February 23, 2015
Dear Honorable Mayor Calrton and City Council Members,
Thank you for reviewing during your meeting of 2/24/15 the proposed scope of the EIR for the
proposed Greenheart project at 1300 El Camino Real.
I hope you will discuss thoroughly the following:
Reasons to Study a Specific Project and to Evaluate Alternatives
The Council will be evaluating not only the environmental impacts but also the potential project
benefits that may warrant a finding of Overriding Considerations (for EIR) and the approval of
Public Benefit Bonus square footage. Thus, the Project definition should be very clear, with no
ambiguities, to provide sufficient information for all three purposes.
Further, the Alternatives should also provide sufficient information for the Council to direct the
applicant towards an Alternative if one proves superior in terms of benefits to the community of
Menlo Park. This is entirely within Council discretion, especially when a project is proposed to
exceed the ECR/Downtown Specific Plan’s anticipated negative impacts and seeks extra
square footage, at the Public Benefit Bonus level.
Project Definition
Issues related to the project definition:
Range for different project uses - As described in the staff report, a range of Square Feet
(SF) is provided for uses that have different environmental AND community benefit
characteristics. Specifically Non-medical Office and Community-Serving Uses do not
have the same characteristics from either perspective. It is inappropriate to lump these
different uses together.
Even the ECR/Downtown Specific Plan had specific numbers for various types of uses,
not ranges. If a range is of interest to the applicant or Council, then Alternatives that
encompass the ranges should be created. The Council has discretion to require this.
Upper Value of Range – the upper values of the ranges provided exceed 100% of the
allowable Square Footage. According to the staff report, the maximum allowable SF for
this site is 420,000 SF but the upper bound of the proposed range is 430,000 SF.
It is inappropriate to study a range that exceeds what is allowable.
The applicant appears to want to reserve the ability to use some of the Community
Serving Uses for non-medical office purposes (see middle of page 154 of staff report).
This means that 12% to 23% of the space designated for Community Serving Uses
would be used for non-medical office, and that the applicant’s real estate office space
inexplicably is not included in the total non-medical office SF.
A specific project needs to be defined, without ranges for dissimilar uses and without
ranges that exceed allowable project size. The applicant’s real estate office should be
part of the non-medical office space, not part of Community Serving Uses space.
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Definition of Alternatives
Issues related to Alternatives:
There is no Alternative that maximizes residential space. All Alternatives assume less
than half the project would be housing.
There are no Alternatives that provide needed information about the tradeoffs in impacts
and benefits for the ranges sought by the applicant.
There seems to be no Alternative that conforms to the state’s expectations for
jobs/housing balance within Preferred Development Areas (PDA). Information provided
as part of Menlo Park’s General Plan Update process indicates that the state expects
PDA’s in our region to provide a ratio of 1.42 jobs/housing (744,230 jobs and 535,575
dwelling units).
The EIR scope should include an Alternative that maximizes residential uses.
If the applicant continues to require a range for non-residential uses, then separate
Alternatives need defined and evaluated to make clear the tradeoffs of impacts and
benefits for the low and high ends of the ranges.
EIR Scope
The staff report claims that the Specific Plan adequately studied issues excluded from this
project’s EIR such as the jobs/housing balance, but as the Sierra Club pointed out during the
Council’s Specific Plan review in 2013, the Plan’s ratio of housing to office will not achieve the
result claimed in the Plan’s EIR (1.56) given the allowable maximum of 50% office, which is
what this applicant seeks at the Public Benefit Bonus level.
As discussed above, it is unclear whether the proposed Greenheart project will conform, or help
the Specific Plan area conform, with the state’s PDA jobs/housing expectations. This project
site, one of the two largest in the Specific Plan area, is one of the key sites suitable for dense
housing. Menlo Park has one of the worst ratios in the Bay area. It is important for the Council
and public to understand how this site’s development will affect the balance.
The EIR scope should include study of the project’s impact on Menlo Park’s
jobs/housing balance, and its conformity with state PDA expectations.
Thank you for your consideration of these issues.
Respectfully submitted,
Sent electronically
Patti Fry, Menlo Park resident and former Planning Commissioner
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