Paul,
Thank you for reaching out to us and for sharing your point of view on this
topic with the Complete Streets Commission.
Sally Cole
On Tue, Aug 12, 2025 at 4:49 PM Paul Collacchi
wrote:
>
>
> Council Members, and CSC commission members,
>
> It has been brought to my attention that the Complete Streets Commission
> (“CSC”) was not asked to review the Parkline project. Is this true? If
> so, why not? It’s a stated role of the CSC to “… *provide input on major
> land use and development projects as it relates to transportation*.”
>
> According to the 7/21/15 Council Staff Report, *“… the City’s
> Transportation Demand Management (TDM) Program Guidelines and the
> Transportation Impact Analysis (TIA) Guidelines define the process,
> requirements and standards for determining a development project’s
> potential impact(s) on the transportation network*”
>
> In my view, it should be routine for CSC to review development projects
> specifically in light of these documents, and I ask you to review the
> Parkline Project for conformance with these guidelines.
>
> Please be advised that in my own review, using Menlo Park’s adopted
> TIA/TDM standards, I noticed the following issues and irregularities:
>
>
>
>
>
> 1. There seem to be at least three places in the adopted TIA policy
> where the analysis clearly deviated from policy,
>
>
>
> 1. *The effectiveness of the alleged Parkline TDM plan was not
> verified *according to policy (TIA note 12)
> 2. *Average Daily Traffic (“ADT) volume (“segment”) counts on
> nearby, sensitive local streets, particularly Ringwood, were not performed*.
> (TIA Section 7.B)
> 3. *Despite many, clear congestion (LOS) impacts (and possible ADT
> segment impacts) no “alternatives” have been evaluated* in the
> event of non-compliance (TIA section 9).
>
>
> - These impacts were so clear that the applicant recently took it upon
> themselves to proposed a commercial reduction (alternative) to reduce
> traffic impacts.
>
>
>
> 2. There are also issues with the DEIR analysis.
>
>
>
> 1. *The EIR analysis considers the alleged TDM plan measures to be
> part of the project, not a project mitigation. *
>
>
> - TIA Section 4.A attachment B makes no mention of including TDM
> deductions in project VMT calculations.
> - I believe the practice is questionable, in part for reasons
> below.
>
>
>
> 2. *The alleged TDM plan is not a specific plan*, similar to the one
> proposed in Table 3. of the 7/21/2015 Staff Report “reference plan”
> conducted by Kimley-Horn for 1315 O’Brien Drive
>
> .(Attached)
>
>
> - The Kimey-Horn TDM plan distinguishes between “*potential*” methods
> and “*proposed*” methods; it includes specific methods (Table
> 3), and it evaluates the effectiveness of those methods (Attachment B).
> - The Parkline “plan” is a promise to make a plan using a set of
> strategies that Parkline “could” or “would” take from a menu of potential
> methods whose listed effectiveness varies and was never verified in the
> Parkline context, in part, because there is no specific TDM plan to verify.
>
>
>
> 3. *Regarding vehicle miles travelled (“VMT”), the Parkline DEIR VMT
> finding of “not significant” relies completely upon a TDM trip reduction
> number, 28%, that seems unrealistic, unprecedented, and unverified*.
>
>
> - The Kimley-Horn TDM plan reduces trips by 21% and VMT by only 17%.
> It notes that a 21% trip reduction is similar to other nearby plans.
> - In the Greenheart DEIR, made by the same EIR preparer as
> Parkline, TDM is inherently acknowledged to be both “unreliable” and “not
> guaranteed”.
> - How can a vague and unreliable element of the project, whose
> effectiveness is unverified and cannot be guaranteed, be relied upon to
> make a finding of “non-significance”?
>
>
>
>
>
> Finally, for reference, I reviewed the transportation/TDM methods,
> practices, standards and findings made by San Carlos in its Alexandria
> Center DEIR.
>
>
>
> The Alexandria Center project in San Carlos is a near-perfect comparable
> for Parkline.
>
> - It is a commercial “infill” project that abuts El Camino Real on the
> east.
> - On the west side of ECR is downtown San Carlos.
> - San Carlos is a suburban community with a suburban city center
> and population of 28,000
> - There is a CalTrain station within .5 miles of the project.
> - San Carlos has an adopted TDM ordinance. (Menlo Park does not).
> It must also comply with C/CAG TDM policies.
> - San Carlos uses the same method to verify TDM effectiveness as
> Menlo Park.
>
>
>
> In terms of rigor, clarity, and honesty the Alexandria Transportation DEIR
> seemed superior in every way to that provided by ICF for Parkline.
>
>
>
> I hope that the CSC reviews the Parline project, or, if not, then I hope
> the CSC performs a post mortem of the Parkline traffic analysis to review
> and critique practices undertaken for the Parkline Project in light of
> Menlo Park’s TIA/TDM policies.
>
>
>
> Sincerely,
>
>
>
> Paul Collacchi
>