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Menlo Park Ballot Measure Concerns re City Actions, Disclosures and Representations.

From: domainremoved <George>
Date: Sun, 10 Aug 2014 16:15:45 -0700

City Council and City Staff have strong interests in exoneration of the
Specific Plan current implementation by seeking the voter’s rejection of
the Initiative attempting to limit office space development underway on El
Camino Real. They are actively campaigning against the Initiative.
However, because of their positions of power and control of City resources,
the City has a duty to only make accurate, complete, non-evasive fair and
impartial disclosures to the voting electorate concerning the election
issues. The City is not doing so. First the City accepted an
incomplete, vague, purportedly impartial report that didn’t even comply
with their scope of work, including failure to do a proper transportation
impact analysis. Second, the City requested no independent analysis of
either the plan as currently proposed to be implemented by two large
projects (Stanford and Greenheart), or modification of that proposed plan
implementation by the Initiative, with the community adapted Vision Plan
and Plan the Guiding Principles. Third, the City is hiding both the impacts
of the 400,000 sf of office proposed in these two projects and the impacts
City council previously waived when adapting the specific plan.

First, the City hired the Lisa Wise Consultants, Inc. (LWC) last May to
perform a hypothetical abstract study of the Initiative compared to the
Specific Plan. However, no requested traffic impact analysis was done in
compliance with City guidelines and accepted practice, which require much
more than a mere calculation of total daily trips that are forecast to or
from a development area, as independent traffic expert, Tom Brohard
Associates, has demonstrated (attached). The consultant who prepared the
LCW traffic analysis lacks the necessary experience to analyze traffic
impacts and ignored the city’s Transportation Impact Guidelines (amended
January, 2014) and the city’s Circulation System Assessment (CSA) document,
which require critical information including volume changes to specific
streets and intersections based upon geographic distribution over specific
roads and intersections. As Mark Spencer in the W-trans Stanford traffic
studies also confirmed, the routes used to those gateways must be assigned
(trip assignment) to determine traffic impacts to roadway segments and
intersections. Instead of requiring a CEQA-level traffic impact analysis
or an analysis applying city guidelines, the city accepted a simplistic
analysis which does not include any determination of whether the Initiative
“would result in equal, greater than, or lesser impacts when compared to
the project evaluated in the ECR SP EIR” that was requested.

Second, the LWC contract scope ignored the anticipated implementation of
the specific plan by the two major proposed projects (Stanford and
Greenheart) and comparison with the Initiative or Plan Vision. These two
projects exploit the Specific Plan’s excessive allowances. Each of these
projects consists of office space amounting to over 90% of their total
non-residential space, a total of 400,000 SF of El Camino Real office space
where no office space presently exists. The Initiative is a direct result
of announcement of these two projects, and the city’s multiple rejection of
attempts to reasonably limit office space. Without these projects and
city’s failures to correct office space loopholes, there would be no
Initiative petition. The city is already studying traffic and CEQA impacts
for each project. Moreover, on July 10, five days before the City Council’s
July 15, 2015 meeting accepting the LWC vague report, Thomas Rogers made a
CEQA finding that the Greenheart project had significant
Transportation/Traffic effects not previously analyzed (attached) requiring
an Infill EIR. That determination was not disclosed at the Council’s July
15 meeting. Given the costly environmental work on these projects, there
is no reason they shouldn’t be fully considered in the City’s independent

The City knows by the city’s CSA document that most office traffic to/from
El Camino Real comes from freeways at peak AM and PM hours, whereas
residential and retail traffic is substantially local and at non-peak
hours. The City CSA document demonstrates that 69% of office traffic
to/from El Camino Real uses city gateways at highways 280 or 101/84 (28% of
office traffic is to/from 280, and 41% to/from 101/84). Arbitrarily
assuming for the moment that 4,400 auto trips a day flow to or from this
400,000 SF of new Stanford and Greenheart office space, then 69% of it --
or approximately 3,000 trips a day – would be headed through our
neighborhoods to highways 280 or 101/84, requiring a traffic impact
analysis of roadway segments and intersections through our neighborhoods to
those destinations.

Third, the City is hiding transportation impacts from the public. To make
an informed decision the electorate needs to know the transportation and
other impacts caused from the new 400,000 square feet of office space on El
Camino Real, which does not exist. The city is hiding these numbers behind
cityspeak that only a much smaller number of square feet should be
considered as new development, because previously those sites were the
location of approved projects, or were included in a prior EIRs, or had
existing buildings on them even if unoccupied. That information may be
relevant to examining or comparing past reports, but is useless in allowing
the electorate to understand what current changes or impacts will be made
to the currently existing traffic volumes and conditions.

City Council also waived significant unavoidable impacts caused by the
Specific Plan’s originally anticipated buildout per its illustrative plan,
on 14 roadway segments, and 15 intersections, including 3 on El Camino
Real, 5 on Middlefield, 3 on Willow and 2 on Santa Cruz Ave, plus queuing
delays. The public understanding at the time was that the public had to
endure impacts, and resulting hardships, to receive benefits from the
vibrancy and village type character and other goals of the Specific Plan
Vision and Guiding Principles. By allowing office space to overwhelm the
possibility of achieving the Plan Vision and Guiding Principles, the public
no longer receives those benefits. Those impacts must be disclosed to the
public to make an informed decision about limiting office space through the

The city has the duty to correct the omission of a legitimate traffic
impact study in the LWC report, to correct any misleading and incomplete
disclosures, expand the scope to include the two projects implementing the
specific plan, and to make true, complete, candid, forthright disclosure,
without purpose of evasion, to inform the public and voters of potential
impacts and benefits from the Plan, the anticipated Plan Implementation by
the two projects and by the Initiative.


George C. Fisher

George C. Fisher
​1121 Cotton Street​
​Menlo Park, CA
(650) 799 5480
Fax (650) 475 1849

Received on Sun Aug 10 2014 - 16:13:00 PDT

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