What can YOU do about congestion? The Stanford GUP
The Stanford General Use Permit (GUP) for the 2018-2035 period has been made available by the County for public comment. The GUP and the Environmental Impact Report (EIR) describes planned growth on the main campus during that period. It will add 2.3 million sq ft of non-residential space to the campus (compared to 2 million sq ft in the 2000-2017 period which is just being completed). It also adds 9,000 housing units. The EIR has a major section on likely transportation impacts:
The major section on cumulative traffic impacts to intersections in neighboring communities concludes that “the impacts would remain significant and unavoidable”. The major section on the Project’s local freeway impacts concludes that “the proposed impacts would remain significant and unavoidable”.
These impacts from the main campus at Stanford will be added to the impacts that will be experienced from two other Stanford developments:
The 2.3 million sq ft of campus non-residential space added in coming years will be in addition to the 1.3 million sq ft of hospital and medical office space that will come online in the next five years and the 0.8 million sq ft of office space targeted in the Stanford Research Park. That means well over 4 million sq ft of non-residential space can be added on Stanford lands while they admit that traffic impacts are “significant and unavoidable”.
40 football fields worth of academic buildings and enough beds to fill 17 Four Seasons hotels
That’s how the Mercury News article describes the impact of the Stanford General Use Permit (GUP) which was submitted to Santa Clara County for approval. And this is at a time when the Annual Citizens Survey in Palo Alto show that two-thirds of residents are already deeply concerned about the level of traffic today.
Stanford is asking the County of Santa Clara to approve a new General Use Permit for the main campus. They have presented an Environmental Impact Report to the County and have identified mitigations measures that would offset the request for over two million feet of non-residential building and 900 units of housing.
A copy of the Draft EIR can be found on the county website
We believe that some of the mitigations are inadequate. We’ve listed some of them below:
1. Adequate review of Stanford ‘participation’
The EIR for the Campus (Stanford University: 2018 General Use Permit October 2017, EIR Volume 2) has a detailed section on the likely transportation impacts. The key part of Stanford’s proposal is their pledge that any new development will produce ‘No net new trips to the campus’ (Stanford GUP EIR 5.15-42). But they note that if Stanford participates in off-campus trip reduction, credit will be given that reduces the net trips to Stanford (EIR, 5.15-43/44). Thus, two key parts of the mitigation have a significant impact on Stanford’s achieving their ‘no net new trips’ goal: increasing Stanford students and workers use of alternative to non-single vehicle trips; or monetary contributions to projects outside of the campus that reduce single occupancy vehicles usage on any of the commute routes external to the campus. Note that monetary contribution are very important because most Stanford land is exempt from Property Taxes which are the essential revenue source of all local governments (City, County and School districts). The county will be the judge of the Stanford ‘credits’.
2. Inadequate Traffic mitigations
The traffic analysis identifies significant deterioration in surrounding intersections, at least five of them in Palo Alto. The EIR describes intersection mitigations at some of the intersections but recognizes that there are no significant changes possible at most of them since many of the impacts are located in other jurisdictions that that have limited budgets. They conclude: “Since additional funding would be required it is not certain that these improvements would be implemented” (EIR, 5.15-91). The section on cumulative traffic impacts to intersections in neighboring communities concludes that “the impacts would remain significant and unavoidable” (EIR, 5.15-90). Note that when Stanford claims the roadways will be at failing levels even without the campus expansion, they are not explicitly identifying Stanford’s contributions for non-residential growth and traffic contributed by the new buildings outside of the campus on Stanford land at the Stanford Medical Center or the Stanford Research Park.
The major section on the Project’s local freeway impacts is similar. They note that the freeway ramps near Palo Alto on both 1-280 and Highway 101 are already at a LOS of F and note that the mitigation of freeway impacts is considered beyond the scope of an individual development project. Thus, “the proposed Project’s freeway impacts would remain significant and unavoidable” (EIR, 5.15-100).
3. Cal Train responsibility
With mitigations on the intersections and the local freeways falling short, the alternative transportation options become even more important. But the goals become aggressive. Stanford assumes that Caltrain ridership by Stanford commuters will rise by over 2000 on a daily basis or some 60% above today’s level (EIR, 5.15-159). But that assumes a 20% increase in number of rush hour train trips and a 65% increase in passenger capacity of each train. (EIR, 5.15-158/59). They also assume an increase of 24% in the number of bus riders on both local and express buses. (EIR 5.15-165, 167). Even with these very optimistic forecasts, Stanford is asking for 3400 new parking spaces. (EIR 5.15-172).
Key question is what financial support Stanford is willing to offer for train and roadway improvements, especially for Caltrain. Not only is Caltrain facing a sizeable bill for electrification but for the building of grade crossings in Palo Alto and elsewhere that will deal with the resulting traffic disruptions. This raises the stakes for finding effective contributions they can make to surrounding roadway and transportation systems. Since Stanford is paying little for property taxes to either the City or the County who fund most of the costs of Caltrain, it is important that their contributions be clearly stated.
4. Cumulative impacts and fiscal responsibilities
These impacts from the main campus at Stanford will be added to the impacts that will be experienced over the next fifteen years from two other concurrent developments on adjacent Stanford land. The 2.3 million square feet of campus non-residential space to be added in coming years will be coming on line just as Stanford is completing two major adjoining projects in the city of Palo Alto. The first is the 1.3 million square feet of hospital and medical office space that will come online in the next five years or so. The second is the 0.8 million square feet of office space targeted for the Stanford Research Park. That means approximately 4.4 million square feet of additional non-residential space can be added on Stanford lands immediately adjacent to Palo Alto (and add to existing traffic and congestion). And this comes at a time when the Annual Citizens Survey in Palo Alto shows that two-thirds of residents are already deeply concerned about the level of traffic existing today.
5. School responsibility
Stanford is adding 900 housing units that will include 3150 new beds within the campus (EIR, 6-4). This will include some 550 units for faculty, staff, post-docs and workers. This means more than 1200 other family members (EIR, 6-5). Many will be children, located near the center of the campus. This implies that there will probably be enough young children to open a new school on campus. Again because most school funds come from local property taxes that Stanford is exempted from, special attention must be paid to the financial commitments of Stanford to the school district.
If you agree with any of these points, please come and speak at the open session on November 30th or send a note or email about your concerns to the County referencing the EIR . The comments are particularly effective if you cite the specific page in the EIR that you are discussing. Stanford must respond to each concern raised.
The public meeting on the Draft EIR will be held:
November 30 (Thursday) from 7-9 p.m.
Palo Alto Arts Center Auditorium
1313 Newell Road, Palo Alto
(Special County Planning Commission meeting to receive public comments on the Draft EIR.)
The county must receive your written comments by mail or email not later than December 4. Send comments to:
County of Santa Clara
Department of Planning and Development
Attention: David Rader
County Government Center
70 West Hedding Street, San Jose, CA 95110
Phone: (408) 299-5779
Email: David Rader
The Palo Alto City Council will review the City’s response to the Stanford GUP and DEIR at it’s meeting on December 4, 2017. A copy of the staff report is available here.