Honorable Planning Commissioners (with copy to City Council),
Following are comments that further my oral comments made when this topic was addressed previously by the Planning Commission. These focus mostly on the El Camino Real/Downtown Specific Plan area:
I am fearful that we residents will lose more restaurants and resident-serving retail and other personal services businesses with additional development at the same time our community is projected to increase dramatically in population. That will reduce quality of residential life and increase traffic as we have to drive to other cities to get needed goods and services.
Our Downtown and El Camino Real corridor comprise not only the heart of our city, they also contain the "neighborhood" shopping and personal services for my own area of Central Menlo, as well as Districts 3 and 4. Unlike other towns of similar size, our "downtown core" contains only a few blocks on Santa Cruz Avenue, and has had many community-serving businesses along El Camino Real as well. But there is no requirement to retain any such businesses along El Camino Real except at the intersection with Santa Cruz Avenue. We will need them - and more - in this corridor to serve new and existing residents.
There is nothing in the rezoning that will prevent further Office development from occurring, pushing out more restaurants and other small businesses that will be needed by a growing population. We know what happens from experience when FAR is increased, with the examples of the Middle Plaza and Springline developments after the ECR/D Specific Plan was adopted. Each of those projects maximized overall FAR - and Office FAR - at their Base and Bonus levels, respectively, while falling far short of the allowable number of Residential units. By HUNDREDS more of potential units in each project! This can happen again, even with increased potential housing density.
Why? Because there has been no requirement to create housing, or to tie non-residential development to housing development, even in zoning districts labeled as Mixed Use. Further, the ratio of allowable Office to housing or other uses simply exacerbates the existing - and increasing - imbalance of jobs and housing in our city. As shown in the attachment, in the ECR/D Specific Plan area, a jobs/housing ratio of 6.67-20.00 jobs/housing unit, assuming contemporary job densities, is baked into the zoning where Office can be 50% of the FAR. That has to change.
With the new Housing Element, the remainder of ECR-SE where the Big 5/BevMo shopping center exists is now designated as no longer subject to discretionary review. Without restrictions on Office, and without a requirement to retain ANY of the existing businesses, we should expect more of the same: the maxing of Office FAR, underwhelming amount of housing - if any - despite even higher density being allowed, and the loss of essential businesses that serve us residents.
Worse, there is a new FAR incentive to develop more housing with no restriction on the ratio of Office to Housing or requirement that such additional FAR be utilized solely for residential uses.
In order to encourage a robust residential community, I recommend the rezoning:
* Limit Office to the Base level (i.e., not allowed at the Bonus level) in all zoning districts. This can be readdressed when Menlo Park needs more jobs or Office space.
* Require a minimum amount of residential units for all projects in mixed use districts, not just projects that choose to be mixed use.
* Reduce the amount of Office allowed so that each mixed use project with housing provides more units than jobs (see attached easy calculator).
This should incorporate a sliding scale similar to the Base level already in use for R-MU in the Bayfront area. [note that the Bonus level allowances in R-MU allow jobs to exceed housing units]
* Modify the zoning for ECR-SE and ECR-SW so we do not lose valuable revenue-producing and community-serving restaurants and retail, by requiring at least the existing amount of retail SF to remain Retail/Restaurant. There is precedence -- the requirement to provide 10,000 SF of retail on the Middle Plaza project area. Only that amount was constructed. So it is essential to require a minimum amount in our existing shopping areas.
We will need more, not fewer, restaurants and resident-serving businesses to serve a growing population. This rezoning effort must address the inherent imbalance allowed by zoning that allows so much Office to displace non-Office uses. Further, simply allowing more housing density will not result in an improvement in the housing/jobs imbalance unless there are restrictions on allowed Office.
Sincerely,
Patti Fry, former Planning Commissioner
PS ECR-SE is not mentioned in the notes to the exhibit on page A116 of the staff report about maximum height. Why?
