The staff report for Tuesdays meeting about the Housing Element does not appear to include correspondence such as my letter below nor does it mention the Planning Commissions recommendations regarding the SRI/Parkline site to include greatly more housing in numbers akin to that of the recently approved Willow Village.
I would like to stress the critical and time-sensitive importance of work on design guidelines, particularly for projects that could be approved ministerially. Menlo Park is one of very few cities in the bay area that has no architectural design guidelines. Not only do nearly all other cities have such guidelines to guide development, reviews, and approvals, many cities also have a separate architectural design commission. Design guidelines are extremely valuable to architects and property owners when available early in the design process when changes are less expensive to make, both financially and emotionally. Design guidelines are also very valuable to neighbors of new projects to provide protections for quality of life. Unfortunately, the HE describes a process that does not even begin for two years and is geared toward obtaining only developer input. Please authorize a plan that begins much earlier, such as with a volunteer workgroup tasked to present ideas and pros/cons for design guidelines and objective standards, and that includes residents, not just developers.
Do not open the floodgates to development with neither project reviews nor design guidelines/standards in place.
Patti Fry
---------- Forwarded message ---------
From: Patti Fry
>
Date: Tue, Jan 10, 2023 at 12:18 PM
Subject: Comments for Joint Meeting regarding Housing Element Update
To: >
Cc: City Council >
Commissioners,
Below are some observations and recommendations related to the Housing Element Update.
1. Exclusion of viable housing sites may raise red flags, unnecessarily
It makes little sense to exclude properties where there is developer interest, such as near Marsh Road (i.e., Haven and in the Bohannon office park). Surely that will raise red flags at the state and regional level, in addition to missing out real opportunities to house people. Careful planning and rezoning can help avoid "sins of the past" that led to inequitable development. Sound planning also can help convert office space to mixed use, ensure that there is a mix of housing for a variety of income levels, and ensure that new development improves the jobs/housing imbalance.
Additionally, it makes little sense to proceed with projects like SRI that ignore past planning precedents (as explained in former Council member Paul Collacchis recent correspondence) and instead add far more workers than housing in which they could live. Continuing to approve projects that worsen the jobs/housing imbalance will doom Menlo Park in future RHNA cycles.
Recommend inclusion of the Haven and Bohannon office park sites with consideration of zoning rules that avoid problems of the past, and also to require a balanced SRI project.
2. Expanded zoning rules may result in more jobs and demand for housing than in an improved jobs/housing balance.
Menlo Parks zoning rules that allow Office uses at 40% FAR in commercial zones such as C-B-2 and 50% in the El Camino Real/Downtown Specific Plan area are inherently imbalanced from a jobs/housing ratio perspective. Business practices have changed so that more workers are packed into the same space than when those zoning rules were written. "Horizontal Mixed Use" doesnt improve the housing shortage unless the allowable office space is reduced significantly. Further, the mixed use zoning rules need to be modified so that it is no longer possible to maximize office space to the exclusion or detriment of housing and community-serving uses (e.g., retail, restaurants, services businesses). This phenomenon has occurred in small and large developments along El Camino Real where projects could have included hundreds more housing units; instead office space was maximized, displacing important community-serving businesses and literally building on top of land where housing could have been built.
Recommend a program that limits office development [by reducing the allowable Office FAR].
3. Menlo Parks budget will suffer by at least $5 million every year if the Housing Element is adopted without other planning.
The Financial Impact Report (FIA) estimates the net impact to our citys budget to be a negative $4,829,839 -- annually! The actual negative impact could be much greater because the Housing Element targets retail areas for redevelopment (e.g., Safeway and Big 5 shopping centers) where there currently are no zoning requirements to retain or develop even one square foot of sales tax generating uses such as retail/restaurants.
The FIA states that it has taken into account the loss of employees of non-residential properties that would be replaced, but it has not taken into account the potential loss of revenue from those businesses. This is not a minor amount -- the FIA estimates that 770,000 SF of commercial space would be demolished! That is more than DOUBLE the amount of commercial space in the enormous new Middle Plaza AND Springline projects on El Camino Real - combined. The financial impact of such massive losses could be huge unless plans are made. Yes, this is beyond the scope of the HE per se but essential to our communitys future.
Recommend a planning effort to retain and add revenue-producing businesses.
3. Current and new residents may have few places to shop or find services in Menlo Park
There is huge risk for residents and existing businesses that serve our community from the proposed Policy H4.7 "Redevelopment of Commercial Shopping Areas and Sites- Modify to remove the caveat that adequate retail services remain."
While ostensibly to promote development of affordable housing, such a policy change would undermine the livability of our existing and future residential communities. Not only must neighborhood markets be protected in some way, larger areas with major retail and community-serving businesses on El Camino Real and downtown side streets also must be protected. This policy change would go in the opposite direction. That could lead to residents needing to travel to other cities to obtain basic goods and services. New residents will need new retail and services establishments, not to be faced with fewer, yet that is a likely impact unless plans are made to retain and to add retail and community-serving businesses. As experienced so far in the Specific Plan area, offices have been displacing revenue-producing, community-serving businesses at a rapid rate. Zoning changes must be made to address this problem.
Recommend do not modify Policy H4.7 [not remove "the caveat that adequate retail services remain"] and also recommend adjusting zoning rules to promote retail and community-serving uses along El Camino Real and downtown side streets (e.g., like first floor uses on Santa Cruz Ave) and to minimize the proportion of allowable office, which neither adds revenue or goods and services for a rapidly growing residential population.
4. Development of objective streamlined project reviews are missing residential input in favor of developers wishes
The stated objectives for proposed Programs H4.E Streamlined Project Review and H7.A Create Residential Design Standards are to "add greater certainty to and streamline the development review process" by seeking input from the development community. There is no mention about seeking input from residents who deserve certainty, too. More density can be beautiful with few negative impacts on neighboring residents IF - and only if - the rules have residents in mind, too. The quality of life for residents can be supported in any objective standards and streamlining, if residents are involved, too.
Recommend inclusion of residents in the process of developing objective standards and streamlined project reviews.
5. A more comprehensive planning effort is needed
Few residents have been engaged so far in these major growth changes to Menlo Parks Specific Plan and General Plan. The public engagement process has paled in comparison with the ECR/D-Specific Plan and ConnectMenlo General Plan processes, yet the magnitude of potential development and impacts are at least as profound. How many in the community know that the parking lots downtown may become housing sites? How many people know that the city just examined nearly doubling the population? How many people know that additional traffic congestion and neighborhood cut-through traffic have not been addressed in the EIR?
The enormous amount of growth contemplated in the Housing Element has not been accompanied yet by commensurate comprehensive planning. The heart of Menlo Park is targeted to be redone in a major way without benefit of an updated community visioning effort. It is your duty to do better than this.
Recommend appropriate steps to involve residents and local businesses in a visioning and comprehensive planning process for El Camino Real and downtown.
This update process should not be an exercise to check off boxes. It needs to be a comprehensive guide for our communitys future. Much more planning is needed.
Thank you for your service,
Patti Fry, long-term Menlo Park resident and former Planning Commissioner
Former member Residential Review Task Force and of Commercial Zoning Ordinance Update
PS Please be sure the Housing Commissioners also receive this; there is not a single email address for that commission.