Something is missing from the almost 5,000 pages of text detailing how the environment would be affected by Facebook's plans to build three 75-foot-tall buildings (two offices and a hotel), and add an estimated 6,550 employees to Menlo Park.
That something, said Tameeka Bennett, executive director of Youth United for Community Action, is a four-page letter written by a coalition of agencies in East Palo Alto submitted almost a year ago.
Bennett said she and her colleagues had spent "hours and hours" working on the letter, going door to door, hosting focus groups and meetings with residents, stakeholders and planners in East Palo Alto to define what they'd like to see included in the environmental-impact report about Facebook's expansion plans. The letter was the culmination of those efforts, and it's not included in the appendices of the report where other letters from the public are located.
Bennett's 2015 letter raised major concerns about the health impacts of increased air pollution due to traffic increases in Belle Haven and East Palo Alto, and the "multiplier effect" the tech boom would have on job growth.
The coalition then asked Menlo Park for a 15-day extension of the July 11 deadline, and a promise that the city will forward the coalition's letter to everyone who has expressed interest in the Facebook expansion draft environmental-impact report, whether as a public commenter, someone who has attended a meeting on the topic, or someone who has submitted an email address to learn more about it.
Bennett told this to the East Palo Alto City Council at its meeting July 5, attended by Menlo Park staff, and Kirsten Chapman, a representative from the consultant group ICF International that put together the report. An email several hours earlier was also submitted to the Menlo Park City Council noting the omission.
"Yes, yes," responded Bennett to questions from the East Palo Alto City Council about whether the letter was submitted on time, and if there was proof of its submission.
"Everything was in order," she said.
The environmental-impact report is supposed to respond to all relevant concerns that people raise before the study starts, including the omitted letter, according to state regulations.
"I was shocked to see it wasn't included," Bennett told the Almanac.
Her organization, Youth United for Community Action, is one of the agencies in the "Build East Palo Alto" coalition, which also includes the groups Peninsula Interfaith Action, El Comite de Vecinos and Urban Habitiat. She called the coalition a "Justice League" of sorts, where each organization works on its own most of the time, but bands together at times of communitywide concern. It is the same coalition that brought a lawsuit against the city of Menlo Park in 2012 for failing to update its housing element for 20 years.
The irony was not missed on East Palo Alto Councilman Carlos Romero, who told Menlo Park staff: "I am floored, almost speechless that the very group that actually almost took (your) city to court ... and compelled you to approve a housing element and to put money on the table so people could develop affordable housing ... Their letter was not included?"
City of Menlo Park staff is currently trying to track down the cause for the omission, Assistant City Manager Chip Taylor said. Some of the issues raised in the letter were discussed at some level in the environmental-impact report for the city's general plan update, he said.
That update could allow an addition of up to 2 million square feet of nonresidential development and 4,500 housing units, resulting in an estimated 5,000 more jobs and 11,250 more residents. That project is also in its 45-day review period, which ends July 15.
The omission of the letter combined with the double-duty environmental review period casts Menlo Park under certain unfavorable "optics," said Daniel Saver, a housing attorney at Community Legal Services in East Palo Alto. He sent an email on behalf of "Build East Palo Alto" to Menlo Park City Manager Alex McIntyre, which said: "Overwhelming the public with technical documents about two immense projects while restricting comments to a mere 45 days creates an appearance that Menlo Park may be trying to avoid rigorous public input and simply rubber-stamp the (draft environmental impact reports).
"The optics of this situation are compounded by the city's failure to recognize one of the key comment letters expressing deep concerns about the projects' scope and impact."
"Carbon dioxide emissions and traffic congestion have significant effects on air quality in East Palo Alto," Bennett wrote. "East Palo Alto, like many other low-income communities, has a higher prevalence of respiratory ailments than its more affluent neighbors."
While the draft environmental-impact report did not include a study that looked at health impacts specifically, it did study the potential air pollution and found that it would fall below the state's threshold for constituting a "significant and unavoidable" impact.
However, Bennett said, "We know expanding the Facebook campus will mean more trips, (and) that only adds more to our health issues in East Palo Alto."
Smog especially, she said, can worsen respiratory problems.
East Palo Alto and eastern Menlo Park kids are hospitalized for asthma at almost double the San Mateo County rate according to the Ravenswood Family Health Center in East Palo Alto, as reported by the Palo Alto Weekly in 2012.
While Facebook would add a lot of new employees, the draft environmental report says it would limit the number of vehicles allowed to enter and leave from its campus each day. According to Taylor, those limits are tracked carefully and Facebook gets fined $50 for each car over the limit. The trip cap would permit only an additional 438 rush-hour morning trips and 123 rush-hour evening trips.
Another potential impact the coalition said it wanted studied is whether Facebook's expansion would have a "multiplier effect," in which each high-tech job created generates numerous other service sector jobs, which pay much less.
According to Councilman Romero, some Bay Area economists say that each high-tech employee generates 2 to 4.5 new, mostly service-sector jobs, which puts even further strain on the local "below market rate" housing stock and creates longer commutes.
The omitted letter wasn't the only problem that East Palo Alto council members had with Menlo Park's development plans. Romero expressed concern that it looks like Menlo Park expects its neighboring cities to house the vast majority of new employees that a proposed office expansion at Facebook would bring, while it alone reaps the tax benefits and other perks of being the hometown of the world's biggest social network.
Less than 5 percent of Facebook's employees currently live in Menlo Park, and only about a third of 1 percent now live in East Palo Alto, according to a Facebook-funded study by Keyser Marston Associates, which looked at how the new project would affect local housing demands. In East Palo Alto, that's about 28 employees.
Despite the study's assumption that East Palo Alto would only experience an increase in demand of 21 housing units citywide because of Facebook's expansion, East Palo Alto council members seemed uncomfortable with the study's underlying conclusion that Menlo Park's neighbors and outlying cities will be expected to bear the brunt of housing 95 percent of the company's new employees.
"This would be impossible for Menlo Park to agree to if it were happening to you," Romero told Menlo Park staff.
"Our low-income communities ... have a lot of people to absorb as it is," Bennett said. "To assume other communities will absorb those numbers while Menlo Park is reaping all the benefits ... it's really terrible."
On July 6, Bennett received a call from a Menlo Park city staff member telling her that the public-comment-period deadline for Facebook's draft environmental report would not be extended.
The deadline to submit comments on the report is 5:30 p.m., Monday, July 11. Comments may be submitted to Kyle Perata, city senior planner, by email (email@example.com) or by regular mail to: City of Menlo Park, Community Development Department, Planning Division, 701 Laurel St., Menlo Park, CA 94025.