Despite acknowledging the area's need for more housing, Palo Alto has come out swinging against a new county analysis that considers requiring Stanford University to build enough housing to accommodate for the university's proposed academic growth.
In a strongly worded letter that the city sent to Santa Clara County on July 24, staff argue that the revised draft Environmental Impact Report (EIR) issued by the county earlier this year fails to spell out the specific problems the new housing would create in surrounding communities and, as such, fails to comply with state law.
Stanford's proposal, as laid out in its application for a new General Use Permit, calls for building about 2.275 million square feet of new academic space and 3,150 housing units (that is, apartments and student beds) on campus between now and 2035. In response to concerns from neighboring cities and the county Board of Supervisors about insufficient proposed housing, earlier this year county planners agreed to include in the draft EIR a study of two housing alternatives, A and B. The scenarios would add 5,699 housing units (Alternative A) and 4,425 units (Alternative B) as part of Stanford's expansion.
The Santa Clara County Board of Supervisors is set to review Stanford's General Use Permit application in the fall, with the goal of making a decision on it by the end of the year.
The city's letter of response to the analysis, signed by interim Planning Director Jonathan Lait, argues that the revised draft EIR effectively and unfairly forces the cities to bear the burden of Stanford's growth, particularly when it comes to off-campus housing built in their cities.
"Local agencies in which off-campus housing would be located can and should mitigate the environmental impacts from off-campus housing to the extent feasible," the county's analysis states.
Palo Alto officials took issue with this language.
"This is not a satisfactory mitigation under CEQA (California Environmental Quality Act) and irresponsibly shifts the burden from the university to Palo Alto and surrounding communities to mitigate the housing impact," Lait's letter states. "The university has the land and resources to mitigate housing-related impacts and the county can and should require greater analysis of how induced population growth will impact Palo Alto and to require mitigation measures."
In addition to requesting the county do further and better analysis, the letter aims to synthesize disparate comments that were made by City Council members during their June 25 review of the two housing alternatives. Councilmen Tom DuBois, Cory Wolbach and Adrian Fine voiced support for the alternatives, with DuBois saying they "make a lot of sense," particularly Alternative A, which would house 100 percent of Stanford's new employees and students. Fine called the alternatives "promising," while Wolbach said he is much more in favor of the alternatives than the original Stanford proposal.
Other council members either remained agnostic about the alternatives or focused on the negative impacts that additional housing would usher in, including the prospect of new 130-foot-high buildings on El Camino Real, across from Town & Country Village.
Building housing of such height will be "problematic with the whole community" and would impact things like "vistas, viewpoints and compatibility," Councilwoman Karen Holman said at the meeting. She and DuBois also raised concerns about eliminating the building-setback requirement on El Camino, while Fine and Wolbach said they have no problem with Stanford having more flexibility to build closer to the street.
The city's letter tries to balance the council's hopes and fears by stating the city's support for denser housing on the Stanford campus, as well as its desire to see a new analysis for where the new housing would be located. The notion that future housing "must be up to 134 feet tall adjacent to El Camino Real exaggerates the impact of placing housing in the identified location," the city's letter states.
"The city encourages the county to take a closer look at how and where housing could be placed so it respects and preserves the surrounding character," the letter states. "If such further analysis does not result in meaningful changes, it is difficult to support the conclusion based on information contained in the (analysis) that such housing would not degrade the existing visual character or quality of surroundings.
"El Camino Real has low-profile buildings, and construction contemplated in the alternative would significantly alter the character of the street and by extension the character of Palo Alto," the letter states.
While the letter doesn't take issue with requiring Stanford to build more housing, it rejects as wholly "unfounded" the draft EIR's suggestion that Palo Alto's recently revised Comprehensive Plan somehow accounted for Stanford's projected growth.
The Comprehensive Plan anticipates housing growth of 4,420 units through 2030, which would have accommodated Stanford's original proposal for 3,150 housing units. But the Comp Plan did not consider the additional 2,342 housing units contemplated in Housing Alternative A, the more ambitions of the two scenarios.
"Citing the Comprehensive Plan and suggesting it anticipated this additional growth is not only wrong, failure to disclose impacts renders the document inadequate under the California Environmental Quality Act," the letter states.
One issue on which the Palo Alto council generally agreed is the need to request more assistance from Stanford on transportation. The letter makes that case by pointing to growing dissatisfaction in the city with traffic levels. The letter notes that resident satisfaction with "ease of travel by car" has plummeted since 2003. In 2017, only 42 percent gave the city good ratings on this issue, the lowest level in 14 years of data collection. For residents closest to the university, the letter notes, the figure dropped to 31 percent.
According to the draft environmental analysis, traffic would increase close to the campus (the analysis found that Housing Alternative A would add about 2,100 trips during the morning and evening rush hours, while reducing trips by commuters by about 700). As such, the city requests that the university provide upfront funding to "improve the efficiency, capacity and reliability of Caltrain," as well as "fair share contributions" to the city's effort to separate Caltrain tracks from local roads at the city's four rail crossings.
The city's letter also acknowledges, though does not delve into, Stanford's potential impacts on the Palo Alto Unified School District (PAUSD) -- which, according to the school district, are not disclosed in the revised EIR. The City Council, the letter states, "encourages the county and university to work closely with PAUSD to address these concerns and ensure the district maintains its neighborhood enrollment standards."
"The impacts to PAUSD, new school sites and funding for increased enrollment, should be more clearly disclosed to the public in an updated environmental document," the letter states. "Unmitigated impacts to the school district is a significant concern to the city."