January 24, 2025
City of Menlo Park Planning Department
Attn: Calvin Chan
Via email to: CChan@menlopark.gov
Subject: 80 Willow Road
Dear Mr. Chan,
The Sierra Club Loma Prieta Chapter’s Sustainable Land Use Committee (SLU) advocates on land use issues in San Mateo and Santa Clara Counties. We have been following the evolution of the 80 Willow Road proposal and wish to reinforce and support the comments sent to you earlier by Naomi Goodman, resident of Menlo Park, on the Scope of Work for the EIR consultant.
We will be submitting scoping comments when the NOP for the EIR is issued. However, we are now requesting that you include the following items into the “Scope of Work” in the RFP for the EIR consultant (or in an addendum to the RFP) for the upcoming environmental impact report for the project:
- A geotechnical study with soil borings
The project plans indicate that only a thin band of land along the creek would be preserved undisturbed and the parking lot will extend to the creek bank. The project site is within an "Earthquake Zone of Required Investigation", as identified by the CA Geologic Survey, https://maps.conservation.ca.gov/cgs/informationwarehouse/eqzapp/, indicating that the land is at high risk of liquefaction. Placing 400 foot high towers in this location could destabilize the creek bank and affect groundwater flows as construction will require extremely deep pilings to support the towers and potential dewatering affecting the creek's groundwater. The EIR needs to study whether the project is feasible at this location without causing environmental damage.
- A biological resource assessment of the creek
This is required as San Francisquito Creek hosts federally protected Central California Coast steelhead trout. The creek banks and existing vegetation provide habitat for birds and other wildlife. Changes to the creek through bank destabilization, disturbance of existing habitat, shading from tall buildings, artificial lighting at night and noise impacts could degrade that habitat.
- A traffic study
This should include not only the CEQA-mandated vehicle miles travelled (VMT) per person but also a Level of Service (LOS) analysis, which will show how many intersections will be impacted. The study should also include the projected traffic impacts at build-out of the proposed Parkline development nearby.
- Public safety
This should include impacts addressing limited capacity of traffic arterials needed for emergency evacuation for earthquake or fire or flooding. Both Middlefield and Willow Road are currently heavily impacted evacuation routes. In addition, the scope of work will need to study the emergency response team capacity for high-rise building fires, earthquakes or other calamitous events.
We look forward to keeping in touch with the City going forward on this project.
Respectfully Yours,
Gita Dev, FAIA, Chair
Sustainable Land Use Committee
Sierra Club Loma Prieta Chapter
Cc: Deanna Chow, Community Development Director, PlanningDept@menlopark.gov
Mayor and members of the city council, city.council@menlopark.gov
James Eggers, Executive Director, Sierra Club Loma Prieta Chapter