329-2155 | [email protected]
https://link.edgepilot.com/s/0a79fb1c/8pMnObfe90eBGV0as8meoA? u=http://www.cityofpaloalto.org/
From: Gennifer Wehrmeyer <[email protected]>
Sent: Monday, April 22, 2024 4:59 PM
To: North Ventura Coordinated Area Plan <[email protected]> Cc: Shree Dharasker <[email protected]>; Raybould, Claire <[email protected]>; CPRU-Dropbox <[email protected]> Subject: VW File 33840 - NVCAP SEIR Review at Matadero Creek
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
Dear Kelly Cha,
The Santa Clara Valley Water District (Valley Water) has reviewed the Draft Supplemental EIR (SEIR) and Draft North Ventura Coordinated Area Plan (NVCAP) to plan for a walkable, mixed- use neighborhood on approximately 60 acres roughly bounded by Page Mill Rd, El Camino Real, Lambert Ave, and the Caltrain tracks in Palo Alto, received on March 8, 2024. Based on our review Valley Water has the following comments on the SEIR and NVCAP plans:
SEIR COMMENTS
1. The NVCAP will impact Valley Water facilities. Valley Water currently has easement, exclusive easement, and fee title property within the project area along Matadero Creek, as seen in the deeds linked here:
https://link.edgepilot.com/s/96c3194b/K2t1q2gA0kKhEdFAJKBNZA? u=https://fta.valleywater.org/fl/aFJnDlpWvc. Please submit plans showing the proposed work in greater detail on or adjacent to Valley Water right of way. In accordance with Valley Water’s Water Resources Protection Ordinance (WRPO), any construction activity within or adjacent to Valley Water property will need an encroachment permit. A copy of the encroachment permit application can be found here:
https://link.edgepilot.com/s/54803bf0/zhYcv18m4UeWZzeSg9W1KA? u=https://www.valleywater.org/contractors/doing-businesses-with-the- district/permits-working-district-land-or-easement/encroachment-permits. Valley Water encroachment permits are discretionary actions, and therefore, Valley Water is a responsible agency under CEQA.
2. Santa Clara Valley Water District (Valley Water) should not be referred to as “District” throughout the SEIR. While the official name of the agency remains Santa Clara Valley Water District, Valley Water has been used as a moniker since 2019. Please replace “District” with “Valley Water” on pages 142 and 143.
3. SEIR Figures 2.3-3 through 2.3-6, pages 33 through 36, and NVCAP plan Figures 36 and 42, pages 43 and 51, depict the removal of Matadero channel improvements, including the removal of Valley Water’s maintenance path and concrete channel lining, and replacement with a widened channel section with a riparian corridor, pedestrian paths, and a pedestrian bridge over Valley Water fee title property and easement.
At a minimum, proposals to naturalize the Matadero Creek flood protection facility must not: increase our costs to maintain the facility; reduce maintenance access; reduce the level of flood protection currently provided by the channel; and create channel instability.
Additionally, proposals must: include a net benefit to Valley Water (including the reservation of lands in Valley Water fee title for the Valley Water’s use in fulfilling future mitigation planting requirements for its stream maintenance program); provide sufficient additional right of way to Valley Water to operate and maintain the modified facility (including all areas required to contain the same level of flood protection currently afforded); include regulatory permitting; provide appropriate mitigation (that do not include use of Valley Water right of way for mitigation planting); and be a geomorphic, stable channel that will not increase erosion or sediment deposition or increase the potential for damage to or failure of the adjacent concrete channel lining, up or downstream of the proposed naturalization.
Once a proposal is provided to Valley Water for review, we will be able to provide comments. Valley Water expects adjacent landowners to provide right of way to accommodate any desired recreational facilities and amenities that are not conducive to sharing space with a maintenance road.
4. SEIR page 149, “Hydrology and Water Quality”, and page 204, “Storm Drain System”, states that the creation of Matadero Park and naturalization of Matadero Creek through the establishment of a 100-foot riparian buffer will result in a net reduction of impervious surfaces, and that this net decrease in impervious surfaces will result in a corresponding decrease in stormwater runoff. It is not clear if the determination of “less than significant impact” regarding impacts related to drainage relies on the proposed naturalization of Matadero Creek. Since this work is not proposed as a part of the NVCAP, naturalization of Matadero Creek should not be considered in the impact analysis for drainage and this discussion should be revised for accuracy and clarity.
5. SEIR page 24, Section 2.3.9, “Naturalization of Matadero Creek”, discusses the removal of Lambert Avenue Bridge and replacement with a new 100-foot clear-span bridge.
Since the section of Matadero Creek at Lambert Avenue is not proposed for naturalization, the need for the bridge replacement as a part of the naturalization work is unclear. Any plans for replacement of Lambert Ave Bridge should be submitted to Valley Water once available for review and comment.
6. Valley Water has an exclusive easement reserved for flood control purposes on APN 132-38-011, which would restrict the ability of the City of Palo Alto (City) to obtain a trail easement over this portion of the Matadero Creek maintenance road without Valley Water relinquishing the exclusivity of its easement. Further discussions will be needed between Valley Water and the City if the City wishes to pursue access through this easement.
7. Please modify the “Water Resources Protection Ordinance and District Well Ordinance” section on SEIR page 156 to include the following statement in its entirety:
Valley Water operates as a flood protection agency for Santa Clara County. Valley Water also provides stream stewardship and is the wholesale water supplier throughout the county, which includes the groundwater recharge program. In accordance with Valley Water’s Water Resources Protection Ordinance, any work within Valley Water’s fee title right of way or easement or work that impacts Valley Water’s facilities requires the issuance of a Valley Water permit. Under Valley Water’s Well Ordinance 90-1, permits are required for any boring, drilling, deepening, refurbishing, or destroying of a water well, cathodic protection well, observation well, monitoring well, exploratory boring (45 feet or deeper), or other deep excavation that intersects with the groundwater aquifers of Santa Clara County.
8. Please submit plans for any proposed underground structures or dewatering plans to Valley Water for review once available. Valley Water cannot determine that dewatering activities will not substantially decrease groundwater supplies or substantially interfere with groundwater recharge until such plans are made available.
9. SEIR page 140, Section 3.8, “Hydrology and Water Quality”, 3.8.1.1, “Regulatory Framework, Federal and State”, should include a brief summary of California’s Sustainable Groundwater Management Act (SGMA) under the State regulatory framework because Valley Water’s 2021 Groundwater Management Plan (mentioned on page 142) is a DWR approved Alternative to a Groundwater Sustainable Plan (Alternative) under SGMA.
10. SEIR page 142, “2021 Groundwater Management Plan” should include the following detail near the beginning of the paragraph: “The 2021 GWMP is the first periodic update to the approved Alternative to a Groundwater Sustainability Plan under SGMA.”
11. SEIR pages 145 and 148, “Groundwater”, should be modified to read “Typical groundwater depths in Palo Alto range from less than 10 to 30 feet below ground surface (bgs).” because groundwater depths can be shallower than 10 feet in many areas of Palo Alto. For example, City well 06S03W12R010, located directly adjacent to the project site, regularly has water levels about 5 feet bgs (most recent data for March 2024 is 5.5 feet bgs). Groundwater level data in Palo Alto can be viewed on Valley Water’s historical groundwater elevation data website:
https://link.edgepilot.com/s/52ad5893/UoPDYbO-AUicIroC7bXiEw? u=https://gis.valleywater.org/GroundwaterElevations/map.php.
12. On SEIR page 148, the project site is located entirely overlying the confined zone of the Santa Clara Subbasin and not within the recharge zone. Therefore, any rainfall or irrigation that infiltrates the Project site would recharge the shallow aquifer above the confining layer. The deeper, confined aquifer is the primary groundwater supply of the Santa Clara Subbasin, not the shallow aquifer. This is why Valley Water has no recharge ponds or facilities near the Project site.
13. On SEIR page 148, “Standard Permit Conditions”, given the first bullet (Prohibit dewatering during the rainy season.), we recommend that the Project construction activities consider that groundwater levels are typically the highest (closest to land surface) during the rainy season.
14. On SEIR page 148, given that the Project overlies the confined aquifer, potential dewatering activities are unlikely to negatively impact the groundwater supply because the primary supply is from the confined aquifer. However, the Project site is located within the seawater intrusion outcome measure area, as defined in the 2021 Groundwater Management Plan (see Chapter 5 and Appendix H). We recommend that any future dewatering permit applications evaluate and mitigate if the dewatering activities, particularly any long-term or ongoing dewatering, will negatively affect the spatial pattern of seawater intrusion in the shallow aquifer.
15. On SEIR pages 148, 149, and 150, there is conflicting text about impacts to groundwater that should be resolved. This includes text on page 148 stating “Temporary or permanent dewatering could affect groundwater supplies.” and page 149 stating “… NVCAP in compliance with the above standard permit conditions and existing regulations (including the NPDES General Construction Permit and MRP) would not substantially deplete groundwater supplies…”. Page 150 also states “…NVCAP would not substantially decrease groundwater supplies…”
16. According to the Federal Emergency Management Agency’s (FEMA) Flood Insurance Rate Map (FIRM) 06085C0017H, effective May 18, 2009, the majority of the project site is within FEMA Flood Zone X, an area with a 0.2% annual chance flood hazard, and the areas of Matadero Creek are located within Flood Zone A, a special flood hazard area with 1.0% annual chance flood discharge contained in the structure with no base flood elevations determined.
17. Santa Clara Valley Water District (Valley Water) records indicate that 40 active wells are located on the subject property. Valley Water’s Well Information App can be used to help locate wells on the Project site: https://link.edgepilot.com/s/aaa90e47/RLSVX5- BN0enFpbUy2GAaQ?u=https://www.valleywater.org/contractors/doing-businesses- with-the-district/wells-well-owners/well-information-app. While this app indicates there are many destroyed wells and active water supply and monitoring wells on the project site, there could be additional unknown abandoned wells. If any existing wells are to be destroyed by the Project and if any abandoned wells are identified during the Project, they need to be properly destroyed in coordination with Valley Water staff at the Well Permitting and Inspections Hotline: 408-630-2660
(https://link.edgepilot.com/s/35f51adc/myTamLqd5E6RYVllMlQvEw? u=https://www.valleywater.org/contractors/doing-businesses-with-the-district/wells- well-owners .
18. The State GeoTracker webpage
(https://link.edgepilot.com/s/5aca8e9f/JJuzdFwpNUOX6LmjG7LaJw? u=https://geotracker.waterboards.ca.gov/) lists at least 8 open cleanup sites within the Project footprint. Any proposed groundwater dewatering near these sites should be approved by the relevant regulatory oversight agency.
NVCAP PLANS COMMENTS
19. Figure 36, page 43, Figure 42, page 51, and Figure 75, page 107, of the NVCAP plans show multiple crossings of Matadero Creek, while Figure 43, page 52, only shows one creek crossing. The number of creek crossings is to be minimized. Valley Water only supports one creek crossing. Please reference Valley Water’s Water Resources Protection Manual, Design Guide 4, “Riparian Revegetation or Mitigation Projects”, and Design Guide 16, “Guidance for Trail Design”, when designing creek crossings.
20. Page 60, “Green Infrastructure”, discusses the use of green stormwater infrastructure as a part of the NVCAP plans. Re-development of the site provides opportunities to minimize water and associated energy use by incorporating on-site reuse for both storm and graywater and requiring water conservation measures to exceed State standards.
To reduce or avoid impacts to water supply, the City and applicant should consider implementing measures from the Model Water Efficient New Development Ordinance, which include:
A. Hot water recirculation systems.
B. Alternate water sources collection (like cisterns) and recycled water connections as feasible.
C. Pool and spa covers.
D. Encourage non-potable reuse of water like recycled water, graywater and rainwater/stormwater in new development and remodels through installation of dual plumbing for irrigation, toilet flushing, cooling towers, and other non- potable water uses.
E. Require dedicated landscape meters where applicable.
F. Require installation of separate submeters to each unit in multi-family developments and individual spaces within commercial buildings to encourage efficient water use.
G. Weather- or soil-based irrigation controllers.
21. Lighting described on Page 63 must be directed away from the creek. Please explain whether wildlife can trigger motion sensors, as this would counteract efforts to protect habitat from nighttime lighting. Please reference Guidelines and Standards Design Guide 16.I.H for lighting requirements near creeks. The Guidelines and Standards were adopted by the City of Palo Alto under Ordinance 4932.
22. Page 108, Section 5.1.7, mentions the use of pollinator-friendly native plants. Please reference Guidelines and Standards Design Guide 2 for the placement of native plants along the creek.
23. Page 110, Section 5.2 should reference Guidelines and Standards Design Guides 4 and 16 and Section VII.B.
24. Page 112, Section 5.2.7, “Floodwalls”, discusses the use of vegetation within concrete retaining walls. Floodwalls and retaining walls are not the same and it is not clear what is proposed. Vegetation may impact the ability to inspect flood walls and may not be allowed.
If you have any questions or need further information, you can reach me at [email protected]
or at (408) 694-2069. Please reference Valley Water File 33840 on further correspondence regarding this project.
Thank you,
Gennifer Wehrmeyer
ASSISTANT ENGINEER, CIVIL
Community Projects Review Unit
Watershed Stewardship and Planning Division
[email protected]
Tel. (408) 630-2588 Cell. (408) 694-2069
SANTA CLARA VALLEY WATER DISTRICT
5750 Almaden Expressway, San Jose CA 95118
https://link.edgepilot.com/s/a51a4422/h07-tTtJdkqYUPbacYKTWg?u=http://www.valleywater.org/
Clean Water . Healthy Environment . Flood Protection