January 7, 2023
Council members, Planning Commissioners, and Staff,
Thank you for receiving these comments regarding the EIR for the Parkline masterplan ("SRI") project.
The comments append and incorporate historical city documents.
For historical perspective, these comments append and include two public documents created by the City for the 2000 SRI Task force, and a single public document from the 2000 Land Use and Circulation Study ("LUCS"). They include by reference any other existing SRI Task Force or LUCS document still in possession of the City, and any and all City documents associated with the 2013 SRI Campus Modernization project whose CEQA EIR NOP was submitted in July 2013.
* Appendix 1 -- Task Force recommendations for future use/mitigation of the SRI site.
* Appendix 2 -- A thorough regulatory history of SRI including a list of items the Task Force considered.
* Appendix 3 --A Staff Report for the LUCS project showing scope of future planning for the greater downtown Menlo Park area. It describes alternate futures for the SRI site used by the SRI Task Force.
Though the SRI Task Force documents do not appear on City letter head, to the best of my recollection that they are authentic and unaltered copies of public documents that existed at the time and were given to me by staff.
The LUCS and the 2000 SRI task force reviewed SRI alternatives
The LUCS studies coincided with the 2000 SRI Task force whose recommendations are included in the appended documents. The 2000 SRI Task force looked at several alternatives for the SRI site.
1. Proposed [2000] master plan development (1,545,000 s.f.).
2. Reduce development to currently allowed 30% FAR for zoning district.
3. Maintain existing development.
4. Maintain existing development or reduce development to currently allowed 30% or 25% FAR for zoning district, but allow residential development at a higher FAR.
5. Rezone to all residential.
Eliminating the existing Conditional Develop Permit employment caps and counting rules quadruples the sites net housing deficit.
The project proposes to eliminate the existing Conditional Development Permit ("CDP"). The impacts on the projects ability to increase the housing deficit is shown below. Without CDP restrictions the housing net deficit potential swells from 608 units to 2527 units. (table below)
Housing Demand
CDP Employee
Limits
Area
Employees
Debited cap
2775
Office @4/1000 sf (250sf)
1,100,000
4400
Non-SRI @ 2:1
838
Retained lab @ (515) sf
287,000
557
Total Project Employment
4957
Existing Employment
1100
Existing SRI
1100
Net New Project Employment
3857
Total Site
1938
Housing Supply
Dus
Employees*
housed
Luxury units w/BMR @1.9 emp/du*
600
1140
1140
Affordable units @ 1.9 emp/du*
100
190
190
Total Employees Housed
1330
1330
Project (Demand-Supply)
Site (Demand-Supply)
Total project impact on Deficit
2527
608
There are superior project alternatives consistent with policy that should be reviewed.
In my view, several of the LUCS alternatives are clearly superior policy alternatives and should be studied as alternatives in the EIR. In particular they retain CDP employment caps but allow additional housing in place of office thereby increasing housing supply.
My comments are organized in four sections.
1.) Proposed alternatives to be studied
2.) Comments regarding EIR analysis
3.) Comments regarding the Housing Needs Assessment ("HNA")
4.) Comments regarding the Financial Impact Analysis. ("FIA")
Sincerely,
Paul Collacchi
Redwood City, CA
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