Worse traffic and poor air quality caused by construction are among the impacts expected when Menlo Park builds out its ambitious new housing plans spurred by state mandates, according to an environmental analysis reviewed by the Menlo Park Planning Commission on Nov. 14.

The analysis is part of the city's housing element update, a state-mandated process that occurs once every eight years. This time around, the state is strongly enforcing the regulations.

The housing element requires cities to build according to projected growth, with an eye toward balancing jobs and housing. Menlo Park's housing target, also known as the Regional Housing Needs Allocation (RHNA), requires the city to plan for close to 3,800 new housing units by 2031.

Though Menlo Park submitted its housing element to the state in July, which predicted the city would not only reach its RHNA requirements but exceed it by over 2,000 units, it was rejected by the California Department of Housing and Community Development (HCD) on Oct. 9. Menlo Park is required to revise and resubmit a housing element to the state to demonstrate it can build what is proposed. The city has until Jan. 31 to submit a valid housing element for approval. Failing to meet the deadline means the city would have a noncompliant element, which could result in builder's remedy and open the door for developers to build significant housing projects without having to comply with local zoning rules.

The draft supplemental environmental impact report (SEIR) has found that even with mitigation there will be "significant and unavoidable" impacts on air quality and traffic in Menlo Park. The plan is expected to generate a significant amount of vehicle miles traveled and create air pollutants from construction due to things such as equipment exhaust.

The commission reviewed the housing element's SEIR at the meeting, which is open for public comment on until Dec. 19, and plans to continue its discussion at a meeting next month.

Three residents spoke out with concerns about the draft SEIR and commented on revisions they wanted to see. Resident Pam Jones said that she had concerns that HCD would be looking for a more thorough analysis of the environmental effects of potential housing, as some of the environmental justice elements of the draft EIR were based on the Connect Menlo zoning plan that began in 2014, and that the information was outdated.

"I have concern that this document, this process, is not even addressing what we know we're going to have to address in the response to the HDC," Jones said.

Another resident, Jenny Michelle, said that higher density spread across the city, including in low-density areas, is critical to mitigating environmental aspects.

"We need owners coming forward stating 'Yes, in my backyard, we are going to build density housing here and that will improve the environmental impact,'" Michelle said.

Naomi Goodman, a Menlo Park resident representing the Sequoia Audubon Society spoke out about the safety of birds and other wildlife, specifically regarding the enforcement of bird-safe design standards, which she said is often waived, and the importance of reducing light pollution.

The city-commissioned SEIR used the 30% buffer for planned housing, which HCD suggests cities include. The only thing that would trigger an additional study at this point is if over years, circumstances changed or new state regulations are adopted, but the city currently has the ability to work off of the draft EIR previously submitted.

Planning Commission Chair Chris Decardy applauded city staff for recognizing cultural elements of Menlo Park in the draft SEIR and aiming to preserve them.

"I appreciate your point about how conservative you were on the cultural resources," Decardy said. "I don't think it should be used for the wrong purposes. And if our town cares deeply about our historical architecture or other historical elements, then we should invest the effort in order to be able to have a city-wide look at that."

The Planning Commission continued the discussion of the SEIR to Dec. 6, saying that the comments made thus far will be considered in revisions, and the public is welcome to continue submitting comments until Dec. 19.