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Comments on Greenheart Project DEIR

From: domainremoved <Patti>
Date: Mon, 4 Apr 2016 16:06:53 -0700

Dear City,

Thank you for the opportunity to comment on the Draft EIR for the
Greenheart 1300 El Camino project. The site provides an exciting
opportunity to remove long-vacant and under-utilized properties. However,
as indicated by the Draft EIR, the Project studied would introduce
significant adverse impacts, particularly traffic congestion, in the heart
of our town. It also would exacerbate the existing housing shortage.
Because of these major negative impacts, decision-makers have an obligation
to either a) make findings that the project’s benefits outweigh the
negative impacts, b) approve a smaller project that was studied in the
DEIR, or c) work with the developer to create a project that is better for
Menlo Park. The DEIR should study the actual project that Greenheart
intends to build at either the Base or Bonus level.

It is quite troubling that the Project evaluated in the DEIR is not what
the developer intends to build, as indicated in Greenheart’s open house,
their January 27 2016 Proposal, and their presentation to the Planning
Commission on March 21st. For example, Greenheart states that the Bonus
project would only have 182 residential units, about 10% fewer than the 202
units studied in the DEIR. This is material. At the same square feet
allocated to residential, these units would be, on average, 11% larger,
with potentially more school impacts than the DEIR Project.

It also appears the developer has no intention of building 29,000 SF of
community serving uses:

   - Approximately 10,400 SF of “community serving” space in the office
   building is characterized as flex space. That is 36% of the maximum range
   studied.As pointed out in the BAE March 14, 2016 study, office rental rates
   are assumed to be $66/SF and retail rental rates are assumed to be $36/SF.
   With the potential for the flex space to yield revenue of $30 more per
   square foot if it were office, it is unreasonable to think the actual use
   would be anything other than office (not retail or other community serving
   uses). The DEIR needs to acknowledge that.
   - The developer’s January 2016 Proposal mentions using 2,500 SF for real
   estate rental office in the residential building, further reducing what is
   potentially community serving.

It also is quite troubling that the BAE Urban Economics March 14, 2016
financial modeling and public benefit analysis used assumptions about uses
of space that do not match the DEIR Project or Base Alternatives. The
assumptions also do not match those in the Project Case and Base Case
presented by Greenheart in their January 27, 2016 Proposal to the City.

   - In the BAE analyses, costly elements such as underground parking
   spaces, are greater in quantity than in either the DEIR Project and the
   Greenheart Proposal, and developer revenue is understated by omitting
   revenue for commercial and residential tenant parking, which is
   Greenheart’s stated intention to charge. These serve to underestimate the
   financial return of the actual project.
   - Both the Greenheart Proposal and the BAE analysis also use a different
   Base Case than either of the Alternatives evaluated in the DEIR. For
   example, the Greenheart Proposal states that at the Base level, there would
   be 130 residential units whereas the DEIR evaluated 206 and 139 units in
   the Base Residential and Base Office Alternatives, respectively.

The Greenheart and BAE comparisons between a Bonus project and a Base
alternative provide artificial comparisons because neither utilize the same
project components as the Bonus and Base alternatives in the DEIR, and not
even the same ones as each other.

This development is in the part of the downtown Specific Plan designated to
focus on residential development. The City, and the DEIR, should evaluate a
Bonus-level Residential Alternative, which would better satisfy the
Specific Plan’s goals for this area while also imposing significantly less
rush hour commuter traffic into our already congested intersections and

The DEIR should study the real Project, not a hypothetical one, and at
least one Bonus level Alternative. Any analysis of financial and other
benefits of the Project and Alternatives also should be of the same project
alternatives. The evaluation process Is a sham otherwise, and the City will
be making decisions based on faulty information.

Additional comments are attached.


Patti Fry

Menlo Park resident, MBA, and former Planning Commissioner

PS Any analysis of financial benefits should omit impact fees. By law,
these are required to be no greater than the additional costs to the city.

Received on Mon Apr 04 2016 - 16:12:33 PDT

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