Dear Planning Commissioners,
Please consider these recommendations and rationale for them, and discuss the questions following.
RECOMMENDATIONS
1.Include all Specific Plan subdistricts in the zoning and plan changes. Don’t omit ECR-SE and ECR NE-R
2. Limit allowable office in mixed use areas to a maximum FAR that is tied to appropriate housing growth. Make sure the arithmetic works properly so that growth through development is likely to improve both the housing supply AND the balance of jobs and housing.
3. Include an overlay along El Camino Real that preserves community serving uses (including restaurants and retail) and excludes new 1st-level office space.
QUESTIONS FOR DISCUSSION AND RATIONALE FOR ABOVE RECOMMENDATIONS:
A. WHY ARE MAJOR OPPORTUNITY AREAS NOT INCLUDED?
The list in Attachment B excludes Specific Plan subdistricts ECR-SE and ECR NE-R. The former, ECR-SE, includes the new Middle Plaza area, the large Big 5 shopping center, and parcels north along El Camino Real to Ravenswood. It makes no sense for this large area, and the NE-R area, to be excluded.
B. HOW WOULD OFFICE GROWTH BE LIMITED?
Because there seems to be near-insatiable developer demand for office - even post-COVID. A major driver of housing demand has been the big increase of office space in Menlo Park. Zoning changes that address only housing can make it possible to build more housing but not improve the ever-worsening balance of jobs and housing. Alternatively, zoning changes coulc implemented specifically to result in an improved balance of housing and non-residential development.
Consider there is no current requirement (except Bayfront R-MU) for office growth to be tied to commensurate increases in housing. If FAR is simply increased now, without any other adjustments, the amount of space available to develop office would also increase.
• In the Specific Plan, office growth currently is “limited” to 40% of the total allowed FAR (See attached SP Table E2 Development Intensity and Building Height Standards for reference)
o If FAR is increased, the amount of office allowed will increase, too. And so would the related demand for new housing (e.g., if the total FAR is 200%, the office FAR could be 80%).
o Even with a “limit” for office, a project can be all-office
o Office growth in the Specific Plan area has surpassed housing growth and displaced community-serving uses and retail/restaurants. This result was not anticipated when the SP was created. Housing and retail growth was expected, and office growth was not (see Footnote 1). The opposite has happened. Note that prior to the SP, office growth was limited to 40% FAR (lot area); it appears the change for office in the SP was misguided given the actual market conditions since then.
• No changes to the zoning ratios have been made yet. Why not now?
o Old arithmetic doesn’t work. Offices have packed in more workers than previously, leading to more demand for housing for the same amount of office space than when the Specific Plan and General Plan were created. As a result, Menlo Park has greatly increased its office space but fallen short on housing.
The arithmetic of two “commercial” floors and five housing floors may not be adequate to add enough new housing for new demand while also remedying the current shortage (see Footnote 2).
o If the ratio of housing and workers does not improve - even if the housing supply increases - Menlo Park will be faced with yet another large RHINA allocation in the future.
To stop chasing its tail with new demand for housing (from more office space) while also addressing the current housing deficit identified by the state, the plan and zoning changes must limit office more than the rules currently allow AND tie office growth to housing growth.
C. HOW WILL A BALANCE OF USES BE ENCOURAGED FOR RESIDENTIAL QUALITY OF LIFE?
A major increase in population will require a major increase in community-serving uses, including retail, restaurants, dry cleaners, and repair shops. What many residents have loved about Menlo Park is the ability to live, dine, shop, and take care of personal business locally without needing to go to another city. Now is the time to address these needs through zoning changes, too.
A considerable number of community-serving businesses have been lost in redevelopment in the SP area. The SP studied and anticipated an increase, not a decrease in such businesses. In fact, SP traffic studies assumed that impacts like traffic would be lessened because of the proximity of such uses. Thus, it may be possible that zoning changes to better protect such uses would not require additional environmental study.
Although there is a retail overlay on Santa Cruz Ave., there is no requirement on the entire length of El Camino Real for ANY community serving uses (other than the token 10,000 SF that’s now part of Middle Plaza). Yes, there is no current requirement for retail or restaurants on the Safeway or Big 5 shopping center sites. More can go bye-bye like the popular Jeffrey’s Burgers.
Thank you for your consideration.
Patti Fry, former Planning Commissioner
PS I have attached SP Table E2 Development Intensity and Building Height Standards for reference.
FOOTNOTES
Footnote 1: Task G Public Benefit: Financial Feasibility Analysis March 9, 2012, page 20 concluded “In the short- to mid-term [2040], once the office market is restored, the analysis shows that the proposed base and maximum FAR office buildings would still be infeasible.”
Footnote 2: Assuming a current ratio of square footage/worker (150 SF/worker as used by Meta) and an average housing unit size of 900 SF/unit, the ratio of new housing space to new office space must be no less than 6:1 (900 SF and 150 SF as shown in the example) or one-seventh of total FAR using these assumptions if ALL the remaining SF is housing.
If the project also includes other non-residential uses, the housing to office ratio would need to be even greater. This calculation only results in one new unit for one new worker, not any new units for existing workers.
