Dear Mayor and Councilmembers,
I am writing on behalf of Menlo Forward to express support for the Staff recommendation to select LSA as the consultant for the Environmental Impact Report (EIR) for the 80 Willow Road project.
However, having read LSAs Proposal, and due to the exceptional size, complexity, and regional implications of this Builder’s Remedy project—and the limited discretionary review afforded under SB 330—it is essential that key issues be addressed upfront, prior to the initiation of EIR work. Without this early direction, legitimate concerns about bias, transparency, and scope limitations may arise later in the process, undermining public trust and the integrity of the environmental review.
To that end, we respectfully urge the City Council to consider amending the contract to address several areas of concern. These revisions should be incorporated into the scope of work and memorialized via administrative direction from the City Manager to LSA to minimize ambiguity. These proposed amendments are designed to enhance analytical rigor, ensure compliance with CEQA, and promote meaningful public engagement:
Peer Review Transparency and Independence
A number of assessment areas are dependent on Applicant Provided studies and peer review. Any technical studies submitted by a project applicant should undergo a transparent and independent review. Full peer review memos should be included in the EIR and should clearly explain whether the reviewer agrees with the applicant’s conclusions and what changes were made. The EIR consultant must be able to run their own models or gather additional data if needed.
Initial Study Transparency and Scoping Integrity
The Initial Study should not omit (“scope out”) any potential environmental impacts. The study should be posted for public viewing for a meaningful period (such as 30 days), and any conclusions that impacts are minimal must be backed up with clear evidence.
Biological Resources and Creek Setback Verification
Since the project is on San Francisquito Creek, the consultant should independently verify any maps or reports from the applicant that describe wetlands, creeks, or protected zones. Any buffers or setbacks should be clearly mapped and based on real data. Additional species surveys and environmental fieldwork may be needed to understand ecological risks fully.
Comprehensive Jobs-Housing Impact Analysis
This large project adds commercial and office space, so the study should include a thorough analysis of how many jobs will be created and whether the housing provided is enough to match those jobs, especially for low- and moderate-income workers. This analysis should consider how far workers will need to travel and the environmental effects of that travel.
Inclusion of the Housing Needs Assessment (HNA)
A Housing Needs Assessment should be a required part of any EIR for a large mixed-use development. It should explain how the project fits with the city’s HCD-certified Housing Element and help identify any mismatch between job creation and available housing, especially in terms of affordability.
Displacement and Socioeconomic Impact Analysis
The EIR should analyze whether this project may indirectly cause people or businesses to be priced out or displaced. This includes looking at broader social and equity impacts.
Evaluation of a Jobs-Housing Balanced Alternative
The EIR should include at least one alternative that emphasizes housing—especially affordable housing—over commercial space. This allows decision-makers to compare how different development approaches affect things like traffic, housing balance, and environmental performance.
Infrastructure and Utility Systems Capacity Analysis
The EIR should assess whether local infrastructure—such as sewers, storm drains, and water supply—can support the new development. It should quantify the project’s demand, identify any needed upgrades, and account for other nearby projects that might also affect system capacity.
Fire and Emergency Services Review
Larger or taller developments, plus LOS traffic impacts will likely place new demands on fire and emergency services. The EIR should examine whether the local fire district has the equipment and staff needed, whether response times and evacuation routes could be affected, and how coordination with neighboring jurisdictions would work.
Cross-Jurisdictional and Border Impacts
The EIR should examine how it might affect neighboring communities (Palo Alto, East Palo Alto, Santa Clara County, etc.), including impacts on traffic, utilities, and emergency services. Interagency coordination should be documented, along with any mitigation measures agreed to.
Oversight and Accountability During EIR Preparation
To ensure public confidence, the City Council or Planning Commission should receive regular updates on the EIR’s progress—especially when the Draft EIR is released. These updates should highlight key findings, changes to analysis, and how concerns raised earlier were addressed.
This list may seem long, but by addressing these items now, the Council can reduce future risk and litigation exposure while setting a high standard for transparency and thoroughness.
These amendments do not undermine the applicant’s rights and ensure that the public interest is fully represented throughout the EIR process.
Thank you for your consideration.
Kevin Kranen
Menlo Forward
