Dear City Council,
Please pull the Menlo Update project, so the City Council and the Planning Commission can discuss the project as part of an overall discussion on ConnectMenlo. I suggest a joint meeting out of respect to the residents serving, and so they can hear the concerns -- including the ones related to hazards and safety.
Unfortunately, the City lacks an in-house knowledgeable “disaster planning manager” or other suitably titled. deeply knowledgeable staff member who can advise on safety as it pertains to development. To me, the City planners and elected officials are not getting a balanced view when considering development in a high hazard area. Instead, they appear too dependent on information supplied by outside consultants hired by the developer. However impartial this type of consultant might try to be, the situation seems to be a set up for at least an unconscious bias towards what the developer-employer wants. I believe that the City also lacks an in-house geologist and/or sea level rise expert.
We also have considerations of fairness that need to be institutionalized into planning. There are others. Just speaking about Housing alone, District 1 has 3,192 housing units in the pipeline according to the 8/4/21Housing Commission staff report. That is almost the full RHNA allotment for Menlo Park. At the rapid development pace, much new Housing may continue to be built in District 1 to further that area’s dipropionate allotment of new housing.
ConnectMenlo Process
1. Environmental injustice. ConnectMenlo worsened the already severe environmental impacts to Belle Haven. This community started as a redlined community of mostly Blacks, Latino’s and low-income residents. Ironically, the Menlo Park Library recently hosted reporter Kate Bradshaw giving an update on her “Uneven Ground” series of reports that detailed the history of unfair treatment to communities like Belle Haven. It’s time to do something about this information.
2. No vision for Menlo Park, let alone Belle Haven. A General Plan Land Use update is supposed to be a vision for long-range planning across an entire jurisdiction. In contrast, ConnectMenlo focused on a small area of Menlo Park – roughly 5% of the City’s overall size -- to maximize development to generate revenue to the City. The development in District 1 continues without an overall plan for what the desired end result will look like. The development was also supposed to take until 2040 to finish.
3. The rushed process. This reduced participation. Those living outside of District 1 were told that the zoning changes would not impact their area. Much time was spent on the frontend collecting people’s opinions, yet the approval process was rapid. The final decision was made via a consent calendar item with only three Council members present.
4. The parallel Belle Haven visioning process. I believe that this confused Belle Haven residents, while also reducing public input. In short, Belle Haven residents believed they would be getting something for the development, which reduced their resistance. They also had to choose what meeting to attend, which reduced public participation. My review of the “visioning documents” showed that the top priority expressed was for education and a full-service library in Belle Haven. Yet no member of the Library Commission served on the ConnectMenlo Advisory Body. I believe that the Library Commission was the only City Commission without a seat. This was a conscious decision as I checked into this decision early on in the process. Why?
5. Conflict of interest. A major developer and property owner in District 1 had a seat on the ConnectMenlo Advisory committee. The zoning changes resulted in a financial windfall for the five major property owners in Belle Haven, including the one serving on the advisory committee.
Foundational documents -- Environmental Impact Report
1. Need a review. As an example, please see the Geology, Soils and Seismicity document (part of the Placeworks overall Environmental Impact report series of documents). The Geology, Soils and Seismicity document has an impact discussion section that lists various Land Use and Safety Element goals as evidence of safety. At the end of section, it points to the goal statements in broad assurances of safety. Yet I think that at least some of these (pointed to) goals were not operationalized or implemented. To me, this document seems slanted towards a preferred outcome in the form of justifying ConnectMenlo. It takes a careful eye, and much knowledge, to recognize omitted information and incomplete information. Thanks to self-study and seminars, I can say that something seems odd with at least this particular document. Someone who is an expert, should read all of the ConnectMenlo justifying documents with a careful eye and in light of new information.
2. Omitted Information and New Information. As an example, the Geology, Soils and Seismicity document did not include the threat from a major eruption of the Hayward fault, which will impact Belle Haven. It dismissed this threat because the fault does not lie underneath Menlo Park. It also made no mention of “soft-story” buildings as a seismic hazard, which were a known threat by 2016. The then City Council heard about the “HayWired Scenario” at a May 2018 Council meeting. This update included informing Council about the risk of possible litigation following the eruption should enough members of the public find out that the City could have done more to prepare for and mitigate for this disaster, but it did not. What's particularly odd to me is that Placeworks now specializes in helping jurisdictions develop their Environment Justice Elements. These are designed to help restore "justice" to prior unfair land-use decisions, such as what I believe occured in District 1.
Promises made:
1. ConnectMenlo would follow all applicable State laws. I’m not a lawyer, but I can read and follow clearly written documents. To me, it seems obvious that ConnectMenlo was not an authentic general plan update that faithfully followed the intent of California State law and guidelines for an authentic general plan land use element update.
2. Guiding Principles would protect the community. However, these were never operationalized, measured and reported. Most of the statements are more platitudes.
3. Benefits justify the environmental impact, to people and places. Program Level EIR or Resolution No 6356 includes a Statement of Overriding Considerations that justifies ConnectMenlo due to the “benefits.” (Please see the separate excerpt.) The economic benefits may have been realized but at what cost to the public good? The environmental benefits often point the reader elsewhere without an adequate explanation. The “Social Benefits,” to me, seem more like creative writing than a benefit based in reality.
Finally, the County of San Mateo’s 2021 Local Hazard Mitigation Plan update refers to documents like the ConnectMenlo Land Use and (outdated) Safety Element in assurances of safety today and tomorrow:
“This plan [2021 Local Hazard Mitigation Plan] update assumes that some new development triggered by increased population occurred in hazard areas. Because all such new development would have been regulated pursuant to local programs and codes, it is assumed that vulnerability did not increase even if exposure did. San Mateo county and its incorporated cities and towns have general plans that govern land-use decisions and policy-making, as well as specialty ordinances such as building codes and flood-management regulations based on state and federal mandates…” (Volume 1, section 2.2.2.
In other words, because a City like Menlo Park has a general plan, the County assumes that new development in a high hazard zone will be safe. I question this assumption on the County’s part.
It’s never too late to try to do the right thing. I believe that it’s more than time to examine the ConnectMenlo process from a fairness perspective. More importantly, it’s needed for public safety.
Lynne Bramlett
