August 5, 2019 – Palo Alto Matters
Editors note: This story has been updated to clarify the DEIR’s conclusions regarding net new daily car trips and distinguish between total daily trips and new trips on specific roadways.
The City of Palo Alto will finally enter the fray after standing on the sidelines of a multi-year public relations battle between Castilleja and its residential neighbors over the private school’s ambitious proposal to redesign its campus and expand enrollment to 540 students over the next four years (125 more students than allowed under their existing Conditional Use Permit). On August 14, the Planning and Transportation Commission will hold the first public hearing on a Draft Environmental Impact Report for the project. The DEIR, released on July 17, is subject to a 60-day public comment period, ending on September 16, 2019. The Historic Resources Board will hold another public hearing on September 12. Council action is not yet scheduled.
The sometimes fractious tale of two projects that has unfolded in recent years has the school touting its redesign as a much needed “modernization” that will expand access to “the unique transformational power of an all-girls education,” including to the 22 percent of students who receive financial assistance. (Tuition and fees for 2019/20 school year cost $49,900; current aid recipients represent incomes from below $20,000 to $300,000.) School representatives cite 30 community meetings held since 2012 to support their claim that the plan incorporates neighborhood input and was developed in consultation with the community in order to minimize, and even reduce, neighborhood impacts.
Castilleja officials emphasize that the school’s above-ground building footprint will not increase and that their proposed enrollment growth will be incremental and closely monitored. If it results in an increase in car trips, the next increment must be delayed until the school can bring car trips back under a cap of 440 cars during peak commutes. Finally, they argue that a new underground garage (adding 68 additional parking spaces to the school’s inventory, for a total of 142 spaces) will not invite more driving, but rather is intended to reduce on-street parking and traffic spillover on neighborhood streets.
Neighbors, on the other hand, tell the story of commercial expansion by a tax exempt corporation in an R-1 residential zone, through redevelopment that would overwhelm the quiet neighborhood with traffic and noise, eliminate heritage trees, and violate the city’s municipal code by improperly excluding the underground garage from the site’s floor area limits, resulting in “30,000 more above-ground square feet than is allowed by current code.”
They describe a process that ignored or misrepresented public input, a garage that will incentivize more driving as well as change the face of the neighborhood, replacing houses with a garage exit that will shine hundreds of headlights directly into neighboring property, disrupt traffic patterns, and cause cars to queue along Emerson and Bryant Streets as they wait to enter or leave both the parking garage and Embarcadero Road.
The fact that Castilleja “increased enrollment from 415 to 450 over 12 years [in violation of the school’s Conditional Use Permit], starting 2 years after they agreed on 415,” looms large as a source of mistrust regarding Castilleja’s intentions, practices, and reliability for future compliance.
Castilleja’s plan includes removing two school-owned houses, replacing five existing buildings with a single new, three-story academic building, eliminating 47 surface parking spots, freeing up green space (including a .33 acre “park” that neighbors would be permitted to access), adding a 50,500 square foot underground parking garage, lowering the pool below grade, and rebuilding basement classroom space. On net, above grade building area will be slightly reduced and below grade built area will increase, resulting in a total expansion of 77,784 square feet, a 47 percent overall increase.
Development will occur in four phases over three to four years, with student enrollment increasing to 490 students in phase one, 520 students in phase three, and reaching the maximum 540 students in phase four. If the school exceeds the car trip cap of 440 peak trips per day, subsequent enrollment growth will be put on hold until they return to compliance.
The Draft Environmental Impact Report noted that the project would “enable improved safety, sustainability and programmatic space” for Castilleja’s student population, and acknowledged features designed to minimize “school-related disruptions on the surrounding neighborhood,” such as new limits on special events, as well as amenities designed to benefit the community, including landscaping, preservation of mature trees, and .33 acre “park” that could be used by the school’s neighbors.
On the other hand, the DEIR concluded that higher student enrollment could significantly increase daily car trips, from the current total of 1198 trips to 1477 total trips, despite Castilleja’s current Transportation Demand Management program. “The net new trips associated with the increased enrollment is 279 or an 18.9% increase from the existing conditions.” Citing a June 2019 analysis prepared by Castilleja’s TDM consultants, Nelson/Nygaard, the DEIR anticipates that the enhanced TDM program proposed in Mitigation Measure 7a could reduce car trips by 12 percent to 22 percent. At the high end of effectiveness, that could mean a net reduction of daily trips to 1152. However, if the enhanced TDM measures perform at the lower end, the project would still produce a net increase of 102 daily trips.
Importantly, even if a successful, enhanced TDM program results in a net reduction in total daily trips, the concentration of school-related traffic on specific roadways due to the consolidation of parking in the underground garage would create significant and unavoidable project-related traffic impacts. In particular, the project would significantly increase daily car loads on Emerson Street between Embarcadero Road and Melville Avenue, and cause considerable new delays at the intersection of Alma Street and Kingsley Avenue. The DEIR deems the enhanced TDM program in Mitigation Measure 7a insufficient to reduce those traffic impacts to less than significant levels. The resulting potential to exacerbate existing land use conflicts between the school and its residential neighborhood was deemed a further significant and unavoidable impact of the project that would “create land use incompatibility or physically divide and established community.”
The DEIR also identified significant or potentially significant environmental impacts on noise, trees (biological resources), air quality and seismicity associated with the project, but concluded that mitigation measures could reduce those impacts to less than significant.
Finally, the Castilleja project was found to be generally consistent with the city’s Comprehensive Plan. However, the DEIR’s zoning consistency analysis highlights that the proposed above-grade gross floor area represents a .41 Floor Area Ratio whereas the maximum FAR allowed on the site per city code would be .3026. Existing buildings on the site represent a FAR of .43 and Castilleja has requested a variance from the city to allow it to maintain its existing above-grade FAR. Because the proposed project results in a smaller non-compliance, the DEIR deems the proposed .41 FAR to present no new adverse physical environmental effects. The DEIR analysis does not count the project’s 128,166 below-grade basement square footage in the FAR calculation.
In addition to analysis of Castilleja’s proposed project, the Draft EIR analyzed three alternatives:
- Alternative 1: No project.
- Alternative 2: Moderate enrollment increase. Reduce maximum enrollment from 540 to 506 students, allowing for slight reductions in both the size of the new academic building and the number of off-street parking spaces.
- Alternative 3: Moderate enrollment increase with reduced parking. Reduce maximum enrollment from 540 to 506 and reduce on-site parking to 92 spaces (minimum required by city code), with 52 spaces in the below grade garage and the rest in on-site surface lot at the corner of Emerson and Kellogg.
The public has 60 days to comment on the DEIR. You can email comments to Castilleja.email@example.com, offer oral comments at the August 14 Planning and Transportation Commission Hearing (6:00 pm, Council Chambers, City Hall) or the September 12 Historic Resources Board Hearing (8:30 am, Council Chambers, City Hall), or send them to:
Amy French, Chief Planning Official, Planning & Community Environmental Department, City of Palo Alto, 250 Hamilton Ave, 5th Floor, Palo Alto, CA 94301
Following the public comment period, a Final Environmental Impact Report will be prepared, including responses to each submitted comment and any additional analysis conducted. The FEIR will also be subject to a public comment period and will provide the final analysis to guide City Council’s decision on whether to approve or deny the proposed project or an alternative. A Final EIR indicating significant and unavoidable impacts would require the council to make a finding of “overriding considerations” justifying approval of the project.
Note: DEIR comments are most effective when they specifically address impacts identified in the report or gaps in analysis or offer additional relevant information that can inform the analysis.
For more information related to the project visit the following websites:
City of Palo Alto: DEIR Executive Summary
City of Palo Alto: Castilleja DEIR documents
Castilleja School: Castilleja Re-imagined
Protect Neighborhood Quality of Life: grassroots organization of Castilleja neighbors