City and School District criticize impacts analysis and sufficiency of mitigations for Stanford’s growth plans.

School Board takes forceful stand on new Stanford growth analysis. City also submits substantial concerns, but with limited council input.

Santa Clara County will accept public comments until July 26.

In response to the recirculated Draft Environmental Impact Report for Stanford’s proposed academic expansion, commonly referred to as the GUP, the PAUSD hired a lawyer to assess the sufficiency of the analysis and held a special meeting during their summer break to weigh in on the district’s draft comment letter to Santa Clara County, the body responsible for approving Stanford’s General Use Permit. In contrast, after hearing a rough summary of projected impacts from two newly proposed housing alternatives in the recirculated DEIR, City Council offered general comments and delegated the city’s formal letter to staff with no further council review or public meeting prior to the close of the comment period. Despite their different approaches, both the school district and the city found the recirculated DEIR to be sorely inadequate, both in its analysis of likely impacts and the sufficiency of offered mitigations.

Also relevant to the GUP, in addition to a recent proposal to raise the county’s housing impact fees to $143 per square foot for Stanford’s academic growth, Santa Clara County is now considering an inclusionary housing ordinance that would require new rental or for-sale faculty and staff housing projects to designate 16 percent of units as below-market-rate housing. If located more than six miles from campus, the inclusionary rate would increase to 20 percent of total units. As currently drafted, the ordinance would not allow Stanford to pay in lieu fees instead of building the BMR units. The County Planning Commission will consider the draft ordinance on July 26.

The comment letters submitted by the PAUSD and the City of Palo Alto, attached and summarized below, along with the recent Palo Alto Matters article on the recirculated DEIR offer details and food for thought about Stanford’s proposed expansion. Don’t miss your chance to make sure your voice is heard too. The final EIR must address every comment submitted. Public comments will be accepted via email until July 26:

County of Santa Clara
Department of Planning and Development Attention: David Rader
County Government Center
70 West Hedding Street, San Jose, CA 95110
Email: David.Rader@pln.sccgov.org

Key conclusions outlined in the PAUSD letter include:

Newly identified significant and unavoidable impact to housing, Impact 5-17, “obfuscates the Project’s scale and impact.”  Impact 5-17, concludes that “construction and/or operation of off-site housing would result in off-site environmental impacts,” referring to an unspecified amount of affordable housing in unspecified locations that would “disproportionately” affect Palo Alto, Menlo Park and Mountain View, but makes no effort to quantify those effects.The district argues that Impact 5-17 “changes the nature, scope and scale of the project … without providing any detail as to what are the precise changes” and finds it “so fundamentally and basically inadequate and conclusory in nature” that the DEIR must be revised and recirculated in its entirety.”

Mitigation Measure 5.17.1 is so vague and unenforceable that it amounts to “improperly deferred mitigation.”  The Measure offers no enforcement mechanisms, merely stating that other local governments “can and should mitigate the impacts caused by the project’s off-campus housing.”

Analysis understates current and future enrollment impacts and threatens to impose a major funding burden on Palo Alto taxpayers. By using outdated student generation rates (SGR), the DEIR analysis “understates future enrollment demand by almost 50 percent.” The district estimates that Alternative A (all new housing need met on-campus) would generate 2,834 additional PAUSD students.

The cost of educating 2,834 new students at current per-student expenditures would “exceed $51 million per year.” Furthermore, as a basic aid district, PAUSD operations are funded directly by property taxes, not state funding. “Much of Stanford’s development is on land that is exempt from paying property tax, yet the … project documentation is silent [on] how PAUSD and the people of PA can be expected to educate the incoming students created by Stanford’s development.

Fails to fully mitigate impacts related to school operations. Even though development fees are automatically deemed sufficient (under state law) to mitigate need for new school facilities, “the EIR must still examine environmental impacts that affect school operations but are not directly related to the need for new school facilities.” Those secondary impacts include exacerbating traffic (changing traffic patterns), noise, GHG emissions, air quality, and safety concerns.

For every 400-500 new elementary students generated by Stanford, PAUSD would have to build an additional neighborhood school, with each requiring a 3-4 acre site. The RDEIR “ignores the secondary potential environmental impacts associated with this new development that would be needed as a direct result of Stanford’s development.”

Key conclusions outlined in the City letter include:

Newly identified significant and unavoidable impact to housing lacks specificity and wrongly suggests that the city’s updated Comprehensive Plan accounted for the Stanford project’s growth. The city contends that such a conclusion is “unfounded and there is no evidence in the administrative record to support [the] assertion.” Furthermore, [c]iting the City’s Comprehensive Plan and suggesting it anticipated this additional population growth is not only wrong, failure to disclose impacts renders the document inadequate” under CEQA.

Like the school district, the city finds mitigation measure 5.17.1 sorely deficient. Stating that local agencies “can and should” mitigate the environmental impacts from off-campus housing is “not a satisfactory mitigation under CEQA and irresponsibly shifts the [mitigation] burden from the University to Palo Alto and surrounding communities.” The letter asks the county to require “greater analysis of how induced population growth will impact Palo Alto” as well as specific mitigation measures, citing three potential examples.

Findings regarding Vehicle Miles Traveled impacts are flawed. The DEIR finds that  VMT will increase and air quality will worsen under Alternative A (housing needs met on-campus) as compared to the base project (only 550 units/beds provided on-campus). However, no analysis was undertaken regarding the VMT and air quality impacts of off-campus housing necessitated by the base project, despite the mitigation requirement that local communities absorb Stanford’s unmet housing need. In the absence of proper analysis of the VMT and air quality impacts from off-campus housing demand caused by the base project, “[a]ny comparison between the Project and the Alternatives is meaningless and misrepresents the environmental impacts to decision-makers.”

The No Net New Commute Trips mitigation does not adequately address direct and indirect traffic-related impacts. The city reiterates its concerns regarding the methodology and feasibility of NNNCT and cites the significant strain Stanford’s growth has placed on the City’s transportation network and resident satisfaction. “By not identifying the true traffic-related impacts of the Project, the burden of responsibility shifts from the University to Palo Alto and surrounding communities. Not only is this not equitable, it is inconsistent with CEQA.” Three additional mitigation measures are suggested, including funding for transportation infrastructure, coordination and enhanced connections between the Marguerite and City Shuttles, and fair share payments in line with the city’s transportation impact fee requirements.

Other Concerns: The city also takes issue with the sufficiency of the DEIR’s housing alternatives analysis regarding aesthetics, project objectives and public services and offers support to PAUSD, calling for “the impacts to PAUSD, new school sites and funding for increased enrollment [to be] more clearly disclosed to the public in an updated environmental document.”

If any of those concerns strike a chord with you, or if you have alternative issues to raise, be sure to get your own comments in by Thursday July 26.

Should Stanford meet housing demand it creates?

New analyses show current housing fees insufficient and confirm heightened congestion impacts particular to housing development.

Public comments related to Stanford’s proposed academic expansion raised big concerns about obscured impacts in Stanford’s analysis and unmet new housing demand. Under the leadership of Board President Joe Simitian, the Santa Clara County Board of Supervisors stepped up to the plate to clarify costs and implications.

The original Draft Environmental Impact Report for Stanford’s pending General Use Permit application, (commonly referred to as the Stanford GUP), relied on surrounding communities to provide 2,245 new housing units to support the university’s growth. But vagueness about how much would go where led to limited, generalized analysis of potential impacts. To offer the public a fuller picture, the county commissioned a nexus study to quantify the cost to the county (i.e., taxpayers) of meeting below-market-rate housing needs created by Stanford’s planned expansion. Also at the county’s initiative, Stanford analyzed two alternative housing scenarios in which Stanford would build on-campus housing for more of the faculty, staff and students its expansion would generate. Updated findings are published in a Recirculated Draft Environmental Impact Report.

Together, the new data and analysis highlight a fundamental conundrum. Unless there is a major adjustment to housing impact fees, allowing Stanford to shift its housing burdens to off-campus communities would also shift significant costs to taxpayers (and may risk that the housing won’t get built). But requiring the university to house the new demand it creates will cause additional, substantial, and concentrated impacts in Palo Alto. In addition to teeing up those key trade offs to inform the county’s decisions about the project, the new housing analysis also reveals that even in a truly transit-rich environment, residential development, by its nature, makes it harder to get cars off the road. Read on to learn more about impact fees and key takeaways from the updated DEIR analysis.

If you want to tell the Board of Supervisors your thoughts on housing impact fees, you can email Joe Simitian (our District 5 supervisor) here and find contact info for other supervisors here. The public has until July 26, 2018 to submit comments on the recirculated DEIR to Santa Clara County.

The county will host a public meeting to hear and receive comments on the recirculated DEIR in Palo Alto on July 10, 2018 from 6:00- 8:00 pm (Palo Alto Art Center, 1313 Newell Road).

Housing impact fees fall far short of full mitigation for newly created below-market-rate housing needs.

 

2018 Santa Clara County nexus study on housing impact fees. According to county staff report, “The Administration is recommending the maximum supportable fees per square foot for Academic Space and Faculty and Staff Housing.”

Santa Clara County and many municipalities, including Palo Alto, impose housing impact fees on new development to help offset the cost of public subsidies to meet related affordable housing needs. The new county nexus study indicates that the cost to support below-market-rate housing demand created by Stanford’s planned growth comes to $143.10 per square foot of new academic space. A similar nexus study commissioned by Palo Alto in 2016 found that a housing impact fee charged to commercial developers (office/R&D) could be justified at up to $264 per square foot. Stanford currently pays the county a housing impact fee of $35 per square foot. The 2018 Stanford GUP proposed reducing that payment to $20 per square foot.

On May 8, the County Board of Supervisors discussed raising impact fees to better reflect nexus study findings. County staff recommended charging the maximum supportable fee of $143.10 per square foot for Stanford’s academic development:

“Fee levels below the maximum will exacerbate the existing jobs-housing imbalance and wage disparity – the root causes of the housing affordability crisis.”

Stanford strongly objected, claiming that such a change would “cripple” the university’s ability to fulfill its mission. Board President Simitian countered that even the highest fee would amount to only 0.2 percent of the university’s annual budget, or a mere 2 to 3 days worth of growth in its endowment. Simitian contrasted that impact with 30 percent to 50 percent increases in rent, within a mere couple of years, faced by area residents. The Board of Supervisors expressed support for raising the floor of an impact fee to $68.50 per square foot (roughly double the current charge), with a ceiling of $143.10. It has been reported that Stanford has since offered to increase its housing contribution to about $24.60 per square foot, which they claim aligns with the housing fees paid for office development “in most Bay Area cities.” 

The nexus study indicated that a fee of $75 per square foot would be sufficient to provide affordable housing in the county for new Stanford workers with household incomes up to 80 percent of the Area Median Income (AMI). In 2017, the AMI for a family of four was $113,300 per year in Santa Clara County. The board will take a final vote after review by two other county committees.

[Note:  In March 2017, City Council voted 5-4 (DuBois, Filseth, Holman, Kou dissenting) to set Palo Alto’s housing impact fees for office/R&D development at $35 per square foot, a significant reduction from the $60 per square foot fee approved by the previous council in December 2016.]

Stanford says more on-campus housing will significantly increase car trips and local congestion, despite transit-rich environment.

 

Stanford’s free shuttles create comprehensive transit system.

Policy makers at every level of government make great hay over the promise of car-light housing in “transit-rich” areas to reduce car use and ownership, thereby reducing traffic and parking congestion impacts. The new Stanford analysis, however, confirms what many Bay Area residents have long contended is a weakness in that approach: it turns out the complicated transportation demands created by residential development – for trips to school, child care, shopping, medical care, religious services, socializing, recreation, entertainment, etc. – make it less likely people will get out of their cars.

The recirculated DEIR studies two new alternative scenarios: Additional Housing Alternative A, in which all newly created housing demand is met through on-campus construction (adds 2,483 additional multi-family housing units and 66 student beds to the original project); and Additional Housing Alternative B, in which approximately half of the housing demand (1,209 multi-family units and 66 student beds added to the original project) is met on-campus. Even with Stanford’s rich transportation resources, on-campus residential development under both alternatives will lead to more car trips and greater congestion. Stanford also notes that although vehicle miles traveled are reduced when people live near where they work, many new Stanford households (as in all cities), would include folks who commute to work elsewhere, offsetting some of those reductions.

“[O]ne might think having more housing on campus will reduce car trips. But campus residents will need to drive on local roads to do things like take kids to school, buy groceries and commute to off-campus jobs. Analyses show that residents generate more local car trips than commuters to campus.”

– Catherine Palter, Stanford’s associate vice president for land use and environmental planning. 

In order to meet its highly touted No Net New Commute Trips standard (set under the previous, 2000 GUP), Stanford has created a sophisticated Transportation Demand Management program, imposed permit parking requirements across campus, and embraced multi-modal infrastructure to encourage bicycle and pedestrian transportation. Perhaps most importantly, it has effectively deployed an extensive free shuttle system, the Marguerite, that zig zags the entire campus and connects riders to Stanford, Town and Country, and San Antonio Road Shopping Centers, Stanford’s Medical Center and Research Park, downtown Palo Alto and the Palo Alto Transit Center on University Avenue. 

“[T]he No Net New Commute Trips standard may not be achieved because travel demand management (TDM) measures are not as effective in reducing residential trips, compared to commute trips.”

– Recirculated DEIR, p. 2-54

Yet according to the recirculated DEIR, even in that enviable and uncommonly transit-rich environment, and with the addition of new parking and “40,000 square feet of trip reduction amenities such as onsite childcare and mobility hubs,” enough additional residents will still drive that new congestion impacts will be significant and unavoidable.

If Stanford were to build the housing itself, but with all or some of it off-campus (outside Stanford’s transit rich environment), the needed housing units “would disproportionately affect [Palo Alto, Menlo Park and Mountain View] compared to other communities in the Bay Area that house Stanford affiliates.” Though not noted in the original GUP analysis, that also of course would be true without new Stanford housing, but in that case the impacted communities would also have to find a way to get the housing built (or face more long distance commuters).

Even if Stanford builds its own housing, Palo Alto will experience heavy new impacts.

Greater building heights and density along local roads; increased traffic and school growth; and new demands and costs for safety services, water, and parks.

 

Distribution of on-campus development under 2018 GUP with Additional Housing Alternative “A”

Perhaps most revealing, the new housing alternatives give the public its first concrete description of what 1,200 to 2,400 units of local housing could look like, as well as the on-the-ground impacts of such a sizable increase in population (12,573 new residents by 2035 under Alternative A). Stanford proposes that the new housing would be concentrated in East Campus (near Stanford Avenue), along El Camino Real, in the Quarry Road area, and on West Campus (between Sand Hill Road and Campus Drive). Although designated on-campus open spaces are preserved in the new housing alternatives, Stanford suggests that the increased on-campus development density  may increase pressure to develop outside the Academic Growth Boundary after 2035.

Key impacts of new housing alternatives:

Development

The housing itself would add 2.3 million square feet of additional development under Alternative A. Alternative B would add 1.14 million square feet of additional construction and associated environmental impacts. The proposed multi-family housing projects could include densities of 40 to 80 dwelling units per acre, building heights from 50 feet up to 100 to 135 feet, and setbacks of less than 20 feet along local roads. Stanford asserts that the development standards in the El Camino Corridor Plan and the Stanford Community Plan would need to be amended.

Traffic

As for traffic, 55 percent of residential car trips are expected to stay local to Palo Alto and both housing alternatives will increase peak-hour traffic volumes on Palo Alto streets, with a notable (but not deemed technically significant) volume increase in the Crescent Park area. Alternative A will also create new significant impacts at the intersections of Stanford Avenue and Bowdoin Street and Charleston and Middlefield Roads. Under both alternatives, impacts at the intersection of Alma Street and Charleston Road will be significant and unavoidable.

Schools

Alternative A is estimated to add 1,446 new school-aged children to the Palo Alto Unified School District, beyond those counted in the original analysis, while Alternative B would add 861 more new PAUSD students. However, Stanford-owned rental housing is eligible for property tax exemptions and therefore rarely contributes to local property tax revenues that make up the vast majority of local school funding. By contrast, many other universities such as Harvard, Brown, and MIT do pay property taxes for their non-student rental housing. Dartmouth pays property tax for all on- and off-campus housing, including dormitories.

According to PAUSD Trustee Todd Collins, the current enrollment of about 350 students from tax-exempt Stanford housing represents approximately $4.5 million in annual unfunded costs for Palo Alto schools. An influx of new students from tax-exempt housing could have a severe economic impact on the school district.

Public Services

Other population related impacts include substantially greater demands on city-provided Fire and Emergency service to the campus, police dispatch, parking enforcement, and bicycle and pedestrian safety services, including crossing guards. Both alternatives will substantially increase consumption of both potable water and groundwater, including additional use and treatment of groundwater for emergency use to supplement the potable water supply. The water detention basin in the West Campus will have to be relocated, affecting city flood control facilities. Use of city parks, particularly in the College Terrace neighborhood will notably increase, impacting the quality of the facilities and increasing maintenance costs beyond the impacts identified in the original DEIR.

Let the county know what you think of the new alternatives and their impacts, either at the July 10 public meeting (6:00-8:00 pm, Palo Alto Art Center), or by submitting your comments by July 26 to:

County of Santa Clara
Department of Planning and Development Attention: David Rader
County Government Center
70 West Hedding Street, San Jose, CA 95110
Email: David.Rader@pln.sccgov.org

City staff are seeking a courtesy extension in order to allow the council an opportunity to review the city’s comments before submittal to the county. If granted, the council likely will discuss them at its special meeting on July 30. The PAUSD Board of Trustees is likely to meet on July 17 or 19 to discuss the GUP.

Palo Alto school board may ask Stanford for another school site

Palo Alto Daily Post – by Allison Levistsky / January 29, 2018

The Palo Alto school district has responded to Stanford’s plan to expand by 2.3 million square feet with nine demands, including a third elementary school on campus, more on-campus housing and a commitment by the university to not seek tax exemptions for new homes it builds.

In a draft of a letter to Santa Clara County planners that the school board will finalize at a board meeting tomorrow (Jan. 30) night, the district calls for the university to increase its student generation rate, or the average number of K-12 students expected to live in each home the university builds.

The university has set a student generation rate of 0.5, while the school district says 0.98 is more appropriate.

Residents sound off on Stanford’s expansion

Questions linger over university’s ability to address growth impacts

Palo Alto Weekly – by Sarah Klearman / January 24, 2018

More than 200 residents of Palo Alto and surrounding communities attended a meeting on Stanford University’s proposed expansion Tuesday, with many citing traffic, parking, housing and foothills protection as their top concerns about the project.

Hosted by Santa Clara County Supervisor Joe Simitian, the meeting focused on the Draft Environmental Impact Report (DEIR) for Stanford University’s General Use Permit (GUP). If approved by the county, the permit would allow Stanford to build 2.275 million square feet of academic space, in addition to 3,150 housing units and 40,000 square feet of child care centers by 2035.

How big should Stanford get? Palo Alto asks for permanent limit.

Palo Alto Daily Post – by Allison Levitsky / January 23, 2018

Palo Altans will have another opportunity at City Hall tonight (Jan. 23) to sound off on Stanford’s application to expand its academic facilities by nearly 2.3 million square feet.

Last night, Palo Alto City Council signed off on its final 35-page comment letter on Stanford’s Draft Environmental Impact Report, in which the city officially responds to the university’s request. That letter will be sent to the county, which has the authority to grant or deny Stanford’s application.

Council made a few notable changes to the letter last night, including a call to set a permanent limit on how much Stanford will ever be allowed to build, referred to as a maximum buildout.
The suggestion narrowly passed, with councilmen Greg Scharff, Greg Tanaka, Cory Wolbach and Adrian Fine opposing.

Meeting set for Tuesday on Stanford expansion

Public comment period winding down for university’s large-scale expansion plan

Palo Alto Weekly – by Gennady Sheyner / January 18, 2018

Santa Clara County Supervisor Joe Simitian will host a public meeting on Tuesday regarding Stanford University’s 2018 General Use Permit (GUP) application. As the public comment period is ending Feb. 2, the meeting will be one of the last opportunities for residents to make verbal public comments regarding the GUP.

If the permit is approved, the permit will allow Stanford University to build up to 2.275 million square feet in academic space, 3,150 housing units and 40,000 square feet of child care space and other supporting facilities between 2018 and 2035.

Should there be any limit on Stanford’s growth? How dense should campus become?

Palo Alto Daily Post – by Allison Levitsky / January 17, 2018

As Stanford seeks Santa Clara County leaders’ approval to build nearly 2.3 million square feet of new academic facilities, one question lingers. How much should the university be allowed to build on its campus? How high? How dense? How wide?

Because Stanford occupies an unincorporated part of the county, the Board of Supervisors signs off on all major expansions.

But the land isn’t subject to zoning limitations on density per parcel, so the county has been approving the university’s growth in increments. The county issued Stanford’s last General Use Permit, or GUP, in 2000, allowing for more than 2 million square feet of academic facilities and 3,018 housing units.

City seeks more protection from Stanford expansion

Palo Alto Weekly – by Gennady Sheyner / December 1, 2017

Palo Alto officials, residents question university’s plans to manage anticipated traffic and housing problems

The City Council plans to approve on Monday night a comment letter on the project’s voluminous draft Environmental Impact Report, which assesses likely consequences of the expansion. The letter takes issues with Stanford’s assumptions about traffic, groundwater and fire-service demand, among many other things.

Cities seek more time to vet Stanford’s proposed expansion

Palo Alto Weekly – by Gennady Sheyner / November 29, 2017

Palo Alto and Menlo Park request 60 more days; Stanford calls proposal ‘unwarranted’

As the comment period on Stanford University’s proposed expansion winds down, city officials from Menlo Park and Palo Alto are calling for the Santa Clara County Planning Department to give them another 60 days to evaluate the potential impacts of the General Use Permit amendment that the university is seeking.

In arguing against the extension, Stanford may have received some help from Palo Alto Mayor Greg Scharff, who called Girard last week to discuss the topic.

Scharff said he called Girard because he had questions about how the extra 60 days would impact the planning process. But Girard recalled that Scharff said that he does not believe the 60-day extension is necessary.

“He said he hadn’t heard that much demand from his constituents for an extended period,” Girard said.