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Planning & Design Meetings Response to CEQA Questions/Comments on the Draft Initial Study 4/13/2010 - Minutes 350 Frank H. Ogawa Plaza Suite 300 Oakland, CA 94612 510.839.5066 phone 510.839.5825 fax www.esassoc.com memorandum date April 19, 2010 to Palo Alto Unified School District from Lesley Lowe, AICP - ESA Project Manager Cory Barringhaus, AICP – ESA Senior Associate John Wilson, P.E., - Wilson Engineering subject Gunn High School: Response to Questions/Comments on the Draft Initial Study (ESA No. 209002) On October 6, 2009 the Palo Alto Unified School District (Lead Agency) released for public review a Draft Mitigated Negative Declaration for the Gunn High School Master Plan (SCH# 2009102024). The 30-day public review and comment period began on October 6, 2009 and closed at 5:00 p.m. on November 4, 2009. Further, a public hearing on the project was held on October 27, 2009, at a regularly scheduled School Board Meeting. This memorandum summarizes and responds generally to the comments and questions on the Draft Mitigated Negative Declaration for the Gunn High School Master Plan. Following circulation of the Draft Mitigated Negative Declaration, minor changes were made in response to comments to clarify the project description and add specifics to mitigation measures presented in the document. Comments have been organized by general concern and further categorized by a subtopic. The subtopic is summarized and a response provided. Comment letters received during the public review period are attached as Attachment A. The minutes from the October 27, 2009 School Board Meeting are attached as Attachment B. Responses to Comments Transportation and Circulation Trip Generation Comment states the trip generation rate from ITE underestimates the forecast of new auto trips based on the proposed increase in student population; e.g., no school buses are used. Response: The traffic analysis prepared for the draft Initial Study utilized Institute of Transportation Engineers (ITE) Standard Trip Generation Rates when estimating increases in traffic which could be associated with potential increases in student population over the next nine years. The ITE rates are based 2 on studies of over 20 sites throughout the U.S. and are generally considered the best available on an overall basis. However, the rates are qualified to the extent that more research is needed relative to use of school busing and transit and whether the schools were private or public. A breakdown of means of commute information was not provided in the ITE manual other than to state the percentage of students transported by transit and/or bus varied considerably. At both Palo Alto High Schools, with limited transit and essentially no busing, there is a different sort of variation which occurs. At both Palo Alto and Gunn High Schools a high percentage of students (as much as a third of the student body) bicycle. During clear weather in the Fall, as many as 600 plus students or a third or more students regularly commute by bike to Gunn. Surveys of existing travel modes conducted last year at the two high schools were completed on brisk March days when the bicycle commute was significantly reduced (by 200 plus). This reduction results in a proportional increase in auto commuting, typically in the form of drop-offs. Parking at the schools is controlled with permits and students cannot simply drive themselves on a cold or rainy day. As such, the survey of drop-offs (inbound and outbound trips) showed a significantly increased number relative to what regularly occurs on a sunny day and should be interpreted as more of a worst case estimate. In response to the comment, the following table summarizes trip generation estimates utilizing the more conservative or worst case results from the March surveys. The numbers are based upon a simple pro rata increase of survey results (driveway counts) relative to the potential increase in student population at Gunn. The student population is forecast to increase from a level of 1,948 for the 2008/2009 year to 2,259 in 2018 or by 15.96 percent. Table 6 of the Initial Study is revised to reflect the alternative trip generation methodology. With this methodology the increase in students at Gunn would generate approximately 147 addition vehicle trips. TABLE 6 AM PEAK HOUR TRIP FORECAST Existing Student Population Forecast 2018 Student Population Net Increase in Auto Trips Net Inbound/ Outbound Trips 1948 2,259 147 98/49 SOURCE: Wilson, 2009 Intersection Levels of Service Comment states that study intersections are not quantified in terms of additional delay attributable to the increased traffic relative to a pro rata increase of trips surveyed versus estimates utilizing ITE trip generation forecasts. Commenter also states there is no comparison between cumulative with project and cumulative without project. Response: Table 6.5 below presents the results of a revised LOS analysis which assumes the revised trips generation rates discussed in the response to the Trip Generation comment above. The table presents the project’s contribution to delay and changes in traffic volumes at the study intersection under the Existing plus Project scenario (under Project) in seconds of delay and changes in volume to capacity ratio (V/C) per standard traffic engineering practices. The quantified increase in delay and v/c ratio at the study 3 intersections attributable to project related traffic can be represented by subtracting the “Existing” delay from the “Existing Plus Project” delay. These are the two metrics the City uses to quantify impacts when an intersection is already operating at an LOS F prior to the addition of project traffic. However, in terms of the actual LOS calculations/ modeling process, it must be noted that results at impacted intersections can quickly exceed the capability of the modeling process. Once traffic volumes exceed intersection capacity and an intersection is forecast to operate at an LOS F, further estimates of delay and v/c ratios become increasingly erroneous as volumes are increased. At LOS F the theoretical capacity of the facility is exceeded. As noted in the Initial Study discussion, two of the study intersections are currently operating at a low level of service even assuming completion of the City’s proposed re-striping of Arastradero Road. The intersections of Miranda Avenue and the Gunn driveway entrance with Arastradero Drive are currently operating at an LOS F during the morning peak hour and will continue to do so with the city’s proposed re-striping plan of Arastradero Road assuming the “Preferred” or Hybrid Alternative. TABLE 6.5 EXISTING AND FUTURE LEVELS OF SERVICE (LOS) AND AVERAGE VEHICLE DELAY (seconds/vehicles)a Control Existing w/City’s Hybrid Alternative a Existing w/City’s Hybrid Alternative + Project Intersection Typeb Delay b V/C LOS Delay b V/C LOS AM Peak Hour Arastradero / Foothill Signal 42.7 0.66 D 43.2 0.68 D Arastradero / Miranda Signal >120c 1.18 F >120c 1.21 F Arastradero / Gunn HS Entrance Signal >120c 2.45c F >120c 2.79c F Arastradero / Donald / Terman Signal 43.4 0.88 D 45.4 0.88 D a The Hybrid Alternative assumes restriping of Arastradero Road with essentially one lane in the eastbound direction east of the cemetery b Represents average vehicle delay in seconds for overall intersection at signalized intersections. c Delay and V/C calculations at this location exceed the capability of the traffic model process. SOURCE: Wilson (2009) As presented in Table 6.5, and noted in the Initial Study, two of the studied intersections are forecast to operate at unacceptable levels assuming completion of the City’s proposed re-striping of Arastradero Road and are forecast to continue to do so with completion of the proposed project. The intersections of the school driveway and Miranda Avenue with Arastradero Road currently operate at an LOS F during the morning peak commute period, and are forecast to continue to do so when the City’s re-striping of Arastradero Road takes place assuming the preferred “Hybrid Alternative”. In addition, both intersections are forecast to experience an increase in v/c ratios in excess of 0.01 or the City’s threshold for a significant impact, if the project is completed and the student body grows as forecast. Again, in terms of the actual LOS calculations/ modeling process, results for the intersection of the Gunn driveway and Arastradero Road far exceed the capability of the modeling process. Once traffic volumes exceed intersection capacity and an intersection is forecast to operate at an LOS F, further estimates of delay and v/c ratios become increasingly erroneous. 4 Traffic Demand Management Policies and Implementation Comment states the current and proposed TDM plan is inadequate for the following reasons: • Many of the proposed mitigations are already being implemented through the TDM and by other means • Transportation mode shift from auto to other modes is not quantified • Proposed carpool matching program lacks goals and specific implementation information • Additional bike parking is not quantified Response: After further discussions with the community it was determined that Mitigation Measure TRANS-1, the carpool matching program, would require community involvement and efforts from the student’s guardians. As such, the success of the program can not be measured or enforced by the PAUSD. PAUSD will still implement the carpool matching program for the Los Altos Hills Community and will encourage, but not enforce its use. PAUSD main efforts to traffic mitigation would be focused on Mitigation Measure TRANS-2. Mitigation Measure TRANS-2, which addresses onsite circulation, includes the following revisions which further identify when the TDM policies would be implemented and outlines additional policies that would be added to the current program: The City’s criteria for determining an impact, or when mitigation is needed, when an intersection is already operating at a LOS F, is when forecast increases in traffic are estimated to increase delay by more than four seconds or the v/c ratio by more than 0.01 or one percent. The critical intersection in determining impacts and the potential need for mitigation is the intersection of the Gunn entrance driveway and Arastradero Road during the morning peak commute. As discussed above, the delay related calculations exceed the capability of the traffic model given the current level of traffic demand in the area. Both intersections were compared and found that the Gunn entrance driveway is the controlling intersection for mitigation. Therefore, the following assessment of levels of significance relative to this project is based on anticipated increases in volume to capacity or v/c ratio relative to a one percent or more increase. The assessment focuses on the intersection of Gunn with Arastradero where the largest increase in v/c ratio is forecast to occur. Measures sufficient to reduce trip increases at this location to acceptable levels would be sufficient to mitigate potential impacts at the intersection of Miranda Avenue and Arastradero. A.M. peak hour traffic counts at the intersection of Gunn and Arastradero completed in March of 2009 showed a total volume of 2,363 vehicles entering the intersection in a one hour period. An increase of one percent would be an additional 24 vehicles. Again, using the results of the Gunn surveys completed in March of 2009, this would be equivalent to an increase of 50.78 or 51 new students. At this point, the City’ level of significance criteria relative to an increase in v/c ratio would be exceeded and traffic related mitigation is warranted. In terms of monitoring the success of proposed measures, traffic counts would be completed at the entrance to the school on an annual basis during a pre-selected time. The results of the counts would then be compared to baseline counts and if increases exceed 24 vehicle trips during the morning peak hour, additional mitigation measures would have to be implemented. The timing of the counts does not matter relative to time of school year as long as school is in full session (no holidays, winter break, special testing, etc.), the weather is dry, and the counts are conducted the same time every year. To that end, the 5 District would conduct a week long hose count of the Gunn driveway entrance (both inbound and outbound) in the early spring (4th week in April for five consecutive school days starting in 2010) or closest period when weather could be expected to be dry to establish the baseline monitoring number. The counts would then be repeated on an annual basis. The baseline will be established this spring, 2010, before mitigation measures begin to be implemented to allow identification of the degree of success of measures. The monitoring of driveway volumes would then continue on a yearly basis, and as long as the student population exceeded baseline plus 51 conditions (or an increase of 24 vehicle trips in the AM peak hour). When the annual counts show an increase of more than 24 trips during the morning peak hour, measure will have to be implemented: • Implement alternative means of class scheduling expanding the peak arrival times to the campus to mitigate the additional students on campus. Examples of alternatives include a zero, eighth period or offering expanded online courses (with the intent for students to arrive outside the peek period), or altering school start times. The District will also be evaluating the potential to provide VTA Passes to students. However, the primary means of mitigating increased enrollment will be to drift student to alternate arrival times. In addition, the following TDM efforts are included as part of the Master Plan: • Increase the number of bicycle racks by a minimum of 15.9 percent. • Parking re-striping plan. In response to the safety concern the Facilities Steering Committee has approved Parking and Drop-Off project to include the parking and drop-off area at the Miranda entrance. With the implementation of the TDM program and the mitigation measure, the proposed project would have a less than significant impact on local roadways. The implementation timing of these mitigations will be monitor in the Mitigation Monitoring and Reporting Program, and mitigations will be reviewed and added as necessary. Access and Circulation Comment states that using staff to monitor and direct traffic during peak drop-off/pick-up times lacks specific implementation information and has been unsuccessful in the past. Comment states that the drop-off queue on Arastradero Road is shared with students entering the school site to park, which increases backups, and is not analyzed in the traffic study. Response: The project is attempting to improve student drop-offs and on-site circulation through the re-design of the onsite circulation system, parking lot layout, bicycle access, etc. Goals of the redesign include minimizing conflicts, facilitating bike access and maximizing the smooth and efficient flow of traffic onto and off of the site. The District will also be implementing measures to limit site trip generation as discussed above. In addition, Gunn High School and the District will increase notifications to parents and students with information on onsite circulation patterns and designated parking areas (modified Mitigation Measure TRAN-4). 6 Transit Ridership Comment states that bus ridership was not quantified in the traffic study. Response: As discussed in Section 15, Transportation, of the Initial Study, bus service in Santa Clara County is operated by the Santa Clara Valley Transportation Authority (VTA). Commuter rail service (Caltrain) is provided from San Francisco to Gilroy by the Peninsula Joint Powers Board. Route 88, 88L, and 88M, currently provide service in the vicinity of the project. Under existing conditions, these buses generally operate close to seating capacity during peak commute periods near Gunn (VTA, 2010). During rainy weather the buses can operate more towards overall or standing capacity. The proposed project, which could result in as much as a 15.96 percent increase in student population, could increase ridership on these lines. The ability of the busses to accommodate increases in student traffic will be a function of the degree of increase. Minor increase should be able to be accommodated with current equipment and schedules. Parking Demand Comment states that mitigation limiting onsite parking spaces and permits would shift parking to adjacent neighborhoods, which should be addressed. Response: As necessary, the District would work in conjunction with the City of Palo Alto to offer a permit only parking if the proposed project resulted in students parking in the adjacent neighborhoods. Intersection Levels of Service Comment states that LOS F intersections at school entrances on Arastradero Road (main entrance and Miranda Avenue) are not quantified in terms of additional delay attributable to the increased traffic. Response: Please see response to earlier comments regarding LOS. Drop-off at Miranda Avenue Comment states that drop-offs at Miranda Avenue are currently almost as large as those occurring at the Arastradero Road entrance (44%) and operates at LOS F. Mitigations envisioned in the funded phases of the Master Plan only address the Arastradero entrance; therefore, the Miranda entrance would be inadequate for both drop-off s and emergency vehicle access. Item 4.d of the Master Plan should be moved into the current work plan. Comment states that the Santa Clara Sheriff’s Office is currently ticketing vehicles dropping off students at the Miranda VTA bus stop. Therefore, use of this drop-off location may not be available for the foreseeable future and the traffic study should be revised to reflect this condition. Response: The Facilities Steering Committee has approved the Parking and Drop-Off project to include the parking and drop-off area at the Miranda entrance. 7 Bell Schedule/Start Times, etc. Comment disagrees with mitigation regarding earlier school start times. Additional commenters state a staggered bell schedule would be effective mitigation. Other mitigation proposed by the comment includes: 1) online learning, 2) independent study options, 3) late afternoon/evening courses, 4) extension of school day by adding 0 and 8th periods, and 5) off-campus course work. Response: As described in the project description of the Initial Study, the Gunn High School Master Plan is a planning level document and as such specific details such as bell schedules have not been developed at this stage in the planning process. Potential impacts related to Traffic Demand Management Polices and Implementation would be mitigated to a less than significant level by Mitigation Measures TRANS-1 and TRANS-2. The District will evaluate alternative class scheduling options as necessary to stagger arrival times to the campus. Hydrology Mitigations Details Comment notes lack of detail regarding stormwater runoff design and compliance with the Regional Water Quality Control Board’s C.3 requirements. Response: As described in the project description of the Initial Study, the Gunn High School Master Plan is a planning level document and as such specific details of the stormwater drainage system have not been developed at this stage in the planning process. Potential impacts regarding stormwater runoff would be mitigated to a less than significant level by Mitigation Measure HYD-1, which requires compliance with provisions of the NPDES regulations, including the C.3 provisions. Municipal Stormwater Permit Comment notes that the project will have to comply with the new regional municipal stormwater permit, which also requires use of low impact development techniques under C.3. Response: The PAUSD acknowledges the comment and will fully comply with the regulatory requirements of the NPDES through implementation of Mitigation Measure HYD-1. Greenhouse Gases Greenhouse Gases and Noise Comment notes that the greenhouse gas and noise analysis use traffic numbers that may need to be updated depending on the use of the ITE trip generation rate. 8 Response: The trip generation estimates were revised to address public comments and the net new morning vehicle trips were increased by approximately 16 percent. Pages 24 and 29 of the Initial Study, is updated as follows to reflect the increase in vehicle trips: Operational Emissions The project would result in a net increase in emissions of criteria pollutants (ROG, NOx and PM- 10) primarily because of a resultant increase in average daily vehicle trips. Based on the traffic analysis, the proposed change in land use would result in an increase of approximately 532 617 net new daily vehicle trips. Increased vehicle trips would lead to a small increase in ROG (approximately 2.7 3.0 pounds per day), NOx (approximately 2.2 2.6 pounds per day) and PM-10 (approximately 6.9 8.0 pounds per day) due to vehicle exhaust. Increases in emissions from stationary sources at the site (such as natural gas combustion for space and water heating, landscaping, use of consumer products, etc.) would also be minimal (approximately 0.72 pounds per day of ROG and 1.06 pounds per day of NOx). Together, operational emissions increases resulting from the project would represent approximately ten percent or less of the quantities BAAQMD currently identifies as significant (80 pounds per day of either ROG, NOx, or PM-10, individually). Therefore, once operational, the development under the Master Plan would not significantly contribute to a violation of any air quality standard in the area. Project emissions would also be below new CEQA thresholds proposed by BAAQMD of 54 pounds per day of ROG, NOx and PM-2.5 and 82 pounds per day of PM-10. Changes to GHG on page 29 of the IS: The proposed improvements to Gunn High school under the Master Plan would result in an increase in daily operational CO2 emissions from project-related traffic and area source emissions for space and water heating as well as electricity demand. Operational emissions of CO2 from vehicle traffic as calculated by URBEMIS2007 would be 665 772 “short” tons per year or 603 700 MT per year. URBEMIS also calculates natural gas combustion emissions based on square footage of improvements. CO2 emissions from natural gas emissions are calculated to be 233 “short” tons per year or 211 MT per year. Electricity demand based on square footage of improvements and California specific emission factors of the California Climate Action Registry and high school-specific electrical demand estimates would result in an additional 430 MT per year of GHGs emitted indirectly as a result of the project. Consequently the total operational CO2 emission rate resulting from implementation of the proposed Master Plan is estimated to be 1,244 1,341 MT per year. When compared to the state facility reporting requirement for GHG emissions of 25,000 MT per year CO2e, the maximum GHG emissions for the project (222 MT per year CO2e during construction; and 1,244 1,341 MT per year during operations are not significant enough to require reporting to the CARB relative to the requirements of AB32. Additionally, although not yet adopted nor applicable to the proposed Master Plan, project GHG emissions would be less than the proposed 7,000 MT per year Preliminary Staff Proposal threshold for industrial projects under consideration by CARB. 9 BAAQMD has recently proposed a GHG significance threshold of 1,100 MT/year for development projects. While this threshold has not yet been adopted, the proposed project GHG emissions would exceed this proposed threshold by 22 percent. Consequently, mitigation measures to reduce GHG emissions are recommended. The modified trip generation would not increase noise due to the projected increase in vehicle traffic, as volumes on Arastradero are high volume roadways and the project contributions are relatively small. Land Use and Planning Land Use and Community Design Element Comment notes minor edits in reference to the City of Palo Alto Comprehensive Plan. Response: The PAUSD acknowledges the comments and page 20 of the Initial Study is revised as follows: City of Palo Alto, Palo Alto Comprehensive Plan 1998-2010, Land Use and Community Design Element, adopted July 20 17, 1998 2007. All references in the Initial Study to the “Palo Alto Comprehensive Plan Update 1996” are revised to read “Palo Alto Comprehensive Plan 1998-2010.” Attachment A Lesley Lowe From: Aimee Lopez [alopez@ocmi.com] Sent: Monday, November 02, 2009 9:14 AM To: Lesley Lowe; Cory Barringhaus Subject: FW: Public comment, Public Hearing, Gunn CEQA documents and westside traffic Page 1 of 3 1/29/2010 Additional comment for CEQA   Aimée    From: Robert Golton [mailto:rgolton@pausd.org] Sent: Friday, October 30, 2009 11:54 PM To: Tom Hodges; Aimee Lopez; elee@dlm.com; Ron Smith Subject: FW: Public comment, Public Hearing, Gunn CEQA documents and westside traffic please add this to your CEQA comments. Robert Golton, Chief Business Official Palo Alto Unified School District 3 Please consider the environment before printing this e-mail. From: Kathleen Ruegsegger Sent: Friday, October 30, 2009 4:09 PM To: Robert Golton; Kevin Skelly Subject: FW: Public comment, Public Hearing, Gunn CEQA documents and westside traffic FYI.  This went to the Board and me. Kathleen Ruegsegger Administrative Assistant to the Superintendent Palo Alto Unified School District 25 Churchill Ave., Palo Alto, CA 94306 650.329.3737 (w) 650.321.3810 (fax) www.pausd.org From: Duncan MacMillan [mailto:dmcmllan@pacbell.net] Sent: Friday, October 30, 2009 3:35 PM To: Melissa Caswell; Barbara Klausner; Barbara Mitchell; Dana Tom; Camille Townsend Cc: Kathleen Ruegsegger Subject: Fw: Public comment, Public Hearing, Gunn CEQA documents and westside traffic Fyi since I added a few comments, shown in italics, since the Board meeting. The net of it all is that: Without addressing Miranda (>44% of the drop-off + emergency access issues), the mitigation measure proposed in the current CEQA document (TRAN-3) will be defective and a MITIGATED NEGATIVE DECLARATION should not, therefore, be awarded. Regards, Duncan --- On Wed, 10/28/09, Duncan MacMillan <dmcmllan@pacbell.net> wrote: From: Duncan MacMillan <dmcmllan@pacbell.net> Subject: Public comment, Public Hearing, Gunn CEQA documents and westside traffic To: "Tom Hodges" <thodges@pausd.org> Cc: "Dr. Robert Golton" <rgolton@pausd.org> Date: Wednesday, October 28, 2009, 3:15 PM Hi, Tom: As you suggested, here is a restatement of my remarks made at public hearing during the PAUSD Board meeting last night. Without a 3-minute limit, I also took the liberty of providing additional comments, which are shown in italics.... "My name is Duncan MacMillan, from Los Altos Hills. "I was happy to receive the nearly 100-page CEQA report on Gunn and especially the inclusion of the Wilson Engineering traffic data. "That report clearly confirms that Arastradero is currently at capacity at both the Main Entrance and Miranda intersections. It also provides a grading of the Level of Service at several points. The two intersections mentioned received a LOS of "F", certainly a failing grade ("Operatons with delays unacceptable to most drivers occurring due to over-saturation, poor progression, or very long cycle lengths"). "Most important, on page 80 of the CEQA report, collected traffic data (by Wilson Engineering) shows that the drop-offs at Miranda are currently almost as large as those that occur via the Main Entrance - more than 44% of Gunn drop-offs occur along Miranda at the present time. "The mitigations envisioned in the funded phases of the plan only address the Main Entrance. Without a change in priorities, Miranda can not be addressed for many years, until yet another bond issue. "Miranda is inadequade for both current drop-off traffic and for emergency access to the west side of campus. An improved west-side access would enhance the ability of emergency vehicles getting to the most campus buildings and to some of the more likely buildings to have problems - the science building, for instance. "The Board should move the current Item 4.d into the current work plan, which could then address the issues of improved drop-off and emergency access traffic at Miranda. That work has been estimated at a little over $1 million, against the current work plan of more than $76 million. Page 2 of 3 1/29/2010 "If the Board does not act, the dual safety issues of an adequate drop-off and emergency access for the Gunn campus will not be addressed for many, many years. An unacceptable situation. "Thank you." Duncan MacMillan Los Altos Hills --------- additonal comments ---------- Special attention should be drawn to the current Mitigation Measure TRAN-3 in the CEQA document, which cites a number of physical enhancements to address the Main Entrance traffic issues. Unfortunately, the Main Entrance carries only slightly more than half of the current drop-off load (161 at Miranda versus 204 via the Main Entrance for at total of 365 drop-offs for the campus; a shift of only 20 drop-offs would make the loads equal). TRAN-3 needs to expanded to address Miranda or the Gunn site can not be expected to grow to its projected level of enrollment without Arastradero deteriorating even further, below its current F LOS rating, "the worst operating conditions" as enumerated in the CEQA report. In addition, there may be a "paint and pylon" opportunity next fall and winter to experiment with an internal drop-off via the west entry along Miranda. The T-transportable classrooms will have vacated the area during the summer of 2010. Construction will not begin (A/B Buildings+) until the spring of 2011. Once the classrooms are removed, the Miranda access road and previous parking areas will be exposed and the judicious use of paint and pylons (as was done on the Main Entrance this past year) could test a drop-off/turnaround scheme. Please move this project forward both in its detailed planning and possible experimentation, as well as implementation during the currently-funded work plan. Without addressing Miranda drop-off safety and emergency access issues, the CEQA mitigation effort will be barely 50% complete and a MITIGATED NEGATIVE DECLARATION should not, therefore, be awarded. #### Page 3 of 3 1/29/2010 Lesley Lowe From: Aimee Lopez [alopez@ocmi.com] Sent: Tuesday, November 03, 2009 4:36 PM To: Lesley Lowe; Cory Barringhaus Subject: FW: no to earlier arrival times Page 1 of 1 1/29/2010 Another CEQA Comment   Aimée M. Lopez | Project Manager O'Connor Construction Management, Inc. Palo Alto Unified School District 25 Churchill Ave., Bldg. D, Palo Alto, CA94306 650.329.3968 | Fax 650.327.3588 | Cell 925.580.2714 e-mail: ailopez@pausd.org   From: Tom Hodges Sent: Tuesday, November 03, 2009 3:44 PM To: Aimee Lopez Subject: Fw: no to earlier arrival times From: Beatriz Magaloni <magaloni@stanford.edu> To: thodges@pausd.org <thodges@pausd.org> Sent: Tue Nov 03 18:18:43 2009 Subject: no to earlier arrival times Dear Tom, I am a mother of three kids, one going to middle school next year and the other two in K and 2. I am very concerned about Gunn High School's intention to get kids to arrive earlier to school. With what is going on in the community among kids that age, and especially at Gunn, I think it is extremely inadequate to demand earlier arrival from kids. Studies amply show that high-school kids need MORE sleep -- even 30 minutes can have a huge impact on both physical and emotional health. I support kids arriving LATER to high-school, not earlier, and I know I am among a large group of parents supporting later arrivals. Beatriz Magaloni Department of Political Science Stanford University 616 Serra St Stanford, CA 94305 (650) 723-1806 magaloni@stanford.edu Palo Alto Council of PTAs 25 Churchill Ave Palo Alto CA, 94306 650-326-0702 November 18, 2009 Attn: Tom Hodges Palo Alto Unified School District 25 Churchill, Building D Palo Alto, CA 94306 The Palo Alto Council of PTAs Traffic Safety Committee respectfully submits the following comments on the Transportation /Traffic sections of the Gunn and Paly Draft Mitigated Negative Declarations. Trip Generation Projection--The report uses standard figures for increases in trips based on the land use category from the ITE. While this may satisfy a California Environmental Quality Act (CEQA) requirement, it does not necessarily predict the situation at Gunn High School or Paly today. For example, the present number of morning peak hour auto trips at Gunn is 922. The ITE formula is for every 3.79 students we add one car trip. Based on the ITE model there currently should be 514 auto trips in the peak hour. So, readers of this report should be cautioned that the ITE formula underestimates the forecast of new auto trips with the increase in student population. The increase in trips very likely will be significantly greater than the ITE forecast of 82 trips, possibly as much as 75% higher when we extrapolate from today’s 2.11 students per car trip. A difference of this scale will likely have a significant impact but it is not modeled in this analysis. Traffic is one of the top concerns cited by participants at Gunn planning meetings. TDM Plan Lacks Specific Goals & Critical Program Details The Gunn and Paly reports rely on Transportation Demand Management (TDM) plans for mitigations. However, the proposed mitigation plan doesn’t define performance criteria. Transportation mode shift, that is the percentage of students shifting from autos to other modes of transportation, which would be needed to provide adequate mitigation, is never quantified. Without that data, it is impossible to evaluate whether or not the reports’ conclusions that adequate mitigation is achievable is correct or incorrect. What is the mode shift goal of these mitigations? How many car trips need to be shifted to other modes in order to mitigate the transportation impacts of this expansion? Precisely how will that goal be achieved? Further, elements that could determine the success or failure of a TDM plan are not adequately specified, making it unenforceable. Typically, well written TDM plans have very specific participation and mode shift goals that should be attributed to each element of the plan. There is none of that in this plan. For example, a carpool matching program is cited as a required mitigation measure, yet the program has no goals attached to it in terms of participation. No specifics about organization of the matching program are outlined. Who will be responsible for organizing and managing the carpool matching program? Staff? PTA volunteers? Have they agreed to do this? What funding source will be used for this? This is time intensive work. What resources will PAUSD be required to apply to the carpool matching program? Carpool matching programs are most successful when students are matched at the very beginning of the school year before commute patterns are established. Will PAUSD release information to make it possible to create a carpool matching database or maps in time to meet this critical deadline? Even with this commitment, we don’t yet have a carpool matching model that we know really works for this school district. The PTA Traffic Safety Committee has experimented at Escondido and Ohlone with several carpool matching models yielding limited success. (Our best performance to date has been this year’s report from Ohlone, increasing from 26 carpoolers last year to 45 carpoolers this year.) The district has not allowed us to create an on-line matching program so we have not been able to explore that as an option. Another example is the bike parking facilities mitigation in the Gunn report: Mitigation Measure TRAN-2 states that bike racks should be located in convenient areas to facilitate ease of queues, safety, and accessibility. This is a good idea; however, the number of additional bike parking spaces required for adequate mitigation should be quantified in the Gunn and Paly reports. Further, the mitigation measure should specify that these additional spaces will be made available during the construction period as staff has agreed to do in recent meetings. A plan that depends on encouraging alternative modes as a primary mitigation should carefully spell out facilities capacity needs for those alternative modes. We suggest, at minimum, that enough bike parking spaces should be provided to meet current peak demand. That would require a minimum of 633 bike parking spaces at Gunn and 582 at Paly. Since the goal is to increase the number of bikes, we should plan for even greater numbers based on mode shift need for mitigation. Bike counts for both high schools for the last ten years were provided to staff at the beginning of the planning process to help them project probable future growth rates. The CEQA document should project probable bike count increases and specify a bike parking space number requirement in the mitigations. Further, the driveway and circulation design for both sites is still underway. It will be critically important to address the comfort and safety of bicyclists and pedestrians if we are to achieve successful mode shift. Usually, the parking/circulation plan for all modes would be included in the mitigations list as it must be part of the mitigation in a TDM plan in order to make it work. Gunn Mitigation Measure TRAN-4 requires staff to monitor and direct onsite traffic during peak drop-off/pick-up times. This is something Gunn staff has not been able to do consistently in the past. Is there funding for additional staff time? Has anyone asked Gunn staff how they will be able to implement this mitigation in the future? (Traffic Direction is not something PTA volunteers can do. The PTA insurance policy explicitly excludes this activity. If staff cannot do it, it won’t get done.) The same is true at Paly. Most of the other mitigations proposed for Gunn already have been implemented. Gunn PTA Traffic Safety Team already directs bike access away from the main Gunn campus driveway. We already provide maps and circulation instructions on the school web site and information about alternative modes of transportation (including buses, pedestrian and bike route maps, etc.) at the beginning of the year. Gunn already limits the number of parking permits. Paly provides some information re: Transportation on their web site as well. Please direct staff to specify that this is already being done in their final document. We can’t realistically expect a significant incremental mode shift from activities we are already doing. To reiterate the primary point: Most of the mitigations proposed in this document are already in place. We have a good idea how much mode shift we can achieve with these measures because we are already doing them. What we cannot tell from these documents is what additional mode shift is required to adequately mitigate the additional vehicle impacts of this project. That goal is not quantified anywhere in the document; therefore, it is impossible to evaluate whether or not the goal is achievable as the report claims it is. That reporting failure should be corrected. Without it the Mitigated Negative Declaration is inadequate. Bus ridership The Gunn report doesn’t quantify am/pm VTA bus ridership. The same is true of City of Palo Alto Shuttle use at Paly. Was bus use studied? Intersection Level of Service On page 78 (Gunn report) the report notes that Arastradero intersections at Miranda and the Gunn driveway already are at LOS F. Additional intersection delays are not specifically quantified because the intersection operations already are operating at an unacceptable level. However, though there isn’t a worse LOS “grade” than F, it is possible for real world road users to experience greater delay than they currently do. Further degradation of these intersections will impact the performance of Arastradero Road as a whole. The report only reports this as >120 seconds in these cases, and it does not specifically quantify the delay. Delays at the Gunn driveway at morning bell time are a key factor driving peak hour performance of the Arastradero street system. Currently, no other single facility on Arastradero has a more negative impact on operational efficiency of the road than Gunn HS. We need to make sure the district has gotten this right. The likely effect of further LOS degradation would be “peak spreading”—the peak period during which the intersection operates at LOS F will become longer with road users choosing to travel earlier and earlier to avoid delays. Under most circumstances, traffic would also spread later, but that cannot happen at school sites where peak periods are driven by bell times. Peak spreading will make the Gunn Mitigation Measure TRAN-2 that provides early morning study areas or breakfast incentives necessary. A mitigation to address LOS degradation was suggested in the original traffic study for this project by Wilson Engineering. That was staggering Gunn bell times. This would spread out arrivals, eliminating peak loads that precede current bell times. This same mitigation was independently proposed by City of Palo Alto Consulting Engineer Gary Kruger to improve LOS at impacted Arastradero corridor intersections. The district rejected this mitigation, citing logistical difficulty of implementation. If the engineers’ recommended mitigation is rejected, then a substantive alternative is required that will adequately mitigate the LOS impacts. The current proposed mitigations do not include such an alternative mitigation. The LOS problem remains and increased enrollment will worsen the situation at multiple Arastradero intersections, including: Gunn driveway, Foothill, Donald/Terman. If the district opts not to shift bell times, an adequate alternative mitigation must be identified. Gunn PTSA has suggested opening the library earlier and adding many more zero period classes. Zero period classes might help, depending on the number of classes. If this is to be required as an alternate mitigation, the number of zero period classes needed to provide adequate mitigation should be studied. The requirement should be very specific as to the number of zero period classes needed to insure adequate split of the auto surge to mitigate LOS impacts. Further, a traffic engineer should check to make sure that the timing of the zero period arrival time will not add traffic to affected Arastradero intersections during the Terman morning bell time surge. Bike Facilities—p. 79 should note the bike path that connects the rear of campus to Georgia. Parking demand—Gunn has 461 total existing spaces with current demand at 440 (or 95 percent). As parking mitigations require no increase in parking spaces or permits, how will PAUSD deal with probable shift of auto parking to nearby neighborhoods? Has this probable outcome been studied and/or discussed with the City of Palo Alto? This will be less of a problem at Paly where parking capacity is closer to projected demand, but it is a likely problem for both sites. Because projected trip generation is underestimated (see below), it is likely the parking problem will be much greater than the CEQA document indicates. The purpose of an environmental review is to insure that information is gathered to inform the planning process for proper mitigation. It is an important responsibility to the community to get this right. We appreciate this opportunity to comment on the Draft Mitigated Negative Declarations for Gunn and Palo Alto High Schools and we thank you for giving these comments your usual thoughtful consideration. Sincerely, Penny Ellson, 2009-10 Chair and Middle School Schools Representative Palo Alto Council of PTAs Traffic Safety Committee Christine Fawcett, High Schools Representative Palo Alto Council of PTAs Traffic Safety Committee George Pierce, Elementary Schools Representative Palo Alto Council of PTAs Traffic Safety Committee  1 Comments on the Initial Study and Environmental Checklist for California Environmental Quality Act for the Gunn High School Master Plan dated September 2009 Arthur M. Keller, Gunn Facilities Planning Committee, PTSA Public Transit Coordinator, Palo Alto Planning and Transportation Commission member, Gunn parent 1. The reference on page 20 to the Land Use Element of the Palo Alto Comprehensive Plan is erroneous. The chapter is called the Land Use and Community Design element, and it was part of the Palo Alto Comprehensive Plan for 1998-2010 adopted well before 2007. 2. The greenhouse gas analysis on page 24 and noise analysis on page 66 each assume in increase in daily trips of 532, which may be an underestimate. 3. The various references to the Palo Alto Comprehensive Plan Update 1996 should instead refer to the Palo Alto Comprehensive Plan 1998-2010. 4. Table 7 on page 82 states that the AM peak hour delays will remain at LOS F for both Arastradero Road / Miranda Avenue and Arastradero Road / School Driveway. However, no specific measure of critical delay was made other than the vague “> 120”; however the City of Palo Alto’s traffic significance thresholds states, “A significant impact results if the existing LOS is already D or worse at the intersections not included in ‘a’ above and the addition of project traffic causes an increase of one second or more of critical movement delay.”1 It is likely that the expected increase in traffic will increase the critical movement delay by more than one second, and the mitigations proposed are unlikely to reduce this increase to no more than one second. Furthermore, the increase in critical movement delay of 1.8 seconds exceeds the threshold of significance as determined by Palo Alto standards for the Arastradero Road and Donald/Terman intersection (see Table 7, page 82), even though the report implies that this increase is less than significant with mitigations. It is not demonstrated how the increase in critical movement delay would be reduced by mitigations to below one second. 5. Mitigation TRAN-1 regarding setting up a carpool-matching program for students is not realistic. The primary mechanism for such a matching program is through the student directory, which is not released to the students until November and does not geocode the student addresses. There is no quantification for the amount of carpooling currently occurring nor are there quantified goals for the increase in carpooling. No reference is made as to the apportionment of the increase of carpooling between students in carpools driving to Gunn High School versus parents dropping off and picking up carpools. 6. Mitigation TRAN-2 contains measures that are already in practice, and it is unclear the extent to which these measures will “not increase traffic volumes to the high school as the student body increases.” (page 82) 7. Spillover traffic and parking at the adjacent Barron Park neighborhood may be a consequence of the lack of increase in onsite parking spaces. No mitigation measures to address that consequential effect is provided. For example, there may be an increase in student dropoffs by parents on Georgia to avoid the Gunn High Driveway delay.                                                          1 See “TRANSPORTATION SIGNIFICANCE THRESHOLDS—STUDY SESSION AND NEW INTERIM STANDARDS (CONTINUED FROM SEPTEMBER 19, 2002),” dated October 9, 2002, http://www.cityofpaloalto.org/civica/filebank/blobdload.asp?BlobID=7475  2 8. Will the price of student parking permits be increased if demand exceeds supply of permits, as proposed to be limited relative to 2009. In particular, as the number of teachers will be increased with student enrollment, more of the proposed-to-be-fixed parking spaces will have to be allocated to staff, with fewer students parking on campus. Replacing students driving with being dropped off by parents means replacing one-way trips with round trips. More morning round trips means long cycle times for cars exiting Gunn High School, adding to the critical movement delays at the Arastradero Road / Gunn High School intersection. While doing so may be beneficial from a land-use perspective, it is not an effective measure to reduce traffic impacts. 9. Maps are currently provided at the start of the school year illustrating preferred bicycle routes, which includes directing students to access the campus via Georgia and Los Robles rather than Arastradero Road. The data on Figure 12 indicates that this is successful and it is clear what greater success is intended by these measures. 10. The proposal to get students to arrive at Gunn High School before the peak rush through breakfast or by providing study areas is particularly unrealistic. High school students are chronically sleep deprived.2 11. The PTSA bicycle count has exceeded 600 on a warmer day (page 84), a suggested mitigation is to ensure that there is sufficient bike parking. As the enrollment is projected to increase by 21% over current levels, a proportionate increase would mean at least 750 secured bicycle parking spaces. Increased incentives (such as even more than a proportionate increase in bicycle parking) to bicycling would help to “not increase traffic volumes to the high school as the student body increases.” (page 82) 12. Measures have already been taken to increase student use of the VTA 88 bus routes. Another transportation mitigation measure that should be considered is to provide free VTA Eco Passes to all students at Gunn High School as a sticker on their student body card. The cost per student might be less if students at both Gunn High School and Palo Alto High School were included in the program. As demand for VTA bus service increases, PAUSD should provide support for working with the VTA to increase the number of buses provided before and after school and perhaps increase the number of distinct routes from the current three. 13. Another transportation mitigation measure to consider is to increase PAUSD bus service to accommodate demand by the approximately 160 Gunn students from Los Altos Hills and approximately 100 Gunn students from Stanford. 14. The queue of dropoffs (1100 feet in two lanes) is shared with the queue of students parking. This combination queue increases backups, and is not considered in the report. 15. Which staff members are proposed to monitor and direct traffic during peak dropoff/pickup times and how are they to be funded? 16. Another potential traffic mitigation is to have a right turn arrow from Arastradero Road into the Gunn High School driveway, so that inexperienced drivers do not stop when they have a “free” right turn and there are no pedestrians wanting to cross. Including signalized pedestrian crosswalk across the “free” right turn would handle the pedestrian/vehicle conflict.                                                          2 See Laura Brown, “Early start time deprives teenagers of crucial sleep,” the Paly Voice, December 17, 2004, http://voice.paly.net/view_story.php?id=2431  3 17. The increase in AM peak hour trip forecast of 57 more inbound trips and 25 more outbound trips (Table 6, page 81) is contradicted by data elsewhere in the report. On page 84, it states that the number of vehicles dropping off students is expected to increase from 365 to 450, an increase in 85. Thus, one would expect an increase of 85 more inbound and outbound trips just from student dropoffs alone. Considering the limitation in parking, this number is likely to increase as noted in Item 8 above. 18. Current 11th day enrollment for Gunn High School is 1,898 and was 1,907 last year. 3 Table 6 (page 81) cites an existing student population of 1,948 with forecast of 2,259. However, page 5 cites an enrollment (last year) of 1,917. The increased enrollment based on Table 6 is less than 16%, while the actual increase from current levels to 2,300 is over 21%. Such a discrepancy calls into question the remaining figures in the analysis of the Initial Study. 19. The parking requirement stated is “one [parking] space for each four teaching stations.” (page 85). The report computes 92 teachers, but Gunn has 120 classrooms4 and likely even more “teaching stations.” 20. We observe that only increases in the numbers of students walking, bicycling, or riding buses to school, or increases in carpooling decreases traffic. The Initial Study states, “The goal of the TDM program is to not increase traffic volumes to the high school as the student body increases.” Thus, the TDM (Transportation Demand Management Program) must be sufficient with measureable quantified goals so that an additional 400 students must arrive at Gunn High School through alternative means. The number of students walking to school is limited by geography and is unlikely to increase. Specific and measureable mitigations are required to increase bicycling, bus use, and carpooling totaling 400 students. We believe that the report is inadequate because it fails to quantify the amount of critical movement delay in the intersections studied that are at LOS F, fails to consider the significant increase in critical movement delay at Arastradero Road and Donald/Terman that is at LOS D, and fails to identify specific, measurable and effective mitigations that increase bicycling, bus riding, and carpooling along with quantified goals, and fails to analyze whether the proposed mitigations will reduce the increase in critical movement delays to a less than significant level.                                                          3 http://www.paloaltoonline.com/news/show_story.php?id=13854 4 http://www.trulia.com/schools/CA-Palo_Alto/Henry_M_Gunn_High_School/ DRAFT Dear Honorable Board of Education Members, I am submitting for your review my draft comments on the Trasnportation /Traffic sections of the Gunn and Paly Draft Mitigated Negative Declarations. The transportation elements of the Paly and Gunn environmental documents are remarkably short for projects of this scale. It makes reading them quick, but thoughtful review difficult. Some basic information is missing. TDM Plan Lacks Specific Goals & Critical Program Details The Gunn report relies on Transportation Demand Management (TDM) plans for mitigations. However, the proposed mitigation plan doesn’t define performance criteria. Transportation mode shift, that is the percentage of students shifting from autos to other modes of transportation, which would be needed to provide adequate mitigation, is never quantified. Without that data, it is impossible to evaluate whether or not the report‘s conclusion that adequate mitigation is achievable is correct or incorrect. What is the mode shift goal of these mitigations? How many car trips need to be shifted to other modes in order to mitigate the transportation impacts of this expansion? Precisely how will that goal be achieved? Further, elements that could determine the success or failure of a TDM plan are not adequately specified, making it unenforceable. Typically, well written TDM plans have very specific participation and mode shift goals that should be attributed to each element of the plan. There is none of that in this plan. For example, a carpool matching program is cited as a required mitigation measure, yet the program has no goals attached to it in terms of participation. No specifics about organization of the matching program are outlined. Who will be responsible for organizing and managing the carpool matching program? Staff? PTA volunteers? Have they agreed to do this? What funding source will be used for this? This is time intensive work. What resources will PAUSD be required to apply to the carpool matching program? Carpool matching programs are most successful when students are matched at the very beginning of the school year before commute patterns are established. Will PAUSD release information to make it possible to create a carpool matching database or maps in time to meet this critical deadline? Even with this commitment, we don’t yet have a carpool matching model that we know really works for this school district. The PTA Traffic Safety Committee has experimented at Escondido and Ohlone with several carpool matching models yielding limited success. (Our best performance to date has been this year’s report from Ohlone, increasing from 26 carpoolers last year to 45 carpoolers this year.) The district has not allowed us to create an on-line matching program so we have not been able to explore that as an option. Another example is the bike parking facilities mitigation in the Gunn report: Mitigation Measure TRAN-2 states that bike racks should be located in convenient areas to facilitate ease of queues, safety, and accessibility. This is a good idea; however, the number of additional bike parking spaces needed should be quantified in the Gunn and Paly reports. Further, the mitigation measure should specify that these additional spaces will be made available during the construction period as staff has agreed to do in recent meetings. A plan that depends on encouraging alternative modes as a primary mitigation should carefully spell out facilities capacity needs for those alternative modes. I suggest, at minimum, that enough bike parking spaces should be provided to meet current peak demand. That would require a minimum of 633 bike parking spaces at Gunn and 582 at Paly. Since the goal is to increase the number of bikes, we should plan for even greater numbers based on mode shift need. Please direct staff to make these corrections in the final draft. Further, the driveway and circulation design for both sites is still underway. It will be critically important to address the comfort and safety of bicyclists and pedestrians if we are to achieve successful mode shift. Usually, the parking/circulation plan for all modes would be included in the mitigations list as it must be part of the mitigation in a TDM plan in order to make it work. Gunn Mitigation Measure TRAN-4 requires staff to monitor and direct onsite traffic during peak drop-off/pick-up times. This is something Gunn staff has not been able to do consistently in the past. Is there funding for additional staff time? Has anyone asked Gunn staff how they will be able to implement this mitigation in the future? (Traffic Direction is not something PTA volunteers can do. The PTA insurance policy explicitly excludes this activity. If staff cannot do it, it won’t get done.) Most of the other mitigations proposed for Gunn already have been implemented. Gunn PTA Traffic Safety Team already directs bike access away from the main Gunn campus driveway. We already provide maps and circulation instructions on the school web site and information about alternative modes of transportation (including buses, pedestrian and bike route maps, etc.) at the beginning of the year. Gunn already limits the number of parking permits. Please direct staff to specify that this is already being done in their final document. We can’t realistically expect a significant incremental mode shift from activities we are already doing. To reiterate the primary point: Most of the mitigations proposed in this document are already in place. We have a good idea how much mode shift we can achieve with these measures because we are already doing them. What we cannot tell from these documents is what additional mode shift is required to adequately mitigate the additional vehicle impacts of this project. That goal is not quantified anywhere in the document; therefore, it is impossible to evaluate whether or not the goal is achievable as the report claims it is. That reporting failure should be corrected. Bus ridership The Gunn report doesn’t quantify am/pm VTA bus ridership. Was bus use studied? Intersection Level of Service On page 78 (Gunn report) the report notes that Arastradero intersections at Miranda and the Gunn driveway already are at LOS F. Additional intersection delays are not specifically quantified because the intersection operations already are operating at an unacceptable level. However, though there isn’t a worse LOS “grade” than F, it is possible for real world road users to experience greater delay than they currently do. Further degradation of these intersections will impact the performance of Arastradero Road as a whole. The report only reports this as >120 seconds in these cases, and it does not specifically quantify the delay. Delays at the Gunn driveway at morning bell time are a key factor driving peak hour performance of the Arastradero street system. Currently, no other single facility on Arastradero has a more negative impact on operational efficiency of the road than Gunn HS. We need to make sure the district has gotten this right. The likely effect of further LOS degradation would be “peak spreading”—the peak period during which the intersection operates at LOS F will become longer with road users choosing to travel earlier and earlier to avoid delays. Under most circumstances, traffic would also spread later, but that cannot happen at school sites where peak periods are driven by bell times. Peak spreading will make the Gunn Mitigation Measure TRAN- 2 that provides early morning study areas or breakfast incentives necessary. An alternate mitigation that might be considered (suggested in the original traffic study by Wilson Engineering) would be staggering Gunn bell times. This would spread out arrivals, eliminating peak loads that precede current bell times. There would be schedule complications, but this would immediately reduce the bell time surge of auto traffic. This is critically important because at Gunn there is only one driveway. The current bell time surge at that driveway is the equivalent of over 1,200 autos entering per hour in the twenty minute period 7:40-8:00am. This problem certainly will be exacerbated by a campus expansion and could be most effectively addressed by staggering bell times. However, when this was previously discussed it was dismissed as impractical by the district. Site expansion creates enough additional delay that this is an option worth revisiting. Bike Facilities—p. 79 should note the bike path that connects the rear of campus to Georgia. Parking demand—Gunn has 461 total existing spaces with current demand at 440 (or 95 percent). As parking mitigations require no increase in parking spaces or permits, how will PAUSD deal with probable shift of auto parking to nearby neighborhoods? Has this probable outcome been studied and/or discussed with the City of Palo Alto? This will be less of a problem at Paly where parking capacity is closer to projected demand, but it is a likely problem for both sites. Because projected trip generation is underestimated (see below), it is likely the parking problem will be much greater than the CEQA document indicates. Trip Generation Projection--The report uses standard figures for increases in trips based on the land use category from the ITE. While this may satisfy a California Environmental Quality Act (CEQA) requirement, it does not necessarily predict the situation at Gunn High School or Paly today. For example, the present number of morning peak hour auto trips at Gunn is 922. The ITE formula is for every 3.79 students we add one car trip. Based on the ITE model there currently should be 514 auto trips in the peak hour. So, readers of this report should be cautioned that the ITE formula underestimates the forecast of new auto trips with the increase in student population. The increase in trips very likely will be significantly greater than the ITE forecast of 82 trips, possibly as much as 75% higher when we extrapolate from today’s 2.11 students per car trip. A difference of this scale will likely have a significant impact but it is not modeled in this analysis. The purpose of an environmental review is to insure that information is gathered that can inform the planning process for proper mitigation. It is an important responsibility to the community to get this right. Thank you for giving these comments your usual thoughtful consideration. Sincerely, Penny Ellson To: Tom Hodges, Program Director Palo Alto Unified School District 25 Churchill Ave., Palo Alto, CA 94306 From: Joan Jacobus 3833 La Donna Ave, Palo Alto, CA 94306 Subject: Gunn High School Master Plan dated September 2009 CEQA Initial Study and Environmental Checklist in support of proposed Mitigated Negative Declaration – TRAFFIC, pages 75-86 Date: November 17, 2009 In light of the Sheriff’s Office changing their policy regarding drop offs at the Miranda VTA bus stop, the Wilson Engineering Reports, on which the traffic mitigation measures are based, will need to be revised. Even if the Sheriff’s Office reverses their current decision, at any point in the future they could again prevent drop offs at the bus stop. Presently 161 cars (44%) use Miranda for morning drop off, compared to 204 cars that use the Gunn driveway, so this is a significant issue. Those 161 cars cannot be redirected to the Gunn driveway which is already overcapacity (LOS F). Identifying another drop off location on the Los Altos Hills side of campus is critical. Given the low level of service (LOS D&F) already present at the four study intersections, additional traffic mitigation measures must be considered. Several educational options were identified by the High School Task Force, which met during 2007 and published its report to the PAUSD Board of Education on 12/18/07, that could be considered for traffic mitigation. They are: a. Online learning b. Independent study options c. Late afternoon/evening courses d. Extension of the school day by adding 0 and 8th periods e. Staggered start times for students f. Off-campus course work What these educational options have in common is that they allow students to arrive at campus as needed, but not necessarily at the morning bell, thus may be helpful in mitigating the morning traffic peak. Now is the time for PAUSD and Gunn staff to begin investigation of one or several of these options to meet the needs of the growing Gunn population and its growing traffic demands. For more information, please refer to the PAUSD BOE packet, Discussion Item 1, Recommendations from the High School Task Force, 12/18/07, page3-4. Given the shortcomings in the CEQA document concerning traffic mitigation proposals, the Mitigated Negative Declaration should not be adopted by PAUSD without additional traffic mitigation measures. Thank you for the opportunity to submit comments. If you have any questions, please contact me at 650-856-7480. TRANSPORTATION DIVISION Memorandum Date: November 16, 2009 To: Tom Hodges, Program Director, Palo Alto Unified School District From: Rafael Rius, P.E., Transportation Project Engineer, City of Palo Alto Subject: Palo Alto Unified School District – Transportation Comments on the Gunn High School and Palo Alto High School Master Plan, Initial Studies The following are the City’s comments on the Transportation/Traffic sections (Chapters 15) of the Initial Studies for the Draft Mitigated Negative Declarations (MND) prepared for the Gunn High School and Palo Alto High School Master Plans, dated October 2, 2009 and October 3, 2009, respectively. Impact Analysis: Trip Generation provided is based on the Institute of Transportation Engineers – Trip Generation Manual. Per the ITE, for unique instances or where more detailed information is available, actual count data should be applied. Part of the reason is that the school district does not provide any bus services, and the local public transit is limited to approximately 3 routes during each of the peak periods. Re: Palo Alto HS - PAUSD conducted a traffic analysis in May 2009 which included detailed data collection and projections of traffic. Per the May 2009 study, approximately 134 additional vehicles would drive and park on the campus and 148 additional vehicular drop-offs would occur. Combined, this would result in approximately 430 additional AM peak hour vehicle trips, which is substantially greater than the 138 additional trips presented in Table 7 of the MND. Re: Gunn HS - PAUSD conducted a traffic analysis in May 2009 which included detailed data collection. Per the May 2009 study, approximately 93 additional vehicles would drive and park on the campus and 85 additional drop-offs would occur. Combined, this would result in approximately 263 additional AM peak hour vehicle trips, which is substantially greater than the 82 additional trips presented in Table 6 of the MND. The City of Palo Alto has significance criteria for intersections that already operate at LOS E or F. The impact analysis for the deficient intersections was not quantified using the City’s thresholds of significance, and should be conducted to determine if a November 16, 2009 Page 2 of 3 significant impact would occur. Instead the impact analysis qualitatively states that the proposed project would increase vehicular traffic. By quantifying the level of impact, appropriate levels of mitigation can be identified. Attached are the City’s significance criteria for traffic impact analysis which should be used in evaluating the traffic impacts generated by the project on Palo Alto streets. Proposed Mitigation Measures: Because the estimated increase in traffic is underestimated, the proposed mitigation most likely will need to include more stringent measures aside from incentives or voluntary ride-share programs. Comprehensive carpooling programs at other schools in the area have shown minimal success. Mitigation measures should be identified subsequent to preparation of an updated traffic analysis using the City’s significance criteria. By restricting the amount of parking permits, the measures should include any proposals to minimize the amount of parking on neighborhood streets. A staggered bell schedule for Gunn High School was previously recommended by the PAUSD consulting traffic engineers, as well as City of Palo Alto staff. This should be included as a potential mitigation alternative, since it would be one of the more effective measures. Attachments: City of Palo Alto Significance Criteria for Transportation Impacts ENVIRONMENTAL CRITERIA (SIGNIFICANCE THRESHOLDS) USED BY THE CITY OF PALO ALTO Transportation A traffic impact is considered significant if the project will: • Cause a local (City of Palo Alto) intersection to deteriorate below Level of Service (LOS) D; or • Cause a local intersection already operating at LOS E or F to deteriorate in the average control delay for the critical movements by four seconds or more, and the critical volume/capacity ratio (V/C) value to increase by 0.01 or more; or • Cause a regional intersection to deteriorate from an LOS E or better to LOS F; or • Cause a regional intersection already operating at LOS F to deteriorate in the average control delay for the critical movements to increase by four seconds or more, and the critical V/C value to increase by 0.01 or more; or • Cause queuing impacts based on a comparative analysis between the design queue length and the available queue storage capacity. Queuing impacts include, but are not limited to, spillback queues at project access locations; queues at turn lanes at intersections that block through traffic; queues at lane drops; queues at one intersection that extend back to impact other intersections, and spillback queues on ramps; or • Cause a freeway segment (for each direction of traffic) to operate at LOS F or contribute traffic in excess of 1% of segment capacity to a freeway segment already operating at LOS F; or • Impede the development or function of planned pedestrian or bicycle facilities; or • Impede the operation of a transit system as a result of congestion; or • Create an operational safety hazard; or • Cause any change in traffic that would increase the Traffic Infusion on Residential Environment (TIRE) index by 0.1 or more on a local or collector residential street; or • Result in inadequate on-site parking capacity; or • Result in inadequate emergency access. 1 Lesley Lowe From:Aimee Lopez [alopez@ocmi.com] Sent:Monday, November 02, 2009 9:59 AM To:Lesley Lowe; Cory Barringhaus Subject:FW: Comments on Draft Mitigated Negative Declaration for Gunn HighSchool Master Plan I believe you may have these already. Following are additional comments. Thanks, Aimée -----Original Message----- From: Tom Hodges Sent: Monday, November 02, 2009 8:23 AM To: Aimee Lopez Subject: FW: Comments on Draft Mitigated Negative Declaration for Gunn High School Master Plan To ESA please. T ________________________________________ From: Sue Ma [SMa@waterboards.ca.gov] Sent: Friday, October 30, 2009 3:16 PM To: rsmith@pausd.org; thodges@pausd.org Cc: Joe Teresi; Ken Torke; Phil Bobel; Brian Wines; Dale Bowyer Subject: Comments on Draft Mitigated Negative Declaration for Gunn High School Master Plan Greetings: Water Board staff has reviewed the Draft Mitigated Negative Declaration for the Gunn High School Master Plan project located at 780 Arastradero Road, northeast of the intersection of Arastradero Road and Foothill Expressway in the city of Palo Alto. The proposed project features construction of new buildings and other structures, including two new classroom buildings, a new gymnasium, and a new Performing Arts Center. The subject document identifies water quality as an issue and acknowledges that the project is subject to the New and Redevelopment Requirements (Provision C.3.) in the City of Palo Alto's municipal stormwater permit. Provision C.3. requires that new and redevelopment projects treat stormwater runoff to remove pollutants to the maximum extent practicable and consider/limit changes in the runoff hydrograph. The subject document mentions vegetated swales, detention basins, and landscape infiltration systems as methods to comply with C.3. but does not provide any specific details on the proposed methods being considered for this particular project. These issues need to be identified and addressed early in the planning and design process; stormwater treatment should not be an afterthought once the project is built. Therefore, the subject document should be revised to provide enough detail on the proposed mitigation alternatives so that we can adequately assess the project's compliance with Provision C.3. You should also be aware that a new regional municipal stormwater permit (Water Board Order No. R2-2009-0074) was issued on October 14, 2009, to all municipalities and local agencies in Alameda, Contra Costa, San Mateo, and Santa Clara counties, and the cities of Fairfield, Suisun City, and Vallejo. Provision C.3. of the new permit specifically requires that stormwater treatment be addressed using Low Impact Development techniques, such as infiltration, harvesting and reuse, evapotranspiration, and biotreatment. Please call or email me if you have any questions. Sue Ma Water Resources Control Engineer 2 1515 Clay Street, Suite 1400 Oakland, CA 94612 510-622-2386 FAX 510-622-2460 SMa@waterboards.ca.gov November 19, 2009 FROM: Penny Ellson Attn: Tom Hodges Palo Alto Unified School District 25 Churchill, Building D Palo Alto, CA 94306 The CEQA document points to a higher volume of drop-offs on Miranda (161) than previous years. It is not clear what the reasons for an increase in volume at that location might be. In addition, the County Sheriff, in response to recent traffic safety complaints from VTA, began ticketing people for dropping off students at that location last week. This activity has begun pushing autos from Miranda to the Arastradero entrance. We can’t assume that additional volume can be accommodated elsewhere on the public streets. We request that the CEQA document be revised to include the effects of any resulting diversion of drop-off traffic from Miranda. These revisions should be included in the existing conditions so that mitigations might be studied to address this issue, considering motor vehicle, pedestrian and bicycle safety. At today’s City School Traffic Safety Committee meeting, CPA Transportation Engineer Rafael Rius stated that the city would be open to discussing possible safety improvements to the Miranda area with PAUSD.  1 Comments on the Initial Study and Environmental Checklist for California Environmental Quality Act for the Gunn High School Master Plan dated September 2009 Arthur M. Keller, Gunn Facilities Planning Committee, PTSA Public Transit Coordinator, Gunn parent 1. The reference on page 20 to the Land Use Element of the Palo Alto Comprehensive Plan is erroneous. The chapter is called the Land Use and Community Design element, and it was part of the Palo Alto Comprehensive Plan for 1998-2010 adopted well before 2007. 2. The greenhouse gas analysis on page 24 and noise analysis on page 66 each assume in increase in daily trips of 532, which may be an underestimate. 3. The various references to the Palo Alto Comprehensive Plan Update 1996 should instead refer to the Palo Alto Comprehensive Plan 1998-2010. 4. Table 7 on page 82 states that the AM peak hour delays will remain at LOS F for both Arastradero Road / Miranda Avenue and Arastradero Road / School Driveway. However, no specific measure of critical delay was made other than the vague “> 120”; however the City of Palo Alto’s traffic significance thresholds states, “A significant impact results if the existing LOS is already D or worse at the intersections not included in ‘a’ above and the addition of project traffic causes an increase of one second or more of critical movement delay.”1 It is likely that the expected increase in traffic will increase the critical movement delay by more than one second, and the mitigations proposed are unlikely to reduce this increase to no more than one second. Furthermore, the increase in critical movement delay of 1.8 seconds exceeds the threshold of significance as determined by Palo Alto standards for the Arastradero Road and Donald/Terman intersection (see Table 7, page 82), even though the report implies that this increase is less than significant with mitigations. It is not demonstrated how the increase in critical movement delay would be reduced by mitigations to below one second. 5. Mitigation TRAN-1 regarding setting up a carpool-matching program for students is not realistic. The primary mechanism for such a matching program is through the student directory, which is not released to the students until November and does not geocode the student addresses. There is no quantification for the amount of carpooling currently occurring nor are there quantified goals for the increase in carpooling. No reference is made as to the apportionment of the increase of carpooling between students in carpools driving to Gunn High School versus parents dropping off and picking up carpools. 6. Mitigation TRAN-2 contains measures that are already in practice, and it is unclear the extent to which these measures will “not increase traffic volumes to the high school as the student body increases.” (page 82) 7. Spillover traffic and parking at the adjacent Barron Park neighborhood may be a consequence of the lack of increase in onsite parking spaces. No mitigation measures to address that consequential effect is provided. For example, there may be an increase in student dropoffs by parents on Georgia to avoid the Gunn High Driveway delay.                                                          1 See “TRANSPORTATION SIGNIFICANCE THRESHOLDS—STUDY SESSION AND NEW INTERIM STANDARDS (CONTINUED FROM SEPTEMBER 19, 2002),” dated October 9, 2002, http://www.cityofpaloalto.org/civica/filebank/blobdload.asp?BlobID=7475  2 8. Will the price of student parking permits be increased if demand exceeds supply of permits, as proposed to be limited relative to 2009. In particular, as the number of teachers will be increased with student enrollment, more of the proposed-to-be-fixed parking spaces will have to be allocated to staff, with fewer students parking on campus. Replacing students driving with being dropped off by parents means replacing one-way trips with round trips. More morning round trips means long cycle times for cars exiting Gunn High School, adding to the critical movement delays at the Arastradero Road / Gunn High School intersection. While doing so may be beneficial from a land-use perspective, it is not an effective measure to reduce traffic impacts. 9. Maps are currently provided at the start of the school year illustrating preferred bicycle routes, which includes directing students to access the campus via Georgia and Los Robles rather than Arastradero Road. The data on Figure 12 indicates that this is successful and it is clear what greater success is intended by these measures. 10. The proposal to get students to arrive at Gunn High School before the peak rush through breakfast or by providing study areas is particularly unrealistic. High school students are chronically sleep deprived.2 11. The PTSA bicycle count has exceeded 600 on a warmer day (page 84), a suggested mitigation is to ensure that there is sufficient bike parking. As the enrollment is projected to increase by 21% over current levels, a proportionate increase would mean at least 750 secured bicycle parking spaces. Increased incentives (such as even more than a proportionate increase in bicycle parking) to bicycling would help to “not increase traffic volumes to the high school as the student body increases.” (page 82) 12. Measures have already been taken to increase student use of the VTA 88 bus routes. Another transportation mitigation measure that should be considered is to provide free VTA Eco Passes to all students at Gunn High School as a sticker on their student body card. The cost per student might be less if students at both Gunn High School and Palo Alto High School were included in the program. As demand for VTA bus service increases, PAUSD should provide support for working with the VTA to increase the number of buses provided before and after school and perhaps increase the number of distinct routes from the current three. 13. Another transportation mitigation measure to consider is to increase PAUSD bus service to accommodate demand by the approximately 160 Gunn students from Los Altos Hills and approximately 100 Gunn students from Stanford. 14. The queue of dropoffs (1100 feet in two lanes) is shared with the queue of students parking. This combination queue increases backups, and is not considered in the report. 15. Which staff members are proposed to monitor and direct traffic during peak dropoff/pickup times and how are they to be funded? 16. Another potential traffic mitigation is to have a right turn arrow from Arastradero Road into the Gunn High School driveway, so that inexperienced drivers do not stop when they have a “free” right turn and there are no pedestrians wanting to cross. Including signalized pedestrian crosswalk across the “free” right turn would handle the pedestrian/vehicle conflict.                                                          2 See Laura Brown, “Early start time deprives teenagers of crucial sleep,” the Paly Voice, December 17, 2004, http://voice.paly.net/view_story.php?id=2431  3 17. The increase in AM peak hour trip forecast of 57 more inbound trips and 25 more outbound trips (Table 6, page 81) is contradicted by data elsewhere in the report. On page 84, it states that the number of vehicles dropping off students is expected to increase from 365 to 450, an increase in 85. Thus, one would expect an increase of 85 more inbound and outbound trips just from student dropoffs alone. Considering the limitation in parking, this number is likely to increase as noted in Item 8 above. 18. Current 11th day enrollment for Gunn High School is 1,898 and was 1,907 last year. 3 Table 6 (page 81) cites an existing student population of 1,948 with forecast of 2,259. However, page 5 cites an enrollment (last year) of 1,917. The increased enrollment based on Table 6 is less than 16%, while the actual increase from current levels to 2,300 is over 21%. Such a discrepancy calls into question the remaining figures in the analysis of the Initial Study. 19. The parking requirement stated is “one [parking] space for each four teaching stations.” (page 85). The report computes 92 teachers, but Gunn has 120 classrooms4 and likely even more “teaching stations.” 20. We observe that only increases in the numbers of students walking, bicycling, or riding buses to school, or increases in carpooling decreases traffic. The Initial Study states, “The goal of the TDM program is to not increase traffic volumes to the high school as the student body increases.” Thus, the TDM (Transportation Demand Management Program) must be sufficient with measureable quantified goals so that an additional 400 students must arrive at Gunn High School through alternative means. The number of students walking to school is limited by geography and is unlikely to increase. Specific and measureable mitigations are required to increase bicycling, bus use, and carpooling totaling 400 students. We believe that the report is inadequate because it fails to quantify the amount of critical movement delay in the intersections studied that are at LOS F, fails to consider the significant increase in critical movement delay at Arastradero Road and Donald/Terman that is at LOS D, and fails to identify specific, measurable and effective mitigations that increase bicycling, bus riding, and carpooling along with quantified goals, and fails to analyze whether the proposed mitigations will reduce the increase in critical movement delays to a less than significant level.                                                          3 http://www.paloaltoonline.com/news/show_story.php?id=13854 4 http://www.trulia.com/schools/CA-Palo_Alto/Henry_M_Gunn_High_School/ Correspondence sent via email • These November 18, 2009 TO: Tom Hodges <thodges@pausd.org>, CC: Bart Carey <bcarey@careyvision.com>, Tom Jacoubowsky <tjacoubowsky@pausd.org>, Noreen Likins <nlikins@pausd.org>, Duncan MacMillan <dmcmllan@pacbell.net>, Tracey Stewart <tstewart@folsom.net>, Dear Mr. Hodges: I am writing to forward the statement of the Los Altos Hills Education Committee (EC) and the Los Altos Hills City Council as public comment against the adoption of a Mitigated Negative Declaration under the California Environmental Quality Act (CEQA) for the projects at Henry M. Gunn High School (Gunn), located at 780 Arastradero Road, Palo Alto. This position has been reviewed and approved by the Los Altos Hills City Council. The Committee wishes to raise its concern that the CEQA document is inadequate concerning proposed traffic mitigations at Gunn, specifically that the report ignores approximately 44% of student drop-offs that now occur along Miranda Avenue from its proposed mitigation, TRAN-3. In addition, it appears to the Committee that the situation along Miranda has seriously worsened over the past weeks with the Santa Clara County Sheriff's Department ticketing parents along Miranda for what were previously thought to be permissible drop-offs. It also appears from a meeting between a subcommittee of the EC and the principal and assistant principal of Gunn that sufficient resources do not exist internally at Gunn to proactively deal with the short-term traffic issues along Miranda. We are additionally concerned that any west-side entry mitigations would need to wait until another bond issue if they are not addressed now. There should be an agreement now to task the traffic engineer and architect to propose mitigation recommendations along Miranda, including a possible campus entry point for drop-off purposes. For these reasons, the Los Altos Hills Education Committee and the Los Altos Hills City Council feel the CEQA document is inadequate, should be rejected as defective, and that a Mitigated Negative Declaration should not be adopted until and unless Miranda Avenue traffic issues are addressed as part of the initially-funded phases of improvements at Gunn. Sincerely, Bart Carey Chair, Los Altos Hills Education Committee 26379 Fremont Road Los Altos Hills California 94022 650 / 941-7222 Fax: 650/941-3160 Lesley Lowe From: Aimee Lopez [alopez@ocmi.com] Sent: Thursday, November 19, 2009 4:57 PM To: Cory Barringhaus; Lesley Lowe Cc: 'John Wilson' Subject: FW: Gunn expansion needs a new bell schedule, not earlier start times Page 1 of 2 1/29/2010     Aimée M. Lopez | Project Manager O'Connor Construction Management, Inc. Palo Alto Unified School District 25 Churchill Ave., Bldg. D, Palo Alto, CA94306 650.329.3968 | Fax 650.327.3588 | Cell 925.580.2714 e-mail: ailopez@pausd.org   From: Tom Hodges Sent: Wednesday, November 04, 2009 9:40 AM To: Aimee Lopez Subject: FW: Gunn expansion needs a new bell schedule, not earlier start times For ESA   Thomas Hodges - Sr. Vice President O’Connor Construction Management, Inc. 7041 Koll Center Parkway, Suite 135 | Pleasanton, CA 94566 925.426.1578 | 925.426.1587 FAX | 650.296.8087 CELL     From: Meri Gruber [mailto:meri.gruber@gmail.com] Sent: Monday, November 02, 2009 10:55 PM To: thodges@pausd.org Subject: Gunn expansion needs a new bell schedule, not earlier start times Dear Mr Hodges, I am writing to send you my comments to the Gunn High School Master Plan, Initial Study and Environmental Checklist Form California Environmental Quality Act (CEQA) The traffic mitigation plan on p. 83 suggest getting students to school earlier. This is counter to the well documented research regarding teens and sleep. The teen internal clock shifts and earlier start times forces chronic sleep loss. We continue to operate with the assumption that teens are like adults, that sleep loss is tiring but manageable. However the well researched and documented reality is that the magnitude of the effect of sleep loss on teens is exponentially damaging. Also, the document significantly under estimates the increased traffic. The use of a standard trip rate doesn't reflect local conditions (i.e. no school buses). For example, the present number of morning peak hour auto trips at Gunn is 922. Using the standard trip rate the number would be 514. This is a great opportunity for a staggered bell schedule, not earlier arrival times. Best regards, Meri Gruber -- Meri Gruber cell: 650-269-3570 Page 2 of 2 1/29/2010 Attachment B Approved: November 17, 2009 Regular Meeting October 27, 2009 Page 1 BOARD OF EDUCATION Attachment Consent 4 PALO ALTO UNIFIED SCHOOL DISTRICT Date: November 17, 2009 Complete tape recordings of most Board Meetings are available at 25 Churchill Avenue. Meetings are also available on demand at http://www.communitymediacenter.net/watch/pausd_webcast/PAUSDondemand.html MINUTES FOR REGULAR MEETING OF OCTOBER 27, 2009 Call to Order The Board of Education of Palo Alto Unified School District held a Regular Meeting in the Board Room at 25 Churchill Avenue, Palo Alto, California. Barb Mitchell, President, called the meeting to order at 5:30 p.m. Members present: Ms. Barb Mitchell, President Ms. Barbara Klausner, Vice President Ms. Melissa Baten Caswell Mr. Dana Tom Ms. Camille Townsend Mr. Steve Zhou, Student Board Rep, Gunn High School Mr. Jason Willick, Student Board Rep, Palo Alto High School Staff present: Dr. Kevin Skelly, Superintendent Dr. Linda Common, Assistant Superintendent Mrs. Ginni Davis, Assistant Superintendent Dr. Scott Bowers, Assistant Superintendent Dr. Robert Golton, Co Chief Business Official Mrs. Cathy Mak, Co Chief Business Official Dr. William Garrison, Director Adjourn to Closed Session The Board adjourned to closed session pursuant to Government Code 54957 for Employee Evaluation regarding the Superintendent; pursuant to Government Code 54961 for Liability Claims – Ng vs PAUSD; Flusberg vs PAUSD; Miao vs PAUSD; pursuant to Government Code 54957.6 for Conference with Labor Negotiator Dr. Scott Bowers, regarding PAEA, CSEA, and Non-represented groups; pursuant to Government Code 54957 regarding Employee Discipline / Dismissal / Release; and for Student Discipline in Two Cases. Reconvene in Open Session The Board reconvened in open session at 6:32 p.m. Mitchell announced the board took action, as follows, on three liability claims. MOTION: It was moved by Townsend, seconded by Baten Caswell, and motion carried 5-0 to issue payment in the amount of $436.41 in Ng vs PAUSD. MOTION: It was moved by Townsend, seconded by Baten Caswell, and motion carried 5-0 to issue payment in the amount of $787.09 in Flusberg vs PAUSD. MOTION: It was moved by Townsend, seconded by Baten Caswell, and motion carried 5-0 to reject the claim in Miao vs PAUSD. Approval of Agenda Order MOTION: It was moved by Baten Caswell; seconded by Townsend; and motion carried 5-0 to approve the agenda order. Student Board Representatives Willick, of Palo Alto High School, reported homecoming week is ongoing; a rally was held during advisory and showcased a new Paly fight song; the quarter ended last week; there is online reporting by teachers; and he commented on the impact at Paly from the recent suicide. Zhou, of Gunn High School, reported on girls’ water polo; homecoming was the previous week and students worked around the weather; student government was reviewing issues from the event; discussed the recent suicide and student-led promotion of communication among students and adults Staff and Student Successes Skelly noted the 120 commended high school students for the National Merit Scholarship included in the packet. He also commented on violin performances of Alexi Kenney. Skelly commented on the continuing work on the issue of suicide, impressed with how students at Gunn are working with staff. Staff is attending meetings on the state budget, working on reductions with the leadership team remaining faithful to the values, have reached tentative agreements with the bargaining units and hope to bring agreements to the Board on Approved: November 17, 2009 Regular Meeting October 27, 2009 Page 2 MINUTES FOR REGULAR MEETING OF OCTOBER 27, 2009 November 10, 2009, action for on November 17; are pleased to work with Triona Gogarty (PAEA) and Jeremy Sakakihara (CSEA). Skelly spoke of his cycling to “Scaremeadow” and other schools with Townsend and Klausner. Staff is researching the achievement gap question raised at the previous meeting and will be providing information on November 10, 2009. Skelly then introduced Ann Durkin, new director of technology, who comes to the district from HP. Durkin noted she was thrilled to be part of the district and that she is looking forward to meeting everyone. Golton showed phots from walk/cycle day at the various schools, the Terman science fair, and Nixon tree planting. The construction update included the Citizens’ Oversight Committee meeting, the El Camino fields at Paly, the Gunn pool and dedication, and the Gunn industrial arts building. Consent Calendar MOTION: It was moved by Tom, seconded by Townsend, and motion carried 5-0 to approve the consent calendar including certificated and classified personnel actions, warrants of September 2009, the Uniform Complaint (Williams Settlement and Valenzuela/CAHSEE Lawsuit Settlement) Quarterly Report for July 1-September 30, 2009, Addendums No. 3, 4, and 5 with Gelfand Partners, and the renewal of Student Teaching/Intern Agreements. The minutes for October 13, 2009, were pulled for separate discussion. Klausner requested the minutes be changed to pull the phrase “in the not yet proficient category” from the eighth bullet on page two, feeling the term is confusing. MOTION: It was moved by Klausner; seconded by Townsend, and motion carried 5-0 to approve the revised minutes with the correction as noted above. Public Hearing Notice of Intent to Adopt a Mitigated Negative and Declaration Draft Initial Study/Mitigated Negative Declaration for 780 Arastradero Road, Palo Alto, CA (Gunn High School) Mitchell opened the public hearing. Duncan MacMillan spoke about the traffic data presented in the report, referring to page 80, noting it only addresses half the traffic issues. He felt miranda needs to be addressed now or it won’t be done for years. He asked for this priority move up on the list. Penny Ellson spoke about mitigations and the need to address car trips, noting we can’t expect load shift by continuing what is already being done. She would like to look at other trip reductions. Bike parking spaces are needed; car parking is probably underestimated as well. She referred the Board and staff to the document she sent. Mitchell closed the public hearing. Public Hearing Notice of Intent to Adopt a Mitigated Negative and Declaration Draft Initial Study/Mitigated Negative Declaration for 50 Embarcadero Road, Palo Alto, CA (Palo Alto High School) Mitchell opened the public hearing. Penny Ellson indicated the same issues apply to Paly. The left turn pocket into the school needs to be reconsidered, same issues for bike parking, car parking, and supervision. Mitchell closed the public hearing. Information Strategic Plan Goals and Accountability Results Skelly indicated this is the second of two reports. Common thanked Garrison for gathering the data on high schools. The PowerPoint presentation reviewed: • Purpose of the report • Strategic Plan Goals 1 and 2 • The UC/CSU a-g course requirements • Comparisons of Selected CA High Schools – percentage of students completing the a-g courses • Number of students and percentage of those meeting a-g requirements for 2008 and 2009 • Number of African American and Hispanics students and percentage meeting a-g requirements for 2008 and 2009 • Number of students and percentage of those missing 1 or 2 a-g course requirements • College Board SAT Exam mean scores and participation rates for 2006, 2007, 2008, and 2009 for Critical Reading, Math, and Writing • SAT comparison for class of 2009 vs California and national for Critical Reading, Math, and Writing • 2008 SAT Rankings: 10 Top CA High Schools for Critical Reading, Math, and Writing (including class of 2009 for Gunn and Paly) • National Merit Students commended or semifinalists for Gunn and Paly 2008, 2009, and 2010 • AP Exams Taken, May 2009 Results for both high schools • AP Exam Scores from May 2007, 2008, and 2009 • 2008 AP Rankings comparisons for selected California High Schools • California Standards Tests proficient and advanced for science (biology, chemistry, physics) for 2007, 2008, and 2009 • California Standards Tests proficient and advanced for history/social science (social science, world history, and US history) for 2007, 2008, and 2009 Approved: November 17, 2009 Regular Meeting October 27, 2009 Page 3 MINUTES FOR REGULAR MEETING OF OCTOBER 27, 2009 • California Standards Tests proficient and advanced for mathematics (algebra I, geometry, algebra II) for 2007, 2008, 2009) • CAHSEE – students fulfilling all requirements for graduation except the CAHSEE: 2006 – 0; 2007 – 1 (who has since graduated); 2008 – 0; and 2009 – 1 Mitchell congratulated students, parents, and teachers for these accomplishments. Board member comments included appreciation for progress on a-g requirements; noted the difficulty of the comparisons in light of the recent suicide; noted test scores are one piece of the puzzle and perhaps have an outsized significance; asked about classification of ethnicity and the recent change; asked about percent of students taking at least one AP test; inquired whether students are encouraged to take AP classes; asked if trends for AP score percentages are the same for individual classes; noted scores are different depending on the class, asked if AP classes taken are outside of PAUSD; asked what can be done to monitor a-g requirements for African American and Hispanic students; asked what is being done to scaffold these students so they can do better; noted the numbers are phenomenal, students need to realize how above average they are; would like a visual for students so they can understand how they look compared to the state and nation; asked how well the District is doing with data management; would like to extrapolate how many are taking at least one AP class; noted students are incredibly accomplished; commented on the complex issue of overstretching and balance while still encouraging students to take AP classes—need to address individual students; asked if student’s AP scores have been correlated with student’s grades in the classroom; asked if the data is broken out for gender; student reps asked what is being done to help the students not passing CAHSEE; asked about Newsweek’s poll; asked about students not meeting a-g requirements and whether teacher advisors could help keep them on track; would like to ask principals about course offerings and what input is coming from students; and asked about students taking a-g courses through outside sources. Information Update on Project to Install Bleachers at Palo Alto High School Skelly indicated this item was discussed at the October 13, 2009, regular meeting. Golton said staff is going back to the drawing board based on that discussion and further discussion with site staff. Future meetings have been scheduled and will be publicized for the public. This will include the landscaping plan for the Paly campus. The bleacher plans have been pulled from review by DSA. The plan is for replacement in summer 2011. The visitors’ bleachers will be addressed this summer. Public Comment Catherine Martineau from Canopy offered help in care and enhancement of trees. She spoke of her conversations with staff in regard to the bleacher project. Canopy did not approve the approach presented. Sharon Kelly, also from Canopy, explained her role in recent advice offered to the District. This had a positive effect at Gunn. She would like to provide more input for the El Camino fields and bleacher projects at Paly. Board members comments included ongoing community membership; asked for clarification of which items will be discussed by the landscape committee; thanked staff for listening to the concerns and for looking for a compromise to address everyone’s needs; asked for clarification of visiting bleacher timeline; and asked for 3D renderings of proposals. Skelly thanked Jacqueline McEvoy, principal, and noted staff will look more comprehensively at the plan. Open Forum Public Comment No one asked to address the Board. Action Springboard to Kindergarten This item was discussed at the October 13, 2009, regular meetings. Board comments included the value of networking; appreciated the generosity of the donors; noted it represents a leveling up for kindergartners and assessment of results; and noted this is multi prong approach to the achievement gap. Motion: It was moved by Tom; seconded by Baten Caswell; and motion carried 5-0 to approve the Springboard to Kindergarten three-year pilot program. Discussion Summary of the 2009 Summer School Program and Proposal for the 2010 Program Davis commented on what the summer school programs provide for students. Staff would like to expand the secondary program for the high school so students can work on a-g courses. Barbara Lancon, coordinator, thanked all who worked so hard over the summer on these classes. She outlined the sites, dates, and tuition. She noted the state continues to cut funding, so an increase is being requested as well as a sliding scale fees for intervention programs. Pat Dawson, professional development, spoke about the 2009 literacy program and progress of students. Melissa Hauer spoke about the math program. Board member comments included asking about the intervention program and how parents will be informed about financial aid; asked if financial aid in the budget; asked about varying numbers from report to budget; asked about matched scores being tracked in the data systems; noted this would show the lasting impact and how we are doing in achieving the strategic plan goals; asked about math pre and post-tests; asked if the Barron Park college bound program being used in intervention; support tracking the long term results; asked about state restrictions and how they are being addressed; asked if intervention programs would be the same; noted it was good to see high school courses, being addressed; asked if there will be financial aid requests; asked for the dates for longer high school classes; asked if principals see a difference in their Approved: November 17, 2009 Regular Meeting October 27, 2009 Page 4 MINUTES FOR REGULAR MEETING OF OCTOBER 27, 2009 students in the fall and how it is discussed; would like to see principals be able to discuss that data; asked if expenses came in under the budgeted amount; expressed comfort with the proposal to charge a fee, but offer assistance; noted the significance of tying in CST scores into the assessment picture; asked if other assessments can be developed through summer school; would like to hear how CST data can be used starting with this past summer and perhaps the prior year’s summer school testing data; suggested summer school might need to be longer; looked forward to supporting the proposal at the next meeting; appreciated the role the program plays; supported the comments about using the data to understand the impact in attaining goals; would like to see whether it could be expanded; and noted principals spoke well of these resources. Discussion Notice of Intent to Adopt a Mitigated Negative and Declaration Draft Initial Study/Mitigated Negative Declaration for 780 Arastradero Road, Palo Alto, CA (Gunn High School) Golton noted there is an item for each high school to meet the California Environmental Quality Act (CEQA). The items will not return to the board until later in the year after input has been received. Hodges noted this is time for the Board to add their comments. All comments received will be compiled and possible amendments will be considered. Corey Barringhouse, ESA Associates, noted they looked at both of the master plans and the impact of their implementation to find impacts and how best to mitigate them to make them less than significant. He noted the 30-day public review is in progress. All comments will be responded to. Mitigation measures will be monitored. Board members comments included having the Sustainable Schools Committee review the information; noted the high speed rail could impact the plan and asked how does the District will react; asked about eminent domain; asked whether staff have Ms. Ellson’s letter; noted support for requests of Canopy; asked if oral comments are included; and asked whether there will be cost information about mitigation costs in the final report. Discussion Notice of Intent to Adopt a Mitigated Negative and Declaration Draft Initial Study/Mitigated Negative Declaration for 50 Embarcadero Road, Palo Alto, CA (Palo Alto High School) Public Comment Kirsten Essenmacher felt there was insufficient information about the public hearing and asked for two additional weeks for comments. She expressed concern about the footprint of buildings vs landscapes. Board members comments included a question about noticing practices and looking for multiple ways to send the information outbound; and suggested the extension be advertised. Discussion Award of Bid for the Purchase of Smartboards Mak noted that an excess of $76,700 in orders for Smartboards have been received. Bid results produced one bidder. The bid is consistent with past work done by this vendor. Board member comments included asking why there was only one bidder. It was agreed to bring the item back on consent. Action Memorandum of Understanding (MOU) Among Basic Aid School Districts in San Mateo and Santa Clara Counties Skelly noted the Board received information on costs. Board member comments included asking about those costs; would like numbers included in future requests to reconsider if the costs go higher; noted this was not an annual MOU, but can be canceled on 30 days notice. MOTION: It was moved by Klausner, seconded by Townsend, and motion carried 5-0 to approve the Memorandum of Understanding Among Basic Aid School Districts in San Mateo and Santa Clara Counties. Action Stipulated Expulsions (Two Cases) MOTION: It was moved by Baten Caswell; seconded by Tom, and motion carried 5-0 to ratify the recommendation for stipulated suspended expulsion for the remainder of the 2009-10 school year for student 01-0910, and that the Terms of Expulsion be fully implemented MOTION: It was moved by Baten Caswell; seconded by Tom, and motion carried 5-0 to ratify the recommendation for stipulated suspended expulsion for the remainder of the 2009-10 school year for student 02-0910, and that the Terms of Expulsion be fully implemented. Board Members’ Reports Townsend noted the City-School Liaison meeting would cover student mental health, the library bond, and technology at City and District libraries. Baten Caswell commended students and staff at Terman for their recent science fair. Closed Session The Board adjourned to closed session at 9:55 p.m. to complete business from earlier in the evening as noted above. Adjournment The Board reconvened in open session at 11:30 p.m. Mitchell announced the Board took no action. The meeting was adjourned at 11:30 p.m. ________________________________ Secretary to the Board Mitigation Monitoring and Reporting Program Gunn High School Master Plan 1 ESA / 209002 Mitigation Monitoring and Reporting Program April 2010 MITIGATION MONITORING AND REPORTING PROGRAM (MMRP) – GUNN HIGH SCHOOL MASTER PLAN Mitigation Measures Party Responsible for Implementing Mitigation Party Responsible for Monitoring Timing 1. Aesthetics No mitigation required. 2. Agricultural Resources No mitigation required. 3. Air Quality Mitigation Measure AIR-1: During future construction, PAUSD shall require the construction contractor to implement BAAQMD’s “basic” dust control procedures which are required for all construction sites of less than four acres and which would mitigate the potential impact to a less than significant level. Elements of the “basic” dust control program for project components that disturb more than four acres shall include, but not necessarily be limited to the following: Basic Control Measures • Water all active construction areas at least twice daily. Watering should be sufficient to prevent airborne dust from leaving the site. Increased watering frequency may be necessary whenever wind speeds exceed 15 miles per hour. Reclaimed water should be used whenever possible. • Cover all trucks hauling soil, sand, and other loose materials or require all trucks to maintain at least two feet of freeboard (i.e., the minimum required space between the top of the load and the top of the trailer). • Pave, apply water three times daily, or apply (non-toxic) soil stabilizers on all unpaved access roads, parking areas and staging areas at construction sites. • Sweep streets (with water sweepers using reclaimed water if possible) at the end of each day if visible soil material is carried onto adjacent paved roads. • Sweep streets daily (with water sweepers) if visible soil material is carried onto adjacent public streets. PAUSD/Construction Contractor PAUSD/Construction Contractor During construction, demolition, or ground-disturbing activities Mitigation Monitoring and Reporting Program MITIGATION MONITORING AND REPORTING PROGRAM (continued) Mitigation Measures Party Responsible for Implementing Mitigation Party Responsible for Monitoring Timing Gunn High School Master Plan 2 ESA / 209002 Mitigation Monitoring and Reporting Program April 2010 Mitigation Measure AIR-2: Building development plans resulting from the Master Plan shall include “green building” features to reduce energy consumption to the extent practicable. These measures may include: • Building design consistent with the Collaborative for High Performance Schools (CHPS). CHPS is a third party program that oversees the nation’s first green building rating program especially designed for K-12 schools. CHPS has published design guidelines and performance criteria specific to California schools. • Install efficient lighting and lighting control systems. Site and design buildings to take advantage of daylight. • Plant trees and vegetation near structures to shade buildings and reduce energy requirements for heating/cooling. • Preserve or replace onsite trees (that are removed due to development) as a means of providing carbon storage. • Install light-colored “cool” roofs and cool pavements. • Install energy efficient heating and cooling systems, appliances and equipment and control systems. • Install light emitting diodes (LEDs) for traffic, street and other outdoor lighting. • Install water efficient fixtures and appliances. PAUSD/Construction Contractor/Architect of Record PAUSD/Construction Contractor / Architect of Record During construction activities 4. Biological Resources Mitigation Measure BIO-1: PAUSD shall require its contractor(s) to install silt fence along the chain-link fence bordering the debris basin and wetland area on the west side of the campus. This would prevent any sensitive wildlife from entering active construction zones on the project site and will keep disturbed material, sediment, or hazardous materials from travelling into these waters. The fence shall be constructed of geotextile fabric with a minimum 3.5-inch overlap between panels. Fence panels shall be attached to the chain-link fence or to wooden fence posts, and sunken to a minimum of 6 inches below grade. PAUSD/Construction Contractor PAUSD/Construction Contractor Prior to construction, demolition, or ground-disturbing activities Mitigation Monitoring and Reporting Program MITIGATION MONITORING AND REPORTING PROGRAM (continued) Mitigation Measures Party Responsible for Implementing Mitigation Party Responsible for Monitoring Timing Gunn High School Master Plan 3 ESA / 209002 Mitigation Monitoring and Reporting Program April 2010 Mitigation Measure BIO-2: PAUSD shall require its contractor(s) to implement the following measures: • Prior to construction or demolition activities within 250 feet of trees/structures with at least a moderate potential to support special-status bats, a qualified biologist (i.e., a biologist holding a CDFG collection permit and a Memorandum of Understanding with the CDFG allowing the biologist to handle and collect bats) shall survey for bats. If no evidence of bats (i.e., visual or acoustic detection, guano, staining, strong odors) is present, no further mitigation is required. • If bats raising pups (also called a maternity colony) are identified within 250 feet of the project area during preconstruction surveys or project construction (typically April 15 through August 15), the PAUSD will create a no-disturbance buffer acceptable in size to the CDFG around the bat roosts. Bat roosts initiated within 250 feet of the project area after construction has already begun are presumed to be unaffected by project-related disturbance, and no buffer would be necessary. However, the “take” of individuals (e.g., direct mortality of individuals, or destruction of roosts while bats are present) is prohibited. • Trees or buildings with evidence of bat activity shall be removed during the time that is least likely to affect bats as determined by a qualified bat biologist (in general, roosts should not be removed if maternity bat roosts are present, typically April 15 – August 15, and roosts should not be removed if present bats are in torpor, typically when temperatures are less than 40 degrees Fahrenheit). Non-maternity bat roosts shall be removed by a qualified biologist, by either making the roost unsuitable for bats by opening the roost area to allow airflow through the cavity, or excluding the bats using one-way doors, funnels, or flaps. • All special-status bat roosts that are destroyed shall be replaced at a 1:1 ratio with a roost suitable for the displaced species. The roost shall be modified as necessary to provide a suitable roosting environment for the target bat species. PAUSD/Qualified Biologist PAUSD/Qualified Biologist Prior to construction, demolition, or ground-disturbing activities Mitigation Measure BIO-3: If construction or vegetation removal must be performed in the bird nesting season (February 1 through August 31), a qualified biologist shall be retained to survey the project area for nesting raptors and other birds and verify the presence or absence of nesting birds or raptors no more than 14 days prior to construction activities. If active nests are observed, buffer zones shall be established around trees/shrubs with nests, with a buffer size established by the qualified biologist through consultation with the appropriate regulatory agency (e.g., CDFG). Buffered zones shall be avoided during construction activities until young have fledged or the nest is otherwise abandoned. PAUSD/City of Palo Alto / Construction Contractor PAUSD/City of Palo Alto / Construction Contractor Prior to construction, demolition, or ground-disturbing activities Mitigation Monitoring and Reporting Program MITIGATION MONITORING AND REPORTING PROGRAM (continued) Mitigation Measures Party Responsible for Implementing Mitigation Party Responsible for Monitoring Timing Gunn High School Master Plan 4 ESA / 209002 Mitigation Monitoring and Reporting Program April 2010 Mitigation Measure BIO-4: PAUSD shall require its contractor(s) to implement the following measures: • Fulfill pre-construction requirements consistent with Section 2.15 of the City of Palo Alto Tree Technical Memo, including establishment of a tree protection and preservation plan; verification of tree protection; a pre-construction meeting with the City Arborist, community representative, and District Arborist to coordinate a tree replacement plan and protective fencing for retained protected or street trees; establishment of tree protection zones for retained trees; and trimming of any retained trees. • When in City grounds, obtain a tree removal permit for removal of any street trees in the project area by submitting the following to the City of Palo Alto: 1) Protected Tree Removal Application; 2) Application fees; and 3) Letter report from a certified arborist including tree species, location, size (DBH, height and crown spread), condition, and life expectancy and prognosis. • Obtain a permit from the City of Palo Alto Department of Public works for any construction activities occurring within the dripline of a street tree. • Remove no more than 25 percent of a protected tree’s canopy during pruning activities of retained trees, and remove no more than 25 percent of a protected tree’s root mass during construction activities. • Replace all removed street trees as specified by the City of Palo Alto’s Director of Planning and Community Environment and in conjunction with standards described in section 3.15-C in the City of Palo Alto Tree Technical Manual. PAUSD/City of Palo Alto / Construction Contractor PAUSD/City of Palo Alto / Construction Contractor Prior to construction, demolition, or ground-disturbing activities 5. Cultural Resources Mitigation Measure CUL-1: If previously unidentified cultural materials are unearthed during construction, work shall halt in that area until a qualified archaeologist can assess the significance of the find. Additional archaeological survey will be needed if project limits are extended beyond the present study limits. Prehistoric materials might include obsidian and chert flaked-stone tools (e.g., projectile points, knives, scrapers) or toolmaking debris; culturally darkened soil (“midden”) containing heat-affected rocks, artifacts, or shellfish remains; and stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered stone tools, such as hammerstones and pitted stones. Historic-era materials might include stone, concrete, or adobe footings and walls; filled wells or privies; and deposits of metal, glass, and/or ceramic refuse. If any find is determined to be significant, the project proponent and the archaeologist will meet to determine the appropriate avoidance measures. If the resources cannot be avoided they must be evaluated for their eligibility to the California Register of Historical Resources. PAUSD/Qualified Archaeologist PAUSD/Qualified Archaeologist During construction or ground-disturbing activities Mitigation Monitoring and Reporting Program MITIGATION MONITORING AND REPORTING PROGRAM (continued) Mitigation Measures Party Responsible for Implementing Mitigation Party Responsible for Monitoring Timing Gunn High School Master Plan 5 ESA / 209002 Mitigation Monitoring and Reporting Program April 2010 Mitigation Measure CUL-2: Prior to the start of any subsurface excavations, all construction forepersons and field supervisors shall receive training by a qualified professional paleontologist, as defined by the SVP (1995), who is experienced in teaching non-specialists, to ensure they can recognize fossil materials and will follow proper notification procedures in the event any are uncovered during construction. Procedures to be conveyed to workers include halting construction within 50 feet of any potential fossil find and notifying a qualified paleontologist, who will evaluate its significance. Training on paleontological resources will also be provided to all other construction workers, but may involve using a videotape of the initial training and/or written materials rather than in-person training by a paleontologist. If a fossil is determined to be significant and avoidance is not feasible, the paleontologist will develop and implement an excavation and salvage plan in accordance with SVP standards (SVP, 1995; SVP, 1996). PAUSD/Construction Contractor / or Qualified Paleontologist PAUSD/ or Qualified Paleontologist During construction or ground-disturbing activities Mitigation Measure CUL-3: If human remains are encountered unexpectedly during construction excavation and grading activities, State Health and Safety Code Section 7050.5 requires that no further disturbance shall occur until the County Coroner has made the necessary findings as to origin and disposition pursuant to PRC Section 5097.98. If the remains are determined to be of Native American descent, the coroner has 48 hours to notify the Native American Heritage Commission (NAHC). The NAHC will then identify the person(s) thought to be the Most Likely Descendent of the deceased Native American, who will then help determine what course of action should be taken in dealing with the remains. PAUSD/Qualified Archaeologist PAUSD/Qualified Archaeologist/NAHC/ County Coroner During construction or ground-disturbing activities 6. Geology and Soils Mitigation Measure GEO-1: The proposed construction shall comply with site specific recommendations made in design level geotechnical investigations by the District’s geotechnical engineers. These recommendations shall be designed to mitigate geologic hazards and shall become part of the project. The final seismic considerations shall be submitted to and approved of by the Division of the State Architect (DSA), prior to project commencement, to ensure compliance with the most current California seismic building codes. PAUSD/Geotechnical Engineer/ Division of the State Architect PAUSD/Geotechnical Engineer/ Division of the State Architect Prior to final plan check review Mitigation Monitoring and Reporting Program MITIGATION MONITORING AND REPORTING PROGRAM (continued) Mitigation Measures Party Responsible for Implementing Mitigation Party Responsible for Monitoring Timing Gunn High School Master Plan 6 ESA / 209002 Mitigation Monitoring and Reporting Program April 2010 7. Hazards and Hazardous Materials Mitigation Measure HAZ-1: The PAUSD shall require its contractor(s) to use construction best management practices typically implemented as part of its construction activities to minimize the potential adverse effect of the project to groundwater and soils from construction activities. These shall include the following: • Follow manufacturer’s recommendations on the use, storage, and disposal of chemical products used in construction; • Avoid overtopping construction equipment fuel tanks; • During routine maintenance of construction equipment, properly contain and remove grease and oils; and • Properly dispose of discarded containers of fuels and other chemicals. PAUSD/Construction Contractor PAUSD/Construction Contractor During construction, demolition, or ground-disturbing activities 8. Hydrology and Water Quality Mitigation Measure HYD-1: The PAUSD shall apply for coverage under the State General Construction Permit to comply with federal NPDES regulations. The NPDES and State General Construction Permit require a project applicant to develop and implement a Storm Water Pollution Prevention Plan (SWPPP) that identifies appropriate construction BMPs in order to minimize potential sedimentation or contamination of storm water runoff generated from the project site. BMPs could include, without limitation, silt fences, gravel or sand bag berms, storm drain inlet protection, soil stockpile protection, preservation of existing vegetation, use of straw mulch, dust control, and others. The SWPPP shall also include any additional measures identified in the Santa Clara Valley Urban Runoff Pollution Prevention Program, as required. The District shall adhere to the identified BMPs as well as the waste discharge and stormwater requirements outlined in the permit. PAUSD/Construction Contractor PAUSD/Construction Contractor Prior to construction, demolition, or ground-disturbing activities 9. Land Use and Land Use Planning No mitigation required. 10. Mineral Resources No mitigation required. 11. Noise Mitigation Measure NOI-1: The PAUSD shall collaborate with a certified acoustical engineer to assist in design and verification of noise insulation measures for the classrooms proposed under the Master Plan. PAUSD/Architect of Record/Certified Acoustical Engineer PAUSD/Architect of Record/Certified Acoustical Engineer Prior to final plan check review Mitigation Monitoring and Reporting Program MITIGATION MONITORING AND REPORTING PROGRAM (continued) Mitigation Measures Party Responsible for Implementing Mitigation Party Responsible for Monitoring Timing Gunn High School Master Plan 7 ESA / 209002 Mitigation Monitoring and Reporting Program April 2010 Mitigation Measure NOI-2: To reduce potential structural damage impacts from pile driving (if necessary), PAUSD shall employ the following measures: • Verify the construction method of adjacent buildings of concern. If buildings are constructed of reinforced concrete, steel or timber without plaster, these structures can withstand vibrations of up to 0.5 PPV without structural damage. If located at a distance of at least 30 feet from pile locations potential structural impacts would be considered less than significant. • Use alternative driving methods. If adjacent buildings are non-engineered timber and masonry buildings or concrete and masonry buildings with no plaster then alternative driving methods may be employed to reduce vibration impacts to a less than significant level. Use of a sonic (or vibratory) pile driver can result in typical vibration levels being reduced from 0.644 feet per second to 0.170 feet per second (U.S. DOT, 2006). Alternatively pile holes may be pre-drilled to reduce vibrations. PAUSD/Construction Contractor PAUSD/Construction Contractor Prior to construction, demolition, or ground-disturbing activities Mitigation Measure NOI-3: To reduce the potential for annoyance impacts from pile driving (if necessary) at occupied adjacent classrooms, PAUSD shall have the contractor schedule any pile driving activities during the summer or winter breaks or other times when classrooms within a 150-foot radius are unoccupied. Additionally, any required pile driving should be restricted to daytime hours. PAUSD/Construction Contractor PAUSD/Construction Contractor Prior to construction, demolition, or ground-disturbing activities Mitigation Monitoring and Reporting Program MITIGATION MONITORING AND REPORTING PROGRAM (continued) Mitigation Measures Party Responsible for Implementing Mitigation Party Responsible for Monitoring Timing Gunn High School Master Plan 8 ESA / 209002 Mitigation Monitoring and Reporting Program April 2010 Mitigation Measure NOI-4: Construction contractors shall be required to follow appropriate time restrictions consistent with the City’s Municipal Code. Specifically, it is recommended that contractors be required to limit noisy construction activities, including related on-road truck use in the immediate project vicinity, to the hours of 8:00 a.m. to 6:00 p.m. on weekdays. No construction shall be allowed on Sundays and legal holidays. In addition, although not required, it is recommended that the use of impact tools (e.g., hoe-ram, jackhammers, pile driver) be limited to the hours of 8:00 a.m. to 5:00 p.m. Construction Related Noise Attenuation Measures • Notify adjacent residents of any planned pile-driving activities, as well as any particularly noisy activity that would affect them for a given short period of time so they can plan their activities accordingly. • Ensure that all diesel equipment is equipped with effective mufflers, in accordance with the manufacturer’s specifications, and that the mufflers are in good repair. • Use temporary noise barriers along the perimeter of the sites, to the maximum extent feasible during demolition and grading activities. • Locate stationary noise-generating equipment such as generators and compressors as far as possible from the nearest residential property line. • Locate any construction trailers or offices as far from the adjacent residential uses as possible. PAUSD/Construction Contractor PAUSD/Construction Contractor/City of Palo Alto During construction, demolition, or ground-disturbing activities 12. Population and Housing No mitigation required. 13. Public Services No mitigation required. 14. Recreation No mitigation required. 15. Transportation and Traffic Mitigation Measure TRANS-1: PAUSD shall coordinate a voluntary ride-sharing program for the Los Alto Hills Community. PAUSD/Gunn High School PAUSD/ Gunn High School Yearly Mitigation Monitoring and Reporting Program MITIGATION MONITORING AND REPORTING PROGRAM (continued) Mitigation Measures Party Responsible for Implementing Mitigation Party Responsible for Monitoring Timing Gunn High School Master Plan 9 ESA / 209002 Mitigation Monitoring and Reporting Program April 2010 Mitigation Measure TRANS-2: PAUSD shall require Gunn High School to continue the existing TDM program. The TDM program shall include the following: • No net increase in the number of onsite parking spaces relative to 2009 (461 parking spaces); • No increase in student parking permits relative to 2009; • Direct bicycle access via Georgia and Los Robles versus Arastradero Road to remove bicycle traffic from the main driveway to improve existing intersection level of service; • Locate bicycle racks in convenient areas to facilitate ease of queues, safety, and accessibility; • Provide maps at the start of the school year illustrating preferred bicycle access routes; • Extend arrivals over a longer period of time by getting students to school before the peak rush. Consider providing study areas or breakfast incentives or similar to encourage student to arrive a little before school starts. • Increase the number of bike racks by at least 15.9 percent. Each building design shall be coordinated to include additional bike racks near the buildings. PAUSD shall implement the following measure when the student population increases by more than 51 students or 24 vehicle trips (annual driveway vehicle counts shall be taken as part of monitoring): • Implement alternative means of class scheduling with the goal of expanding the peak arrival times to the campus. Examples of alternatives include adding a zero, eighth period, offering expanded online courses, or altering school start times. PAUSD / Gunn High School PAUSD / Gunn High School On-going through buildout of the Master Plan. Annual traffic count measurements of the Gunn driveway entrance (both inbound and outbound) during the 4th week in April for five consecutive school days. Mitigation Measure TRAN-3: PAUSD shall incorporate the following measures into the project site’s final internal circulation design: • The drop-off lane shall be designed to accommodate queuing onsite during the morning commute period without blocking driveways or the Arastradero Road entrance; • Internal driveway approaches shall be painted red to prohibit stopping and maintain sight-distance; • Internal roadway curbs shall be painted red to prohibit stopping; • Internal circulation would use a curbside drop-off zone, which shall be painted white and striped with a lane to allow vehicles to pass on the left-side of loading/unloading vehicles; • The loading zone shall be marked with signs/pavement markings that make vehicles aware of pedestrian and loading activities; • Signs and pavement markings (i.e., painted arrows) shall designate directional flow through the parking lot. PAUSD/Architect of Record PAUSD/Architect of Record During the Parking and Drop-Off Design period. Mitigation Monitoring and Reporting Program MITIGATION MONITORING AND REPORTING PROGRAM (continued) Mitigation Measures Party Responsible for Implementing Mitigation Party Responsible for Monitoring Timing Gunn High School Master Plan 10 ESA / 209002 Mitigation Monitoring and Reporting Program April 2010 Mitigation Measure TRAN-4: PAUSD shall integrate the following measures to reduce potential queuing impacts: • Increase notification to parents and students that discuss onsite circulation patterns and designated parking areas, and • Encourage drivers with disabled passengers that would require longer dwell times (i.e., wheelchair users) to use ADA parking spaces for loading/unload. PAUSD / Gunn High School PAUSD / Gunn High School Yearly 16. Utilities and Service Systems No mitigation required.