CGF scoping comments on the proposed Stanford Shopping/Medical Center Expansion

(CGF submitted the following comments on the scoping (preparation) of the environmental review for the Stanford Shopping Center and Medical Center expansions. We'll also review the actual environmental documents when the drafts are available. -Brian)

October 1, 2007

Steven Turner
City of Palo Alto

Re: Scoping comments for the Stanford Medical Center and Shopping Center Expansion EIR

Dear Steven;

The Committee for Green Foothills submits the following comments for scoping the EIR for the Stanford Medical Center and Shopping Center:

· The purpose of the approval for this project must be defined by the City, not by the applicant. If the purpose that the permissions the applicants seeks (such as improving medical care) can be done in a way that the applicant does not seek, that option remains within the purpose of the City. Legally, the applicant cannot define the purpose in a way that artificially narrows the scope of the project and its alternatives. Because the City is deciding whether to approve the agreement, it has to define the purpose.

· The EIR must consider a “no expansion/seismic only upgrade” alternative for the Medical Center.

· A “no increase in medical office space” alternative should be included. Conditions should be placed defining what type of activity or organization may use “medical office space.”

· Any relaxing of existing zoning standards will violate thresholds for environmental significance that the standards are meant to protect, unless compensatory environmental mitigation is required. This is especially true given the large size of the project. For example, easing density restrictions should be compensated with open space protection.)

· Increased building height and density should be compensated with open space protection. Decreasing views of hillsides and of natural areas are visual impacts that can be appropriately compensated for by open space protection.

· Increase utilization of recreational resources must be analyzed in the EIR for direct, indirect, and cumulative impacts. The City should compare the analysis used for the Stanford GUP in Santa Clara Clount’s EIR for comparison. Increased utilization is a significant impact unless mitigated.

· The EIR process should analyze the phasing and mitigation monitoring used in the Stanford GUP EIR to avoid similar problems. For the Stanford GUP, six years after the impacts have occurred, the promised trails have not yet been constructed. Mitigations should not just be begun before the impacts have occurred, they should be completed, or at least a schedule established with clear stop dates.

· The hospital opening should be in phases, with none the medical office space opening until all environmental mitigations have been complied with. This will make mitigation monitoring and enforcement more credible if it stops use of medical office space until environmental conditions are complied with as opposed to stopping use of the hospital.

· Any net increases in greenhouse gas emissions are cumulatively significant.

· “Green building” standards should be required.

· The impact on housing will be significant unless mitigated and must be analyzed. The impact will also affect open space and traffic, because if new housing is not constructed by Stanford, it will be constructed mostly in Central Valley and elsewhere, with workers commuting in on area highways. The City must do its own calculations about the number of jobs generated by the amount of space created. Secondary (off-site) economic impacts must also be considered in determining the net demand for housing created by this project.

· All newly-created housing demand should be fully mitigated with housing creation that matches the income level of housing demand generated.

· Any analysis that concludes a “no net increase” mitigation standard for transportation is not feasible, must also determine why it is feasible for the much larger Stanford GUP expansion but not for this project.

· Significant and unavoidable impacts must be compensated for in a comparable manner. For example, the visual impact of Medical Center skyscraper will be unavoidable, but rather than simply accept that as the cost the community must bear, it should be compensated for with open space protection where buildings do not predominate views.

· Eliminate Stanford’s “plateau bargaining” through the use of binding promises in the process. For example, Stanford has made promises on where it would agree to place the S1 Trail on its property, and then after much work had been done by the County so it could accept the offer, Stanford reneged on the promises unless dramatic new concessions were added. This problem can be stopped by spelling out in advance when and which parts of a promise are binding.

Please contact us if you have any questions.

Sincerely,

Brian A. Schmidt

Legislative Advocate, Santa Clara County