Preface
Greenmeadow Community Association, Inc.(GMCA) would like to preface our comments on the DEIR by thanking TKCJL and BUILD for their outreach to our community. Their early recognition of the need for a study of the Charleston/Arastradero School Corridor helped to move the C/A Study forward. We appreciate the seed money that was provided by TKCJL and BUILD to jumpstart the C/A Study. Further, their participation in the stakeholders group and support of the C/A Plan was helpful in getting the C/A Plan approved. We thank them for that and we hope that this positive working relationship will continue into the future.
We have tried to shape our comments on the DEIR in such a way that they will contribute constructively toward the development of a project that will be a source of pride both for the applicants and our Palo Alto community.
Comprehensive Plan Amendment and Zoning Change
The 901 San Antonio DEIR explains that this project requires a Comprehensive Plan amendment and zoning changes. It does not provide information about the potential impacts of making those zoning changes if, for some reason, one or both of these projects fails to move forward and others take its place. GMCA asks that the Final EIR provide information about whether or not the Comprehensive Plan amendment could or should have a sunset clause and whether the zoning changes (Mixed Use and PC) could or should be specific only to this project.
Without knowing the funding status of the proposed BUILD & TKCJL projects, a concern is that if the proposed projects do not move forward, then another developer might take advantage of the significant density bonuses that would be granted by these changes. Another project might not deliver the synergistic uses and other community benefits that this project promises to deliver in exchange for the density bonuses.
It would be prudent to explore this possibility, especially because the DEIR reminds us that Comp Plan amendment changes cannot be conditioned.
Pedestrian/Bicycle LOS Impacts
The 901 San Antonio TKCJL and BUILD projects are located on the Charleston/Arastradero (C/A) School Corridor, a school commute route that serves eleven public and private elementary, middle and high schools. The Charleston/Arastradero Study identified safety improvements for pedestrians and bicyclists on Charleston/Arastradero. The improvements are intended to mitigate cumulative pedestrian and bicycle safety impacts created by the proposed 901 San Antonio projects and other proposed and anticipated projects on the school corridor.
Despite the identified impacts of 901 San Antonio, its DEIR does not study pedestrian and bicycle LOS impacts as GMCA previously requested in December 2004. In that statement we asked that the EIR measure impacts on pedestrian and bicycle level of service, using the U.S Department of Transportation Bicycling Compatibility Index and the Florida DOT pedestrian model (the scale applied in the C/A Study).
Excluding the ped/bike LOS analysis is inconsistent with the approved Charleston/Arastradero Study and Plan. Failure to study pedestrian and bicycle safety issues on the school corridor also is inconsistent with Comp Plan Goal T-6: “A High Level of Safety for Motorists, Pedestrians, and Bicyclists on Palo Alto Streets” and Policies T-40: “Continue to prioritize the safety and comfort of school children in street modification projects that affect school travel routes,” and T-28” Make effective use of the traffic-carrying ability of Palo Alto’s major street network without compromising the needs of pedestrians also using this network.”.
Further, this lack of ped/bike LOS analysis fails to acknowledge Charleston/Arastradero’s special status as part of the School Commute Corridors Network that was adopted by Council in October 2003. Council adoption of the School Corridors Network comprised a statement of policy for the City of Palo Alto that principal school commute routes be given priority for public investment purposes and be accorded enhanced review as regards proposals for new commercial driveways and other street changes. Collectively, we believe that these policies and goals require that the DEIR study pedestrian and bicycle impacts. Currently, the DEIR does not, even though this information is readily available in the data and models that were prepared for the C/A Study.
The C/A Plan pedestrian and bicycle safety improvements should be called out as mitigations for this project. The C/A Plan is being constructed for implementation of a paint trial in Fall 2006. If the trial fails, what alternative mitigations might be recommended to mitigate ped/bicycle impacts?
While the DEIR ignores the ped/bicycle safety impacts and mitigations identified in the C/A Plan, the DEIR recommends vehicle capacity improvements provided by the C/A Plan (Mitigations Measure B.1-1).
Interestingly, the DEIR transportation analysis shows minimal increase in trips during peak hours and large increases in trips throughout the day. This underscores the need for corridor safety improvements recommended by the C/A Plan, particularly reducing speeds for school commuting children during the afternoon. This also supports the C/A Plan safety improvements being called out as a mitigation for the project.
The Comprehensive Plan and the approved C/A Plan do not prioritize vehicular capacity over safety and, therefore, as a matter of policy, ped/bike safety impacts should be addressed in this EIR.
Site Access on Charleston
The DEIR states, “A passenger drop off and pick up area is proposed on East Charleston Road, approximately 290 feet west of San Antonio Road. A second connected driveway on East Charleston Road would be used for service vehicles, deliveries, and residential parking for senior residential uses and for limited access to parking below residential buildings.”
Consistent with Mitigation Measure B.3.1 of the DEIR, GMCA opposes left turns in or out of this access point. Vehicles waiting to turn left into the driveway probably would block at least one lane of traffic while waiting for gaps to turn during peak hours. The resulting queues and unexpected lane changing as drivers try to maneuver around left-turning vehicles would create both delay and potential for conflict between vehicles.
Left turns out present a different problem in that it is possible there is not adequate queue length to accommodate cars waiting to turn left during peak hours.
Further, as the DEIR points out, “This segment of Charleston is designed as a future bike route with Class II bike lanes. Allowing full movement access driveways at mid-block increases the number of conflict locations, which could negatively impact safety conditions.” The benefits of making the facility a safe bike/ped destination are clear, and plans should support making alternative modes of transportation to the site as safe as is reasonably possible.
Even if left turns are not permitted, we would like the DEIR to analyze whether or not the queue length of this driveway is adequate to keep cars from queuing on Charleston. For instance, if fifty (or even only ten or twenty) people come to pick up Bubbe and Zaydie (Grandma and Grandpa) for Shabbat dinner during Friday evening rush hour (this is prime Bubbe/Zaydie pick up time), will the queue spill out onto Charleston? The on-site queue capacity is unclear given the need to share this space with the garage exit, loading dock entrance/exit as well as ped/bike access. Also, one might expect that average loading time for seniors will be a little longer because many older people have to move a little more slowly. Queue analysis should plan for these necessary delays.
Finally, Mitigation Measure B.3.1 says, “It is anticipated that left turn access to and from the site to and from Charleston Road will be prohibited, unless additional widening for a turn lane is permitted by the city.” A decision to widen the road would require heightened review for bicycle and pedestrian safety as is required on any portion of the Palo Alto School Commute Corridors Network. Heightened safety review of road widening has not been provided in the DEIR.
Loading Dock Access
GMCA opposes possible relocation of the loading dock to Charleston as suggested in Mitigation Measure B.4.1. Slow moving, large trucks maneuvering in and out of a loading dock in this segment would present an additional barrier to traffic flow between and through the busy San Antonio/Charleston and Charleston/Fabian intersections. Trucks limit
visibility of drivers around them. Further, trucks would create potential for conflict with bicyclists on the planned Class II bike route. Analysis of the Bicycle Compatibility Index would be a useful tool to help understand the effect of a loading dock on this segment of Charleston.
However, it is not clear from the explanation and drawings in the DEIR how the San Antonio loading dock would work. A Fabian relocation of the loading dock might be acceptable if room can be made for it.
Transportation Demand Management (TDM)
Easy public transit access from this site is limited. The project is 1 ½ miles from the nearest train station. During the preliminary review meetings and study sessions for the project, the possibility of shuttles for the residents of the project was discussed. This is not included in the Transportation section of the DEIR.
In City Council Preliminary Hearing Minutes from June 14, 2004, Ms. Hebert, TKCJL Executive Director, Campus Development is quoted as saying, “…part of the planning for the senior residential project on the CJL was transportation services through a shuttle or other comparable type of service. In addition, it was important for the project to be developed as a walkable, pedestrian- and bicycle-friendly environment, and to make it possible for children to get to the site readily to participate in the recreational and after-school programs.”
We agree, and we hope that transportation shuttles for residents are still part of the plan. It would be useful to have a description of a TDM program and an analysis of its trip reduction projections in the Final EIR.
School Impacts
This section contains an error. On page 225, Hoover Elementary, a magnet school, is identified as the neighborhood school for the project. This is not correct.
The DEIR estimates 22 new elementary, middle and high school students would be added to PAUSD by the project. It acknowledges
that “there could be some indirect student generation in other residential neighborhoods as seniors move from their existing residences to proposed senior apartments…” However, it claims that this secondary effect cannot be accurately estimated. The EIR, therefore, does not discuss it.
Unlike older regions of Palo Alto, housing in the south Palo Alto area was developed in the mid- to late- 1950s. Young couples and families moved there over 40 years ago and populated the schools. Their children are no longer school aged, and many of the homes are due to turn over to the next generation of users of our school system. Our analysis of the 1990-2000 census reflects this coming “bubble” of household transition based on the significant demographic shift in distribution of head-of-household age distribution.
Census data shows households only increasing by less than 3.5% in the 94306 zip code, growth in households age 75+ grew by approximately 20%--from 1,076 in 1990 to 1,270 households in 2000. This is a strong indicator of potential higher rates of future turnover due to the aging demographic and a corresponding influx of families. PAUSD projections do not incorporate this impending demographic change and, therefore, may have significantly overestimated school capacity in south Palo Alto. The transition could create overcrowded conditions for children who live here now and who might move into our community.
With so many people reaching the age when a single-family home may become a burden, it is good that developers like BUILD & TKCJL are building residential projects with support facilities that specifically target this demographic group. However, it is reasonable to assume that these market factors could trigger a larger number of single-family home sales as older residents move from their long-time homes into these new residences. This could exacerbate the “bubble effect” and rapidly bring a larger percentage of families with new students into the district. We had hoped (and previously requested) that the EIR would investigate this possibility.
We wonder if comparable projects for seniors could be found that might provide some indication of how high the probability of this transition might be. This might give the community some indication for planning purposes of what the real impacts on schools of population displacement might be.
Library Impacts
The DEIR says that “the incremental increase in library usage generated by the project would not significantly impact the City’s library system.” (DEIR, p. 226). What will the project pay in library impact fees? Will some portion of the project be excused from paying impact fees? Please clarify.
Floor Area Ratio (FAR)
Given that the project has changed so substantially from the project described in the DEIR, we had to ask staff what current FAR is for the site. Could the Final EIR please spell out total FAR for the current proposed project?
Southern Gateway Aesthetics
As of this writing, March 19, 2006, the photo simulations of the project in the DEIR and the architectural plans for the TKCJL/BUILD site, do not show combined elevations of the proposed projects for the San Antonio frontage from the perspective of a visitor entering the city via San Antonio Road.
A concern is that a long, tall wall of varying heights extending 1,133 feet (roughly 2/10 of a mile) along San Antonio and rising to about 60-70’ at the San Antonio/Charleston intersection may create an unwelcoming entry to south Palo Alto and could be an invitation to graffiti artists.
Comp Plan goal L-6 requires “Well designed buildings that create coherent development patterns and enhance city streets and public spaces.” And policy L-49 “Design buildings to revitalize streets and public spaces and to enhance a sense of community and personal safety…avoid blank or solid walls at street level; and include human-scale massing.” A stated project objective is “to develop a project that creates a visible marker as a southern gateway to the City”. A question the DEIR might investigate is what the treatment of this wall will be that will make this gateway friendly and welcoming (public art? landscaping? other options?) and prevent graffiti vandalism.
The applicant has explained that they will provide some landscaping, motion sensitive cameras and 24-hour security and that graffiti would be quickly dealt with. We appreciate their sensitivity to the security issues. However, this answers only part of the question.
This frontage is where Palo Alto has planted its “Welcome to Palo Alto” sign. It will be where visitors get their first impression of our community. Of course, plans for the project are still unfolding. Many issues are still being worked out by the architects. We look forward to seeing a rendering of the combined TKCJL & BUILD San Antonio elevations to illustrate the architects’ vision for the full length of the San Antonio frontage.
Bicycle Parking
Bicycle Parking appears adequate, but it is not clear from the drawings what accommodations will be in place to help bicyclists merge safely with vehicular traffic to get to the bike racks in the garage.
Cumulative Impacts
The List of Pending Projects in Appendix D is missing several large projects which likely will have impacts on intersections studied in this DEIR. These should be included:
-San Antonio Circle (120 efficiency affordable studio units in Mountain View currently under construction near Alma and San Antonio)
-Re-occupancy of the Shoreline Area vacant office space (50%--442,800sf assumed according to 100 Mayfield Mall Project DEIR, Table 4.12-14.
-Charleston Plaza (140,000sf retail in Mountain View currently under construction at the intersection of Charleston, Rengsdorff, and 101S access.
Transportation—Regional & Local Connections
The DEIR says that the project will generate fifteen additional trips in the am peak hour (App. B. p. 4-22). As our community reviews 100 Mayfield Mall and TKCJL/BUILD EIRs, GMCA hopes that we will
keep in mind that, although these two projects both report incidental increases in traffic, they are subtracting trips generated by the previous use that have not been on the streets in nearly a decade. In the interim, background growth has filled capacity that was engineered for the previous use. Only in the Lewis Carroll world of EIR traffic analysis does traffic vanish on this scale. The cumulative reality we will have to live with is quite different.
That is why the C/A Study was done. The resulting plan mitigates the transportation capacity and safety impacts that this project and others will create on Charleston/Arastradero. The Plan did not, however, provide necessary mitigations for other arterials, expressways and residential arterials that will be affected by this and other projects.
The DEIR points to 2015 cumulative conditions at San Antonio/Middlefield (Vol. II, Technical Appendices, Transportation Section, Appendix E, p.2) that would require “extensive reconstruction of the intersection adding a second northbound left turn lane, a second left turn, and an exclusive eastbound right turn lane. These improvements would require the acquisition of right-of-way, removal of mature trees, relocation of sidewalk and utilities, and modification to the traffic signal. The DEIR excluded this mitigation from the summary of recommended mitigations. Comp Plan policies that may apply here include:
T-27 “Avoid major increases in street capacity unless necessary to remedy severe traffic congestion or critical neighborhood traffic problems. Where capacity is increased, balance the needs of motor vehicles with those of pedestrians and bicyclists.”
T-39 “Continue to make safety the first priority of citywide transportation planning. Prioritize pedestrian, bicycle, and automobile safety over vehicle-level-of service at intersections.”
T-40 “Continue to prioritize the safety and comfort of school children in street modification projects that affect school travel routes.”
GMCA would like to suggest that the interplay of San Antonio vehicular capacity and pedestrian/bicycle safety should be examined more closely in context of this project , 100 Mayfield Mall, Charleston Plaza and San Antonio Circle projects. We have three areas of concern:
1). Improving bicycle connectivity across San Antonio at Nita
If mid-day trip volumes on San Antonio are to increase, improved amenities for bicyclists across Nita to the Bryant Street Bike Boulevard would be necessary to provide the Palo Alto community and the Greenmeadow neighborhood with safe non-motorized access to the San Antonio train station.
Further, it would provide a safe extension of the School Commute Corridors Network for Palo Alto school students who live on the south side of San Antonio to designated school routes on Mackay and Nelson. An additional advantage would be improved connection of Palo Alto neighborhoods to private schools in Mountain View, including the Jewish Day School and Girls Middle School, which many Palo Alto children attend.
2). Functionality of Arterials
In the interest of preventing diversion of arterial traffic to neighborhood streets in south Palo Alto and Mountain View, we hope that the Council will look carefully at the data provided in the 100 Mayfield Mall and 901 San Antonio EIRs regarding cumulative trips added to south Palo Alto arterials.
Some balance between vehicular capacity and provision of safe passage for pedestrians and bicyclists will need to be struck.
We are not suggesting that another major study (on the order of a C/A Study) is necessary, but we should consider what capacity improvements might be necessary and whether or not they would improve or degrade bike/ pedestrian safety.
3). Arterial Access
If access to eastbound San Antonio were eliminated during rush hour by the closure of the San Antonio underpass to southbound traffic (as has been suggested as a possibility in the 100 Mayfield DEIR), this may trigger the TIRE index on some streets within Palo Alto as cars will have to seek alternate routes. It is unlikely that the short unsignalized queue from southbound Central to eastbound San Antonio will be able
to replace the capacity currently provided by the San Antonio underpass, especially with cumulative increases in traffic volumes.
Freeway Access
How will the cumulative impacts of all of these projects affect access to 101S at the end of Charleston Road? The addition of 140,000sf retail (This project is visible from the freeway and is likely to invite cars to exit at San Antonio/101 and get back on at Charleston/101), the 901 San Antonio project, 100 Mayfield and numerous other projects are likely to impact freeway access points. This freeway access does not appear to be studied in the DEIR.
Conclusion
We thank you for this opportunity to comment on the 901 San Antonio Draft Environmental Impact Report. We hope that these comments can be used constructively to develop a Final Environmental Impact Report that provides information that is needed to ensure a successful project. The proposed project offers a rich cultural addition and significant affordable housing to our community. TKCJL and BUILD will be welcome neighbors.