With Castilleja School's plans for expanding student enrollment slapped down this week by the Planning and Transportation Commission, Head of School Nanci Kauffman on Thursday criticized the panel's decision, which she said was based on innuendos and anecdotes rather than facts and data.

In a written statement and an interview Thursday, Kauffman said she was surprised by the tenor of the commission's Wednesday discussion, which culminated in a series of 3-2 votes in which the three-member majority reduced the proposed enrollment figures in the school's conditional use permit from 540 to 450 (the current enrollment in 418) and reduced the number of special events — those with 50 or more people — that the school would be allowed to have from 70 to 50. This in addition to five "major events" with 100 or more people.

In both cases, Chair Ed Lauing, Vice Chair Doria Summa and Commissioner Bryna Chang voted to support these changes while commissioners Barton Hechtman and Cari Templeton voted against them. Commissioner Giselle Roohparvar was absent and Commissioner Keith Reckdahl recused himself because of his participation in Palo Alto Neighborhoods, an umbrella organization that issued a letter critical of Castilleja's plan before Reckdahl's appointment to the commission.

The rulings by the three-member majority marked a shift for the commission, which had already approved the Castilleja plan in 2020. The initial proposal called for a gradual ramp up in enrollment, which would be based on the school's ability to establish a comprehensive transportation-demand-management program and to follow a "no net new trips" policy, which would be confirmed several times a year. Any addition of car trips would have required Castilleja to add additional traffic-reduction measures and, if those don't succeed, to reduce enrollment.

The City Council considered the proposal in March 2021 and kicked it back to the commission and to the Architectural Review Board for further reviews. This included taking another look at the "conditional use permit" and enrollment figures.

After the commission issued its new recommendations Wednesday, Kauffman told this news organization that she was particularly surprised by the tenor of the discussion. The decisions by the three commissioners, she said in a statement, appeared to "rely on a handful of public comments with no basis in fact, but that instead spread misinformation, innuendo and personal bias.

"Once again, the high quality of education we offer is being threatened on the basis of intangible and immeasurable factors," Kauffman said, "This is no way to govern any city, let alone the birthplace of Stanford and the heart of the global technological industry."

In a follow-up interview, Kauffman said that what particularly stood out for her were the numerous instances in which commissioners quoted a public comment from an opponent of Castilleja's plan as justifications for decisions to rule against Castilleja. At several points, Chang and Lauing talked about the lack of trust between Castilleja and the neighborhood, with Lauing citing a comment from a parent, Susie Hwang, who spoke on March 30 and who suggested that the school's overenrollment was "commonly discussed among Castilleja parents and staff" even before the city learned about it in 2013. Palo Alto fined Castilleja $285,000 that year for exceeding enrollment restrictions in its permit and forced it to gradually reduce enrollment figures.

Chang also cited anecdotal evidence from neighbors who complained about the noise impacts of Castilleja's special events. She used that as part of her justification to call for limiting the number of special events (those with 50 or more participants) to 50 per year.

Both Templeton and Hechtman pushed back against the three-member majority, with Templeton calling the new number of events "arbitrary." And while Chang talked about the need to take neighborhood concerns seriously, Hechtman argued that neither the enrollment figures nor the number of events proposed by the three commissioners are based on any evidence or studies.

"What I didn't hear was evidence of impacts that would be generated by 540 (students) that are not present beyond 450," Hechtman said immediately after voting against the motion.

Kauffman told this news organization that she had similar concerns after hearing three commissioners relying more on anecdotes from the project opponents than on the school's environmental analysis for the project.

"It was surprising how often there were instances where a few public comments were quoted multiple times," Kauffman said in an interview Thursday. "But I didn't hear anyone talk about the EIR."

The question of how much discretion the commission has to deny Castilleja's request came up at the beginning of the meeting, when Lauing set the stage by suggesting that the commission has wide latitude on modifying or rejecting the school's plans. He called the process a "negotiation between the application and their desires versus the city" and contended that a conditional use permit is a "privilege not a right." As such, the city's actions on whether to approve the school's request are "totally discretionary," Lauing said.

Hechtman pushed back and suggested that the commission's findings, whether in favor or against Castilleja, need to be backed up by established facts, a view that Assistant City Attorney Albert Yang concurred with.

"There must be a clear logical link between the facts that are in our records and the findings that are required by our code, as well as the ultimate recommendations of approval or denial," Yang said. "In that sense, there's not total discretion. We are still bound by what is in the record before the commission."

Kauffman also said she was surprised by the three commissioners using alleged "lack of trust" to justify their votes. The need to gain the neighborhood's trust has been central to Castilleja's decisions to roll out an extensive transportation-demand management plan and to include even more traffic-reducing measures in its plans to reconstruct its campus at 1310 Bryant St., she said.

"When you consider how dramatically we have reduced our impact on the neighborhood over the last 10 years in terms of reducing trips, reducing events, reducing noise, reducing parking — we feel we have earned our right to be trusted at this point," Kauffman said in an interview.

Kauffman said the school believes that its plan to increase enrollment, construct new academic buildings and add an underground garage will "have a positive impact on the neighborhood and on future generations of women leaders." She also said in a statement that the plan that the school submitted in 2016 already represented years of compromise with neighbors.

She called the commission's decision on Wednesday to reduce student enrollment and the number of special events "shocking."

"For many teens and their families, schools are now a central source of deep connection and enduring friendship," she said in a statement. "Increasing our enrollment and maintaining our on-campus gatherings allows Castilleja to deliver on its mission and expand opportunities for teen wellbeing at a time when it has never been more critical. Palo Alto should not abandon its leadership position as a city that makes choices and decisions that reflect our community's commitment to ensuring that all youth, at any school, in any neighborhood, remain our top priority."

The council is scheduled to consider the commission's recommendation on May 23.

Correction: Ed Lauing alluded to a comment from a parent alleging that Castilleja School's exceeding of its enrollment cap prior to 2013 was an issue that was commonly discussed. The article originally attributed it to Bryna Chang, who talked about issues of trust but did not cite a specific comment.