Dear Council, I appreciated your discussion on Dec 16 (with Drew Combs recused) and the questions/comments that three of you made regarding more housing at Facebook Village. Agree completely that one EIR option should be full mitigation for the housing needs for the new employees that would work at Willows Village. Facebook has yet to actually build any housing in District 1. This is despite their recent public pronouncements about "Facebook's Plan to Address Housing, Transportation. https://www.mercurynews.com/2019/10/22/opinion-facebook-strategy-to-address-housing-and-transportation/ > (PDF also attached.) Talk is cheap, but actions send a louder message. The entire 59-acre plot of land could be used mostly for housing! Below is a slightly modified version of the memo that I spoke from: Re: Willows Village EIR Sending the EIR to the draft EIR stage would be sending it along a path that would be difficult to turn back from. The ICF statement of work proposal includes Task 13: Certification Hearings. Their proposal assumes ultimate approval for the Willows Village EIR. The busy holiday season further limits the public’s notice of the Willows Village EIR, and their ability to respond. Summary of Main Concerns • Inadequacy of Public Notice • Inadequate incorporation of Public’s prior input • The project description was inadequate. • EIR needs to examine additional elements. • Objectivity of the studies used in the EIR • Inadequacy of ConnectMenlo as the foundation for the Willows Village Development Inadequate Public Notice There was inadequate solicitation of input from agencies and the public regarding the Notice of Preparation stage. The postcard mailing went to a small geographical group. The State Clearinghouse mailing also went to relatively few groups. As evidence, relatively few members of the public, and groups, gave input into the NOP stage at the October Planning Commission meeting. For a project of such regional significance, much more effort was needed. Although the Staff said (at your meeting) that they sent the notice to the MP Fire District, I am surprised that the Fire Chief did not respond. So I have doubts about the adequacy of the process including if the mailed notice allowed enough time to respond. The project packet should have included a replica of the notice sent to residents. In the past, some projects have been described in ways that did not adequately alert the public. If the notice did not explicitly name the project as Willows Village, that would also reduce responses. The timing of the EIR, during the busy Holiday Season, will also reduce responses. The following types of groups and people should have been notified. One way to handle uncertainty or doubt about the adequacy of the City's process is to ask the recipients to send an email verifying that they got the notice and that they will not be supplying input at this EIR stage. • All school districts in Menlo Park and in adjacent communities, including Ravenswood City Elementary Schools, Menlo Park City School Districts and Redwood City School District. Also Beechwood School. • Environmental groups such as: Sierra Club, Save the Bay, Audubon Society, Planning and Conservation League, and Environmental Protection Agency. • Existing business near the proposed Willows Village Site, and those that will be displaced by the Site. • Menlo Park Fire District • Redwood City & Palo Alto (especially as their roadways may be impacted) • Sam Trans and other public transportation agencies. • Non-profits in District 1: Boys & Girls Club, Senior Center • A broader group of Menlo Park residents beyond the quarter-mile radius from the proposed site. • More newspapers, including The Almanac, Palo Alto Weekly and San Mateo County Daily Journal. • Frequent posts to social media, including NextDoor. Recommendation: Update the City's Public Noticing Policy https://www.menlopark.org/DocumentCenter/View/273/Public-Noticing-Policy > Inadequate Incorporation of Public’s Prior Input * The public has asked for the housing and grocery store to be built in the first phase. Yet it's not there. * The public also asks why the gas station on Hamilton needs to be moved across the street instead of some other location. No response give. * The public also has asked for a greatly increased amount of housing. Instead, the proposed EIR includes one variant with only 1,500 (less) housing units. Instead, one variant should look at 3,000+ possible housing units. Even better would be full mitigation as Council has requested. * Facebook states that it wants to help end the housing shortage. They have an opportunity in Menlo Park to use the 59-acre site for housing and community amenities instead of building more office. * The general comments that the public made regarding the jobs/housing imbalance were basically dismissed in the responses as being beyond the scope of the EIR. However, the project will need Council’s approval for the zoning changes needed to allow the development. * Council could change the District 1 zoning to increase housing. Facebook will need Council approval for zoning changes for Willows Village. Council has more leverage than it is using. Inadequate Project Description * The project description did not adequately describe the scope of the two transit hubs in the two parking garages. The project also shows another parking garage for the Visitors Center. The description needed more details so that the public could respond to the likely impacts of these private transit hubs. The public might also like the opportunity to suggest a public-private partnership with SamTrans (or some other agency) so that the public can use the Facebook transportation system as a way to reduce solo driving. This could be considered as one of the mitigations. * What kind of retail is being considered should also be listed. While specific stores don’t have to be named, the description could include generalities (such as hardware store, bike repair shop, etc.) As Willows Village has been in the works for years, one expects more specifics. * The packet did not include the Ramboll Consulting scope of work or the biological studies already prepared by Facebook. . * The project description did not adequately detail the possible groundwater and soil contamination from prior land uses at the proposed site, so that the public had enough information to make an informed response. More specifics were needed. EIR needs to examine additional elements * The project’s impact on global climate change needs to be studied as a separate EIR item. * It should include Facebook’s overall strategy to reduce risk from flooding at the Willows Village proposed site, and their other sites. * District 1 lacks a disaster response plan. The EIR should examine the project’s impact to disaster response, especially when combined with the cumulative prior, current and future development planned in Menlo Park and in surrounding areas. Objectivity of the studies used in the EIR * The project sponsor, Facebook, is either supplying some of the studies that will be used in the EIR or Facebook is the direct client for various studies that ICF will incorporate (or use as evidence) into the Draft EIR. While ICF will review these studies, it raises concerns over objectivity due to conflicts of interest. For example, Facebook has conducted a “baseline Biological Assessment” (page 10 of ICF proposal). Facebook is also working directly with Ramboll yet Ramboll’s scope of work is not included in the packet. * Full transparency is needed regarding Ramboll’s statement of work. There may also be other consultants working directly for Facebook and supplying details for the EIR. Instead, full transparency is needed and possibly a different consultant reporting arrangement to avoid even the appearance of a conflict of interest. Inadequacy of ConnectMenlo as a foundation The community has broader concerns about the land planning policies, objectives and outcomes in the ConnectMenlo exercise. Yet the Staff Report packet, including the ICF proposal, includes many references to the ConnectMenlo exercise as justification. Some of these references were selective only and they also did not detail the public’s concerns with ConnectMenlo. The most serious pertains to the legal foundation for ConnectMenlo. The CM Givens” included: General Plan will Comply with State Law. However, CM focused explicitly on making zoning changes in a small area of land, roughly 5% of Menlo Park’s overall size), leaving the rest of the City’s zoning intact. The City could be at risk of being sued for not having a complete and adequate general plan (Gov Code 65750, et seq.) The public has also raised concerns about the adequacy of the ConnectMenlo Program-level EIR (Resolution 6356 https://www.menlopark.org/DocumentCenter/View/15010/6356---Connect-Menlo-CEQA?bidId =>). First, the statement of overriding considerations listed many benefits that the public considers overstated. The CM program-level EIR also based its assumptions, at least in part, on broader projections (such as Plan Bay Area 2040) that were not accurate. The Caps were not really caps either, and the employee count is understated. The program-level EIR mitigation measures may also not be measured and/or compliance verified. Additional concerns: • The ConnectMenlo Guiding Principles lacked metrics and routine measurement. These Principles were used to reduce opposition to the ConnectMenlo zoning changes. In fairness to the public, it’s time to review these to see if the current development in District 1 reflects the “values” in the Guiding Principles. • David Bohannon, a major property owner in District 1, had a seat on the ConnectMenlo Advisory Board. This represents a conflict of interest as Bohannon stood to gain materially from the zoning changes he helped influence. • District 1 has no plan for purposeful development. The residents have called for an area plan. ConnectMenlo was explicitly about revenue generation and it’s not a plan for livability or resident quality of life in District 1. • ConnectMenlo zoning changes are also counter-productive towards the City’s stated concerns about global climate change. • The ConnectMenlo Community Amenities (Resolution No. 6360 https://www.menlopark.org/DocumentCenter/View/15009/6360---Community-Amenities?bidId =>) list need price tags for each one, and a workable process. The public has legitimate concerns about the basis for the Willows Village EIR. At minimum, the Connect-Menlo program level EIR should be reviewed in light of the global climate change emergency and the current "baseline" conditions in District 1. The public also has legitimate concerns about the entire ConnectMenlo process and if its process and outcomes did, in fact, comply with the California State requirements for General Plans. It's time to reevaluate these decisions. Lynne Bramlett application/pdf attachment: scan0020.pdf
