Good morning Menlo Park City Council and staff,
I hope you are all having a pleasant weekend. HLC appreciates the city’s
diligent work preparing an RFP to promote development on the city’s
downtown parking lots. The city’s vision to build affordable homes on its
downtown parking lots reflects the council’s commitment to meeting the
housing needs of all residents.
However, as written, Menlo Park’s draft RFP
includes requirements that will discourage applicants and render any future
project infeasible to build. Without amendments to the RFP, Menlo Park will
fail to implement its housing element commitments, missing a unique
opportunity to provide deeply affordable homes for local teachers, service
workers, and families.
Specifically, two provisions of the “Minimum Project Requirements” outlined
in section 3.1 of the RFP undermine the city’s stated intent to promote
affordable homes on the city’s parking lots:
- Requirement C, mandating a developer “Provide at least 556 parking
spaces … without financial contribution from the city" (pdf p. 15 from the
staff report
).
- Requirement D, mandating a developer “Design a development consistent
with applicable development and design standards, as opposed to a proposal
which meets some standards and seeks waivers and/or incentives pursuant to
the state density bonus law and/or the City’s AHO” (pdf pp. 15-16 from the
staff report
).
Requirement D is particularly bizarre because Menlo Park’s RFQ
explicitly supported developers using flexibility afforded them by state
and local law. In fact, the draft RFP also recognizes the flexibility
provided by state density bonus and the local AHO (pdf pg. 15 of the staff
report). The city’s inconsistency will discourage applicants and
needlessly reduce the sites’ potential for more affordable homes. If Menlo
Park does not want affordable housing developers to use the city’s own
Affordable Housing Overlay, then the policy is functionally useless.
Requirement C does not reflect the financial realities of affordable
housing development. Parking stalls cost as much as $50,000 per space.
Menlo Park is essentially asking a nonprofit affordable housing developer
to fully bear the cost of a parking structure that might cost more than $27
million. The citys housing element never analyzed the constraint imposed
by requiring at least 556 replacement parking spaces; in fact, the housing
element never mentions mandated replacement parking at all. Successful
affordable housing projects on public lots in Burlingame and Redwood City
have used additional city subsidy to fund parking structure development.
HLC recommends the city provide flexibility in its RFQ to best inform the
city council of realistic options that will produce feasible development
proposals. The city should remove requirement D entirely and replace
requirement C with the following language:
*“Provide as much replacement parking as economically feasible without
financial subsidy from the city or suggest the additional subsidy necessary
to fund additional replacement parking.”*
Menlo Park can only be a leader on affordable housing if the city council
and staff recognize the financial realities such developments face and
provide corresponding flexibility. By amending its draft RFP for homes on
the downtown parking lots, Menlo Park will more successfully meet the
parking and housing needs of its community.
Thank you for your consideration,
Jeremy
*--*
*Jeremy Levine (he • him)*
Policy Manager
Housing Leadership Council of San Mateo County
2905 El Camino Real
San Mateo, CA 94403
*www.hlcsmc.org *
650.242.1764
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