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About this blog: I grew up in Los Angeles and moved to the area in 1963 when I started graduate school at Stanford. Nancy and I were married in 1977 and we lived for nearly 30 years in the Duveneck school area. Our children went to Paly. We moved ...  (More)

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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.
Local Journalism.
What is it worth to you?


Posted by Eric Rosenblum, a resident of Downtown North,
on Oct 22, 2017 at 12:16 pm

Thanks for writing this, Steve. It's a really useful summary of the key issues, and also a good way of thinking about our responsibility to future generations

Posted by Elaine Uang, a resident of Downtown North,
on Oct 22, 2017 at 2:13 pm

Steve, Thank you for doing and writing this analysis. It was a pleasure serving with you on the Comp Plan CAC and I always welcomed the critical analysis you provided regarding city and regional economic trends. The economic health of our city is clearly complex and depends on an ecosystem. Residents and businesses both contribute to the success and vitality of our home and I hope decisions about the future of our city take these Dynamics into consideration.

Posted by Curmudgeon, a resident of Downtown North,
on Oct 22, 2017 at 7:08 pm

There is little point to debating an ancillary document to a CC which will be duly adopted and then ignored, except to be occasionally cherry picked to support whatever development proposal is being promoted by the city staff at any given moment.

The decade-plus delay preparing this CC shows its actual importance. It just isn't a priority.

Posted by WOW, a resident of Addison School,
on Oct 22, 2017 at 7:17 pm


Way to just diss all the hard work 25 residents' work on the Comp Plan. Instead of complaining, yet again, how about offering something positive for a change? While the process was arduous there was a lot of really good dialogue and understanding happening at those meetings (at least the ones I attended). They were grappling with some really hard issues and your dismissive and cynical attitude should be kept to yourself. I, for one, am grateful that we had dedicated and thoughtful residents dealing with issues that will impact all of us.
Thank you Eric and Elaine and all the others for your service to our city. While the Comp Plan is not perfect, we all benefit from your fine leadership!

Posted by Palonorte, a resident of Downtown North,
on Oct 22, 2017 at 7:29 pm


- Way to just diss all the hard work 25 residents' work...
- Instead of complaining, yet again, how about offering something positive for a change?
- your dismissive and cynical attitude should be kept to yourself."

Scorpions sting, frogs croak and Curmudgeon complains.
No way you are going get that pig to sing. Stop trying and just ignore.

Posted by Anonymous, a resident of Another Palo Alto neighborhood,
on Oct 23, 2017 at 7:44 am

Non-academic economist Steve Levy is making the same "dynamic growth" argument Congressional Repubs make when they want to cut taxes. At the Federal level tax cuts completely explain the growth in deficits since Reagan. Dynamic growth doesn't work.

It just shows how politicized economics has become.

Posted by Tired of the usual complainers, a resident of Monroe Park,
on Oct 23, 2017 at 9:03 am

"Non-academic economist Steve Levy is making the same "dynamic growth" argument Congressional Repubs make when they want to cut taxes. At the Federal level tax cuts completely explain the growth in deficits since Reagan. Dynamic growth doesn't work."

To Anonymous, Curmudgeon and others who behave in the same way...

I'm so tired of these baseless and irrelative attacks on anyone who promotes progress. Change is inevitable, and from where I stand, generally positive. Yes, Palo Alto is different today than it was in 1920, 1950, 1980 or 2010 but I'm in favor of where we are headed. Steve makes clear points supported by easily defended facts. Make an argument that is as thoughtful or educated and I'll be glad to hear your point. Otherwise, stop with the smear tactics. This type behavior has no place in my Palo Alto.

Posted by George Drysdale, a resident of another community,
on Oct 23, 2017 at 10:28 am

Steve Levy is right. What he doesn't include is the boondogling of the government (rent control and "affordble housing:unaffordble). Land valuation is the key. The Buena Vista trailer park is a real gem for students of economics and therefore politics. I don't know if we can really project growth in California anymore. Like the highest taxes? The desert is returning. The greatest traffic congestion on earth? Government needs cleansing: The San Jose Property Rights initiative: Google
George Drysdale land economist and initiator

Posted by stephen levy, a resident of University South,
on Oct 23, 2017 at 11:03 am

stephen levy is a registered user.

Anonymous has the "who's in line with the Republicans and Trump just backwards.

He or she argues that my blog is the same as saying that tax cuts reduce the deficit. He or she and I actually agree that this is nonsense.

What I did say that anonymous may (?) be disagreeing with is that in the past Palo Alto has had growth accompanied by cleaner air (actually the Air Resources Board reports that GHG emissions have fallen), fewer students and lower water use.

This is all true, nothing to with being an economist, and is likely to be true going forward--cars are cleaner, we have a climate action plan and a transportation management plan, appliances are more energy and water use efficient. And birth rates are lower than when the current generation of students were born.

So it is actually anonymous who is arguing the Trump climate change and science denying line as well as denying what has happened already and, in addition, doubting the power of science, ingenuity and the conservation ethic of Palo Altans in preparing for the future.

Posted by Curmidgeon, a resident of Downtown North,
on Oct 23, 2017 at 12:10 pm

"Way to just diss all the hard work 25 residents' work on the Comp Plan."

Not me doing the dissing. City hall will do the dissing many times in the coming decades.

You just think your work is done. I was once naive like you. It is my duty to warn the current newbies.

"Instead of complaining, yet again, how about offering something positive for a change?"

OK, since you failed to heed my several real time warnings about the process, and apparently overlooked Hizzonner the Mayor's cavalier but real dismissal of a major part of the citizen input (he was simply being honest, but too soon), then you guys have your work cut out for you. Get to every city council meeting at which the CC might be invoked and defend your baby. Speak up loudly in person. Show some commitment beyond the keyboard.

Posted by Curmudgeon, a resident of Downtown North,
on Oct 23, 2017 at 2:04 pm

"To Anonymous, Curmudgeon and others who behave in the same way..."

I cannot speak for the others, but all I ask is you read before you write.

Posted by Allen Akin, a resident of Professorville,
on Oct 23, 2017 at 5:34 pm

Steve wrote: "This is all are cleaner, we have a climate action plan and a transportation management plan..."

The quantity of pollutants in the air is affected by climate, the number of vehicles, and the pollutants produced per vehicle. Analyzing the effects of climate change is beyond my pay grade. But increasing the population without building transportation systems that eliminate the need for cars will increase the number of cars. The fleet of cars in use changes slowly, so if the number of cars increases faster than the reduction in emissions per car, things will get worse for a period of time that is probably measurable in decades. At least in the case of ozone emissions this appears to be exactly what's happening; see this chart on the Spare the Air website Web Link . And of course the Trump administration's policies tend to increase emissions per-vehicle, worsen climate change, and seek to override California's standards where possible. The full extent of these problems remains to be seen.

Anecdotally, I have a particulate-matter counter (for PM2.5) that I use in my woodworking shop. I move it outdoors occasionally to see how the ever-increasing traffic through my nominally residential neighborhood affects air quality. The short answer is that nowadays air quality never gets above "poor".

Moving on to transportation management, many of us have argued that the comp plan offers no realistic framework for implementing new transportation infrastructure that would reduce traffic and parking requirements below current levels in any significant way. This is obviously more of a concern as the population increases without limit.

I won't go into more detail, because these issues have all been discussed before (and at length by people involved in the comp plan development). Fact-based arguments have already been made, but largely ignored. As traffic, parking, air quality, noise, pedestrian safety, commercial services for residents, school class sizes, and a dozen other quality-of-life issues show deterioration, at some point you're forced to concede that unlimited growth isn't workable. Many of us would argue that we're already there, at least to the extent that there is not enough funding and political will to make the changes that would be required for more growth.

Posted by Chris, a resident of University South,
on Oct 23, 2017 at 5:50 pm

Part of the problem is that although people love to complain about parking and traffic, neither is bad enough to make a majority of people push City Council harder.
CC is taking baby steps with TDM and putting a price on free parking. We can hope they take bolder steps in the coming year.

Posted by Allen Akin, a resident of Professorville,
on Oct 23, 2017 at 6:18 pm

Allen Akin is a registered user.

Chris wrote: "people love to complain about parking and traffic, neither is bad enough to make a majority of people push City Council harder."

I see it a little differently. We have permit parking now in order to reduce the impact of commercial parking in neighborhoods, so we do make progress occasionally. Complaints about traffic have been going on for as long as those concerning parking, but the fixes are too intrusive for the current growth-oriented Council to consider. Council is the main problem.

Posted by Todd, a resident of Another Palo Alto neighborhood,
on Oct 23, 2017 at 6:44 pm

"people love to complain about parking and traffic"

Close, though people actually seem to complain mostly about others' contribution to traffic and parking issues as if they're some sort of disinterested 3rd party observer...

Posted by sidney, a resident of College Terrace,
on Oct 24, 2017 at 8:51 am

""people love to complain about parking and traffic""

How true. I have lived here for 22+ years and people were complaining about traffic back then.
We had a two term council member who's constant whine was "there's too much traffic". This council member tried to change embarcadero road to 1 lane in each direction, and her home happened to be on Embracadero road.

The council is afraid to make tough decisions and is always busy wasting time on items that will allow them to pat themselves on the back and say "job well done".
Then we have council members who are against everything (unless it is historic) and then go off on self serving ego trips--thus we still do not have a bike bridge over 101.

Posted by Don, a resident of Menlo Park: Linfield Oaks,
on Oct 24, 2017 at 2:52 pm

What Comp Plan EIR are you talking about? for the region/ or for some city?

Posted by stephen levy, a resident of University South,
on Oct 24, 2017 at 3:10 pm

stephen levy is a registered user.

The blog is about the Palo Alto Comp Plan.

But some points about the EIR design apply broadly.

Posted by the_punnisher, a resident of Mountain View,
on Oct 25, 2017 at 9:58 am

the_punnisher is a registered user.

I guess the truth is hard for some people to handle....

Posted by Gale Johnson, a resident of Adobe-Meadow,
on Oct 25, 2017 at 3:17 pm

Gale Johnson is a registered user.

I know I'm a short timer...that is... my time on earth is getting much shorter. It's interesting to read about the Comp Plan, EIR, et al, but I won't be around to see how it all plays out in the end. I'm not sure, but I might have already exceeded actuarial table's life expectancy numbers. I had disputes with Steve's articles in the past but this one is different, and I thought it was a good one and well researched and written. It gave some surprising historical facts that I won't challenge, and it tries to give hope for the future. But relating how the past prognosticators got it so wrong to what our current conditions are, and projecting that to what the future will bring is like looking into a crystal ball, or maybe a 'snowflake ball'. Maybe 20 years from now, current predictions and Comp Plan plans will be just a 'blip', and forgotten 'blip' on our cities' history. And maybe the economists at that time can tell their story of how things went wrong or differently than predicted in 2017.

I'll be honest. I'm starting to not like 'my town' anymore. Well that's being too harsh maybe...'not as much anymore' are better words. I didn't think I'd ever say that because I knew 'my town' for so many years the way it was and the way I liked it and wanted it to remain. Lots of fond memories!

And yes, all of us regular posters are familiar with Curmudgeon's posts. Some should be ignored but others offer a kernel of truth that shouldn't be.

I tend to agree that as far as CC is concerned this was just a hurdle to go over and an item to check off on their checklist of accomplishments. Time will tell how they follow up on the Comp Plan and EIR guidelines.

Whoopee for them, CC, to approve market rate housing on El Camino. That softball was easy to hit. Now let's talk about BMR housing. No, don't ever use that other word, 'affordable' again, unless each CC member can clearly and unambiguously define what it means to them. I have a hunch they'll all rush to their Roget's Thesaurus for words to describe it. It's possible we'll all be fooled again.

I poke fun at CC, but I also honor and respect the hard work they do and time they put in for our city. I watch them on TV and get very bored many times, as I assume others do, when watching the live coverage of meetings. It is still a great service and venue that the Peninsula Media Center provides for us.

And yes, an election year is coming up. It will be interesting to see the posturing and preening to entice voters. Records of incumbents are out there for all of us to see. Please take the time to review them and compare them to what they said when they were running for office before.

Posted by We must PLAN for school impacts, a resident of Midtown,
on Oct 26, 2017 at 11:39 am

We must PLAN for school impacts is a registered user.

Mr. Levy paints an optimistic picture of how Palo Alto will undo the significant, data-based, negative impacts of the growth projected in this Comp Plan Update. Since we're smart and good and innovative, we'll find new ways to fix them.

In my view, the smart alternative is to recognize the impacts and plan accordingly IN THE COMP PLAN to prevent or at least manage them. On schools in particular, the heart of our community, we owe it to our kids to acknowledge the dangers and likelihood of school overcrowding and plan to avoid them.

Here are some important facts:

- The EIR assumes that PAUSD can maintain quality services at maximum physical capacity (PAUSD has stated they cannot).

- Yet even so, the EIR analysis shows that elementary and middle school enrollment will WELL EXCEED maximum capacity under this plan.

- Mr. Levy offers false comfort with talk of declining birthrates - PAUSD demographers have discredited birthrates as an unreliable predictor of school enrollment.

- State law PREVENTS an EIR from finding "significant" school impacts, no matter how much the student population grows. So there are no state-mandated mitigations and school impacts alone don't offer a legal basis to reject the city's chosen growth plan. Importantly, however, state law does NOT prevent the city from planning to accommodate and manage anticipated school enrollment growth.

Yet still, this plan is silent on how it will do so.

The city takes no responsibility for monitoring and assessing enrollment impacts in areas it targets for significant new housing (or overflows to other neighborhoods). There also is no zoning accommodation for school expansion or provision for traffic or school commute safety improvements associated with school growth (either in targeted areas or surrounding existing school-owned sites that may be brought online). And even though the city and PAUSD serve a shared constituency, there is no offer of encouragement or assistance should PAUSD seek to adjust District facility impact fees (for new school construction).

Instead, city leadership is pretending that our hands our tied; gambling that impacts will be smaller than predicted and that any problems that emerge can be fixed after the fact. That doesn't feel smart, good or innovative to me.

Posted by Chris, a resident of University South,
on Oct 26, 2017 at 7:21 pm

The housing that needs to be built initially is not for families. Once that has been built, you may find that enrollment patterns have changed. The enrollment now is far below the peak in the 1970's. To be logical, you should have been saying in the 1980's that more housing needed to be built to fill up the schools.

Posted by chris, a resident of University South,
on Oct 26, 2017 at 7:29 pm

I agree that the CC is way too timid at identifying problems and implementing solutions. However, the large number of citizens who are blasé about the issues gives the status quo activists an outsize voice. The blasé majority would support moderate progress but they are not making their voice heard.

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