City of SunnyvaleAgenda Item23-0500 Agenda Date:6/12/2023REPORT TO PLANNING COMMISSIONSUBJECTCONTINUED FROM MAY 8, 2023Proposed Project:Forward recommendation to the City Council related to the Moffett Park Specific Plan (MPSP) to:A. Adopt a Resolution (Attachments 5 and 7) to1. Certify the Environmental Impact Report (EIR);2. Make the findings required by California Environmental Quality Act (CEQA);3. Adopt the Statement of Overriding Considerations and Mitigation Monitoring andReporting Program;4. Adopt the Water Supply Assessment;5. Adopt the Amended Moffett Park Specific Plan (with Staff recommended modificationsto the draft MPSP detailed in Attachment 9);6. Amend the General Plan text and update the General Plan Map; and7. Update the Green Building Program Table.B. Adopt a Resolution (Attachment 6) to:1. Amend the Fiscal Year 2022/23 Master Fee Schedule to adjust the MPSP PlanningApplication Fees, including the addition of the MPSP Maintenance Fee, the MPSPInfrastructure Fee and the MPSP Transportation Impact Fee (TIF).C. Introduce a Draft Ordinance (Attachment 8) to:1. Repeal and Re-Adopt Sunnyvale Municipal Code (SMC) Chapter 19.29 (Moffett ParkSpecific Plan) and make other amendments to Title 19 (Zoning) to implement the MPSP.2. Add SMC Chapter: 3.56 (MPSP Transportation Impact Fee) to Title 3 (Revenue andFinance); and3. Amend the Zoning Plan District Map and re-zone parcels currently within the newMPSP district.Location: Existing Plan: Moffett Park Specific PlanFile number:2018-7715 (Moffett Park Specific Plan)General Plan Designation:Existing: Moffett Park Specific PlanProposed: Moffett Park Specific PlanZoning:Existing Zoning:MP-I: IndustrialMP- TOD: Transit Oriented DevelopmentMP-C: CommercialProposed MPSP Zoning Districts:MP-AC: Activity CenterMP-R: ResidentialPage 1 of 20 Attachment 1 Page 1 of 20
23-0500 Agenda Date:6/12/2023MP-MU: Mixed UseMP-O1: Office 1MP-O2: Office 2MP-E1: Mixed Employment 1MP-E2: Mixed Employment 2MP-E3: Mixed Employment 3MP-H: HospitalityMP-PF: Public FacilitiesProposed Combining DistrictECD: Ecological Combining DistrictApplicant:City of SunnyvaleEnvironmental Review:Environmental Impact Report (SCH # 20210880338)Project Planner: Michelle King, 408-730-7463, [email protected] IN BRIEFGeneral Plan:Existing Land Use Designations: Moffett Park Specific Plan (MPSP), a modernbusiness park. Proposed Land Use Designation: MPSP, a mixed-use Eco-Innovation District.Existing Site Conditions:The first Moffett Park Specific Plan was adopted in 2004 to maximize thedevelopment potential for corporate headquarters, offices, and research and development facilities.The Plan encourages higher-intensity office uses (up to 70% FAR) along the Tasman light rail lineand medium-density floor area ratios (up to 50% FAR) in outlying areas. The allowable FAR dependson the level of green building standards that are met. A Development Reserve was established aspart of the adoption of the 2004 MPSP and is nearly depleted with development and approvedentitlements for about 22.6 million square feet of office, industrial, research and development,supportive commercial (total build out was anticipated as 24.33 million square feet).Issues:The proposed 2023 MPSP envisions a net growth of about 10 million square feet ofoffice/R&D/commercial uses, the addition of 20,000 housing units and a transformation into anecological and innovation district with more open space and circulation improvements to benefit non-auto transportation. The issues and challenges for implementation of the Plan include:Allowing additional residential development at very high densities and more height, particularlyin the activity centers;Preparation of a community benefits and development incentives program;Requiring minimum ground floor commercial area in new mixed-use developments;Significant and unavoidable environmental impacts; and,Transportation/circulation improvements.Staff Recommendation for Planning CommissionForward recommendations related to the MPSP to the City Council:Certification of the EIR and related actions;Adoption of the Moffett Park Specific Plan (with staff recommended amendments) and relatedactions amending the General Plan; and adopting fees specific to Moffett Park; andIntroduce ordinances to amend the Sunnyvale Municipal Code and Rezone propertiesPage 2 of 20 Attachment 1 Page 2 of 20
23-0500 Agenda Date:6/12/2023consistent with the MPSP and General Plan.Detailed recommendations are listed in the Alternatives and Staff Recommendation sections of thisreport.The City Council is scheduled to consider this item on July 11, 2023.BACKGROUNDThe Moffett Park Specific Plan Area is approximately 1,270 acres (hereinafter referred to as “MoffettPark”) located in the northern portion of the City (excluding area within the City limits that are part ofSan Francisco Bay). Moffett Park’s northernmost boundary ends at Caribbean Drive (except for aportion of the Lockheed owned property that extends slightly further north to the treatment ponds).North of the Plan Area are the former/closed Sunnyvale landfill, Sunnyvale Materials Recovery andTransfer Station (SMaRT Station®), Donald M. Somers Water Pollution Control Plant (WPCP),WPCP salt ponds for wastewater treatment (an open-water pond) which are outside the Planboundary, but within the City’s limits. The Plan Area is bounded to the west by Moffett FederalAirfield, to the south by Highway 237 and to the east by Caribbean Drive, Baylands Park and theTwin Creeks Sports Complex.A request for a General Plan Initiation (GPI) to consider updating the MPSP was submitted on May10, 2017. On February 6, 2018, the City Council voted to initiate the Study in accordance with thePlanning Commission recommendation to prepare a work plan and project description after initialcommunity outreach (RTC No. 18-0100) (see link in Attachment 4). The Study was to include anyadditional plan features, such as bicycle and pedestrian improvements, connections across Highway237, access to and out of Mountain View, and to commence work on the studies (including staffing)only if fully paid for by the applicants.Staff returned to the Planning Commission on March 11, 2019, to report on the findings of the MPSPinitial outreach, proposed work plan and project schedule. In addition, staff requested the PlanningCommission make a recommendation to the Council on a proposed set of Guiding Principles toinform and guide the update process. Key Guiding Principles include the Study of housing in the planarea, redefining of the area as an “Ecological and Innovation District”, and the need to prepare andplan for future needed infrastructure. On April 9, 2019 (RTC No. 19-037), the City Council approvedthe project work program and Guiding Principles (see link in Attachment 4) and directed staff toproceed with the update. In addition, a draft Vision Statement was prepared and shared with the CityCouncil at several study sessions and public workshops (see link in Attachment 4). In 2021, aCommunity Priorities Survey was conducted regarding the public’s interest in future amenities andimprovement in the plan area. The results were compiled, presented to the City Council, and postedon the project’s website (see link in Attachment 4).Existing Site ConditionsCurrently, Moffett Park is developed with approximately 18.5 million square feet ofoffice/R&D/industrial, commercial uses (including restaurants and hotels), and institutional uses(including a fire station, post office, Veterans Affairs (VA) research center and community college).Previous efforts by the City to develop Moffett Park as a hub for office space have resulted in a builtlandscape that varies considerably in both age and composition. Most existing buildings are largelyreflective of the type of work and industry of each building’s respective tenants. Older buildingsPage 3 of 20 Attachment 1 Page 3 of 20
23-0500 Agenda Date:6/12/2023consist of mostly one- and two-story offices, warehouses, and R&D facilities. More recent buildingsdepart significantly from this typology, with new office towers typically eight-stories (or approximately130 feet tall). Low-scale buildings (up to 50% Floor Area Ratio - FAR) feature expansive surfaceparking lots. While developments with higher FARs include parking garages, those sites also containlarge surface parking areas. Although Moffett Park features dozens of individual businesses,significant portions of the area are consolidated under six key landowners: Google, Lockheed MartinCorporation, Jay Paul Company, Juniper Networks, Harvest, and the United States (U.S.)Department of the Navy (Navy).Prior to the start of the Specific Plan update, the City approved a variety of office projects withinMoffett Park. These approved but not yet built projects include approximately 4.1 million net newsquare feet of new construction that would increase the total built square footage from 18.5 to 22.6million square feet.Specific Plan and Environmental Impact Report (EIR) Preparation ProcessIn August 2020, Study Sessions were held for both Planning Commission and City Council to presentthe ongoing public outreach, overview of completed technical studies, initial land use concepts, andpreliminary block configurations. In 2021 and 2022, additional public workshops and City CouncilWorkshops and Study Sessions were held on key topics such as:Sea Level Rise and Climate ChangeTransportation and InfrastructureLand UseHousingOpen SpaceEconomic and Market ConditionsCommunity Benefit PrioritiesThe draft MPSP and Draft Environmental Impact Report (DEIR) were released for public commentbeginning on December 19, 2022, and ending on February 10, 2023 (53 days, exceeding theminimum 45-day review period).Following release of the public documents, staff held a Moffett Park Specific Plan “Virtual OpenHouse” on January 17, 2023. The Virtual Open House was well attended, staff recorded the event,and it is available on the project’s website (see link in Attachment 4). Following the Virtual OpenHouse, in March of 2023, the draft MPSP was presented to the Bicycle and Pedestrian Commission,the Sustainable Commission and the Housing and Human Services Commission. The threecommissions recommended approval of the draft MPSP. The minutes from the three commissionsare included as Attachment 14.Airport Land Use Commission (ALUC). The draft MPSP and DEIR were reviewed by the Santa ClaraCounty Airport Land Use Commission (ALUC) on April 26, 2023. The ALUC is charged with reviewingprojects for consistency with the adopted Moffett Federal Airfield Comprehensive Land Use Plan(CLUP). The CLUP is designed to minimize the public's exposure to excessive noise and safetyhazards, and to ensure that the approaches to airports are kept clear of structures that could pose anaviation safety issue.Page 4 of 20 Attachment 1 Page 4 of 20
23-0500 Agenda Date:6/12/2023ALUC found the update to the Moffett Park Specific Plan (MPSP) and the associated General Planand Zoning Ordinance Amendments to be inconsistent with the Moffett Federal Airfield CLUP policiesunless specific language is added to the Moffett Park Specific Plan. At a high level the topics are:How to measure height to determine consistency within CLUPNo residential uses allowed and a 200 persons per acre limit within the Turning Safety ZoneRequire an avigation easement from new developmentAttachment 17 is the letter from the ALUC staff stating the desired language to be added to theMPSP. The text of the recommended ALUC changes is reflected in Attachment 9 as staffrecommended modifications to the draft MPSP.Description of ProjectThe proposed project became a comprehensive, City-led update of the 2004 Moffett Park SpecificPlan (which had several smaller updates to the land use and zoning maps) as the 2004 Plan wasnearly built to capacity; future development proposals would need to continue being considered aspiecemeal amendments to the plan. This comprehensive update provides opportunities to considerand plan for new land uses such as housing, open space and other amenities for new residents andemployees.The proposed Moffett Park Specific Plan update provides a vision, guiding principles, developmentstandards, and design guidelines for future development within the plan area. The Specific Planwould allow for the addition of residential uses with greater building heights than allowed in theexisting Specific Plan; and an increase in the allowable square footage and heights foroffice/industrial/R&D, commercial, and institutional uses within Moffett Park.The updated Specific Plan would also allow for a net increase of:20,000 residential units (there are no residential units existing in Moffett Park today).The Specific Plan also enables additional non-residential development beyond what is currentlyexisting or entitled today:10.0 million square feet of office/industrial/R&D use500,000 square feet of retail use150,000 square feet of hospitality use200,000 square feet of institutional useAs a result, the buildout of the Specific Plan (which would include existing, recently approved, andproposed uses) would result in a total of 20,000 residential units and approximately 33.5 millionsquare feet of commercial, office/industrial/R&D, and institutional uses.EXISTING POLICYAll relevant City General Plan Land Use and Transportation Element (LUTE) and the HousingElements goals and policies are included as Attachment 3. There are many goals and policies thatthe draft MPSP will support and further; the six noted below are foundational.GOAL LT-2: ENVIRONMENTALLY SUSTAINABLE LAND USE AND TRANSPORTATIONPLANNING AND DEVELOPMENT - Support the sustainable vision by incorporating sustainablePage 5 of 20 Attachment 1 Page 5 of 20
23-0500 Agenda Date:6/12/2023features into land use and transportation decisions and practices.GOAL LT-7: DIVERSE HOUSING OPPORTUNITIES -Ensure the availability of ownership andrental housing options with a variety of dwelling types, sizes, and densities that contribute positivelyto the surrounding area and the health of the community.GOAL LT-9: ADEQUATE AND BALANCED RECREATION FACILITIES - The City strives toprovide and maintain adequate and balanced open space and recreation facilities for the benefit ofmaintaining a healthy community based on community needs and the ability of the city to finance,construct, maintain, and operate these facilities now and in the future.GOAL HE-1: ADEQUATE HOUSING - Assist in the provision of adequate housing to meet thediverse needs of Sunnyvale’s households of all income levels. (Housing and CommunityRevitalization Goal A / Adopted In 2009)GOAL HE-4: ADEQUATE HOUSING SITES - Provide adequate sites for the development of newhousing through appropriate land use and zoning to address the diverse needs of Sunnyvale’sresidents and workforce (Housing and Community Revitalization Goal D / Adopted In 2009)GOAL HE-6: SUSTAINABLE NEIGHBORHOODS - Maintain sustainable neighborhoods with qualityhousing, infrastructure and open space that fosters neighborhood character and the health ofresidents. (Housing and Community Revitalization Goal F / Adopted in 2009)ENVIRONMENTAL REVIEWThe City is the lead agency under the California Environmental Quality Act (CEQA) and isresponsible for preparing an Environmental Impact Report (EIR) (State Clearinghouse No.2021080338) for the draft MPSP.An EIR can be used to evaluate either a program that regulates future development, or a specificdevelopment project. In this case, the EIR includes a program-level analysis of the MPSP and wasprepared for the City by David J. Power and Associates.The EIR’s program-level analysis compares the environmental impacts of the MPSP with the existingconditions, specifically land use changes adopted with the Land Use and Transportation Element(LUTE) of the City’s General Plan and associated EIR that was certified in 2017. As stated above, theMPSP includes an increase in housing potential in the Plan Area (20,000 additional net newresidential units beyond what was considered in the LUTE), the Study of up to 10 million square feetof net new office floor area, 200,000 square feet of net new industrial uses,150,000 square feet of netnew hospitality use and 500,000 square feet of net new retail.Attachment 4 contains a link to the Draft EIR (DEIR) and associated appendices, and the Final EIR(FEIR), including responses to comments and minor corrections/clarifications to the DEIR.EIR Public ReviewNotice of Preparation Period and Scoping MeetingPage 6 of 20 Attachment 1 Page 6 of 20
23-0500 Agenda Date:6/12/2023In accordance with Section 15082 of the CEQA Guidelines, the City prepared a Notice of Preparation(NOP) for this EIR. The NOP was circulated to local, state, and federal agencies on August 18, 2021.The standard 30-day comment period concluded on September 16, 2021. The NOP provided ageneral description of the proposed project and identified possible environmental impacts that couldresult from implementation of the project. The City also held a public scoping meeting on August 26,2021, to discuss the project and solicit public input as to the scope and contents of the EIR. Themeeting was held virtually. Appendix A of the DEIR includes the NOP and comments received on theNOP.The DEIR for the Moffett Park Specific Plan project, dated December 19, 2022, was circulated toaffected public agencies and interested parties for a 53-day review period from December 19, 2022,through February 10, 2023. Under CEQA, a 45-day review period is required. The public reviewperiod for the Draft EIR, therefore, included an additional eight days beyond what is required. TheCity undertook the following actions to inform the public of the availability of the DEIR:A Notice of Availability of DEIR was published on the City’s website;Notification of the availability of the Draft EIR was mailed to members of the public who hadindicated interest in the project;The DEIR‘s public review period with the State Clearinghouse began on December 19, 2022.Additionally, it was distributed to various governmental agencies, organizations, businesses, andindividuals (see Section 3.0 for a list of agencies, organizations, businesses, and individuals thatreceived the Draft EIR); andCopies of the DEIR were made available on the City’s website, Library, One-Stop PermitCenter, Community Center, and Specific Plan website.In addition, during the public review period for the DEIR, the City hosted the following meetings andhearings to provide an overview of the DEIR and accept public comments:Specific Plan Open House on January 17, 2023Planning Commission Hearing on January 23, 2023City Council Meeting on January 31, 2023All the written and oral comments (received at public hearings) were considered during thepreparation of the FEIR and are included with a response in the FEIR (see link to FEIR in Attachment4). The FEIR was distributed beyond the required minimum ten-day public review from April 13, 2023,to July 11, 2023, when the City Council will consider the FEIR.Less-than-Significant Impacts and Required Mitigation MeasuresThe EIR analyzes whether the MPSP project would result in any significant impacts. Except for twocategories where significant and unavoidable impacts were found, all impacts were found to be eitherless-than-significant or less-than-significant with required mitigation measures. The full MitigationMonitoring and Reporting Program (MMRP) for a list of mitigation measures. The MMRP is includedis provided separately for ease of reference in Attachment 5).Significant and Unavoidable ImpactsPage 7 of 20 Attachment 1 Page 7 of 20
23-0500 Agenda Date:6/12/2023CEQA considers environmental impacts “significant and unavoidable” when there is no feasible wayto substantially reduce the impacts to a less-than-significant level. The EIR identified significant andunavoidable impacts in air quality (cumulatively considerable net increase of criteria pollutantemissions during construction and for which the air basin is designated nonattainment), greenhousegas emissions, and utilities (cumulatively considerable impact to wastewater services requiring futureexpansion of the Water Pollution Control Plant). See Attachment 7 for a summary of the significantand unavoidable impacts.Statement of Overriding ConsiderationsThe Council may still approve the project if written findings can be made, based on information in theEIR and other information in the administrative record that social, economic, or other benefitsoutweigh the significant and unavoidable environmental impacts. The document containing thereasons for the findings is called a Statement of Overriding Considerations. The project’s Statementof Overriding Considerations contains a list of the benefits that the project will bring to the Cityconsistent with General Plan and MPSP policies (Attachment 7).Project AlternativesCEQA requires that an EIR identify alternatives to a project as it is proposed. CEQA GuidelinesSection 15126.6 specifies that the EIR should identify alternatives which “would feasibly attain mostof the basic objectives of the project but would avoid or substantially lessen any of the significanteffects of the project.” The purpose of the alternatives analysis is to determine whether there arealternatives of design, scope, or location which would substantially lessen the significant impacts,even if those alternatives “impede to some degree the attainment of the project objectives” or aremore expensive (CEQA Guidelines Section 15126.6). While CEQA does not require that alternativesmust be capable of meeting all the project objectives, their ability to meet most of the objectives isconsidered relevant to their consideration.The Specific Plan objectives are congruent with the “Guiding Principles” of the Specific Plan and aresummarized as follows:1. Maintain Moffett Park as an integral part of Sunnyvale.2. Establish Moffett Park as a model community through its commitment to comprehensivelyaddressing resilience, climate protection, and equity in all activities.3. Evolve Moffett Park into a vibrant and inclusive community where all people can thrive.4. Maintain and strengthen Moffett Park as a diverse economic engine that supports economicprosperity for all.5. Create a connected, accessible district that prioritizes the movement of people over vehiclesto reduce climate pollution and to support a healthy community.6. Cultivate dynamic and connected public spaces that accommodate the physical and socialneeds of all users.7. Create a healthy, resilient, and biodiverse environment.8. Integrate innovative and emerging technologies in the district to support community-widegoals.A location alternative was considered but rejected because there are no alternative locations that areof similar size to Moffett Park within the City. In addition, given that the main objective of the project isto establish a long-term strategy to guide future development in the Moffett Park area, it would not bePage 8 of 20 Attachment 1 Page 8 of 20
23-0500 Agenda Date:6/12/2023feasible to evaluate an alternative location in the City. The Moffett Park Specific Plan must, by itsnature, guide future development located in Moffett Park. The following were evaluated asalternatives to the project and described in detail in Section 8.0 Alternatives of the MPSP Draft EIR:No Project/No New Development AlternativeNo Project/Adopted Specific Plan Buildout Alternative25 Percent Reduced Development AlternativeThe CEQA Guidelines state that an EIR shall identify an environmentally superior alternative. Inaddition to the No Project Alternatives, the environmentally superior alternative to the proposedproject is the 25 Percent Reduced Development Alternative. A detailed analysis of the projectalternatives is provided in Section 7.0 Alternatives of the MPSP DEIR.Water Supply AssessmentState Law (SB 610 and SB 221 from 2001) requires the preparation of a Water Supply Assessment(WSA) for amended specific plans to ensure that water supply planning has been conducted, andthat planned water supplies are adequate to meet both existing demands and demands of planneddevelopment. The WSA for the MPSP is included as Attachment 12 of this report and will be adoptedwith Council’s approval. The Council is also required to make specific findings for the WSA, which areincluded in Attachment 7. The WSA found that the MPSP would increase water demand within theCity, but currently projected water supplies will be sufficient to meet the projected annual waterdemands of existing and previously approved uses, and the implementation of both projects duringnormal, single dry, and multiple dry years.Determination of AdequacyThe "rule of reason standard" is applied to judicial review and EIR contents. This standard requiresthat an EIR shows that an agency has made an objective, good faith attempt at full disclosure. Thescope of judicial review does not extend to correctness of the conclusion found in an EIR, but onlythe sufficiency of the EIR as an informative document for decision-makers and the public.Staff finds that the proposed FEIR, consisting of the DEIR, comments received on the DEIR,response to comments received, the MMRP, and a list of persons and public agencies commentingon the DEIR meets the requirements of CEQA both in content and format. Should it be determinedthat the FEIR is not adequate, the Planning Commission or City Council may identify those areaswhere the document is deficient and recommend additional analysis to be prepared prior tocertification.Any changes to the mitigation measures in the FEIR may affect the accompanying determination ofsignificance. However, the Planning Commission may proceed with recommendations on the projectsubject to completing additional work on the FEIR. No project-related actions may be taken (by theCouncil) until the FEIR is certified. Certification of the FEIR does not automatically ensure adoption ofthe MPSP.DISCUSSIONMPSP Background ReportsPage 9 of 20 Attachment 1 Page 9 of 20
23-0500 Agenda Date:6/12/2023Technical Studies completed in the process of updating the plan and informing the DEIR are alsoavailable for public review on the project website (Attachment 4) and include the following:Existing Conditions + Strengths, Weakness, Opportunities and Threats ReportUrban Ecology Technical StudySea Level Rise Adaptation StrategyAir Quality Constraints Assessment for the Moffett Park Specific PlanAir Quality and Greenhous Gas AnalysisCultural Resources Literature Review and Background ReportsMoffett Park Market AnalysisEconomic Impact AnalysisNoise and Vibration AssessmentBiology ReportHazardous Materials General Plan Review and Environmental Evaluation ReportsGroundwater, Stormwater and Sea Level Rise InformationWater Supply AssessmentWastewater Master Plan ReportWater Master Plan ReportWater Storage MemoTransportation ReportsAdditional technical studies were completed to establish development fees for the plan area. Theyinclude:Moffett Park Transportation Impact Fee Nexus Study (MP TIF) (Attachment 10)Moffett Park Infrastructure Needs and Fee Assessment (Attachment 11)Vision Statement and Guiding PrinciplesMoffett Park has served as a critical piece of Sunnyvale’s cultural landscape and built environmentfor decades. Through collaborative input from the City Council, Planning Commission, localstakeholders, and the wider Sunnyvale community, a shared vision statement was created.The Vision:Moffett Park is an integral part of Sunnyvale, and a well-connected ecological innovationdistrict with a diverse mix of uses that serves as a model of resilience, climate protection,equity, and economic opportunity.Additionally, eight “Guiding Principles” were developed to help guide future development of the PlanArea. The principles are summarized above as the EIR “Plan Objectives”. The complete language ofthe principles and their statements of intent can be found in the Draft MPSP (Attachment 4).MPSP OrganizationMoffett Park Specific Plan is divided into ten chapters, each one documenting a different aspect ofdevelopment of the plan area based on analysis, policies, design guidelines and standards,circulation, and implementation items to bring the plan to fruition. Chapter III is a summary of theMajor Plan Strategies and provides an overview of the plans approach to meeting the Vision andPage 10 of 20 Attachment 1 Page 10 of 20
23-0500 Agenda Date:6/12/2023Principles. Chapters IV through IX include goals, policies, requirements, and standards related totheir respective topics. Below is a summary of the Plan chapters:Chapter I. Vision and Principles. Establishes the Vision for the Moffett Park Specific Plan,and Guiding Principles that provide a foundation and regulatory framework for all futuredevelopment proposals, design concepts, and capital improvements within Moffett Park.Chapter II. Planning Foundation. Provides a brief overview of Moffett Park, existingconditions, and a summary of the planning process and development of this Specific Plan.Chapter III: Major Plan Strategies. Highlights the Specific Plan’s major plan strategiesincluding design and policy approaches to shape the future of Moffett Park. These strategies aredetailed subsequently in Chapters IV through X.Chapter IV: Land Use. Describes Moffett Park’s neighborhoods and details the Land UseDistricts across the entire plan area. It also provides a regulatory structure for density/intensity,community benefits, and transfer of development rights programs.Chapter V: Development Standards. Includes standards to regulate site and building designand development. It establishes block standards, site design and lot standards, height, massing,building frontage design, building placement, and other aspects of architecture. It also includesintegrated standards, such as bird safe design and landscape design. Standards arerequirements that must be adhered to for all development.Chapter VI: Open Space and Urban Ecology. Defines the goals, polices, standards andguidelines for the improvement and development of a high-quality public realm that will meet theneeds of residents, workers, and visitors. It integrates the development of park and open spacetypologies with standards to protect and enhance key ecological resources. Standards aretailored to the unique conditions in Moffett Park and indicate the general location, scale, and typeof open space to be developed. It also includes an Ecological Combining District, channel setbackrequirements, and urban forestry.Chapter VII: Mobility. Establishes multimodal strategies and districtwide policy to redesignthe plan area around people rather than vehicles. It defines a complete streets typology andnetwork, and contains standards for designing bicycle, pedestrian, and transit infrastructure.Chapter VIII: Transportation Demand and Parking. Aims to reduce single-occupancyvehicle travel, minimize peak period vehicle trips, and shift trips to transit, biking, walking,scooting, or rideshare. It establishes vehicular and bicycle parking requirements and standards,including on- and off-street parking and loading requirements.Chapter IX: Infrastructure and Utilities. Guides future investment in sea level rise, water,sanitary sewer, stormwater, and district-scale infrastructure projects.Chapter X: Implementation. Includes a list of implementation actions to realize the SpecificPlan vision.Page 11 of 20 Attachment 1 Page 11 of 20
23-0500 Agenda Date:6/12/2023Land Use MapTo transform the Plan Area from an office and industrial employment center to a series of completeneighborhoods, the Draft Plan proposes a revised land use map with new uses and land useintensities for the plan area. The seven new land use designations and a new “combining district” areas follows.ACTIVITY CENTER (MP-AC) Activity Center districts are vibrant, mixed-use places that allowa mix of office, residential, and commercial uses. The District accommodates neighborhood-serving commercial uses, community services, and entertainment in ground floor storefrontsfacing public streets, parks, and open space. To achieve the highest office densities, the ActivityCenter District requires a minimum amount residential uses to ensure day/night activity within thearea, and to support neighborhood-serving commercial uses. Buildings have minimal setbacks.Parking is accommodated in structures, with a focus on shared and district parking strategies.Non-residential FAR from 35% up to 75% with community benefits; minimum residential density is40 du/ac.RESIDENTIAL (MP-R) Residential districts allow for very high-density housing. Residentialneighborhoods and developments are typically located near the Activity Center District and withina short walk to VTA light rail. The Minimum residential density is 70 du/ac.MIXED-USE (MP-MU)Mixed-Use districts provide land use flexibility for property owners,allowing standalone residential, standalone office, or a mixed-use development. The Mixed-UseDistrict allows dense residential or office development to provide flexibility in specific locationswithin the Plan Area. The Mixed-Use District does not require a minimum amount of residentialuses. Non-residential FAR ranges from 35% up to 100%.OFFICE (MP-O1) AND (MP-O2) Office districts provide for higher-intensity corporate andprofessional/administrative office uses. Office districts include high-quality public spacesorganized into a larger block structure.oThe MP-O1 provides for the potential densification of existing office campuses in the WestMathilda and Discovery Neighborhoods up to 100% FAR with community benefits.oThe MP-O2 allows for up to 135% FAR with community benefits, the highest intensity of officeuses in proximity to the MP-AC, MP-R, MP-MU, and high-quality transit.MIXED EMPLOYMENT (MP-E1), (MP-E2), (MP-E3) The Mixed-Employment districts allow fora mix of office, light industrial, and other non-residential uses, as well as open space. Each Mixed-Employment District is unique in character building on its historic development pattern anddescribed as follows:oThe MP-E1 District is the US Navy property, and it allows for a mix of uses, including corporateand professional office in an urban pattern with integrated open space. Non-residential FARfrom 35% up to 75% with community benefits and up to 150% with transfer of developmentrights. Future development and allowed uses on the site are contingent on the on-site cleanupand remediation.Page 12 of 20 Attachment 1 Page 12 of 20
23-0500 Agenda Date:6/12/2023oThe MP-E2 District provides opportunity for a mix of office, R&D, and industrial uses. Non-residential FAR from 35% up to 50% with community benefits and up to 100% with transfer ofdevelopment rights.oThe MP-E3 District provides a mix of office, R&D, and light industrial. A portion of the District ispartially located within the Ecological Combining District and allows for the clustering of futuredevelopment away from the combining zone and the ability to transfer development rights tominimize the amount development near sensitive habitat. The allowed non-residential FAR is35%. The MP-E3 District may not receive transferred development rights and has no option forBonus FAR.HOSPITALITY (MP-H) Allows for hotel uses up to 100% FAR.PUBLIC FACILITIES (MP-PF) This District includes the Santa Clara Valley Water East andWest Sunnyvale and City-owned properties as well as properties used by the U.S. VeteransAffairs Department and Foothill/De Anza Community College District.ECOLOGICAL COMBINING DISTRICT (ECD) Preserves and enhances the existing greenspace and biological resources located at the northwest corner of Moffett Park and provides openspaces with limited public access and passive recreation. The ECD does not limit the gross parcelarea for determining the amount of development permitted. The ECD restricts new privatedevelopment within the zone and special design standards regulate development within andadjacent to the ECD boundary.The MPSP Land Use Map and Land Use Intensity and Density Table are included on page 81 andpage 83 of the Draft MPSP (Attachment 4) and staff recommended changes to the Land Use Mapand corresponding table are included on page 7 of Attachment 9.Transportation/CirculationThe MPSP includes several design features to encourage alternatives to the single-occupant vehicle.Improvements will include pedestrian friendly site design, new pathways for pedestrians and bicycleswithin the blocks, revised street cross-sections to add bicycle lanes and missing sidewalks, sharedparking policies, and compatible and supportive land uses. The plan also has restrictions on thenumber of parking spaces as a disincentive to driving alone.Transportation Demand Management (TDM). The MPSP includes goals and policies to reduce theuse of single-occupant vehicles (SOVs). One requirement in support of this goal is to implement TDMmeasures into project design and operations. Since the late 1990s the City has required higherintensity office (and R&D) developments throughout the City to implement TDM measures to reducepeak hour trips (and in some cases total daily trips). Since 2016, development with mandatory TDMrequirements must conduct annual driveway counts to demonstrate that trip reduction is taking place- if the site is not performing as required a fine is imposed on the site (Sunnyvale Municipal CodeChapter 10.60, Transportation Demand Management).Council Policy 1.1.15 Residential Transportation Demand Management states that new developmentand redevelopment in High Density and Very High Density Residential zoning districts in targetedareas are required to implement TDM techniques. In 2016 the zoning code was modified to requirePage 13 of 20 Attachment 1 Page 13 of 20
23-0500 Agenda Date:6/12/2023residential development above 10 units to include site development TDM features to reduce autotrips; a menu of options is provided, and developments need to achieve minimum points to complywith the regulations.The goal to reduce SOV travel to 50% is not the same as a 50% reduction in trips. A simple exampleis if 100 trips were SOV and 50 of those drivers decided to share a vehicle with one other personthere would be 75 trips (50 remaining SOV and 25 double occupant vehicles); this example achievesthe 50% SOV rate and reduces trips by 25%. Trips will be measured for the peak hour when accessin or out of the MPSP area has the greatest potential for congestion that could negatively affect areasoutside of Moffett Park. Theoretically peak hour trip reduction can be achieved without any reductionin total daily trips by adjusting commute times. Only addressing peak hour trips will not meet thegoals of the plan to reduce the overall use of single-occupant vehicles. The overall development ofthe MPSP area along with the improvements to the transportation network and formation of theMPSP Transportation Management Association will help reduce the overall daily trips by 50% in thelong-term.The greatest source of in-bound a.m. and out-bound p.m. peak hour trips is from office/research &development(R&D) uses which contribute to the most congestion at the gateways. Office/R&D useswill have the highest trip reduction requirements. For MPSP, the goal for a low SOV rate and TDMreductions with required trip reduction rates will be expanded to include residential uses as well. Thisrequirement is more fully explained in Attachment 9, Staff Recommended Changes to the DraftMPSP. In order to meet the City standard for level of service, reduce congestion, and achievereduced vehicle miles traveled in the Plan area, staff is recommending the following peak hour tripreduction rates initially and in the long term:
It is fully anticipated that over time adaptive actions will be needed to assure the MPSP area isoperating comfortably for all modes of travel. As the anticipated MPSP variety of land-uses aredeveloped, trips will become more internalized and shorter, facilitating a higher long-term peak hourtrip reduction rate.Transportation Management Association (TMA). The plan has a requirement to establish a TMA.TMAs can provide a variety of services that encourage more efficient use of transportation andparking resources. They are generally public-private partnerships, consisting primarily of areabusinesses and property owners with local government support (which could take the form of policyand implementation support, not necessarily financial support). The MPSP TMA would provide avariety of services that encourage and support the more efficient use of transportation and parkingresources and would be a public-private partnership with the city, property owners, businesses, andresidents. The MPSP TMA is not the first instance in Sunnyvale; the Peery Park Specific Planrequired the establishment of a TMA. Unlike the Peery Park TMA which was formed to address thePage 14 of 20 Attachment 1 Page 14 of 20
23-0500 Agenda Date:6/12/2023transportation demand management for a planning area dominated by employment, the MPSP TMAwill have a more robust membership including representatives of office, residential and commercialuses. Chapter 8, Section 8.2 includes the requirements for participation, specific TDM requirementsand the responsibilities of TMA members. The TMA will facilitate the implementation of MPSP area-wide TDM measures that will benefit large and small property owners and coordinate access toparking garages throughout the MPSP area. The TMA will eventually assist in the monitoring of tripsand determining how well the MPSP area is meeting the SOV and trip reduction goals.The formation of the MPSP TMA is identified as an “immediate” action item by the “ImplementationActions” in Table 29 of Chapter 10 of the MPSP. Actions that are identified as “immediate” are apriority and are anticipated to occur between MPSP adoption and the year 2027. The formation of theMPSP TMA is anticipated to be included in one of the first Development Agreements for the allocationof office square footage.Transportation Impact Fee (TIF). Similar to the Lawrence Station Area Plan and the El Camino RealSpecific Plan, the Moffett Park Specific Plan will result in operational deficiencies due to the increasein land uses and intensities; additional transportation impact fees will help address these deficiencies.Unlike the other two plan areas, the MPSP will also require significant enhancements to thepedestrian and bicycle infrastructure to support the low single-occupant-vehicle (SOV) goal for theplan area. This item is more fully discussed below under fees.New FeesRecommended new fees are included in the Draft Resolution (Attachment 6). Below is an overview ofthe new fees for Moffett Park. Normally development fees are effective upon adoption. As the TIFrequires an ordinance, the fee would be effective 60 days after adoption of the ordinance (secondreading).Transportation Impact Fee (TIF). A local traffic analysis was prepared for the MPSP area (Attachment10). The analysis identified several roadway intersections and freeway segments that would fallbelow generally acceptable levels of service. The study also identified improvements in the MoffettPark area that will facilitate pedestrian, bicycle, transit, and ride sharing activities. The study identifiedthe nexus between identified improvements and various land uses. Like the Citywide TIF, it is notexpected that all transportation related projects will be completed with only TIF funding.Deficiencies and possible improvements identified in the local traffic analysis are basically four types:Intersections (Sunnyvale, Mountain View, and County of Santa Clara)Freeway SegmentsEast Channel Crossings (including a grade-separated crossing over 237)East Channel Diagonal CrossingsThe first two improvement types are more auto oriented and the second two are more bicycle andpedestrian oriented. Staff has evaluated the transportation impacts and recommends an additionalTIF to cover anticipated City costs for the primarily pedestrian and bicycle serving improvements.Staff assumes 40% of the project costs will come from outside funding sources (state/federal grant orfunds) will be obtained for these major projects.Within the proposed TIF, staff has included the fair share of fees for residential and retail/commercialland uses based on the amount of trips generated in the MPSP area. This followed the same processPage 15 of 20 Attachment 1 Page 15 of 20
23-0500 Agenda Date:6/12/2023as how fees were calculated for development in Peery Park, LSAP and Sunnyvale south of 237. IfCity Council desires and at their discretion, the fees for residential development can be reduced orwaived but that would mean the unfunded portion of the TIF funded projects would increase andbecome the responsibility of the City to fund as opposed to new development. Staff hasrecommended that the TIF for retail/commercial be waived upon adoption of the new fee schedule tolessen the burden for the creation of this needed and important space in the Plan area.The recommended additional TIF for MPSP requires an amendment to the Municipal Code Title 3(Attachment 8).Utility Infrastructure. A nexus study was prepared (Attachment 11) to determine the fair share costsfor water and sewer upgrades that would be needed in the MPSP area to adequately convey cleanwater and wastewater in the park area. If a project builds the larger pipes as part of theirdevelopment, those costs would be credited toward the impact fee.Planning Review Fees. New fees are proposed for planning reviews in the Specific Plan area; theMPSP Site Master Plan Fee and the MPSP Specific Plan Maintenance Fee. A draft resolutionamending the fee schedule is Attachment 6.MPSP Site Master Plan. The MPSP Site Master Plan is proposed as a planning process toprovide a coordinated and integrated approach to Bonus FAR Developments, largerdevelopments, portions of neighborhoods, or areas under certain conditions. This process willallow the City to achieve key Specific Plan goals, such as creating new publicly accessibleopen space and streets, orderly development and land parcellation, and the provision ofneighborhood-serving uses, while allowing development flexibility and an administrativeprocess focusing on key development objectives. A staff recommended MPSP Site MasterPlan submittal requirements is included as Attachment 16. Additionally, a new fee isrecommended for this process.MPSP Specific Plan Maintenance Fee. This new development fee is proposed to collect fundsfor future updates of the Specific Plan. This fee is needed to offset costs for expectedamendments: to ensure that the plan meets its goals, and to keep current with housing anddevelopment law requirements.Sunnyvale Municipal Code Text AmendmentsAmendments to Title 19 Zoning and Title 3 Revenue and Finance of the Sunnyvale Municipal Codeare proposed to provide consistency with the MPSP. The amendments are summarized below withthe full zoning text found in Attachment 8.Repeal and replace Chapter 19.29 (Moffett Park Specific Plan, Site Master Plan in MPSP)Amend Chapter 19.90 (Special Development Permits)Amend ChapterAdd SMC Chapter: 3.56 (MPSP Transportation Impact Fee) to Title 3 (Revenue and Finance);Amend the Zoning Plan Districts Map and re-zone parcels currently within the new MPSPdistrict (see Staff recommended changes in Attachment 9, which include additional changes to theZoning Map).Staff Recommended ChangesStaff has reviewed and responded to all public comments received up until the time of drafting thisPage 16 of 20 Attachment 1 Page 16 of 20
23-0500 Agenda Date:6/12/2023staff report. A summary response “memo” is included as Attachment 9. The memo provides asummary of staff recommended changes related to:Land UseDevelopment StandardsOpen SpaceUrban EcologyMobilityThe staff recommended changes in the memo are shown as additional or revised text, illustrations,and maps. Included as an appendix to the memo is a matrix of all comments received and acomprehensive set of staff responses and all proposed changes. Any correspondence received afterthe staff report’s completion will be included as Attachment 18.Green Building ProgramThe Moffett Park Specific Plan is an ecological-innovation district that integrates moreenvironmentally conscientious elements into the development standards. Staff recommends that thecity-wide minimum green building requirements apply to development projects and that voluntaryincentives in the Green Building Program be removed for Moffett Park. The incentives for density arenot needed as there is no maximum density for residential and the non-residential intensities includeincentive programs as part of the Plan. Incentives for height are also not needed as much tallerbuildings are already reflected in the height standards and were selected based on maximum heightsthat comply with the Moffett Federal Airfield CLUP. The only other Green Building Program incentiveis for lot coverage of residential developments which staff finds is not necessary due to the carefullyselected development standards for residential developments. An update to the Green BuildingProgram is part of the Resolution (Attachment 7).PUBLIC COMMENTAs of the date of staff report preparation, staff has received over 30 comment letters on the DraftMPSP and DEIR. All public comment letters are attached (Attachment 15).Comments contained the following common themes:Clarification on location, size, and design for required parks, open space and other openspace and mobility improvements;Clarification on and in some cases, the reduction of the architectural design standards;Request to change land use designation of parcels from office to mixed-use or from mixed-useto office;Requests to increase parking maximums in the draft Plan;Requests to reduce or provide an alternative method to provide for innovation space in thePlan Area; andRequest for a retail plan that provides more flexibility for future uses and sized tenants.The summary response “memo” (in Attachment 9) provides a summary of staff recommendedchanges related to Land Use, Development Standards, Open Space and Urban Ecology and Mobility.The staff recommended changes in the memo are shown as additional or revised text, illustrations,and maps. Included as an appendix to the memo is a matrix of all comments received and aPage 17 of 20 Attachment 1 Page 17 of 20
23-0500 Agenda Date:6/12/2023comprehensive set of staff responses and all proposed changes. Any correspondence received afterthe staff report’s completion will be included as Attachment 18.FISCAL IMPACTThe MPSP project will assist the City in formulating additional potential revenue and new fees. Due tothe potential new development from the residential and commercial projects, an increase of City’srevenue, such as property tax, sales tax, construction tax, community benefit and others may berealized. Most of these revenues are General Fund revenues, which could be used to supportservices provided to the City as a whole.The MPSP Market Study shows that the market will support new residential units, commercial, office,and hotel uses, which should result in a net increase in revenue for the City. Staff is also proposingan increase to the Master Fee Schedule Planning Application Fees to reflect actual time spent on thepermit types applicable in Moffett Park and two new fees for the Site Master Plan Permit (one forprojects under three acres and one for over three acres). The permit types have been simplified toalign with permit types used throughout the City. A plan maintenance fee of 0.17% of totalconstruction valuation is proposed to apply to subsequent building permits that will be used toreimburse the City for the cost of preparing the MPSP and staff time involved in the upkeep of thedocument during its lifetime (the plan maintenance fee is the same rate as the plan maintenance feefor the Lawrence Station Area Plan and the El Camino Real Specific Plan). The new permit types andproposed fees are included in Attachment 6.In addition to all existing fees, required new development in the MPSP area would pay a new MPSPTransportation Impact Fee (TIF) for net new trips anticipated by the Plan Area, a new MPSPInfrastructure Fee for improvements to sewer and water conveyance systems, Housing MitigationFees for net new nonresidential development, and Park Dedication or payment of In-Lieu Fees forresidential uses prior to building permit issuance or Final Maps approval. Applicants of newdevelopment would also pay fees to their respective school district(s).PUBLIC CONTACTNotice of Public Hearing, Staff Report and Agenda:1 Published in theSunnewspaper2 Posted on the City of Sunnyvale's Web site3 Provided at the Reference Section of the City of Sunnyvale's Public Library4 Agenda posted on the City's official notice bulletin board5 3,970 notices were mailed to property owners and tenants within 2,000 feet of the MPSPboundary6 Email notices sent to interested parties and outside agencies (notices of Planning Commissionand City Council continuances also sent).ALTERNATIVESForward recommendation to the City Council related to the Moffett Park Specific Plan (MPSP) to:1. Approve related actions associated with adoption of the MPSP: Adopt two resolutions andintroduce an Ordinance (Attachments 6, 7, and 8 to this report)A. Adopt a Resolution (Attachment 7) toPage 18 of 20 Attachment 1 Page 18 of 20
23-0500 Agenda Date:6/12/20231. Certify the EIR;2. Make the findings required by CEQA;3. Adopt the Statement of Overriding Considerations4. Mitigation Monitoring and Reporting Program (in Attachment 5);5. Adopt the Water Supply Assessment;6. Adopt the amended Moffett Park Specific Plan (with Staff recommendedmodifications to the draft MPSP detailed in Attachment 9);7. Amend the General Plan text and update the General Plan Map8. Update the Green Building Program TableB. Adopt a Resolution (Attachment 6) to:1. Amend the Fiscal Year 2022/23 Master Fee Schedule to adjust the MPSPPlanning Application Fees, including the addition of the MPSP Maintenance Fee, theMPSP Infrastructure Fee and the MPSP Transportation Impact Fee (TIF).C. Introduce an Ordinance (Attachments 8) to:1. Repeal and Re-Adopt Chapter 19.29 (Moffett Park Specific Plan) and makeother amendments to Title 19 (Zoning) to implement the MPSP;2. Add SMC Chapter: 3.56 (MPSP Transportation Impact Fee) to Title 3 (Revenueand Finance);3. Amend the Zoning Plan District Map and re-zone parcels currently within thenew MPSP district.2. Alternative 1, with modifications.3. Take no action on the MPSP and provide direction on desired changes.STAFF RECOMMENDATIONRecommend Alternative 1 to City Council: Approve related actions associated with adoption of theMoffett Park Specific Plan (MPSP) which are to adopt two resolutions and introduce one ordinance(Attachments 5, 6, 7, and 8 to this report) and to include the staff recommended changes inAttachment 9.With the new MPSP goals, policies, and implementation the district is envisioned to transform fromsuburban office campuses to a “eco-innovation” district; a vibrant mixed-use neighborhood withoffice/employment centers, housing, open space, parks, urban ecology features, robust bike andpedestrian improvements and local serving retail stores and services. This new vision will helpSunnyvale achieve many goals found in the City’s General Plan, Housing Element, ActiveTransportation Plan, Climate Action Playbook, Green Infrastructure Plan as well as help to meetmany other important milestones the City has planned for the future.In particular, the addition of a significant amount of housing in the MPSP responds to great regionaland local housing demand while helping to support the current and future retail and other commercialservices in the area. The plan incorporates improvements to support and encourage walking andbicycling in an area that was previously auto-centric. New parks and urban ecology standards willwork to reduce the heat island effect in the plan area while encouraging outdoor recreation. The planincludes land uses and development standards that will minimize Vehicle Miles Traveled (VMT) bycreating an ideal mix of housing and jobs, adding to the mobility and circulation network, andreducing parking; thereby fulfilling City priorities to increase transit use, reduce single-occupantvehicle trips, and lessen greenhouse gas emissions.Page 19 of 20 Attachment 1 Page 19 of 20
23-0500 Agenda Date:6/12/2023Finally, staff recommend that all Council actions be effective on the same date, 60 days after theCouncil adoption of the ordinances. While resolutions are typically effective immediately, impact feesare not effective for 60 days. Ordinances are not effective until 30 days after the second reading of anordinance. Making all documents effective at the same time will reduce confusion about what isapplicable and ensure that all new fees are appropriately collected should a formal application besubmitted before all of the policies, regulations and fees take effect. This is consistent with what wasdone with the El Camino Real Specific Plan.Prepared by: Michelle King, Principal PlannerReviewed by: Shaunn Mendrin, Planning OfficerReviewed by: Dennis Ng, Transportation and Traffic ManagerReviewed by: Chip Taylor, Director of Public WorksReviewed by: Trudi Ryan, Director of Community DevelopmentReviewed by: Teri Silva, Assistant City ManagerApproved by: Kent Steffens, City ManagerATTACHMENTS1. Reserved for Report to Council2. Noticing and Vicinity Map3. Relevant General Plan Goals and Policies4. Links to DEIR, FEIR, Draft MPSP, and Background Documents5. MPSP Mitigation Monitoring and Reporting Program6. Draft Resolution to Amend Master Fee Schedule7. Draft Resolution: Actions related to Certifying EIR, Statement of Overriding Consideration,Adopting a Water Supply Assessment, Adopting an Amended MPSP and an Amendment to theGeneral Plan, and Update the Green Building Program Table8. Draft Ordinance Amending Sunnyvale Municipal Code (Title 19), Adding Sunnyvale MunicipalCode 3.56 and Amending the Zone Plan District Map within the MPSP District9. Staff Recommended Changes to Draft MPSP10.MPSP TIF Nexus Study, May 202311. MPSP Infrastructure Fee Study, April 202312. MPSP Water Supply Assessment, April 202313. Moffett Park Market Analysis, July 202014. Excerpts from Final Minutes on MPSP Item:a. Bicycle and Pedestrian Advisory Commission on March 16, 2023b. Sustainability Commission on March 20, 2023c. Housing and Human Services Commission on March 22, 202315.Public Comment Letters on Draft Plan and Draft EIR16.Recommended Site Master Plan Process17.Airport Land Use Commission-Moffett Park Specific Plan Referral COA Letter-050523Page 20 of 20 Attachment 1 Page 20 of 20