City of San Jose - Vallco Special Area Specific PlanUTY OF
SANPlanning, Building and Code Enforcement
CTAPrrAL OF: SILICON VALLEY ROSALYNN HUGHEY, ACTING DIRECTOR
March 12, 2018
VIA MAIL AND E-MAIL
City of Cupertino, Community Development Department
Attention: Piu Ghosh, Principal Planner
10300 Torre Avenue
Cupertino, CA 95014
piug@cupertino.org
RE: City of San Jose's Comment Letter relating to the Notice of Preparation for the Vallco
Special Area Specific Plan (File EA -2017-05).
Dear Piu Ghosh,
On behalf of the City of San Josh (City), we would like to express our appreciation for the
opportunity to review and comment on the Notice of Preparation (NOP) for the Vallco Special
Area Specific Plan. The City's comments are outlined below.
PROJECT UNDERSTANDING
The City understands the project to be a Specific Plan for future redevelopment of the Vallco
site, which would facilitate the development of up to 600,000 square feet of commercial uses, 2.0
million square feet of office uses, 339 hotel rooms, and 800 residential units, all consistent with
the City of Cupertino's adopted General Plan. The proposed project includes the transfer of
residential allocation from other Planning Areas in Cupertino to accommodate the increase in
residential allocation for the Vallco Shopping District from 389 to 800 residential units.
CITY NOTICE OF PREPARATION COMMENTS
The City supports infill development on an underused site in close proximity to major
employment centers, residential neighborhoods, and retail. The concept is similar to the
Envision San Jose 2040 General Plan strategy for Urban Villages to accommodate future growth
while preserving existing single-family neighborhoods and minimizing greenfield development.
The City is encouraged that the proposal could add housing at the Vallco site, which will help
reduce regional vehicle -miles traveled (VMT) by increasing opportunities for area employees to
live in Cupertino and walk or bike to their jobs, schools, and entertainment.
However, the City of San Jose is concerned that the proposed increase in residential dwelling
units is not sufficient to offset the environmental effects of 2.0 million square feet of office uses.
If completed, this amount of office space will amplify market pressure for more housing in the
200 E. Santa Clara Street, San Josh, CA 95113 tel (408) 535-3500 www.sanJos6ca.gov
Notice of Preparation for the Vallco Special Area Specific Plan
City of San Jose
March 12, 2018
Page 2 of 4
region, particularly in San Jose. The result would be increased peak hour traffic on Interstate
280 (I-280) and State Route 85 (SR -85), and would also likely result in increased traffic on
Stevens Creek Boulevard and other surface streets. The market pressure for more housing in San
Josh will also further erode San Jos6's jobs -to -employed resident ratio, leading to the potential
for continued fiscal challenges that could reduce City services to San Josh residents. Because
many employees who work in Cupertino live in San Josh, any reduction in City of San Josh
services will affect these residents' quality of life and could result in challenges for regional
employers, including Cupertino employers, to attract and retain employees. These concerns and
how they can be addressed in the EIR are more fully described in the comments below.
1. Project Description
The Specific Plan proposes to increase housing capacity on the site from the 389 residential
dwelling units anticipated in the Community Vision 2015 — 2040 General Plan to 800 dwelling
units. The additional 411 dwelling units will be transferred from other Planning Areas in order
to maintain the overall housing capacity provided in Cupertino's General Plan. The project
description should identify the specific Planning Areas from which the additional 411 dwelling
units will be transferred.
2. Traffic and Circulation
Traffic Operations within the City of San Josh
On February 27, 2018 the City of San Josh adopted City Council Policy 5-1: Transportation
Analysis Policy. This Policy changes the City of San Josh standard for determining traffic
impacts under CEQA from Level of Service (LOS) to Vehicle Miles Traveled (VMT) and is
scheduled to become effective on March 29, 2018. At this time, the City requests that the traffic
report for the Vallco project include an LOS analysis and intersection operations analysis for
City of San Josh intersections near the project, including affected intersections along Stevens
Creek Boulevard, Wolfe Road/Miller Road, Blaney Avenue, De Anza Boulevard, Moorpark
Avenue, and any other intersection based on the Congestion Management Program guidelines for
intersection selection.
The City also requests the traffic consultant use a Travel Demand Model to determine trip
distribution on surface streets, including traffic diverted to surface streets during the peak hours
due to congestion on I-280 and SR -85.
Cumulative Traffic Anal
The following proposed projects are located within the City of San Josh and are either located
within two miles of the Vallco site or are large projects. We request these projects be included in
the cumulative traffic analysis:
• 4300 Stevens Creek Boulevard Mixed Use Project (Fortbay): Proposal for up to 300,000
sq. ft. of office, 22,000 sq. ft. of retail, and 582 residential dwelling units
• Hotel at 5696 Stevens Creek Blvd (AC Hotel): Proposal for a hotel with up to 132 hotel
rooms
200 E. Santa Clara Street, San Josh, CA 95113 tel (408) 535-3500 www.sanJos6ca.gov
Notice of Preparation for the Vallco Special Area Specific Plan
City of San Jose
March 12, 2018
Page 3 of 4
• North San Jose Phase II
• San Jose Downtown Strategy 2040
Background Traffic Analysis
The following projects in the City of San Josh are either approved and unbuilt or are currently
under construction. We request these projects also be included in the background traffic
analysis:
• Santana Row Expansion/Santana West
• Volar
• North San Jose Phase I
• Downtown Strategy 2000 Phase I
• Valley Fair Mall Expansion
Please contact the City of San Jos6's Traffic Manager, Karen Mack for project information.
Karen can be reached at karen.mack cksanjoseca.gov.
Pedestrian and Bicycleprovements
Please include a description of pedestrian and bicycle infrastructure improvements to support the
project. Connections to the new Apple Campus 2, Main Street Cupertino, transit lines (including
potential future Bus Rapid Transit) along Stevens Creek Boulevard, and future development in
the City of San Josh's Stevens Creek Urban Village west of the site will be crucial to giving
people transportation alternatives to driving.
3. Biological Resources — Santa Clara Valley Habitat Conservation Plan
The project site is located outside of the Santa Clara Valley Habitat Conservation Plan
(SCVHCP) area. However, the SCVHCP is the best regional biological science available,
particularly for nitrogen deposition impacts to the Bay Checkerspot Butterfly. Cumulative
impacts to the Bay Checkerspot Butterly resulting from nitrogen deposition due to project -
generated vehicle trips should be evaluated as part of the EIR. Even though Cupertino is not a
part of the SCVHP, the EIR can use the SCVHP framework for analytical information,
disclosure and mitigation for cumulative nitrogen deposition impacts to the Bay Checkerspot
Butterfly resulting from project trips.
4. Alternatives
The Specific Plan proposes up to 2.0 million square feet of office uses and 600,000 square feet of
commercial uses on site. This translates to approximately 8,700 employees (up to 6,700 for the
office development and 2,000 for the commercial uses) based on an estimate of 300 square feet
per employee. Given the trend toward open floor plans, future office development could
accommodate significantly more employees. Adding these employees on the site will increase
demand for housing beyond the maximum 800 dwelling units proposed by the Specific Plan,
resulting in increased demand for housing in neighboring jurisdictions, including the City of San
Josh. Construction of housing to meet this demand in San Josh will exacerbate San Jos6's low
200 E. Santa Clara Street, San Josh, CA 95113 tel (408) 535-3500 www.sanJos6ca.gov
Notice of Preparation for the Vallco Special Area Specific Plan
City of San Jose
March 12, 2018
Page 4 of 4
jobs -to -employed resident ratio (contributing to existing fiscal imbalances), contribute to peak
hour traffic congestion, and increase regional vehicle -miles traveled (thereby increasing regional
criteria air pollutants and greenhouse gas emissions). San Jose strongly supports a more
balanced Specific Plan that either reduces the size of the proposed office development or
increases the number of housing units on the site to help ameliorate these effects.
The City requests the EIR consider the following project alternatives to provide additional
housing on the site.
a) A reduced offices ace alternative: Consider an alternative which reduces office space
to one million square feet or less while retaining or increasing the proposed project's 800
dwelling units. Such an alternative should result in less demand for housing in
neighboring jurisdiction, and could improve regional vehicle -miles traveled and traffic
congestion on I-280 and SR -85 compared to the proposed project.
b) _A balanced housing and employment alternative: The City requests the EIR evaluate an
alternative that balances the proposed increase in jobs on the site with a proportionate
number of residential units. For example, if the Specific Plan continues to propose 2.0
million square feet of office, this alternative would include approximately 4,000 to 5,000
dwelling units. Such an alternative could require a General Plan Amendment to increase
the overall housing supply in the City of Cupertino and depending on the size of the
office development could require increases in density beyond those anticipated in
Cupertino's Community Vision 2015 — 2040 General Plan.
CONCLUSION
We thank you for the opportunity to comment on the Vallco Special Area Specific Plan Notice of
Preparation. The City of San Jose looks forward to continued collaboration, communication, and
implementation of the project. If you should have any questions, please feel free to contact David
Keyon, Supervising Environmental Planner at david.ke on sanJosdca. ov or (408) 535-7898.
Sincerely,
Ned Thomas, Division Manager
Planning, Building and Code Enforcement
City of San Jose
CC: Department of Public Works
200 E. Santa Clara Street, San Josd, CA 95113 tel (408) 535-3500 www.sanJosdea.gov