Dear Mayor and Councilmembers,
I am writing 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, I urge you to amend the contract BEFORE it is executed.
As you know, this is a Builder’s Remedy project with limited discretionary review afforded under SB 330. It is exceptional in size and complexity and has not only local but also regional implications.
It is essential that key issues be addressed upfront, prior to beginning the EIR work, to avoid scope limitations that could arise later in the process. Clear, early direction by the city council ensures transparency and builds public trust and integrity of the environmental review process.
Below are several areas of concern that warrant specific direction from the City Council to ensure that all potentially significant environmental issues are fully scoped in, even if the consultant anticipates low impacts based on prior projects. Including these amendments to the contract will help minimize ambiguity. I respectfully request that the council consider the following:
Transparency and Documentation
• Full peer review memos must be included in the EIR appendices.
• Memos should state areas of agreement/disagreement and whether suggested changes were incorporated.
• LSA must be empowered to conduct independent modeling or fieldwork when needed.
• “Less than significant” findings must be supported by documented evidence to be made available to the public.
Biological Resources and Creek Concerns
• LSA should independently verify any applicant-submitted jurisdictional delineation (JD) for wetlands, riparian areas, or creek-adjacent zones.
• Setback assumptions must be explicitly mapped and supported by data, which should be made available for public review.
• Focused species surveys and supplemental fieldwork should be conducted by a qualified subconsultant to fully characterize potential environmental impacts.
Jobs-Housing Impact
• Quantify jobs created and compare to proposed housing production by number and income level.
• Estimate housing demand, in-commuting VMT, and regional housing impacts.
• Include analysis per CEQA §15126.2(d) on indirect effects, displacement, and equity for the region impacted by the project.
• Include an alternative that reduces commercial space and increases housing supply/affordability.
• Analyze VMT, RHNA alignment, and environmental performance of this additional alternative.
• Ensure full transparency of modeling assumptions and data handoffs and include them all in the EIR.
Impacts to the Surrounding Areas
• Assess potential cross-jurisdictional impacts and interagency coordination needs because the project site lies at the city and county boundary. This should include:
- Traffic impacts on Palo Alto streets.
- Emergency services coordination with Santa Clara County and Palo Alto.
- Any sewer and utility service jurisdiction overlaps.
• Include agency correspondence communication with affected agencies and any recommended mitigation measures in the EIR.
While the list of recommendations may be extensive, addressing these issues early on can help prevent complications and legal challenges later. These suggestions aren’t about opposing the project, but about ensuring a fair, transparent process that thoughtfully considers the community’s interests.
Thank you for your consideration.
Sincerely,
Nadia Naik
