Dear Mayor Nash and Council Members,
Ahead of tonights downtown housing study session, Im sharing a brief
policy proposal on adaptive parking design for the three proposals before
you.
The core idea: the parking structures in these proposals will operate
through the mid-2060s — well past the point where four compounding
conditions (Caltrain at 250 yards, Waymo now operating in Menlo Park,
documented e-bike mode shift, and a Class IV ECR bikeways) will
substantially reduce resident car ownership. Parking built today without a
conversion-compatible design will be far more costly to repurpose later.
The brief proposes a tiered adaptive design standard sized to the evidence
— applying requirements only to the stalls most likely to become stranded
assets (upper-floor public replacement parking and above-base resident
stalls), while exempting base resident parking and ground-floor public
stalls. The near-zero-cost design elements are well-documented in the
literature; a conversion pathway can be structured as a ministerial
entitlement, requiring no new discretionary review.
No California city has yet adopted a tiered, prospective adaptive design
standard of this kind. Tuesdays session is a real opportunity to establish
that precedent.
The full brief is attached.
Thank you for your time.
Ken Kershner
Allied Arts Resident, Menlo Park
--
*Ken Kershner | Co-Founder & CEO*
Cell 650-248-9059 | Email k en@triomotors.co
Trio Motors | Menlo Park
POLICY BRIEF · MENLO PARK DOWNTOWN HOUSING · JUNE 2, 2026
*Design parking for what comes next,*
*at near-zero additional cost today*
Three developers — Alliant Communities, Presidio Bay Ventures, and Related
Companies/Alta Housing — are presenting downtown housing proposals on June
2. Each proposes replacing all 556 downtown surface parking spaces and
adding resident parking on top. Per the submitted developer proposals,
construction is projected to take *3.5 to 5 years from groundbreaking.*
With the November 2026 ballot measure and Surplus Land Act process,
groundbreaking is realistically 2028 at earliest — putting completion in
the 2031–2033 range. The structures will operate through the mid-2060s.
The parking programs embedded in these proposals reflect conditions that
existed before Waymo launched in Menlo Park, before ECR protected bike
lanes reached Palo Alto, and before peer-reviewed research documented a
10-percentage-point car mode shift from e-bike access. Four compounding
conditions have changed the demand calculus for residents of a downtown
Menlo Park building — and none are adequately reflected in the stall counts
being presented Tuesday.
*AB 2097 — A critical legal context*
California AB 2097 (effective January 1, 2023) prohibits any public agency
from imposing minimum parking requirements on projects within one-half mile
of qualifying transit. The Menlo Park Caltrain station is approximately 250
yards from the downtown plazas — well within that radius. Any parking the
three developers propose is therefore voluntary. This reframes the adaptive
design standard as an incentive exchange: the City offers a pre-approved
ministerial conversion pathway in return for voluntary adoption of
conversion-compatible design. No cost to the City. No mandate on the
developer.
*Four conditions reducing parking demand — today*
*Each of the following is a confirmed, present-tense condition in Menlo
Park, not a projection.*
*01*
*Caltrain — confirmed*
~250 yards from the downtown plazas. Residents walk to the station in 3
minutes. AB 2097 already prohibits parking minimums here. Transit proximity
alone reduces car ownership 20–30% below suburban baselines in the
literature.
*02*
*Waymo — operating now in Menlo Park*
Commercial robotaxi service launched in Menlo Park in June 2025, now
covering 260 square miles of the Peninsula including freeways. A resident
without a car can already hail a driverless ride from downtown at any hour.
*03*
*E-bikes — documented 10-point mode shift*
Chevance et al. (Transport Reviews, 2025) — a peer-reviewed meta-analysis
of experimental studies — found that access to an e-bike reduces car mode
share by approximately 10 percentage points and car distance by 2.4 km/day.
A measured behavior change, not a projection.
*04*
*ECR protected bikeway — arriving at the doorstep*
Class IV protected lanes are installed through Mountain View, Los Altos,
and Palo Alto as of 2025. The Grand Boulevard Initiative is beginning Menlo
Park’s own design process in 2026. The downtown project sites sit at the
terminus of this corridor.
These four conditions compound. A resident of a downtown Menlo Park
building in 2031 will be able to walk to Caltrain in 3 minutes, hail a
Waymo at any hour, and ride an e-bike on a protected ECR lane. Parking
demand assumptions set before any of these conditions existed will
systematically overestimate actual demand when the structures open.
*A tiered adaptive design standard-sized to the evidence*
Rather than imposing adaptive design requirements across all proposed
parking, this policy targets only the fraction of stalls the evidence
identifies as most likely to become stranded. The public replacement
parking — a City-owned asset on City-owned land — warrants a partial
requirement. The resident parking above a defensible base ratio carries the
highest stranding risk. Base resident parking and ground-floor public
stalls are exempt.
*Tier*
*Parking category*
*Standard applied*
*Evidence basis*
*Tier 1*
*Public replacement parking*
(~20–25% of 556 spaces ≈ 110–140 stalls)
*Adaptive Conversion Standard*
City-owned land; City has full standing to impose design conditions on its
own asset. Targeting the upper floor(s) of any replacement garage — the
portion most logically converted first as demand falls, consistent with
KTGY’s Park House 2.0 phased floor-by-floor conversion research. Lower
floors remain operational throughout.
*Tier 2*
*Resident parking above base ratio*
(above 0.5 spaces/unit ≈ 20–35% of resident stalls)
*Full Adaptive Conversion Standard*
Smart Growth America’s study of five TODs found actual utilization ran
58–84% of supply even after below-code parking was provided. The 2023 Davis
et al. study found apartments near transit are over-supplied by 0.56
spaces/unit on average. Resident stalls above a 0.5/unit base are the
portion the evidence identifies as most likely to be chronically underused
at this site.
*Tier 3*
*Base resident parking*
(≤0.5 spaces/unit) and ground-floor public parking
No requirement
Evidence suggests this portion will sustain utilization. Exempting it keeps
the policy targeted, limits developer cost exposure to the stalls that
carry the actual stranding risk, and makes the overall standard politically
viable.
On the public replacement parking: these are City-owned plazas. The City
has full standing — and a public responsibility — to impose design
conditions on its own asset. Targeting 20–25% of the replacement garage
(approximately the upper floor(s)) follows KTGY’s Park House 2.0 research,
which demonstrates phased floor-by-floor conversion beginning at the top
while lower levels remain operational. A public garage that can never
become anything but a garage is a permanently stranded public asset.
*The Adaptive Conversion Standard — what it requires*
For stalls subject to the standard (Tier 1 upper floors; Tier 2 above-base
resident stalls), the following design elements apply:
*Near-zero-cost design elements*
*One element with a real premium*
— Dedicated ramp core at building exterior — produces level floor plates
at no added material cost
— Short-span structural bays — Watry Design’s preferred system for
residential conversion; cost-neutral or cheaper than long-span in many
California markets
— (MEP) Mech Elec Plumb chase locations at perimeter and regular bay
intervals — specification decision, not a material addition
— Pre-approved ministerial conversion pathway — City policy commitment,
zero construction cost
— Floor-to-floor height increase (10–14 ft vs. 9 ft standard) carries a
real per-level premium
— Partially offset: taller floors enable double-stacked parking during the
parking phase
— Policy does not mandate this — offers the ministerial fast-track as
incentive for developers who voluntarily include it
— Watry Design: full ground-level adaptive design achievable for under 10%
cost premium when limited to layout and specification changes
*What the Council is asked to direct*
*1. Adopt the tiered framework in principle*
Affirm that the City will impose adaptive design conditions tiered to the
evidence of stranding risk: partial requirement on upper-floor public
replacement parking; full requirement on above-base resident parking;
exempt from base resident and ground-floor public stalls.
*2. Demand Trigger and Ministerial Conversion Pathway*
Direct staff to return with a utilization threshold — informed by ITE
Parking Generation Manual 6th Edition (2023) standards — that, once
sustained for 24 consecutive months, opens a ministerial conversion
entitlement for qualifying stalls. Ministerial means no discretionary
hearing, no new EIR, for projects within the pre-approved design envelope.
*3. 90-day staff return with five specific deliverables*
• Draft tiered Adaptive Conversion Standard as a development condition
template
• Recommended utilization trigger threshold sourced from ITE Parking
Generation Manual 6th Edition
• Legal memo confirming AB 2097 applicability to Plazas 1, 2, and 3
• Structural analysis scoping the cost of upper-floor adaptive design
on the Tier 1 replacement garage
• Initial inquiry to Waymo and Zoox regarding AV staging infrastructure
interest in Menlo Park
*The cost of not acting*
If stalls in Tier 1 and Tier 2 are built without adaptive design,
converting them later requires demolition or major retrofit of sloped
floors and internal ramps, full discretionary entitlement review,
potentially including a new EIR, and structural upgrades to meet
residential live loads, which Watry Design notes are approximately twice
the structural load for which parking structures are designed.
This brief makes no specific retrofit cost claim without project
engineering. What the literature clearly establishes is that the
per-square-foot cost of retrofitting a conventional parking structure
substantially exceeds the near-zero cost of specifying
conversion-compatible design at the time of construction. The tiered
approach limits that exposure to the stalls the evidence identifies as most
at risk — making the policy both efficient and defensible.
*Where California cities stand — and where the gap is*
*Jurisdiction*
*Action taken*
*Date*
San José
Eliminated all minimum parking requirements citywide
Dec 2022
Mountain View
Repealed parking mandates in housing growth areas
Nov 2024
Sacramento
Repealed all remaining parking mandates citywide
Jan 2021
Los Angeles
Citywide ARO: parking garages 5+ years old are eligible for housing
conversion by right
2024
State — AB 2097
Prohibits parking minimums within ½ mile of qualifying transit statewide
Jan 2023
*No CA city yet →*
*Tiered prospective adaptive design standard for new parking, sized to
projected demand reduction. Menlo Park can be first.*
*—*
No California city has yet adopted a tiered, evidence-based, prospective,
adaptive design standard for new parking sized to projected demand
reductions. Every element of this proposal has precedent somewhere in the
state. The synthesis has not been attempted. Tuesday’s session is the
moment to attempt it.
Submitted by: Ken Kershner, Allied Arts, Menlo Park, CA 94025
For: Menlo Park City Council Study Session, June 2, 2026 — Downtown Housing
Proposals
