Planning & Design Meetings Scoping Comments 4/6/2009 - ReportPALO ALTO UNIFIED SCHOOL DISTRICT
25 Churchill Avenue • Palo Alto, CA 94306
Telephone: (650) 329.3?'7 • FAy: (650) 321.3810
OFFICE OF THE SUPERINTENDENT
April 6, 2009
Dan Leavitt, Deputy Director
California High Speed Rail Authority
925 L Street, Suite 1425
Sacramento, CA 95814
RE: Palo Alto Unified School District Scoping Comments for the California High Speed
Rail Authority's San Francisco To San Jose High Speed Train Environmental Impact
Report/Environmental Impact Statement
Dear Mr. Leavitt,
Thank you for the opportunity to comment on the California High Speed Rail Authority's
(CAHSRA) San Francisco to San Jose High Speed Train (HST) Environmental Impact
Report/Environmental Impact Statement (EIR/EIS) process. The proposed HST would be
located along 3.8 miles of the Caltrain right-of-way through Palo Alto along the Caltrain
tracks, adjacent to the Palo Alto High School campus. It is important that the HST project
fully address all potential impacts to Palo Alto Unified School District (PAUSD) students,
employees and facilities, in particular those of Palo Alto High School.
Palo Alto High School
Palo Alto High School is located at 50 Embarcadero Road at El Camino Real. The school
site is bounded by EI Camino Real on the west, Embarcadero Road on the north, Churchill
Avenue on the south, and Caltrain tracks and right-of-way on the east. Total 2008-09 school
year enrollment is 1,755 students. Student enrollment on the campus is projected to increase
to approximately 2,300 students by year 2017. Approximately 180 full-time staff and
employees occupy the campus.
Two classroom buildings (Social Studies and World Languages) and a series of portable
classrooms are located between 60 and 150 feet from the Caltrain right-of-way at the
northeastern end of the campus. These buildings are buffered by paved areas used for vehicle
parking, landscaping, and the paved bike path. A school district maintenance building and the
high school football field are directly adjacent to the paved bike path in the southeastern
portion of the site. A fence separates the school property from the bike path, and another
fence separates the bike path from the Caltrain tracks. The right-of-way required for the HST
alignment would require approximately three quarters of the campus to be affected. This
would include all entrances and exits of the campus by automobile, pedestrian and bicycle
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travel. The Palo Alto High School Master Plan locates a new permanent 2 -story general
classroom building on the northeast end of campus approximately 100 feet from the Caltrain
right -of way. Also included in the Master Plan is a new Media Arts complex, Career Tech
center and 600 seat Theater all within a few hundred feet of the Caltrain right-of-way.
City of Palo Alto Safe Routes to School Background
Palo Alto Unified School District (PAUSD) campuses were designed as neighborhood
schools and so have limited facilities to accommodate automobiles. Therefore, it is
absolutely essential to maintain safe pedestrianibicycle connections to every campus in the
school district because school sites and most surrounding public streets cannot support a
significant increase in auto commuter volumes.
In 2006, 44% of surveyed PAUSD elementary school children reported that they walked or
biked to school. An additional 10% ride a bus or carpool. Similar surveys have not been done
at secondary schools, but recent bike counts at secondary schools for October 2008 are:
• Gunn High School, 600 bikes, representing 31 % of students
• Palo Alto High School, 520 bikes, representing 30% of students
• Terman Middle School, 210 bikes, representing 32% of students
• Jane Lathrop Stanford Middle School, 351 bikes, representing 38% of students
• Jordan Middle School, 495 bikes, representing 53% of students
Many more students walk and ride public transit to PAUSD middle schools and high schools.
These numbers are substantial when one considers 11,345 students and 1,600 faculty and
staff travel to PAUSD schools each day, each of them potentially generating morning and
afternoon daily car trips if other transportation modes are not convenient and safe.'
Safe routes to school are such a high priority in planning for land use and transportation that
the Palo Alto Comprehensive Plan specifically organizes residential land use around
walkable, bikeable centers, including schools (Goals L-3, L-8 and L-6 and Policy T-28
address this and Policy T-40 states: Continue to prioritize the safety and comfort of school
children in street modification projects that affect school routes"). Goal T-3 specifically cites
the need to overcome "physical barriers like the Caltrain tracks and freeways" in
development of the city's bicycle system.
Further, as an outgrowth of these policies and goals, in 2003 the City of Palo Alto designated
a School Commute Corridors Network, a subset of Palo Alto's street system for special
consideration in infrastructure improvement and travel safety enhancement 2 This network
"comprises a comprehensive and continuous system of travel routes linking residential
neighborhoods to public school sites in Palo Alto." The adoption of the School Commute
Corridors Network comprised a statement of policy by the City of Palo Alto that "principal
school commute routes be given priority for public investment purposes and be accorded
enhanced review as regards proposals for new commercial driveways and other street
changes."
' Data received 320/09 from PAUSD Attendance Dept. and on 3/24/09 from PAUSD Human Resources Dept.
2 Adopted School Commute Corridors Network Map, 4up, ,.motp,l di pi _p lCa ilebank hL hdl ad a}p;'RI
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PAUSD school sites are heavily used, not only for educational purposes, but also afternoons,
evenings and weekends as community and recreation centers.
This background is given to establish that by necessity a very high policy priority is placed
on providing safe school commute routes for PAUSD students using alternative modes
(especially bicycling and walking). This priority echoes State and Federal Safe Routes to
School priorities.
Environmental Tonic to be Studied in the EIR/EIS
The EIR/EIS process requires that a substantial number of environmental issues be
addressed. Key issues identified by the PAUSD with the San Francisco to San Jose segment
of the California HST project are presented below. The scope of this letter is specifically
environmental issues that PAUSD believes most relative to its school facilities, specifically
the Palo Alto High School campus which abuts the Caltrain right-of-way. The City of Palo
Alto has also prepared and submitted scoping comments for the HST EIR/EIS to the
Authority, and PAUSD aligns with the City's comments. The following list includes some of
the required topics of study identified in the City's scoping letter, expanded or further
detailed herein as appropriate to PAUSD.
Aesthetics
The EIR/EIS should:
1. Address the impacts of the widened right-of-way, grade separations, and construction
scenarios on existing trees and other vegetation. Evaluate the visual impacts from
construction of sound walls, berms or fencing. Provide feasible mitigation to
minimize the visual impacts, including extensive landscaping to screen the facilities
or fencing as much as possible.
2. Analyze and identify mitigation to offset the impacts of loss (removal or trimming) of
any protected trees and vegetation screening along the Caltrain right-of-way
consistent with the City's Tree Technical Manual Tree Value Replacement Standard.
3. Analyze the appearance of any overhead electric power supply for the trains,
including wires, supporting poles, mast arms, and insulations.
TrafficlCirculation
The EIR/EIS should:
4. Discuss and evaluate the incorporating of new and upgraded pedestrian/bicycle grade
separations of the railroad, as recommended in the 2003 Palo Alto Bicycle
Transportation Plan. The plan calls for reconstruction and upgrading of the
pedestrian/bicycle undercrossing at California Avenue and new pedestrian/bicycle
grade separation of the Caltrain tracks in South Palo Alto and north of the Palo Alto
station to provide safe alternatives to at grade crossings of the tracks with motor
vehicle traffic.
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5. Include discussion and analysis of the provision of safe, grade -separated
pedestrian/bicycle crossings at all of the intersections identified in the City of Palo
Alto School Commute Corridors Network, including:
• Homer
• Embarcadero
• Churchill
• California
• East Meadow
• Charleston
These crossings are designated school commute route intersections with the proposed
future HST tracks, providing east/west bicycle/pedestrian access to PAUSD school
sites and other destinations throughout the day.
6. Analyze traffic impacts to City streets around and leading to Palo Alto High School
and any other PAUSD campuses that would be affected during construction, and
specifically identify any streets that would be detoured or closed during construction
or permanently as part of the project.
7. Analyze the full traffic circulation, traffic safety, and emergency response impacts of
any proposed closures of existing at -grade crossings.
8. Evaluate the potential effects of the possible displacement of the bike path that runs
through the Caltrain right-of-way on the east border of the Palo Alto High School
campus parallel to campus classroom buildings and connects to the Town & Country
right-of-way.
9. If any HST plan option does not provide grade separated crossings for all modes
(auto, bicycle and pedestrian) at any of these designated City of Palo Alto School
Commute Corridor Network crossings, the effects of such change should be carefully
studied, giving particular attention to the effects that such traffic diversion might have
on the safety, convenience, and comfort of designated school commute routes for
PAUSD students.
10. Study of the long-term costs of transportation mode shift related to any changes to the
school commute corridors network.
11. Evaluate the impacts of any changes to designated school commute routes that
may occur during construction. Particularly, it is important to know what effect
road closures, planned detours or other diversion of pedestrian, bicycle and auto
traffic may have on school commute routes. Transportation mode shift caused by
such changes during construction may need to be mitigated to the extent that they
may generate auto traffic in excess of what PAUSD campus facilities (driveways
and parking lots) and surrounding public streets can accommodate.
EM
12. Evaluate potentially including a mitigation measure providing temporary school
busing.
Air Quality
The EIR/EIS should:
13. Evaluate construction activity impacts from construction dust and construction
equipment emissions for the various corridor options including at -grade, elevated or
depressed including open trench and tunneling.
14. Evaluate air quality impacts resulting from the increase in trains along the corridor as
well as any increase in pollutants resulting from the high speed of the trains. The
potential for increased air quality impacts from elevated tracks should also be
analyzed. Any additional air quality impacts resulting from locating a station within
Palo Alto should also be evaluated, e.g., any increase in pollution from train idling or
acceleration in leaving the station.
Hazards
The EIR/EIS should:
15. Evaluate all potential safety impacts to humans using the Palo Alto High School
grounds and facilities from construction and operation of the HST. Palo Alto High
School is located directly along the west side of the Caltrain railroad tracks, and
accidents or explosions from trains traveling at 125 mph could have severe impacts
not only on the school, but on nearby residences, businesses, roadways, and other
facilities. The impacts to be studied should include, but should not be limited to:
a. The potential for derailment from elevated or at -grade tracks through Palo
Alto, and measures (crash walls, etc.) to assure that adjacent facilities (i.e.,
high school) would not be affected.
b. The potential for pedestrians to cross into the rail right-of-way, and measures
(fencing, other barriers) proposed to eliminate potential conflicts.
c. The potential for explosion or hazardous releases from passenger or freight
train crashes or derailments in an elevated, at -grade, tunnel or trench
configuration, and considerations relative to earthquake or terrorism events.
d. The potential for conflicts between heavy freight trains and lighter passenger
trains, whether in an elevated, at -grade, tunnel or trench configuration.
e. Hazards from construction, including from equipment and machinery, traffic
to and from the site, and construction vibrations. Impacts should be assessed
on the adjacent high school, as well as potential damage to streets and other
public facilities.
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16. Evaluate human exposure to electromagnetic emissions, and demonstrate the
project's compliance with applicable local, state, and federal laws and regulations.
17. Analyze and identify any hazardous materials that may be used during construction
and provide suitable mitigation measures.
Historic Resources
On December 8, 1914, Palo Alto Union High School Board selected the architectural firm of
Allison and Allison to design the new high school. Today, only the Haymarket Theatre and
the Administration Building remain as the only surviving portion of the campus as originally
designed by Allison and Allison in 1917. Linked by arched arcades, the two buildings anchor
the northwest comer of the present high school campus (corner of El Camino Real and
Embarcadero Road). The Historic Resources Inventory form prepared by the City's Historic
Resources Board describes the buildings as "the visual focal point of the more recent
buildings in the high school complex".
Therefore, the EIR/EIS should:
18. Evaluate the impact on historic structures listed or eligible for listing on the National
Register of Historic Places and/or the California Register of Historical Resources,
structures listed on the City of Palo Alto's Historic Inventory, and areas identified as
potential National Register historic districts in the "Palo Alto Historical Survey
Update: Final Survey Report" by Dames & Moore, dated February 2001. Evaluation
of impacts should be in accordance with Advisory Council on Historic Preservation's
Section 106 Review for federal compliance and with the California Office of Historic
Preservation for state compliance..
19. Identify alternatives that would avoid or minimize project impacts on identified
historic structures or areas.
20. Evaluate impacts and provide mitigation to offset disturbance of any Native
American archaeological sites located adjacent to the Caltrain right-of-way.
Noise
The EIR/EIS should:
21. Apply the City of Palo Alto's significance criteria to the proposed project to define
whether noise impacts are significant with respect to adjacent school uses. City of
Palo Alto General Plan (GP) Policy N-39 indicates that the maximum outdoor noise
level in residential areas is suggested to not exceed an Ldn of 60 dB. GP Policy N -4C
reads: "Evaluate the potential for noise pollution and ways to reduce noise impacts
when reviewing development and activities in Palo Alto and surrounding
communities." GP Policy N-41 indicates that "When a proposed project is subject to
CEQA, the noise impact on existing residential land uses should be evaluated in
terms of the increase in existing noise levels..., regardless of existing background
noise levels" and specifies that a significant impact is found if the increase in the 24 -
on
hour noise level (Ldn) increases by 5.0 dB or more in an existing residential area if
the Ldn remains below 60 dB, or 3.0 dB if the resultant Ldn exceeds 60 dB. Policy
N-42 notes that measures to reduce noise impacts should be required, and outlines a
number of possible, though not exclusive, means to do so.
The City of Palo Alto has adopted the following maximum exterior noise limits for
land use compatibility: Acceptable is up to 60 CNEL dB; Conditionally acceptable
from 60 CNEL dB to 75 CNEL dB, and Unacceptable from 75 CNEL db or more.
22. Identify the noise from horns from all trains, based on the increased frequency of
train operations. The City understands that most cities on the Peninsula will create
quiet zones under the new Federal Railroad Administration (FRA) regulations to
eliminate the sounding of train horns at all crossings. The HST analysis should be
based on the assumption that all train horns have already been eliminated and that
Caltrain has been electrified. These circumstances should be considered existing in
the No Project alternative.
23. Evaluate noise during the construction period, and document measures and phasing
approaches to minimize those impacts. The project is clearly extensive in scope and
in timeframe, and substantial potential exists for excessive noise impacts in proximity
to the rail right-of-way.
24. Evaluate the impact on the high school property caused by vibration associated with
each construction method, as well as the permanent vibration increase from the rail
operations, and mitigations to reduce those impacts to "less than significant" levels.
25. Analyze the noise and vibration impacts to the school resulting from an increase in
train traffic on the adjacent tracks.
Land Use
The EIR/EIS should:
26. Identify how each of the different vertical track alignments (i.e. tunnel, trench, track
at grade, elevated track) could potentially divide (or connect) the community, in
comparison to the City's Comprehensive Plan policies. The at -grade and
(particularly) elevated options appear to have substantial likelihood of division of the
community. The document should, for those options, outline measures to demonstrate
how such a project can enhance the community by providing attractive connections
and interactions between the high school and area neighborhoods, commercial areas,
and open spaces/parks.
27. Evaluate the impact on City dedicated parks and recreational opportunities, including
impacts on the loss of playing fields and potential mitigations.
28. Evaluate the impact of any right-of-way acquisition on the high school property,
including parking capacity, buildings/facilities, and playing fields, and any potential
mitigations.
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Economic Impacts
The EIR/EIS should:
29. Analyze the impact to real property values near the rail due to more frequent rail
traffic and increased noise, visual impacts, and vibration levels from changes in the
vertical track alignment and number of tracks. Consider feasible alternatives that
would reduce any impacts, such as construction of a tunnel through the area.
The PAUSD appreciates the opportunity to provide these scoping comments for the EIR/EIS
for the San Francisco to San Jose HST Project. The District looks forward to working with
CAHSRA staff on an ongoing basis to review alternatives, impacts and mitigation measures
for this important project.
Sincerely,
Kevin Skelly, Ph.D.
Superintendent