Stanford Open Space Alliance
P.O. Box 19742 • Stanford, CA 94309 • (650) 223-3333
www.sos-alliance.org • info@sos-alliance.org

August 7, 2000

Sarah Jones, County Planner
Santa Clara County PlanningDept.
70 W. Hedding St., 7th Floor
San Jose, CA 95110
Fax: (408) 288-9198

Dear Ms. Jones,

Thank you for the opportunity to comment on the Draft EIR for Stanford’s General Use Permit and Community Plan.

As you are aware, the Stanford Open Space Alliance (SOSA) is a network of students, faculty, staff, alumni and neighbors of Stanford University that is dedicated to the permanent protection of the Stanford Foothills southwest of Junipero Serra Blvd. To date, we have collected more than 10,000 signatures in support of our position.

Please consider the following suggestions for inclusion in the Final EIR for Stanford’s GUP and Community Plan.

Open Space

On January 25, 2000 Supervisor Joe Simitian stated:

"I would specifically ask our EIR consultants and our planning staff to consider the full range of possibilities available to our Board for protecting those 2,000 acres – consistent, of course, with the University's legal rights as a property owner. In addition to the use of an academic growth boundary and/or general plan and zoning designations, I think it would be helpful to consider the potential for open space dedication, the granting of conservation easements, the transfer of development rights, the use of a development agreement, clustered development, or some combination of those tools, to protect the foothills."

These potential tools for protecting the Stanford Foothills should be thoroughly studied in the FEIR.

The FEIR also should study a fourth option for the Academic Growth Boundary (AGB) that would maintain the existing boundary between Stanford’s Academic Campus and Academic Reserve and Open Space (see Figure 4.2-1 in the DEIR). This line is roughly the same as Palo Alto’s Urban Growth Boundary (UGB) and Urban Services Boundary (USB). A map of Palo Alto’s UGB and USB should be included in the FEIR, and an explanation of the differences between these two boundaries should be provided.

Biological Resources

In addition to the California tiger salamander, the FEIR should study the long-term protection and habitat enhancement of other threatened and special status species on Stanford lands, such as the California red-legged frog, steelhead trout and western pond turtle, as part of the Community Plan.

The Felt Lake area should be studied as a possible site for habitat restoration and introduction of threatened species and candidates for the Endangered Species Act (ESA), including the red-legged frog, the tiger salamander and the western pond turtle.

The FEIR should explore prohibiting development within the California Tiger Salamander Management Zone. The FEIR also should include a biological assessment of the golf course, and should consider extending the CTS Management Zone to include the entire golf course.

Findings in the EIR should be based on independent verification from a qualified biologist. It is against County policy to use verification from Stanford's own faculty/staff.

Maximum Build-Out Plan

The FEIR should include an analysis of a maximum build-out plan for Stanford University. Stanford’s current development strategy appears to be aimed at extending and building out the corners of its academic campus, and then focusing on infill at a later date. Therefore, the FEIR for the Community Plan should define the long-term developable areas of the campus so that Stanford can plan accordingly with higher density on the core campus.

To help determine the extent of Stanford’s rights as a property owner, the FEIR should include daytime population figures for both Stanford and Palo Alto.

Reduced Project

The FEIR should study two additional Reduced Project Alternatives. One should consider allowing Stanford to build half of the proposed 3,018 housing units and no academic development. This would meet Stanford’s current shortfall in housing (approximately 1,400 units) without adding more people to its daytime population and thus increasing the demand for housing.

The second alternative should study allowing construction of all 3,018 units of housing proposed by Stanford, but only 1 million square feet of academic development.

Housing

The FEIR should study the following options regarding housing:

1) Housing should be restricted to 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.

2) The FEIR should study the possibility of converting some of Stanford’s existing 170 acres of parking lots into multi-story parking structures to free up other parking areas for housing. A map of Stanford’s existing parking lots should be included in the FEIR along with an analysis of which sites would be appropriate for parking structures, and which would be appropriate for housing.

3) The FEIR should examine restricting all new housing to areas outside of the Tiger Salamander Management Zone.

4) There are many under-utilized sites on the Stanford campus that would be appropriate for higher density housing, allowing Stanford to meet its needs for housing while limiting the environmental impacts. The FEIR should study the following potential housing locations on Stanford’s core campus:

a) West Campus District: the portion within the urban growth boundary and consistent with Palo Alto's agreement with Stanford for Special Area B.

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

c) Carnegie Institution Site: 7.5 acres located just east of the Searsville block.

d) Searsville Block: higher density than the proposed 250 units.

e) Escondido Village: higher density than that proposed by Stanford.

f) Wilbur Hall modules: redevelop for higher density.

5) The FEIR should consider off campus housing sites, including:

a) Old Mayfield School site in Palo Alto (near El Camino and Page Mill Road).

b) The Stanford Research Park. Many sites within the research park are adjacent to single-family neighborhoods and zoned for housing. Stanford policy permits housing to be built there.

c) El Camino Park in Palo Alto.

6) The FEIR should study the impacts of requiring Stanford to make more existing units of housing in Palo Alto’s jurisdiction available and affordable to faculty, staff, students and other Stanford-affiliated individuals. Sites that should be studied include:

a) Stanford West Apartments.

b) Oak Creek Apartments.

c) Stanford Senior Housing.

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

Sincerely,

Peter Drekmeier
Executive Director