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By Steve Levy

The Comp Plan EIR--Pluses and Minuses

Uploaded: Oct 22, 2017

On Monday October 23rd the city council will begin review of the final Environmental Report (EIR) of the new Comprehensive Plan (Comp Plan).

The EIR has three mandated obligations:
--To identify impacts of the project (here the project is various levels of job and population growth)
--To propose mitigation measures when significant impacts are possible
--To identify where significant and unavoidable impacts could remain after mitigation

The final EIR, while including information on all alternatives considered by the council, focused on the so called “preferred alternative” of between 8,435 to 10,455 additional residents, 9,850 to 11,500 additional jobs and 3,545 to 4,420 additional housing units. The job and population growth represent increases of 10-15%.

The Pluses in the Final EIR

The EIR faithfully completed their mandated tasks and should, therefore, be adopted so that the Comp Plan can be completed and we can move forward to implementing policies and mitigations.

The EIR found potentially significant and unavoidable impacts with respect to air quality and traffic/transportation but also no significant impacts with respect to land use, population and housing, water and school enrollment.

However, the mandate of the EIR process has a design flaw that affects how the results should be interpreted with respect to Comp Plan policies and impacts. The impacts that could be unavoidable when looking only at the growth impact could be offset by changes in the behavior of existing residents and workers/companies and the advance of technology and innovation.

The EIR Design Flaw

The EIR focuses on the impacts associated with various levels of future growth.

It is common sense that new jobs and population, by themselves, will add to water use, air pollution, GHG emissions, school enrollment and traffic.

But that is different than saying that in 2030 Palo Alto will have more water use, poorer air quality, more students in school and worse traffic.

The EIR analysis by design does not focus on what happens with the existing residents and jobs. It only focuses on the incremental growth.

Imagine an EIR done 20-40 years ago. Looking at incremental growth, it would have predicted worse air (air quality is much better), more water use (water use in Palo Alto is below previous levels), more kids in school (there are thousands fewer than at the peak enrollment when population was lower) and worse traffic (that assessment would have proven correct).

What happened?

With respect to water use, energy use, and pollution from cars, we have become much more efficient. We have installed low flush toilets, reduced flow showers, more water and energy efficient appliances, cars that get better mileage, commercial facilities that emit fewer emissions and voluntary conservation from an increasingly aware and caring public.

In addition the City has a comprehensive Sustainability and Climate Change Action Plan to move forward with resource efficiency measures. And we are moving forward on various transportation management plans.

With respect to school enrollment birth rates have fallen from near 3 children per family to 2.3 and now fertility rates are near 1.7, below replacement levels. So as existing homes turned over, there were on average fewer children per home. So there were more people and homes but fewer school children.

This is likely to continue in the future. The county is projected to have 300,000 more residents in 2030 but fewer school age children. The current homes and recent projects filled with children from the 2.3 fertility cohort will be replaced on average by children from the 1.7 fertility cohorts.


So the EIR has done its mandated job and should be approved.

My thoughts as someone who came here in 1963 and benefited from the forward thinking of people like Ray Bachetti and Aggie Robinson is that It is time to move forward to adoption of the Comp Plan. Then we can use the information from the EIR along with our existing plans, ingenuity and can do welcoming spirit to leave a great city to future generations, one in which we find ways to make room for middle class folks like we were when we were young and address the challenges of living in the heart of Silicon Valley with a positive and realistic but not fearful attitude.