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Greenheart 1300 El Camino Real comments

From: domainremoved <Patti>
Date: Mon, 12 Dec 2016 11:34:20 -0800

Planning Commissioners:

You have a big responsibility on behalf of the community - especially
during the busy holiday season when few of us residents can participate
actively in project reviews - to conduct due diligence on the proposed
Greenheart project and its EIR and to make recommendations to the City
Council about its negative impacts and potential benefits. I am eager to
see this blighted site cleaned up (the developer has ignored multiple
requests to do that, by the way), and developed. However, I have the
following concerns.

THE PROJECT IS NOT DEFINED - it is one thing for the EIR to have studied a
range of potential uses, but it is another thing for the project to remain
poorly defined. It is now at the stage when you are asked to consider paint
colors and use permit for outdoor seating for restaurants but it is not
clearly that restaurants really are proposed. As worded, the project's
community serving uses could be a bank, real estate office, or business
services - each of which has very different vibrancy and usefulness to the
public than stores and restaurants. The developer wants you to consider a
real estate office, presumably for the housing buildings, as "community
serving". It would only benefit the landlord, the realtor and the tenants,
not the greater community; it is office space.
The developer wants you to evaluate the project and its benefits even
though there is no specific amount of office or community serving space;
those are still being presented to you as ranges that have a difference
equivalent to a half acre of space. There is not a specific project in
front of you yet.
** You should recommend that the "Community serving uses" be specified
clearly - both in type and amount of space - before recommending approval
of Statement of Overriding Considerations instead of agreeing that the
currently vague benefits outweigh the negative impacts.
** You also should recommend consideration of a Use Permit ONLY when
specific restaurant uses are proposed, not now when there is no proposal
for a clear type, size or location of any restaurants.

states "The El Camino Real Mixed Use/Residential designation emphasizes
residential use in close proximity (approximately 1/2 mile) to the station
area and downtown, in order to support area businesses, transit use and
overall downtown vibrancy. This designation also allows for a variety of
retail, office and public and semipublic uses." This project is not really
"mixed use residential"; it is "mixed use office".
Proposed at the bonus level in THE zoning district of the Specific Plan
that has "Residential" in its title it is proposed to include nearly 100%
of the office allowed but only 57% of the housing units allowed. Translated
to how many individuals or families could have a new home: the site only
proposes 183 units but could provide 322 sorely needed housing units. It
could provide 139 more!
** Recommend either that the project be approved as a Base level project
with the maximum Base level housing of 206 units OR at the Public Benefit
Bonus level size with the maximum housing in order to support the Specific
Plan's vision of this area being primarily residential.

opportunity to provide more housing, the project adds significant new
traffic, deemed adverse and unavoidable, that would further congest the
most congested part of El Camino Real. Those estimates are likely to be
understated considerably because the EIR assumes an unrealistic amount of
space per office worker (300 SF whereas national office estimates are 1/2
of that). As described in the staff report, the offices are targeted at
tech incubators, which often house quadruple the number of workers that
were analyzed in the EIR. The negative impacts could be far worse than

The $2.1 million payment is too low. It is approximately 1/3 of the extra
profit described in the flawed BAE Financial Impact Analysis. I use the
term "flawed" because it assumed 86 more underground parking spaces at a
cost of $3,655,000 that would not be required if only 1,000 parking spaces
are provided, and it does not assume ANY revenue for the parking that the
developer stated in council chambers would be charged to tenants. With the
reduced underground parking costs, the profit at the Bonus level would be
at least $10 million, not counting the initial and ongoing revenue from
charging for parking spaces.
** You should recommend a public benefit bonus payment of at least $5
million as shared benefit for the bonus size and its considerable negative

THE PROJECT SHOULD HAVE A TRIP CAP - Because the "effectiveness of the TDM
program cannot be reliably predicted" (FEIR B12), and the amount of traffic
could be quadruple the amount estimated in the FEIR if the offices have a
similar worker space allocation as the new Spaces tech incubator business
near Facebook, there should be a trip cap with penalties if it is exceeded.
After all, this is in the heart of our town and is next to transit.
** You should recommend that the required mitigation measures and the
Development Agreement include a specific trips limit that allows no more
trips than the net impact during peak hours and daily that was assumed in
the Final EIR.

implications of grade separation on this project's transportation
circulation could be profound if Oak Grove and/or Glenwood are lowered,
which would occur in the proposed grade separation alternatives. Not only
would motor vehicle traffic flows be affected, bike movements would also be
affected, and intersections either blocked or complicated.

Additionally, the City has not conducted nexus studies in order to
determine appropriate impact fees for housing impacts or for transportation
improvements. For reference FEIR (3-33) states "the City has not adopted a
valid nexus study that allows for the collection of a housing impact fee"
 The Lisa Wise Consulting Inc firm pointed out in 2014 the lack of a
mechanism for the City to fund public improvements in the Specific Plan
**You should recommend that the City put the horses before the cart, and
adopt nexus studies and impact fees to address impacts of projects like
this one that would worsen the housing shortage, worsen traffic congestion,
and not pay their fair share of needed public improvements.

I heartily encourage appropriate development on this site. That should be a
residential-intensive project that improves, not worsens, Menlo Park's
abysmal jobs/housing ratio. That should also be a project that is truly
transit-oriented, rather than significantly worsening traffic in the most
congested part of our downtown area. Approvals of any project should be
based on a well-defined, not ambiguously described, project. It is time for
this developer to be clear about its intentions rather than continue to be
vague. You need to demand that specificity as part of your due diligence.

Patti Fry
Menlo Park resident and former Planning Commissioner
Received on Mon Dec 12 2016 - 11:38:28 PST

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