The analysis, released last week as part of a revised draft environmental impact report (EIR) for Stanford's proposed expansion, indicates that development alternatives that include more housing would come with increased traffic congestion on local roads and freeways, additional air pollution and greater demand for existing recreational facilities.
These impacts would also put the onus on surrounding cities, including Menlo Park, Palo Alto and Mountain View, to address the problems created by Stanford's growth, according to the draft EIR.
For proponents of additional housing — including the student group Stanford Coalition for Equitable 2035 (SCoPE 2035) and its allies in the SEIU, Local 2007 — the new analysis represents a mixed victory. On the one hand, they succeeded in delaying approval of the Stanford application so that their concerns can be further vetted. On the other hand, this additional study suggests that the type of housing they say is needed comes at a great cost in terms of impacts on the area.
During community meetings last fall, members of SCoPE 2035 urged Stanford to provide more housing for university employees, many of whom commute from afar. Last month, SCoPE 2035 released a platform that calls for Stanford to provide 5,328 housing units for faculty, staff and workers to "better match the projected growth of its workforce over the lifespan of the 2018 GUP (general use permit)."
Palo Alto officials had also raised concerns about Stanford's proposed academic growth and the potential inadequacy of its housing plans. In commenting on the original draft EIR, city officials argued in a letter that the region's housing crisis will be "exacerbated by any project that proposes to add more jobs and more housing demand than housing."
"We urge the county and university to reconsider parameters of the current proposal and either reduce housing demand or increase affordable housing proposed within and proximate to the campus," the city's letter states.
The county performed the additional analysis in response to an outpouring of concerns about housing in response to the initial draft EIR, said Jeff Campbell, the project planner for the GUP application. The county released its initial draft EIR for the Stanford application on Oct. 6, 2017. It extended the period for people to comment on the document, which concluded on Feb. 2.
Campbell — whose firm, M-Group, is the county's consultant for the project — said that initial DEIR elicited voluminous comments about "the dire need for more housing in the area."
The fact that the Santa Clara County Board of Supervisors had made the creation of housing one of its priorities also played into the county's decision to analyze the new alternatives, Campbell said. Board President Joe Simitian has recently proposed a partnership between the county and cities to build teacher housing. The county also signaled support in May for raising the "affordable housing impact fee" that developers of nonresidential projects have to pay from $35 to $68.50 — a move that could have a significant impact on Stanford.
Given the concerns from the board and from the community about housing, the county recirculated a new draft EIR, with two additional alternatives, earlier this month. The comment period on the updated EIR kicked off June 12 and will stretch until July 26.
The county also plans to hold two meetings on the recirculated portions of the EIR, one on June 27 in Menlo Park (6-8 p.m. in the Council Chambers, 701 Laurel St.) and another on July 10 in Palo Alto (6-8 p.m. at the Palo Alto Art Center Auditorium, 1313 Newell Road).
The biggest change in the new document is the addition of two alternatives, each of which includes far more housing than the 3,150 faculty/staff units or student beds that Stanford had proposed in its permit application. One, known as Housing Alternative A, would provide a total of 5,699 units or beds — enough to completely accommodate the increase in the campus population from the academic expansion.
The other, known as Housing Alternative B, would build 4,425 units or beds.
The draft EIR looked at 111 different impacts that the Stanford expansion is projected to incur in areas including noise, air quality, traffic, recreation and public services. In at least 86 cases, the problem would be greater with either of the two housing alternatives than they would be with the original project proposed by Stanford; in a few additional cases, the impact would be "same or greater," according to the EIR.
Traffic: bad to worse
One identified area of concern is transportation. Even without the added housing, the Stanford expansion is expected to have "significant and unavoidable" impacts on traffic volumes at area intersections and freeways. When considered with other "reasonably foreseeable future projects," the added traffic would be "contributing considerably to significant adverse impacts," the EIR states.
The county analysis concluded that Housing Alternative A would generate more traffic even after accounting for the students and faculty who would no longer have to commute to campus because of the new housing. During the morning and evening peak commute hours, the additional housing is expected to result in slightly more than 2,100 additional trips by residents. At the same time, it would reduce the number of commuter trips only by about 700, netting an addition of about 1,400 trips.
The analysis argues that on-campus residents tend to make more trips than commuters to campus and notes that residential rates include trips by both Stanford affiliates and other members of their households.
The county had also previously analyzed a "reduced project alternative" that would result in 1.3 million square feet of new academic space and 1,800 new housing units or beds, as well as a "no project" alternative and a "historic preservation" alternative that would prohibit Stanford from demolishing or remodeling historic resources unless these alterations are consistent with federal standards outlined by the Secretary of Interior's office.
In evaluating the two new housing-focused alternatives, the EIR concluded that they would create more congestion than Stanford's proposed expansion plan. While Stanford's proposed expansion is already expected to create "significant and unavoidable" traffic impacts in the surrounding area, Housing Alternative A would further erode traffic conditions at several already congested roadway segments. These include the northbound Interstate 280 ramp at Sand Hill Road; the intersection of Page Mill Road and El Camino Real; and the intersection of Alma Street and Charleston Road.
That alternative would also add two more Palo Alto intersections to the list of those affected by the project: Bowdoin Street and Stanford Avenue (where the level of service would drop from "E" under Stanford's proposal to "F" in Housing Alternative A); and Middlefield and Charleston roads (where the level of service would be "F" under both scenarios, though with greater delays under Housing Alternative A during both the morning and the evening peak hours).
Housing Alternative B is also expected to bring more traffic to the area, albeit to a lesser extent than Alternative A. The EIR concludes that scenario B would also "increase traffic volumes at area intersections" and create "adverse impacts." And much like Alternative A, it would further exacerbate dozens of impacts that Stanford's expansion is expected to bring, including higher school enrollment, more demand for police and fire services, increased construction noise, additional greenhouse-gas emissions and greater usage of neighborhood and regional parks.
Furthermore, the analysis concludes that both alternatives would "fail to achieve the primary project objective to develop the campus in a manner that reflects Stanford's historical growth rates and the growth assumptions in Stanford's approved Sustainable Development Study."
The additional housing, according to the EIR, would "result in more intense development and construction activity than has occurred over the past several decades." Alternative A would add about 2.5 million square feet of additional development to the campus, beyond what Stanford has proposed in its permit application, while Alternative B would add about 1.2 million square feet.
In addition to evaluating the two new housing alternatives, the recirculated EIR also looked at the impacts that Stanford's development of off-campus housing would have on surrounding communities, specifically Palo Alto, Menlo Park and Mountain View.
The document estimates that Stanford's expansion would result in the demand for 2,425 off-campus housing units. The EIR notes that Palo Alto is currently home to about 19 percent of off-campus students, faculty and staff; Menlo Park and Mountain View have 9 percent and 10 percent, respectively. The potential effects of any off-campus housing development projects, the EIR notes, "would disproportionately affect these jurisdictions compared to other communities in the Bay Area that house Stanford affiliates."
The EIR's findings could make it more difficult for the Board of Supervisors to pursue the types of housing plans that SCoPE 2035 and other housing advocates had been calling for. Even so, Stanford officials have emphasized throughout the process that housing remains a top concern.
"Stanford put considerable effort into proposing a balanced and paced approach that provides new on-campus housing (3,150 student beds and faculty/staff units) in a way that preserves and enhances our academic mission and allows us to properly mitigate the identified environmental and transportation impacts," Jean McCown, Stanford's associate vice president in the office of Government and Community Relations, told the Palo Alto Weekly in an email.
By 2020, McCown said, the university's stock will total 17,900 student beds and housing units. The school has "and will continue to make very significant contributions to the supply of housing."
She also noted that the university is constantly exploring opportunities to build and support construction of new housing, both on campus and in the surrounding region. Stanford is in the midst of building 2,020 new graduate-student beds at Escondido Village, exceeding the amount that the existing General Use Plan calls for. It has secured approval to build 215 apartments in Menlo Park and is now preparing an affordable-housing proposal on Stanford land targeting the school's low-income workers. McCown said Stanford plans to discuss this proposal with county officials in a few weeks.
Comments on the draft EIR should be addressed to David Rader at firstname.lastname@example.org or at Santa Clara County Planning Office, County Government Center, 70 W. Hedding St., 7th Floor, East Wing, San Jose, CA 95110.
By the numbers
2.275 million square feet: Net new academic space
3,150 units/beds: Net new housing
550 units/beds: New housing for faculty, staff, postdoctoral scholars and medical residents
Reduced Project Alternative
1.3 million square feet: Net new academic space
1,800 units/beds: Net new housing
300 units/beds: New housing for faculty, staff, postdoctoral scholars and medical residents
Additional Housing Alternative A
2.275 million square feet: Net new academic space
5,699 units/beds: Net new housing
2,892 units/beds: New housing for faculty, staff, postdoctoral scholars and medical residents
Additional Housing Alternative B
2.275 million square feet: Net new academic space:
4,425 units/beds: Net new housing:
1,825 units/beds: New housing for faculty, staff, postdoctoral scholars and medical residents
Source: County of Santa Clara
A meeting on the recirculated portions of the EIR is set for 6 to 8 p.m. on June 27 in the Menlo Park City Council Chambers at 701 Laurel St., in the Civic Center.
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