Monday, November 16, 2015

Liang - Vallco Specific Plan - underground and air right over Wolfe Road

This is a follow-up comment to this one where Liang mistook the tunnel between two underground garages as the tunnel along Perimeter.
http://letters2cupertinocc.blogspot.com/2015/11/Liang-vallco-impact-tunnel-not-parking.html

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From: Liang C <lfchao@gmail.com>
Date: Mon, Nov 16, 2015 at 2:15 PM
Subject: Re: Comment on Vallco Specific Plan - underground and air right over Wolfe Road
To: "City of Cupertino Planning Dept." planning@cupertino.org

I misread the diagram.
The tunnel between the east and west parking garage would in fact be a new tunnel, in addition to the tunnel along Perimeter Road. The tunnel along Perimeter Road will remain.
Page 6 of Existing Condition shows the existing easement, which was granted to a previous Vallco owner in exchange for another easement (air and underground right) near I-280 for a future light rail station. But Sand Hill does not own that property.
 
 
 
Page 8 of Existing Condition shows the proposed easement: Sand Hill wants to expand the air right over Wolfe to almost an entire block.
Pink blocks shows easement for both underground tunnel and air rights of unspecified depth and height.

Then, we would request that any public land for private use should be used only to the benefits of the public to provide ease of access.
Any air right or underground right should not be granted without a fair exchange or a fair rent, adjustable to inflation.
If only tunnel is required for The Hills at Vallco, the easement should not grant the air right in the agreement without justification, such as the two pink boxes in the diagram.
If the air right is granted, the minimum and maximum height should be specified so that only the air right within a given height is granted.
If the tunnel right is granted, the minimum and maximum depth should be specified so that only the tunnel right within a specified depth is granted.
No structure from the easement either in the tunnel or the air should be counted towards the required provision for the projects, such as parking stalls, or retail shops.

Thanks,
Liang

Liang - Vallco impact on traffic should be based on realistic data

From: Liang C
Date: Mon, Nov 16, 2015 at 12:26 PM
Subject: Comment on Vallco EIR - traffic based on realistic data
To: "City of Cupertino Planning Dept." planning@cupertino.org

RE: Comment on Vallco EIR
From Parking-Drawing.pdf submitted by The Hills at Vallco, here are the parking spaces available.

Total parking spaces = 9,175.
Office: 5033; Retail: 2,500; Residential: 1,427; On-street parking: 215.
The number of parking spaces for the 10,000 workers is apparently insufficient.
Even using the low estimate of 8,000 workers (250 square feet per worker), 5033 parking spaces only provides spaces for 62% of 8,000 workers.
5033 parking spaces only provides spaces for 50% of 8,000 workers.
And some more space has to be reserved for outside visitors for the 2 million square feet of office. So, the actual number of spaces available for employees would be even lower.

If the EIR will assume that some of the workers will use other modes of transportation, such as light rail, biking, walking or carpool, please use realistic assumption that's reasonable.
The 2 million square feet of office will not have only one or major employers. There could be 10 or 20 or even 200 office tenants. If assumption is going to be made about any shuttle service provided by the office tenants, it has to be based on actionable plan that's committed in the Development Agreement. And all office tenants have to be disclosed of the limitation and sign onto any traffic management plan.
Based Apple EIR, even at Apple Inifinite Loop, where the culture promotes biking and other modes of transportation, 72% of the employees arrive in single-occupancy vehicle, another 10% arrive in carpool. So, still the number of parking spaces needed is 82% of the employee population.
With Apple Campus 2, Apple has committed to reduce the number of single-occupancy vehicle trips to 60% with the best efforts. The Hills at Vallco with simply an office park with any number of tenants cannot assume to do even better.
If any assumption is made about the number of single-occupancy vehicles or carpools, please provide realistic data to back it up.
Apple EIR also pointed out the difficulty of using public transit: (Page 38 of Apple EIR Appendix B Transportation Impact Analysis)
"Although there is a fair amount of transit service within the vicinity of Apple Campus 2, there are no easy public transfers to existing high capacity transit corridors such as Caltrain commuter rail and various bus lines along El Camino Real. Express transit services typically operate in directions that inhibit travel using solely public transit to Apple Campus 2 from residential areas along the Peninsula. Furthermore, the poor walkability of the streets around the project site, due to higher traffic volumes, discourages people from walking longer distances to transit stops or stations.

To make some of these Caltrain stations more accessible, Apple provides daily shuttle service to the Lawrence and Sunnyvale Stations. The travel time on Apple shuttles between these Caltrain stations and Apple Campus 2 is approximately 15 minutes to 20 minutes.

Most commuting cyclists travel at a rate of about nine to 10 miles per hour, meaning the Lawrence, Sunnyvale, and Santa Clara Caltrain stations are located about an 18, 23, and 28-minute bicycle ride away from Apple Campus 2, respectively. Only the Lawrence Caltrain station has continuous bicycle infrastructure that connects it to Apple Campus 2 in the form of Class II lanes along Wolfe Road, Reed Avenue, and Aster Avenue."
The condition for taking transit and biking or walking hasn't changed, since Apple EIR.
If any assumption is to be made about the percentage of employees who are able to use public transit or walk or bike, please use realistic data to back it up.
If shuttles are going to be used to transport employees or shoppers to The Hills at Vallco, please study the impact on the parking facilities at each pick up location. Are there sufficient parking spaces today? How many more parking spaces will be necessary for the shuttles of The Hills at Vallco?
A large percentage of passengers riding buses in Cupertino are the 30,000 students at De Anza College. They are provided a free bus pass to encourage bus usage, since it is already charged as a part of their tuition. They are also single young adults who do not have other family responsibilities so that they have to be at multiple places in one day at a fixed time.
So, any statistics about bus ridership should only account for non-student population, unless The Hills at Vallco is going to hire only single young adults and provide them with bus passes for free.
Liang Chao

Liang - Vallco Specific Plan - Underground tunnel NOT for parking


From: Liang C
Date: Mon, Nov 16, 2015 at 9:25 AM
Subject: Comment on Vallco Specific Plan - Underground tunnel is for bicycle and pedestrians, not for parking
To: "City of Cupertino Planning Dept." <planning@cupertino.org>



RE: Comment on Vallco Specific Plan
The underground tunnel under Wolfe Road should not be used for parking spaces, as the Parking Drawing of The Hills at Vallco shows.
 
The tunnel currently has two car lanes and one more lane used for pedestrians and bicycles.
It is a common path for bicyclists to use to get across Wolfe to avoid traffic and the danger of Wolfe Road.
Vallco Specific Plan should include a policy to preserve easy access for pedestrians and bicyclists through the tunnel. It is an important part of a walkable and bikable city.
Below is the diagram from Page 2 of the Parking Drawing.
Not only there is no path way for pedestrian or bicycle to use. And the tunnel is not easily accessible by any bicyclist or pedestrian who need to cross Wolfe Road.
The underground tunnel has been used for parking spaces. It will have to be widened from its current width to provide two rows of parking.
The underground space of a public road belongs to the public. It can only be used to provide ease of access for the public. It should not be used as parking spaces at all, and not parking spaces for a private project.
 

Liang - Vallco impact during heavy rain

From: Liang C
Date: Mon, Nov 16, 2015 at 8:59 AM
Subject: Comment on Vallco EIR - impact of heavy rain
To: "City of Cupertino Planning Dept." <planning@cupertino.org>


RE: Comment on Vallco EIR
Although it doesn't rain much in Silicon Valley, during rainy season, there might be heavy rain, which results in flooding in different areas of the City.
The Hills at Vallco will cover the entire 52-acre of the site with concrete. When it rains heavily, all of the rainwater from the 52-acre would accumulate and it may become a torrent.
Please study the rainwater collection system to see if the capacity is sufficient to cover the heavy rainfall. In case of even heavier rain, please study the impact of an overflow from rain water collection system.
Since the rooftop has varying height from 114 feet to 65 feet at street level, please study the impact of heavy rainwater overflow that might cause more slippery road condition on Wolfe Road and other impacted roads.
On the greenroof slope at west side, which goes from street level to 45 feet and then 65 feet in a short distance, please study the impact of heavy rainwater overflow onto the Perimeter Road.
Please study the safety of bike paths during heavy rain. Is any bike path in danger of being flooded with rainwater on its way to drainage system.
Please study the impact of traffic condition during heavy rain when most people won't bike or walk or even take bus to work, since most bus stops do not have anything to protect waiting passengers from rain.
 

Liang - Vallco impact on overflow parking to neighborhoods. Farmers' Market

From: Liang C
Date: Mon, Nov 16, 2015 at 2:10 AM
Subject: Comment on Vallco EIR - impact on overflow parking to the neighborhood
To: "City of Cupertino Planning Dept." <planning@cupertino.org>


RE: Comment on Vallco EIR
Please study the impact of overflow parking demands on neighboring streets, such as Portal and other side streets, and shopping centers, especially the center with JoAnne Frabric and United Furniture across the street.
Please study the impact of overflow parking demands on neighboring streets of the new K-5 elementary school at Nan Allen Elementary site.
It is well known that the parking stalls required for office park, residential or mixed use sites in the zoning code is well below the needed amount, since the zoning code makes an unrealistic assumption on the number of people who uses alternative methods of transportation. As a result, the neighborhood streets often become parking lot for the nearby mixed use sites.
One resident just spoke on Nov. 3rd about Apple employees at Infinity Loop taking up street parking near Lawson. As a result, parents cannot park near school and are forced to double park to pick up students. The local residents do not want the city to turn the street into a permit parking zone since it means added cost for the residents and added trouble for their guests.
The neighborhood streets around Biltmore Apartments are always full 24-7 to the point that even a guest cannot find a parking space.
Apple Campus 2 with expected emplyes of 14,000 and a commitment to provide alternative transportation for 40% of them, including carpool. So, the expected number of single-driver vehicle is 8,000. The number of parking stalls provided in Apple Campus 2 is 10,980 parking spaces, according to its EIR.

The Hills at Vallco provides only 9,175 vehicles, the very minimum required by the Zoning Code.
Let's see how much would actually be needed.
The Hills at Vallco contains
  • 2 million square feet of office, which will house about 10,000 workers. If 20% car pool or use alternative means (which is already higher than the average from 2010 census), it will need 8,000 parking spaces.
  •  800 housing units, which would require 2 cars per unit or more (if multiple young singles share one apartment or any family has a teenager of driving age). Thus, it will require 1,600 spaces.
  •  625,000 square feet of retail space. Per 1,000 square feet of retail space is recommended to have 5-10 parking spaces. Thus, 3,1250 to 6,250 parking space is recommended.
  • According to "Site Design, Parking and Zoning for Shopping Centers" from Planning.org: "the recommended standard of 10.0 car spaces per 1,000 square feet of net retail area (or a parking ratio of 3:1, i.e., three square feet of parking area for every one square foot of retail sales area)."
  • Loss in Value due to Inadequate Parking: "The shopping center could accommodate the  peak holiday shopping during Thanksgiving and Christmas when the  merchants make up to 50% of their profit for the year.  If a business can not  accommodate its customers during that time, then the property may not have  adequate parking and the property may suffer from obsolescence.  Other  studies have been done which show a need of 5 parking spaces for every 1,000  square feet of building area."
The total parking spaces needed is 8000+1600+3125 = 12,725.
The 9,175 parking spaces at Vallco is only 72% of needed space,
When other shopping center needs extra parking, it overflows to the next one or two streets.
When The Hills at Vallco overflows, it will overflow to the next 10 to 20 streets since the project is more than 10 times bigger than any other shopping mall in Cupertino.
Since there is little mass transit and even less ridership in Cupertino, any assumption of the number of visitors or workers who take public transit has to be realistic.
Note that even in San Jose where there are lightrail, the ridership is still low since the VTA transportation network does not cover enough areas so that most people still had to drive.
Any solution to solve the last mile problem is still experimental, such as Uber or Lyft. The EIR impact analysis should not be based on unproven future trend. It should be based on real data and real transportation method available today or in any committed plan.
Therefore, the effect of overflow parking from The Hills of Vallco needs to be studied using realistic data in every day situation and also worst case situation during Christmas shopping season.
The impact of difficulty of parking on the accessibility of retail shops and other amenities at The Hills at Vallco should be studied.
The impact of difficulty of parking on the willingness of customers to visit shops and other amenities in The Hills at Vallco should be studied.
The impact of difficulty of parking on the sales volume of the shops during Christmas season when most retail shops make 50% of their sales should be studied since it affects the sustainability of the shopping center at Vallco.
The impact of difficulty of parking on community events, like Farmers' Market, hosted at The Hills at Vallco should be studied.
Where will the Farmers' Market be held? Since most farmers sell their produce right off their truck. Would there be space for the farmers to drive up their truck into the Farmers' Market?

Liang Chao

Liang - Vallco impact on bike path and pedestrian safety

From: Liang C
Date: Mon, Nov 16, 2015 at 12:38 AM
Subject: Comment on Vallco impact - bike path and pedestrian safety
To: "City of Cupertino Planning Dept." <planning@cupertino.org>


RE: Comment on Vallco EIR

Please study the impact on bike paths on all artery streets that are logical shortcuts of freeway exits to reach Vallco when freeways or the exits or entrances are congested.
Please study the impact on bike paths on all secondary streets that are logical shortcuts when artery streets are congested.
Please study the impact on bike accident rates in relation to increased volume of vehicles.
Please study the impact on bike accident rates in relation to increase volume of vehicles at intersections making left or right turns.

Please study the impact on bike accident rates in relation to increase volume of vehicles when a bike is making a right turn, left turn or simply straight.
Please study the impact of accident rates involving pedestrians at intersections when the vehicle volume increases.
Liang Chao

Liang - Vallco impact on emergency response time should be based on real data

From: Liang C <lfchao@gmail.com>
Date: Mon, Nov 16, 2015 at 12:14 AM
Subject: Comment on Vallco EIR - impact on emergency response time should be based on real data.
To: "City of Cupertino Planning Dept." <planning@cupertino.org>


RE: Comment on Vallco EIR
Please study the emergency response time for fire protection, police and especially medical emergency with real data.


With an increase of 30% residence population and 50% worker population, the EIR of GPA concludes that
"TRAF-4 Implementation of the proposed Project would not result in inadequate emergency access."
This conclusion is derived simply by mentioning a bunch of General Plan policies, which are often not enforced. There is no real data on the current response time and no data on the predicted response time. No data on the expected expansion needed to provide service to the added population.
The traffic analysis shows that LOS of local streets and freeways would become much worse to the worst level of "Significant and Unavoidable" impact. And yet, the data from traffic analysis is not used at all to evaluate the emergency response time.

Merely reference to a bunch of General Plan policies is not an acceptable way to evaluate the impact.
For example, the following is EIR for GPA Section 4.13. Page 63.
"Because the proposed Project is a program-level planning effort, it does not directly address project-level
design features or building specifications; however, the General Plan includes polices that once adopted
would ensure efficient circulation and adequate access are provided in the city, which would help facilitate
emergency response. Within the Health and Safety Element, Policy 6-8, Early Project Review, would direct
the City to “involve the Fire Department in early design stages of projects requiring public review.....”

"Ongoing implementation of the General Plan policies and the City’s engineering standards would ensure
that adequate emergency access is provided in Cupertino. Therefore, impacts associated with the
implementation of the proposed Project would be less than significant."
This is not good enough. For emergency response time, please study the real impact using real data.
Do not use any personal communication or policies that have not been implemented yet.

Please study the amount of time for residents to reach the nearest hospital in a private vehicle in the event of non-life threatening emergency.

For example, the amount of extra delay in each intersection is already calculated in the LOS study of local streets. The average speed of freeways and delay on freeway on-ramp and off-ramp are also available in the traffic study. Such data could be used to compute the amount of time to reach a hospital from different areas of Cupertino.

Please study the impact on emergency response time for an ambulance to reach a home and from the home to the nearest hospital.

Liang Chao