Liang - Vallco impact on Vehicle Hours Traveled. Time spent stuck in traffic.

From: Liang C
Date: Sun, Nov 15, 2015 at 11:49 PM
Subject: Comment on Vallco EIR - Vehicle Minutes/Hours Traveled
To: "City of Cupertino Planning Dept." <planning@cupertino.org>

RE: Comment on Vallco EIR

Please study the amount of extra time residents and workers need to spend on the road due to the massive office park from Apple Campus 2 and Vallco.

For highway access, please study the Vehicle Hours Traveled (VHT) to understand the amount of extra time vehicles spent on the freeway.

Vehicle Miles Traveled (VMT) is not a true measurement of traffic congestion since it doesn't take into account of the speed vehicles take to travel at all. The longer a vehicle spent on the road the more greenhouse gas emission it generates. Whenever a vehicle travels lower than 50 miles per hour, it emits more greenhouse gas.  The more time vehicles spent on the road and increase the amount of time when accidents might occur. The more time each driver spent on the road, also increase the stress level and impact the health of drivers.

The EIR for GPA provided the average speed of each segment of the freeway. Please convert that to the time it takes to go through each segment. Please provide the time it takes to travel from different points of freeways within 30 mile radius.

The EIR for GPA only studied freeway segments within the City of Cupertino and at most one exit outside of Cupertino. However, 84% of Cupertino workers do not live in Cupertino. Many travel long distance from their home to Cupertino. The Hills at Vallco and Apple Campus 2 will double the number of workers who commute into Cupertino. They won't be living within one exit of Cupertino.

Please extend the study of freeways to a 20-mile radius to provide the LOS data for those road segments and also the time it takes to go through the segment. This way, a worker or a resident can figure out how much longer their commute time will increase.

For local streets, please study the amount of time from different corners of Cupertino to reach schools, libraries, Quinlan center and other common destinations. The LOS is one possible measure for one intersection. But one often need to travel through multiple intersections. At some intersections it takes extremely long to make a left turn and that adds to the local travel time. When the total amount of time it takes to go through artery streets, such as Stevens Creek or Wolfe, is longer than expected, people tend to take a short cut and use other streets, such as McClellan and Blaney. But these secondary streets are not equipped to handle the added traffic and these vehicles taking short cut tend to have impatient drivers who are driving at a higher speed. And that leads to more risks on traffic accidents. And there are more bicycles on these secondary streets, which add to the risks of fatal accidents.

Please study the impact on secondary streets when the artery streets have too many intersections with low LOS, and especially the impact on traffic accidents.

The more time it takes to travel on freeway or local street also increases the emergency response time that emergency vehicles need to get to hospitals. Cupertino doesn't have its own major hospitals. Our patients need to go to El Camino hospital in Mountain View or Good Samaritan Hospital in Los Gatos. Residents often need to drive by themselves to send a sick relative to the hospital. The time it takes to reach hospitals should be studied.

Many services, such as pluming, gardening, cleaning services, etc. for Cupertino residents are provided by companies in San Jose or other areas. The longer time it takes for these service workers to reach Cupertino, the less likely they want to serve Cupertino residents, or the more they will charge the residents. And the longer time Cupertino residents have to wait for these services.

Liang Chao

Lisa - Vallco EIR Scoping Comments - comprehensive

Original comment: https://drive.google.com/file/d/0B7RMc9DXGhUAamZKZlR1eE55UEJJUm5ISEJBTXdlZVlITE9v/view?usp=sharing

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VALLCO   EIR   SCOPING  COMMENTS    -  November 10, 2015
 Pre construction and During construction impacts absolutely need to be studied for anything
being considered in the Vallco area.  How will any project be ‘staged’?  Deconstruction health and
environmental issues must be addressed.  The air and water quality before, during, and after
construction need to be studied.   So many people are concerned about the local cement plant and
it’s impacts on our natural resources and our health.  It is believed by many that the Apple 2 project
construction has had a far worse effect on our environment and toxins being released by the
cement plant.  A FULL analysis of all materials that are part of the existing structures… and
underground… needs to be studied for the safety of our health.    
How long will any proposed construction take  ?  How will traffic, safety, bicycle and
pedestrian routes, noise, air, water,  public services,  law enforcement, infrastructure be
effected ?
FULLY study what the effects on deconstruction/construction requirements will have on the
‘not yet’ completed and occupied Apple 2 Campus and Main Street complex.  Travel of any
kind in these, and surrounding, areas is already a significant challenge. We have seen the
disruption that such construction causes to several environmental elements. .  Quality of life
including air and noise pollution, as well as safety has been compromised.  Regardless of what
Vallco development may be,  the impacts that it will have on the currently unknown (based on non-
completion and non-occupancy)   traffic, safety, pollution of all sorts, infrastructure of all kinds,  will
be staggeringly significant.  How does David J. Powers and Associates, or anyone,  even begin to
analyze the unknown….using the unknown..?
 ALL projects We all know there are projects under construction that are destined to entirely
change numerous aspects what an EIR studies.   VERY careful attention must be made to NOT
MINIMIZE, or omit what is already under construction OR approved in the REGION, not only
Cupertino.    What will be the cumulative impact of this project plus other projects in Cupertino,
neighboring cities,  and the County.    Especially the nearby Apple campus expansion, Main Street,
and anything
 The Butcher, the Baker, the Candlestick Maker.  Need to study all impacts related to the
additional work force that will be necessary to keep a project of this mix and magnitude running
effectively.  The employees and contractors that will be needed to support  daily functions
magnifies the actual number of people traveling to the project What is a realistic figure as to the
number of ‘extra people’  aside from projected office, residential, and retail ‘residents’ .

 Loss of Retail – Can’t ignore this detail.   More people, but less goods and services !!!!   This
effects multiple environmental concerns, and needs to be properly addressed in any study of any
size/mix of project. 

 Loss of Commercial services.  See above.  Also, for both Losses- So many environmental
issues..  and  city revenue from taxes - lost.    This can’t be ignored either.

 Traffic analysis – There are two methodologies for traffic analysis.  It is important that the EIR use
BOTH the current level of service methodology currently in use and the vehicle miles travelled
methodology that has been released in draft form by the Office of Planning and Research.  In
addition,  if EITHER  approach indicates significant impacts, the impacts should be considered
 significant.  Include in report that any significant impacts ARE avoidable.  You avoid them by not
approving a project that creates the traffic. Pollution from traffic must be studied also.

 Parking… oh the parking….   Amount and accessibility, and flow.  Public safety concerns related
to design of structures.  Air quality associated with vehicles traveling (including ‘circling’) to find
parking both in ‘open’ and ‘enclosed’ parking areas.  Excessive amounts of carbon monoxide,
carbon dioxide, NOX emissions will likely be an issue.  EIR should study health and safety issues
related to extremely poor air quality caused by these gaseous chemicals.
 Water supply - EIR should analyze increased water demand and whether it will increase stress on
Santa Clara Valley Water District, the local water wholesaler, or the State Water Project, the
eventual source of SCVWD’s water. How will water for the green roof park area be provided? How
will it be stored, treated?  How will rain water and piped water be drained from the entire site? 
Where will the run off gather and flow too?

 Power supply should be studied - What will be the electrical and gas supply for the new project?
How much will the project increase greenhouse gas generation? How will GHG generation be
mitigated?

 Internet Services  and Cellular Service  capabilities need to be studied.  There should be a way
to provide adequate service to all residents and businesses without erecting faux trees and towers
in numerous areas.   How will the amount of adequate service effect the health of those who live
and work in the area ?

 Housing  The study (EIR) should analyze how the entire project,  ALL uses together, AND
individually, will   impact the immediate area, the entire city, the school districts, the region.  Will the
project result in increasing the pressure on the local housing market, resulting in increased housing
sale and rental prices and forcing lower income households out of the area, increasing their
commute distances to reach jobs in the area?  Type of housing units needs to be analyized, along
with size of units.  Compare ‘for rent apartments’  to  ‘for sale condos/townhouses’  .  Impact on
power and water supplies,  property tax income, quality of life, etc.

 Seismic safety impacts of the massive ‘dirt moving’,  grading , haul off, concrete, non-permeable
hardscape, glass, large green roof park area, etc   must be analyzed/studied/considered.   Has
such a large green roof project been done previously in a seismically active area like Cupertino?
The drought has put stress on the soils and created lowering of grade, and  significant ‘fissures’ in
the land/soils.   Ground water has been depleted significantly.  The EIR needs to address this fact
and analyze any and all cumulative effects that mother nature has created  as it relates to safe
building practices. 

 Existing Trees and  significant landscaping.  Something that needs to be considered and
addressed is how the project proposal will impact all of the trees that exist on the Vallco site,
including street trees.  How will structure footprint, and height , effect available sunlight and the
amount of rain that will reach the trees/landscaping?  What are the risks to existing trees during
deconstruction and enormous amounts of digging, drilling, grading and reshaping of land ?

 Visual Pollution.    Preservation of, and impact on, VIEWS.    EIR should include study of these.
The proposed building height, setbacks, building plane, VERSUS  the requirements in the General
Plan  for these  things.  Building GLARE when glass and bare metal are used… or even white/light
finishes/materials are used.

 Lighting.  Light Pollution.  The GLOW and effect.  – Include analysis of what the effects of any
project mix/size will have on surrounding areas that will suffer from constant non-natural light
during dark hours.  Including the effects of this related to auto and bike travel.

 Reflective Glass -  Heat generated by sunlight reflected off of treated glass is significant.  The
office buildings at Main Street are only one example.  EIR study should include the environmental
effects of  various square footage amounts and locations of reflective glass materials.   How does
generated heat effect, temperature, heath, landscaping, animal life, water evaporation and air
quality.

 Wildlife -  EIR should study the effects on wildlife under current conditions, during deconstruction,
during construction, and post construction. 

Lisa Warren
Cupertino Resident since 1986

Added as a separate comment on ‘Access’

EIR must study any and all required EIR criteria as they relate to off site
development that is the subject of the June 9, 2015 Sand Hill Properties
Company 'Letter of Intent'  written to, and signed by, Cupertino Union School
District Superintendent and CUSD Board of Education President (CUSD signatures
dated June 16, 2015).  If the intent is truly there, then any related development
is part of the application for The Hills at Vallco, and must be considered part of
the project that is being studied in the Vallco Specific Plan Area.

Peggy - Vallco - conflicts with general plan

From: Peggy Griffin
Date: Sun, Nov 15, 2015 at 11:47 PM
Subject: Vallco EIR Scoping Comments - conflicts with the General Plan
To: Piu Ghosh <PiuG@cupertino.org>
Cc: Grace Schmidt <cityclerk@cupertino.org>

SUBJECT:  Vallco EIR Scoping Comments – conflicts with the General Plan

 

The proposed project and specifc plan for Vallco conflict with many of the Policies and Strategies of the Cupertino General Plan as listed below.

 

1.      With 2,000,000 sq. ft. of office, this project will significantly increase the imbalance that already exists to a point that may put the City at risk for penalties.

          

 

2.      The immense size and density of the project conflicts with these GP policies.

     

 

NOTE:  This particular stategy is specific to the Vallco area – note the “human scale”.  There is nothing about this project this is of human scale!

       

 

3.      During demolition, excavation and construction residents will be exposed:

 

 

Sincerely,

Peggy Griffin

 

 

 

Peggy - Vallco impact misc

From: Peggy Griffin
Date: Sun, Nov 15, 2015 at 11:21 PM
Subject: Vallco EIR Scoping Comments - misc
To: Piu Ghosh <PiuG@cupertino.org>
Cc: Grace Schmidt cityclerk@cupertino.org

1)     traffic analysis - EIR should analyze using both the current level of service methodology currently in use and the vehicle miles travelled methodology that has been released in draft form by the Office of Planning and Research. If either approach indicates significant impacts, the impacts should be considered significant.

2)     What will be the electrical and gas supply for the new project?

a)     How much will the project increase greenhouse gas generation?

b)     How will greenhouse gas generation be mitigated?

3)     What will be the growth-inducing impact of the project?

a)     Will the project result in increasing the pressure on the local housing market, resulting in increased housing sale and rental prices and forcing lower income households out of the area, increasing their commute distances to reach jobs in the area?

4)     What will be the cumulative impact of this project plus other objects in and around Cupertino, especially the nearby Apple campus expansion?

5)     What will the seismic safety impacts of the large green roof park area be?

a)     Has such a large green roof project been done previously in a seismically active area like Cupertino?

 

Sincerely,

Peggy Griffin

Liang - Vallco impact on Transportation Impact Fee

From: Liang C

Date: Sun, Nov 15, 2015 at 11:10 PM
Subject: Comment on Vallco EIR - No development project without Traffic Mitigation Fee Program
To: "City of Cupertino Planning Dept." planning@cupertino.org

RE: Comment on Vallco EIR

The EIR for GPA specifically requires the City to commit to implement a Traffic Mitigation Fee Program. The General Plan was also amended to include policies to collect Transportation Impact Fee.

Due the massive impact of The Hills at Vallco, the project should not be approved before the Traffic Mitigation Fee program is in place. In fact, no other development project should be approved before the Transportation Impact Fee is adopted.

EIR for GPA, Sec. 4.13 Page 53:

"Mitigation Measure TRAF-1: The City of Cupertino shall commit to preparing and implementing a
Traffic Mitigation Fee Program to guarantee funding for roadway and infrastructure improvements that
are necessary to mitigate impacts from future projects based on the then current City standards. As part
of the preparation of the Traffic Mitigation Fee Program, the City shall also commit to preparing a
"nexus" study that will serve as the basis for requiring development impact fees under AB 1600
legislation, as codified by California Code Government Section 66000 et seq., to support
implementation of the proposed Project. The established procedures under AB 1600 require that a
"reasonable relationship" or nexus exist between the traffic improvements and facilities required to
mitigate the traffic impacts of new development pursuant to the proposed Project."

"The fees shall be assessed when there is new construction, an increase in square footage in an existing
building, or the conversion of existing square footage to a more intensive use. The fees collected shall be
applied toward circulation improvements and right-of-way acquisition. The fees shall be calculated by
multiplying the proposed square footage, dwelling unit, or hotel room by the appropriate rate. Traffic
mitigation fees shall be included with any other applicable fees payable at the time the building permit is
issued. The City shall use the traffic mitigation fees to fund construction (or to recoup fees advanced to
fund construction) of the transportation improvements identified above, among other things that at the
time of potential future development may be warranted to mitigate traffic impacts."

General Plan Policies on Transportation Impact Fee:

Policy M-10.1: Transportation Improvement Plan

Develop and implement an updated citywide transportation
improvement plan necessary to accommodate vehicular,
pedestrian and bicycle transportation improvements to
meet the City’s needs.

Policy M-10.2: Transportation Impact Fee

Ensure sustainable funding levels for the Transportation
Improvement Plan by enacting a transportation impact fee
for new development.

Each project with EIR only mitigate direct impact of the project on the surrounding areas. However, there are cumulative impacts of the projects on other parts of the city that cannot be mitigated or even measured in relation to only one project.

Transportation Impact Fee provides funding to mitigate such cumulative impacts citywide.
 

If The Hills at Vallco is not required to pay for Transportation Impact Fee at the time of project approval, the significant impact of the project on the traffic infrastructure will significantly increase the Transportation Impact Fee needed for future project since a lot more mitigation measures would be needed to attempt to improve the Level of Service to "less than significant" level from "significant and unavoidable" if at all possible.

Please study the list of extra mitigation measures and thus the amount of mitigation fees needed citywide to mitigate the impact of The Hills at Vallco.

Liang Chao

Peggy - Vallco Impact on Noise, Traffic, Emergency Response

From: Peggy Griffin
Date: Sun, Nov 15, 2015 at 10:58 PM
Subject: Vallco EIR Scoping Comments - Noise, Traffic, Emergency Response impacts
To: Piu Ghosh <PiuG@cupertino.org>
Cc: Grace Schmidt <cityclerk@cupertino.org>

SUBJECT:  Vallco EIR Scoping Comments –

 

The traffic on I-280 and CA-85 has gotten so bad that the following occurs every day:

-        Noise levels have increased so that insulation does not cut the noise level inside the home anymore.
-        Even at night now the noise is high.  It doesn’t die down anymore.
-        Everyday there seems to be an accident on I-280 between Foothill Expressway and Lawrence Expressway.
-        The large employee buses and cars are ditching the freeways and hauling down side streets in Cupertino and Sunnyvale to get to the De Anza Blvd and Wolfe areas.
-        Apple employees are parking up and down our neighborhood streets to avoid having to get out on Mariani and De Anza Blvd.

 

With the addition of 2,000,000 square feet of office that the Hills-at-Vallco is proposing, on top of existing and upcoming projects in the area (Apple 2, Main Street, Agilent re-development, etc.)

please study the impacts of traffic on

-        Noise during commute times as well as at off-peak hours in the evening and during the day
-        Increased accident rates
-        Response times to those accidents

 

When looking at traffic, please look at these points as bailing points and the subsequent traffic on the local streets as a result of cars

-        CA-85 and El Camino
-        CA-85 and Fremont Ave.
-        CA-85 and Homestead Road
-        I-280 and Foothill Expressway
-        Foothill Expressway to Stevens Creek Canyon Road

 

Please study the impacts of traffic as described above on

1.       Noise levels along CA-85, I-280, Foothill Expressway, El Camino Real, Fremont Ave, Homestead Road, Mary Ave., Hollenbeck/Stelling, Saratoga-Sunnyvale Road/De Anza Blvd, Wolfe/Miller, Tantau Ave, Lawrence Expressway from El Camino to Prospect since Prospect goes into the Cupertino hills.
2.      Increased accident rates along those roads listed in #1
3.      Increased emergency response times along those roads listed in #1.

 

Please study the impacts of traffic on cell reception.  Many people have dropped their land lines and are only using cell phones.  When the traffic increases, more people are using their cell phones and the capacity of the cellular companies is stressed.  It is very common now to not be able to complete a call while on De Anza Blvd during rush hour.  This impacts emergency response and the ability of residents, workers and commuters to report an emergency.  This can effect fire, ambulance, etc.  Please study all cellular carriers.

 

Please study the impacts of 10,000 additional workers in the Vallco area on cell reception.  This can impact emergency response due to lack of capacity to complete a call.

 

Sincerely,

Peggy Griffin

Liang - Vallco impact - overbuilding of office space in a very short time

From: Liang C <lfchao@gmail.com>
Date: Sun, Nov 15, 2015 at 10:29 PM
Subject: Comment on Vallco EIR: impact on overbuilding of office space in a very short time
To: "City of Cupertino Planning Dept." planning@cupertino.org

RE: Comment on Vallco EIR

The Market Study done in 2014 for the GPA in fact shows only a demand of 805,428 square feet of office by the year 2035. The estimated demand for office space in Cupertino is 43,300 square feet per year. The 2,000,000 square feet is the equivalent of 46.2 years of office growth in Cupertino. Not only the proposed Hills at Vallco will devastate the traffic condition, it will kill any chance of another major corporation to settle down in Cupertino. The capacity of our traffic infrastructure is very limit since there is literally no mass transit.

Please study the impact of the oversupply of office space in the long run on housing, employment, transportation, quality of life, especially when the infrastructure to support it cannot catch up in the short term.

The area might be able to handle a reasonable growth of office space over 20 or 30 years. However, when 2 million square feet of office is built before the other 2.5 million square feet of office has not even finished construction, the accumulated impact is hard to estimate.

Please study any other area or city that has seen such high growth rate in office space, namely 50% growth of office space in 5 years, and compare its impacts.

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Market Study Does Not Support Two Million Square Feet of Office at Vallco

The Market Study done in 2014 for the GPA in fact shows only a demand of 805,428 square feet of office by the year 2035. The estimated demand for office space in Cupertino is 43,300 square feet per year. The 2,000,000 square feet is the equivalent of 46.2 years of office growth in Cupertino. Not only the proposed Hills at Vallco will devastate the traffic condition, it will kill any chance of another major corporation to settle down in Cupertino. The capacity of our traffic infrastructure is very limit since there is literally no mass transit.

During the General Plan Amendment (GPA) Process, the City of Cupertino hired the consulting firm BAE Urban Economics to conduct a Market Study. Like reading all such consultant reports, ordered by the City, wise readers look at the data collected in the report and derive informed conclusions on their own. The conclusion derived by these consultant reports are often quite biased, and one should read it with caution. The office demand analysis is one such example.


On Page 83 of the Market Study, it shows that the "estimated demand for office space in Cupertino averaging approximately 43,300 square feet per year. After accounting for projects currently entitled or under construction, this suggests that minimum net office demand will total approximately 156,000 square feet by 2020 and 805,400 square feet by 2035, as shown in Table 34."

ABAG projection is regarded as aggressive by many already. However, the Council directed the staff to add "2-3 million square feet of office" when the GPA process was initiated from Aug. 21, 2012 Council Meeting. Therefore, the consultants have to find a way to deliver the expected "office demand".

The Market Study argues:

Table 34 factor in the capacity to accommodate the proposed Apple Campus 2 along with another new corporate campus equivalent in scale to the recent projects shown in Table 33, in addition to the minimum demand estimates that were developed based on projected employment. As shown, this results in a net new demand of approximately 2.9 million square feet by 2020 and 3.6 million square feet by 2035. Given the recent shortage of office spaces in Cupertino containing more than 10,000 contiguous square feet, a new recommended office allocation could also allow for multi-tenant office developments, which could create the space needed for mid-size companies to grow in Cupertino as well as accommodate a new major technology company or future expansion of an existing firm.

Even if a new corporate campus is expected, Table 33 (below) shows the office square footage is mostly under 1.5 million. Even though there is only a shortage of 10,000 contiguous square feet of office, the consultants from BAE Urban Economics concluded that Cupertino has an additional office demand of 2 million square feet, which is quite a stretch. And Table 34 shows the ballooned total office demand of 3.5 million. Take away the 2 million for an non-existent corporate office. Take away the 750,000 square feet already allocated to Apple and under construction. The true office demand is only 805,428 square feet by 2035.

 

Besides Cupertino City Council can always initiate a new GPA process to grant an additional 1.5 million or 2 million square feet of office space if ever another company wants to settle down in Cupertino. There is no need to pre-allocate it in the General Plan.

 

And there is certainly no way to justify giving this 2,000,000 square feet of office to Vallco at all. A major corporation headquartered in Cupertino brings in sales tax plus property tax and a brand name recognition, like Apple brings to Cupertino. Yet, 2,000,000 square feet of office at Vallco merely brings in property tax.

 

Two million square feet is the equivalent of 46.2 years of office growth in Cupertino. (2,000,000/43,300=46.2) All cramed in one location within one block from the 3.5 million square feet of office in Apple Campus 2, which include 750,000 extra square feet on top of the original allocation for HP. That's another 17.3 years of office growth. (750,000/43,300=17.3)

 

More than 60 years of office growth all squeezed into one block area to be built within the next 5 years. Will Cupertino ever have the capacity for another major corporation in the near future? Not likely.

 

The capacity of the traffic infrastructure is limited in Cupertino since there is no true mass transit. VTA doesn't have any plan in the next 25 years to introduce light rail or any other transit that can transport tens thousands of people. Therefore, the amount of office space that Cupertino can accommodate is also limited since Cupertino already has insufficient housing.
 

Allocating 2,000,000 square feet office to Vallco is essentially grabbing the space from other property owners in town, whose properties are already zoned for office. These other property owners won't even be able to build a small amount of office as a result since roads leading into Cupertino would be extremely congested. It is simply not fair to other property owners.

REFERENCE:

1. City of Cupertino GPA Market Study, prepared by BAE Urban Economics, Feb. 13, 2014
2. Job Growth Projection Chart, BetterCupertion Blog We Support Sensible Growth, Planned Growth

CRSZaction.org and BetterCupertino.org
Paid for by Cupertino Residents for Sensible Zoning Action Committee, PO Box 1132, Cupertino, CA 95015, FPPC #1376003