We have studied the Draft EIR for Stanford University's Community Plan and General Use Permit application, and have determined that Stanford is not adequately meeting its housing needs for staff, faculty, students, and Stanford-affiliated individuals, based on the number of new housing units vs. jobs it proposes to create over the next ten years.

DEIR "...the additional faculty/staff and postgraduate housing will, at most, just accommodate the proposed increase in faculty/staff employment and postgraduates. The existing shortfall of faculty/staff housing at Stanford will not be substantially reduced" (pg. 4.3-16/17).

This shortfall is expected to be between 1400-1600 units.

DEIR also notes that there will be a 2,201 increase in the overall population at Stanford (students and faculty/staff) and "the implementation of the GUP may result in the creation of approximately 500-1000 new jobs over and above those created at Stanford University. Many of these jobs will be in the service industry where pay scales would place the employees in the low- to moderate-income housing market." (pg. 5-8)

Although the DEIR proposes between 2655-3022 new housing units to be built over the next decade, in addition to not having enough units to offset the shortfall resulting from job growth, many of the proposed locations are inconsistent with existing city and county urban growth boundaries and open space designations, threatened species habitat, and do not meet the potential for higher density building.

Stanford was initially proposing to build up to 40 units per acre, now the ratio is about 15 per acre. We would like the final EIR to study and include the following, more sustainable and suitable, options in its housing proposal as part of its CP and GUP application to the County:

1) Housing should be linked to academic/job development in the GUP for a more balanced ratio than currently exists and will result from the proposed plan.

2) Housing should be built within the existing core campus as defined by the County's designated A-1 zoning and Palo Alto's urban growth boundary, and should include higher-density housing as much as possible.

3) Parking alternatives should be considered, such as the conversion of the approximately 170 acres of existing surface parking locations to multi-story parking structures. This would much additional space available for housing or academic development.

4) There should be no development within the tiger salamander management zone. Housing Site F should be moved away from Lake Lagunita to protect threatened tiger salamander habitat. Findings in the EIR should be based on independent verification from qualified biologist--it is against County policy to use verification of Stanford's own faculty/staff.

5) There should be no housing built on the Stanford Golf Course and the golf course should be declared an historic site. If hole one is moved it is likely the entire configuration of the golf course will be disturbed, making it much more likely that the entire golf course will be moved in the future resulting in the loss of additional habitat and open space.

6) Alternative potential housing sites on the Stanford core campus need to be explored particularly focusing on redevelopment of underutilized areas and creating multi-storied parking structures to free up additional acreage.

Potential Sites:

a) Searsville block: This includes the area between electioneer Rd and Santa Teresa St. to the south and to the north Stock Farm Rd (including the large parking lot) and the areas behind Cordura Hall and the Carnegie Institution along Campus Drive. Its current use as faculty housing should be retained, but the parcel should be redeveloped in substantially higher density; this block would be a good site for the "Village" concept of mixed faculty/retired faculty housing which has been suggested by faculty. The Carnegie Institution site alone includes (7.5 acres located just north of the Searsville block.).

b) DAPER/Administrative District: redevelopment for student housing tied to the area near Escondido Village.

c) Escondido Village: redevelop for higher density.

d) Corner of Serra and El Camino: north corner could be developed into high density housing and linked to the redevelopment of Escondido village

e) Wilbur Hall modules: redevelop for higher density.

f) Bowdoin street/Quarry trapezoid area between Bing Nursery and SCRA redevelopment to create additional housing units. It is located near Escondido Village childcare and school.

g) Kingscote: corner of Lagunita Drive and Lomita Drive, redevelop for high density housing.

h) Pearce Mitchell

i) Corner of Campus Drive and Galvez.

j) Corner of Campus Drive and Serra.

Use of existing facilities to meet housing demand:

k) Stanford West Apartments: redeployment to make more units available/affordable for faculty/staff housing and Stanford-affiliated individuals.

l) Stanford Senior Housing: redeployment to make more units available/affordable to retired Stanford faculty/staff and Stanford-affiliated individuals.

m) Oak Creek Apartments: redeployment to make more units available/affordable for faculty/staff housing and Stanford-affiliated individuals.

Sites off campus:

n) Old Mayfield School site: (near El Camino and Page Mill Road) consider for high density.

o) El Camino Park: (portion of existing 11.5 acres)

p) Stanford Hills subdivision/Buck Estate

q) Stanford Research Park: many sites within the research park are adjacent to single-family neighborhoods and zoned for housing and Stanford policy also permits housing to be built there.

We appreciate you taking these comments under consideration and ensuring that sustainable development is an inherent part of our County's planning process and implementation.

Prepared by the Stanford Open Space Alliance and Committee for Green Foothills.

Jane Lathrop Stanford