The comment period for the Facebook Campus Draft EIR should be extended from its current 47 days to 60 days, due to both the fact that the comment period spanned the December holiday period, and due to the large magnitude of the project.

City staff is recommending that the review period be extended only to 54 days, so that it would end on Jan 30, one day before City Council is scheduled to review the Facebook EIR (Jan 31). A 60-day review period would end on Feb 6, thus requiring the City Council to delay its scheduled review.

Such a delay is well worth the improved quality of comments that will be received. We do not need to rush through, as fast as possible, what is the largest commercial development project the city has ever considered (in terms of number of employees).

The Facebook EIR is a very long and complex document that is difficult to understand. It contains 16 different types of environmental analyses - any one of these requires at least multiple DAYS to read and fully understand, because they each reference multiple and extensive and similarly difficult to understand appendices.

The comment period for the Facebook EIR spanned the December year-end holiday period, which for practical purposes, is two weeks long. Many residents who are interested in submitting comments on the Facebook EIR traveled out of town early the week of Dec 19, and many did not return to Menlo Park until after the New Year.

Also, the Facebook Campus Project is of a very large magnitude for Menlo Park. Facebook projects up to 9,400 total employees by 2018 - which would then comprise roughly 25% of the city's entire workforce. The environmental impacts associated with the Facebook Campus Project therefore deserve a thorough and detailed review.

In addition, East Palo Alto is considering filing a lawsuit against Menlo Park for flaws that it claims exist in the Draft EIR that constitute a violation of CEQA law. This is yet another reason that the DEIR should be carefully reviewed so that any such flaws that could be a basis for a potential lawsuit can be corrected in the Final EIR.

A lawsuit could significantly delay the Facebook's expansion plans, since based on the recent very rapid expansion of the company, Facebook could exceed the current 3,600 employee cap at the East Campus as early as 2013. If a Development Agreement is not approved by that time, Facebook may consider leasing office space elsewhere.

A lawsuit would also consume valuable staff time.

We can avoid these serious issues by simply extending the current 47-day review period to 60 days.