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Planning & Design Meetings Response to CEQA Questions/Comments on the Draft Initial Study 1/29/2010 - Minutes 350 Frank H. Ogawa Plaza Suite 300 Oakland, CA 94612 510.839.5066 phone 510.839.5825 fax www.esassoc.com memorandum date January 29, 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 Palo Alto 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 Palo Alto High School Master Plan (SCH# 2009102023). 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 Palo Alto 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 on studies of over 20 sites throughout the US and are generally considered to best available on an overall basis. However, the rates are qualified to the extent that more research is needed relative to us of school 2 busing, transit and whether the schools were private or public. This information was not recorded in ITE manual other than to state the percentage of students transported by transit and/or bus varied considerably. At the Palo Alto High School sites there is different sort of variation which occurs. At both Paly and Gunn a high percentage of students 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 bicycle commute was reduced by 200 plus. This phenomenon results in proportional increase in auto commuting, typically in the form of drop-offs as a result of parking at the schools being controlled with permits. Students cannot simply drive themselves on a rainy day. As such, the survey of drop-offs (and inbound and outbound trip) showed a significantly increased number relative to what regularly occurs on a sunny day should be interpreted as more of a worst case estimate. 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 Paly. The student population is forecast to increase from a level of 1,773 for the 2008/2009 year to 2,291 in 2018 or by 29.22% Using this worst case type estimate which assumes Building D with District offices together with all other district uses having access from the Churchill driveway remain yields a total of approximately 260 new trips when bicycle commuting is at its lowest point. As such Table 7 of the Initial Study as been revised as follows: TABLE 7 AM PEAK HOUR TRIP FORECAST Existing Student Population Forecast 2018 Student Population Net Increase in Tripsa Net Inbound/ Outbound Trips 1,773 2,291 260 155/105 a 29.29%increase relative to existing driveway vehicle counts. SOURCE: Wilson, 2009, 2010; Intersection Levels of Service Comment states that study intersections are not quantified in terms of additional delay attributable to the increased traffic. Commenter also states there is no comparison between cumulative with project and cumulative without project. Response: Table 8 of the Initial Study presents the project’s contribution to delay at the study intersection under the Existing plus Project scenario (under Project) in seconds of delay at the intersection per standard traffic engineering practices. This is directly applicable to Existing Conditions only but can serve as a broad estimate of the project related increases in delay at the study intersections under cumulative conditions. The key issue is all intersections are forecast to continue to operate acceptably under Cumulative Conditions regardless of any increase in delay. 3 As noted in the Initial Study discussion, with the addition of project-generated traffic, the study intersections would continue to operate at acceptable levels of service during the a.m. peak hour, and therefore, the project would have a less than significant impact on intersection delay. Likewise, intersection delay analysis under cumulative conditions, found that with project related trips, the intersections would operate at acceptable levels of service, also, having a less than significant impact. However, because the trip generation analysis was revised per public comments intersection level of service has also been revised. As such Table 8 of the Initial Study as been revised as follows: TABLE 8 EXISTING AND FUTURE LEVELS OF SERVICE (LOS) AND AVERAGE VEHICLE DELAY (seconds/vehicles)a Control Existing Existing + Project Cumulative w/Project Intersection Typeb Delayc LOS Delayc LOS Delayc LOS AM Peak Hour El Camino Real and Embarcadero Road Signal 43.9 D 44.2 D 48.6 D Embarcadero Road and School Driveway Signal 9.4 A 10.0 B+ 10.7 B+ El Camino Real and Churchill Avenue Signal 22.8 C+ 23.5 C 23.8 C Churchill Avenue and Alma Street Signal 35.0 C- 35.6 D+ 42.9 D Churchill Avenue and School Driveway TWSC a LOS calculations performed for using TRAFFIX and the 2000 Highway Capacity Manual operations analysis methodology. b Type of control, Signalized or TWSC = Two-way stop (sign) controlled c Represents overall intersection delay of intersections SOURCE: Wilson (2009) As noted in the Initial Study, all studied intersections are currently operating at acceptable levels. With the addition of the project generated traffic, the Cumulative Conditions, the delay would increase at the studied intersections, but would continue to operate at an acceptable level during the a.m peak hour. Therefore, the project’s impact to Cumulative Conditions would be less than significant. Traffic Demand Management (TDM) Policies and Implementation Comment states the current and proposed TDM plans are 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 Response: No specific traffic related impacts requiring mitigation were identified at this school site. Mitigation Measure TRANS-2, which addresses onsite circulation, includes the following revisions which identify TDM policies which would be implemented by the school as part of an overall traffic reduction program. These could be implemented, and monitored, when the Level of Services becomes a LOS F: 4 • Investigate and provide additional Embarcadero Shuttles to Palo Alto High School during the morning peak hour. • Provide 250 VTA Eco Passes to students free of charge. This is an estimated charge of $9,000 to the districts per year. • Coordinate a voluntary ride-sharing program. • Increase the number of bike racks in campus to encourage less driving. In addition, the following TDM efforts would be included as part of the Master Plan • Increase of bike racks. This also includes additional bike racks near the Media Arts Center, close to the Cal-Train entrance. • Parking re-stripping plan 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. Response: Mitigation Measure TRANS-2, which addresses onsite circulation, includes the following revisions which identify when the TDM policies would be implemented and outlines additional policies that would be added to the current program: • Provide additional staff at the Churchill and School Driveway entrance. 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 22 and the Embarcadero Shuttle, currently provide service in the vicinity of the project. Review of current operations of Route 22 with VTA Staff indicates there is excess capacity available. The buses are articulated with a seating capacity of 55 max and standing capacity of about 80 and run on 12 minute headways during peak periods. Since the school is close to the end of the line in Palo Alto, the passenger load in that area is not very high (as compared to downtown San Jose, for example). Approximately 7 to 10 students currently use Route 22. The proposed project which would increase student population by 29.22 percent would increase ridership on these two lines. Both lines have sufficient capacity in accommodate new patrons related to the proposed project. Further, as noted under the TDM response above and under revised Mitigation Measure TRANS-2, the PAUSD would provide 250 VTA Eco Passes to student free of charge. These additional trips can be accommodated under the existing capacity of the transit service. 5 Mode Conflicts Comment indicates intersections with potential conflicts between vehicles and bicycles/pedestrians were not discussed: Churchill Avenue/Casteilleja Avenue and Embarcadero Road/school entrance. Response: Intersections selected for analysis were chosen as those adjacent to the school site and most affected by potential project trip generation and trip distribution. Intersections selected for analysis represent those with the potential to have significant operational impacts due to the increase in the student population at the site. However, as presented in Table 8, as revised in this memorandum, the project is forecast to have a less than significant impact on study intersections. The following intersections were analyzed in the Initial Study: • El Camino Real and Embarcadero Road • Embarcadero Road and School Driveway • El Camino Real and Churchill Avenue • Churchill Avenue and Alma Street • Churchill Avenue and School Driveway Relative to Embarcadero Road and the school entrance, the city is signalizing the intersection which will further reduce conflicts. In addition, currently there is a separate signalized pedestrian crossing which will remain. Bicycle and pedestrian access to the campus was discussed under Section 15, Transportation, checklist item d. As noted in the discussion, the increase in students, and thus pedestrians and cyclists to the campus would use existing facilities and although there would be an increase in the potential for interaction between vehicles and these travel modes, there are no apparent safety concerns between the increase in students and the existing facilities. In addition, the traffic and circulation project, as part of the Master Plan, will address: • Bike path improvements • Embarcadero Road and School Entrance circulation • Churchill Avenue and School Driveway circulation • Bike access improvements at the Churchill entrance High Speed Rail Comment mentions impact of possible high speed rail adjacent to high school campus. Response: At this time it is difficult to determine what the impact of the proposed high-speed rail would be as there is no current program or design. As this is an existing school campus, and the proposed project would increase student population in campus core, the high speed-rail would have similar impacts to that of the existing Caltrain service. The impacts of a high speed rail line related to noise would be similar to the conditions outlined in the Initial Study in Section 11, Noise. It should be noted that PAUSD is following the proposed project, and will assure that potential safety, noise, and visual impacts related to the rail line would be fully mitigated along the school boundary. 6 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 Palo Alto 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. Drainage and Stormwater Comment notes existing drainage problems have not been addressed and that a landscape architect has not yet generated a proposal to keep stormwater on the campus; requests more specific details. Response: As described in the project description of the Initial Study, the Palo Alto 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. Aesthetics Landscape Master Plan. Comment states that the visual impact of the proposed theater on the Haymarket and Tower buildings is not adequately addressed, and requests that renderings of the new theater should be made available. Response: As described in the project description of the Initial Study, the Palo Alto High School Master Plan is a planning level document and as such no renderings, massing studies, or landscaping plans have been prepared. A landscape master plan is currently in programming for conceptual design. 7 Greenhouse Gases Greenhouse Gases and Land Use Comment states the greenhouse gas analysis does not link with the land use discussion. Response: Potential impacts regarding the emissions of greenhouse gases are discussed at length in Section 3, Air Quality of the Initial Study. The proposed project, the Palo Alto High School Master Plan, would not result in any significant impacts due to emissions of greenhouse gases through implementation of Mitigation Measure AIR-2, which identifies several measures designed to reduce the impact to a less than significant level. 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. Response: The trip generation estimates were revised to address public comments and the net new morning vehicle trips were increased by approximately 29 percent. Page 34 of the Initial Study, is updated as follows to reflect the increase in vehicle trips: 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 886 1,143 net daily vehicle trips. Increased vehicle trips would lead to a small increase in ROG (approximately 3.9 4.8 pounds per day), NOx (approximately 3.7 4.7 pounds per day) and PM-10 (approximately 11.5 14.8 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 0.08 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. The modified trip generation would also increase noise, but as noted in Table 2 of Section 11, Noise of the Initial Study, Table 2, roadway traffic noise increases resulting from the proposed project would be less than 1 dBA. Generally, even in a laboratory environment, increases of less than 1 dBA are too small to be detected by the human ear (Caltrans, 1998). Consequently, the increased trip generation rates would not increase roadway noise that would result in a significant impact. Table 2 of the Initial Study is updated to reflect the increase vehicle trips as follows: 8 TABLE 2 TRAFFIC NOISE INCREASES IN ROADSIDE LEQ Road Segment Existing Existing + Project Contribution of Proposed Project Modeled Cumulative Year 2018 with Proposed Project Modeled Cumulative Incremental Increase 2009 vs 2018 with Proposed Project) 1. Embarcadero Road (between Kingsley Avenue and Paly Driveway) 62.9 63.4 0.5 64.5 1.6 2. El Camino Real (between Churchill Avenue and Embarcadero Road) 69.3 69.5 0.2 70.2 0.9 3. Churchill Avenue (between Paly Driveway and El Camino Real) 59.8 60.2 0.4 60.3 0.5 4. Churchill Avenue (between Emerson Street and Alma Street) 57.1 57.4 0.3 59.6 2.5 5 Alma Street (between Kellogg Avenue and Churchill Avenue) 68.7 68.9 0.2 67.6 - 1.1b 6. Alma Street (between Coleridge Avenue and Churchill Avenue) 69.4 69.6 0.2 68.8 - 0.6b a These listed values represent the modeled existing noise levels from mobile sources along specified roadways and are based on traffic data. Road center to receptor distance is assumed to be 50 feet. The speed limit for these segments is assumed to be 25 miles per hour except foe El Camino Real and Alma Streets for which the assumed speed was 35 miles per hour. b A decrease in noise is predicted at these segments because traffic projections predict a decrease in northbound roadway volumes by 2018. SOURCE: ESA, 2010. Land Use 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 24 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 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 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:Friday, October 30, 2009 2:39 PM To:Lesley Lowe; Cory Barringhaus Subject:FW: Comments on Draft Mitigated Negative Declaration for Palo AltoHigh School Master Plan For your review as well, Aimee 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 -----Original Message----- From: Ron Smith [mailto:rsmith@pausd.org] Sent: Friday, October 30, 2009 2:38 PM To: Aimee Lopez Subject: FW: Comments on Draft Mitigated Negative Declaration for Palo Alto High School Master Plan Mo stuff for you! Happy Friday R -----Original Message----- From: Sue Ma [mailto:SMa@waterboards.ca.gov] Sent: Friday, October 30, 2009 2:24 PM To: Ron Smith; Tom Hodges Cc: Joe Teresi; Ken Torke; Phil Bobel; Brian Wines; Dale Bowyer Subject: Comments on Draft Mitigated Negative Declaration for Palo Alto High School Master Plan Greetings: Water Board staff has reviewed the Draft Mitigated Negative Declaration for the Palo Alto High School Master Plan project located at 50 Embarcadero Road, southeast of the intersection of Embarcadero Road and El Camino Real in the city of Palo Alto. The proposed project features construction of new buildings and other structures, including a new two-story, 27-room classroom building and a two-story media 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. 2 Please call or email me if you have any questions. Sue Ma Water Resources Control Engineer 1515 Clay Street, Suite 1400 Oakland, CA 94612 510-622-2386 FAX 510-622-2460 SMa@waterboards.ca.gov 1524 Channing Ave. Palo Alto, CA 94303 November 17, 2009 Tom Hodges PAUSD 25 Churchill Ave., Building D Palo Alto, CA 94306 Dear Mr. Hodges, I would like to comment on several sections of the Draft Initial Study/Mitigated Negative Declaration that was prepared for 50 Embarcadero Rd, Palo Alto High School, pursuant to the California Environmental Quality Act (CEQA). Aesthetics. This section does not adequately address the visual impact of the proposed theater on the historic Haymarket and Tower Buildings and the large open expanse of trees (arboretum) that now exists at the Embarcadero entrance. Based on the orientation of the Tower Building, Paly’s main entrance may appear to be on El Camino Real. However, the official address of the school is 50 Embarcadero Rd. In addition, a far greater number of visitors and students enter the campus through the Embarcadero driveway and/or crosswalk entrances than through the El Camino entrance. The Haymarket Theater and the Tower Building have always been and should remain the central feature of Paly’s main entrance. Traditionally, these buildings have been nestled within an attractive landscape that includes trees, plants and lawn, or in other words, a tranquil setting that accentuates the buildings’ architectural beauty. A landscaping firm has now been hired (as of October 2009) by the Palo Alto Unified School to create a landscape master plan, a central focus of which will be to further beautify and enhance the school’s entrance, and in particular, these buildings and the nature that surrounds them. The conclusions of the reviewer are based on incomplete information and therefore cannot be considered conclusive. Two major pieces of information are lacking. First of all, the landscape architect has not yet adequately studied and created designs for the main entrance. Landscape designs of the main entrance that include and do not include the proposed theater have yet to be presented to the public. It is essential that the public and the reviewer be given both types of designs to be able to adequately evaluate the true aesthetic and environmental impact of the proposed new theater on the historic buildings and the character of the main entrance. In conjunction with the landscape designs of the main entrance, the public and the reviewer needs to be able to see and evaluate one or more potential architectural renderings of the new theater. The reviewer claims that the new theater will not significantly impact the Haymarket or Tower Building, because it will lie 200 ft. from the theater. Merely citing a particular distance, in this case 200 ft, is not enough conclude that there will be no visual impact on the historic structures. Again, the true style, orientation, and size of the theater need to be understood by both the public and reviewer before an adequate statement can be made regarding their environmental impact. On a separate but related topic, the visual impact of the proposed new theater on the student, staff, and visitor experiences of entering or leaving the campus via the driveway and crosswalk entrances were not discussed in this report. Currently students are treated to a wide-open vista of trees, which extends as far as the Stanford arboretum, when they enter the campus via the crosswalk entrance. This vista will be significantly diminished if the proposed new theater is constructed. Similarly the wide vista of treetops that includes trees near the railroad tracks and across to Town and Country village, will be significantly diminished by visitors, staff and students entering the campus through the driveway entrance. If the new theater is built, the main entrance will forevermore have the feel of a more constricted and confined space. The arboretum, the entire collection of trees at the entrance that is a learning space and tranquil area for students to walk through and relax, will be diminished by the construction of a theater in the currently proposed location. This arboretum has space for at least 200 trees. Currently, 25 different species of trees grow in this part of campus. At its present size, future generations of students and staff will have room to create native plant gardens and ecological laboratories. There is space for sculptures and other student art. In reducing this large expanse of open space and trees, which is one of the largest and most beautiful urban parking areas in the City of Palo Alto, both the community at large and the student body will lose a valuable resource. Hydrology. The report does not adequately discuss the difficult problems with drainage on the Paly campus and the limits of the City of Palo Alto’s storm sewer system. A serious problem with the on-going construction at Paly is the net increase in impervious or nearly impervious surface due to all of the proposed and completed projects. Here is a list of these projects with their approximate dates of completion: a) 2004- Science building completed as a large ONE-story building on the west side of the quad. This building could have been built as two-story building with a much smaller footprint. b) Summer 2007 - quarter acre at the El Camino/Embarcadero entrance paved over for (rarely used) parking c) About 2008 - Football field covered with synthetic (nearly impermeable) turf d) Summer 2009 - Three large palm trees and row of mature healthy Eucalyptus trees were removed between Tower building and El Camino field. Replaced by about 6-7 large black poles that will hold a giant net. e) Expansion of the Embarcadero entrance - loss of a mature sycamore. f) Fall 2009 - El Camino field covered with synthetic turf. g) 2011- Classroom building will replace portables that were on land that was once a large beautiful lawn h) 2011-Media-Arts building will replace portables on space that was once a natural area i) 2012- New Theater will replace land that holds or could hold 15 mature trees and many plants. j) 2013- A new Fitness Center will be built and cover a significant portion of open space between the old gym and the new gym. k) After 2018- The Student Center will be expanded covering more open space between the current student center and the El Camino Field. Because Palo Alto’s storm sewer has limited capacity, it is essential that stormwater be retained on campus. However, the landscape architect has not generated a proposal for how to keep stormwater on campus. Before stating that the projects will have a less than significant impact on stormwater runoff, the reviewer and the public need to know more specifics of how this retention will be achieved. Mandatory Findings of Significance. The land losses listed above affect more than simply hydrology. They result in less nature for students to enjoy during the course of their days on campus. Future generations will have less (if any) open space on which to build. There will be less room for outdoor educational activities such as a native plant garden, compost pile, an organic garden, or various outdoor classrooms. These environmental impacts are given short shrift or not mentioned at all in the report. But they do have a substantial effect on the quality of life for students and staff on the campus. They also give the community less flexibility to deal with further growth in its student population. Climate change impacts. Climate change is discussed under air quality in the report. However, this is not tied into the land use section of the report. To reduce the impact of any project on climate change, an essential first step is to study how best to use the land. How can the buildings and land be best used to make the lowest impact on greenhouse gas emissions? This was niether discussed in the report nor has it been adequately explored or addressed by the district in a transparent manner during their planning process. There are alternative designs for the master plan that would have less of an impact on greenhouse gas emissions. The district has failed to prepare and present these plans to the community for evaluation and comparison to the current plan. Thank you for taking the time to prepare the report and to read these comments. Please keep me apprised as the CEQA process moves forward. Best regards, Kirsten Essenmacher Lesley Lowe From: Aimee Lopez [alopez@ocmi.com] Sent: Thursday, November 19, 2009 8:50 AM To: Lesley Lowe; Cory Barringhaus Cc: 'John Wilson' Subject: FW: CEQA Comments Page 1 of 3 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: Thursday, November 19, 2009 6:38 AM To: Aimee Lopez Subject: Fw: CEQA Comments From: candersonb@aol.com <candersonb@aol.com> To: thodges@pausd.org <thodges@pausd.org> Cc: jberkson@pausd.org <jberkson@pausd.org>; rgolton@pausd.org <rgolton@pausd.org>; cycampen@pacbell.net <cycampen@pacbell.net> Sent: Wed Nov 18 23:12:29 2009 Subject: CEQA Comments Good Evening, I would like to submit the following comments in regards to the Palo Alto High School Master Plan, CEQA specifically related to the Transportation/Traffic section. TRANSPORTATION/TRAFFIC Bike cages are generally located at three points in the central area of the campus, including near the gym, near the science building, and near the student center. There is currently one bike cage near the gym, bike racks near the science building and bike racks near the Haymarket Theatre/Arts Building. Approximately 25-30+ students lock their bikes to the fence along the bike path that runs alongside the Cal Train tracks. It would be helpful if the CEQA document specified how many additional bike parking spaces are required to accommodate growth. Bicycle access to the high school would increase as student population increases. Assuming the same rate of bicycle use as observed in the March 2009 counts, the projected number of cyclists at buildout of the Master Plan would be approximately 540. The high school would continue to encourage bicycling to campus as part of their Transportation Demand Management program, and thus would provide adequate and secure bicycle parking, in the form of bicycle cages, at convenient and commute entrances. Their counts seem low and they acknowledged that the PTSA counts were 27% higher (520 vs. 410) as the counts took place during a warmer month. Why weren't these higher numbers used to estimate future needs. They also refer to a TDM program that is run with some variability by volunteers - a PTSA Traffic Safety Representative and members of Paly's Green Team. Is PAUSD planning to organize a program with dedicated staff to insure sustainability? Mitigation Measure TRAN-2: PAUSD shall integrate the following measures to reduce potential queuing impacts: • Circulate informational flyers to parents and students that discuss on-site circulation patterns and designated parking areas; • Encourage drivers with disabled passengers that would require longer dwell times (i.e., wheelchair users) to use ADA parking spaces for loading/unload; • Use staff to monitor and direct on-site traffic during peak drop-off/pick- up times both before and after school (i.e., 7:45 a.m. to 8:00 a.m.). I would question the effectiveness of informational flyers and the use of staff to monitor and direct on-site traffic. Funding for additional staff resources might be necessary to accomplish this. PTA volunteers CANNOT direct traffic. Our insurance policy explicitly declares that we are not covered for directing traffic. With implementation of the above mitigation measures, there would be no apparent circulation design features that would create a traffic safety hazard or significantly increase the potential for conflicts between vehicles, pedestrians and bicycles. There are two areas that have potential for conflict between vehicles and bicycles: Churchill at the Castilleja driveway and possibly along Embarcadero near the school entrance. With no stop signs on Churchill, bicycles and vehicles make right turns into the school driveway at the same time in the AM. Bicycles make a right turn from the bike lane on Churchill to the street/driveway at Castilleja. No bike lanes exist along the driveway. During the PM, bikes exit the school along the bike/pedestrian path, turn left and travel the wrong way on Churchill. Bikes cross at Alma and eventually cross Churchill (usually mid block). Bikes use the bike/pedestrian path because there is so much outbound traffic on Churchill making the crosswalk at Castilleja difficult to use. The high school has an existing parking demand management program which limits student driving to campus though permits. The program is enforced through cooperation with the City police, which uses parking enforcement (tickets) to ensure adherence to the program. Paid parking permits are distributed to eligible students. The carpooling program was eliminated last year by Paly staff because it was difficult to monitor. At present, Page 2 of 3 1/29/2010 the TDM program at Paly is comprised of bike/ped encouragement events that are organized by the PTSA Traffic Safety Rep and the Green Team. Additionally, the Traffic Safety Rep provides advocacy support of engineering improvements to campus and school routes that support alternative modes. Students are encouraged to use the Palo Alto Shuttle. Many do. (Shuttle funding may be in jeopardy with proposed Tier II CPA budget cuts to be considered by City Council Finance Committee in December 2009). The Paly Green Team supports/promotes bicycling/walking/pubic transit as one of their programs, however; there is no group (student/teacher/parent) dedicated to a TDM program at Paly. Thank you for your consideration of the above comments. Best regards, Carol Anderson PTSA Traffic Safety Representative Palo Alto High School Page 3 of 3 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