Planning & Design Meetings Fastspeed Alternative Design 6/29/2010 - Report
25 Churchill Avenue, Building ‘D’ ● Palo Alto, CA 94306 ● Phone 650.329.3935 ● Fax 650.327.3588 ● www.pausd.org
STRONG SCHOOLS BOND
June 29, 2010
Robert Doty
California High Speed Rail Authority
925 L Street, Suite 1425
Sacramento, CA 95814
RE: Palo Alto Unified School District Comments for the California High Speed Rail
Authority’s Preliminary Alternatives Analysis Report for the San Francisco to
San Jose Section of the California High-Speed Train Project (April 2010)
Dear Mr. Doty,
Thank you for the opportunity to comment on the California High Speed Rail Authority's
(Authority) April 2010 Preliminary Alternatives Analysis Report for the San Francisco to
San Jose Section of the California High-Speed Train (HST) Project. The California 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, and would have a long-lasting and
far-reaching impact on campus.
The following discussion provides comments from the Palo Alto Unified School District on the
April 2010 Preliminary Alternatives Analysis Report.
Palo Alto High School
Palo Alto High School is located at 50 Embarcadero Road at El Camino Real. The school site
is bounded by El 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 the year 2017. Approximately 180 full-time staff and
employees also 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. As explained in detail below, the
potential impacts the HST alignment would affect approximately three quarters of the
campus either directly or indirectly. The Palo Alto High School Master Plan locates a new
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permanent two-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.
It should be noted the Preliminary Alternatives Analysis Report focuses only on alignment
alternatives on the Peninsula between San Jose and San Francisco. Accordingly, this letter
focuses solely on the PAUSD’s comments in that regard. Comments on this Preliminary
Alternatives Analysis Report should not be interpreted as tacit approval from the PAUSD for any
of the Peninsula alignment alternatives. The City of Palo Alto’s comments note that many
significant environmental, economic, right-of-way, and other issues still remain unknown about
the project due to lack of sufficient information with which to compare the various alternatives.
Therefore, these comments should not be considered exhaustive or binding. The PAUSD expects
to provide additional comments as more information about the proposed HSR project and
alternatives becomes available.
The following comments relate to potential impacts to Palo Alto High School (PAHS).
A. TECHNICAL COMMENTS
• Comment A-1: The lack of adequate information regarding financial, environmental,
and right-of-way impacts precludes a reasoned determination of preferred alternatives,
both for the PAUSD and the public. In particular, the absence of any meaningful
discussion of noise and vibration impacts makes it impossible to determine which vertical
alignment options would have the least impact on the many sensitive receptors along the
Caltrain right-of-way. The CHSRA must provide a more substantial analysis in the
upcoming Draft EIR and explore the potential environmental impacts of each option to
allow for a meaningful comparison of alternatives. Similarly, the cost impacts
(construction, right-of-way, grade separations, mitigation, community disruption, etc.)
and right-of-way needs leading to potential property “takings” must be fully addressed to
understand the implications of each alternative.
• Comment A-2: The report identifies a certain number of sensitive noise receptors for the
aerial option, which indicates noise mitigation measures would be required. The cross
sections for the aerial option do not show any noise barriers, however, and noise barriers
do not appear to be factored into the cost estimate for the aerial option. The analysis
needs to indicate the degree of noise impact of the aerial option, the type of noise barriers
that would be required to mitigate this impact, and the cost of the noise barriers. Without
this information, it is impossible to evaluate the feasibility and effectiveness of the
mitigation required for this option or to make an informed and reasonable comparison of
this option to the other options.
• Comment A-3: The report does not identify the number of sensitive noise receptors for
the at-grade option, nor does the cost of noise barriers appear to be factored into the cost
estimate for the at-grade option. The analysis needs to indicate the degree of noise impact
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of the at-grade option, the type of noise barriers that would be required to mitigate this
impact, and the cost of the noise barriers. Without this information, it is not possible to
evaluate the feasibility and effectiveness of the mitigation required for this option or to
make an informed and reasonable comparison of this option to the other options.
B. SITE SPECIFIC COMMENTS
• Comment B-1: The right-of-way required for some HSR alignment options may affect
approximately three-quarters of the campus. Significant effects could potentially include
the loss of land for HSR right-of-way, noise and vibration impacts in classrooms and
outdoor use areas, and limitations on access due to the grade separation of either
Embarcadero Road, Churchill Avenue, or both. A maintenance building would likely be
directly affected and require relocation, as would the stadium and bleachers – specifically
visitor bleachers and track jumping runways. The potential project impacts on PAHS
need to be examined in detail and adequate mitigation measures developed and described
in the report. The CHSRA must also analyze whether these impacts to PAHS (reduced
land area, noise, access, etc.) would allow the site to even remain viable for continued use
as a high school.
• Comment B-2: The PAHS Master Plan includes five new facilities that will be in close
proximity to the existing Caltrain right-of-way. These permanent facilities include a:
o two-story general classroom building on the northeast end of the campus and
approximately 100 feet from the Caltrain right-of-way
o media arts complex
o career tech center
o 600-seat theater
o stadium renovation
The Preliminary Alternatives Analysis for the HSR project does not clearly indicate how
much additional right of way would be needed beyond the Caltrain corridor to
accommodate the HSR project. The potential impacts to these proposed facilities must be
identified and analyzed as part of the CEQA review of the HSR project.
• Comment B-3: Pedestrian, bicycle, and auto access to the high school could be affected
by the project, particularly if the Caltrain corridor needs to be expanded to accommodate
the HSR project. A bicycle path currently travels along the rear of the high school
property along the Caltrain corridor and would be eliminated if the Caltrain corridor is
widened. The Embarcadero and Churchill entrances to the high school could be rendered
impassable depending on the vertical alignment option chosen for the HSR project and
the subsequent grade separation changes made at either or both of these two street
crossings. Currently, the majority of bicycle and pedestrian crossings occur at the Alma
Street and Churchill Avenue intersection, which would be directly impacted by the HSR
project. Even the El Camino Real entrance to PAHS could be affected if either the
Embarcadero or Churchill entrance is altered in some way, forcing more auto traffic to
enter and exit the site from the El Camino Real entrance. The CHSRA must evaluate all
impacts to access the PAHS site.
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• Comment B-4: Schools are included as sensitive receptors when considering noise and
vibration impacts. Construction noise and increased rail operations adjacent to the PAHS
could have detrimental effects on students and faculty and could violate noise thresholds
for educational facilities. Consistent with long-standing recommendations for good
practice in educational settings, the standard set criteria for maximum background noise
is 35 decibels for unoccupied classrooms; HSR has been documented to generate 35
dB(A). The attenuation of the noise and the reverberation time should be fully evaluated
to address the impact on the learning environment. The CHSRA must fully evaluate noise
and vibration impacts on PAHS and other sensitive receptors and determine if the project
impacts render the site unviable for continued use as a high school.
The PAUSD appreciates the opportunity to provide these comments for the Preliminary
Alternatives Analysis Report for the San Francisco to San Jose Section of the California
High-Speed Train Project. The District looks forward to working with Authority staff on an
ongoing basis to review alternatives, impacts, and mitigation measures for this important
project. For more information on the above, please contact Robert Golton at (650) 329-3801.
Sincerely,
Kevin Skelly, Ph.D.
Superintendent