Comments regarding Staff Report Number: 21-210-CC re land use strategy
Dear Council, please find my comments for Oct 26 2021 Council Meeting
Due to shortage of time I’ve kept my comments to a minimum and can elaborate as requested.
Warm Regards
Soody Tronson
Menlo Park Resident
Original Content from the report appears inside “quotation marks”). While these comments provide exemplary references, some topics are carried out throughout the report.
Summary:
- I am pleased that the report acknowledges the lump sided number of builds in District 1.
- We must keep in mind that Menlo Park is saturated with offices, and hotels (and businesses, namely Facebook) which continue to add to housing demand.
- If housing has to be near work, let’s not forget that there are many jobs around Sand Hill Rd and behind the golf course.
- Buses can be re-routed.
- The CEOC was a failure.
AND we need robust and defensible LIKELOOD NUMBERS which are currently missing.
TABLE 1: FIFTH CYCLE RHNA (2015-2023) – PROGRESS (UNITS) (PAGE 2 OF THE PDF)
“Table 1 shows Menlo Park’s progress towards meeting its RHNA from the fifth housing element cycle (2015-2023.) Since the beginning of this cycle, building permits were issued for 1,416 new housing units. While this figure is more than double the total amount of required housing (655 units), only the requirement for the “Above Moderate” income level has been met so far.”
We must understand the reasons why the City did not meet 5th cycle Targets. The report does not make any mention of why these numbers are not going met, in particular the low 8% for Moderate units. Without understanding these reasons, it is not clear how we can avoid the same happening again.
“When planning for how to meet the RHNA, HCD recommends an additional “buffer” of the housing allocation between 15-30 percent.”
The buffers do not provide any indication of likelihood of development. While this buffer is appreciated, the numbers do NOT provide an indication for LIKELOOD OF DEVELOPMENT.
COMMUNITY ENGAGEMENT AND OUTREACH (PAGE 12 OF THE PDF)
“From the outset of this effort, the City Council has stressed the importance of community engagement, especially with underrepresented populations, and creating a process that is inclusive and intentional. To assist in achieving this goal, the City Council formed the Community Engagement and Outreach Committee (CEOC) who has helped guide the project team in its outreach efforts. …. ”
As many of you already know, many of the CEOC members have resigned in protest over the implementation of this committee, including myself. Therefore, this is at best a misleading statement.
NET RHNA TARGETS (PAGE 12 OF THE PDF)
“When crafting these strategies, the project team identified various sites that could facilitate housing development, evaluated the potential for added density, and estimated each site’s capacity for both affordable and market rate units. The project team also assigned development ratios to consider the likelihood of sites within broad development areas to develop with housing during the planning period. Criteria for this analysis also included lot size, property ownership, age of existing buildings, proximity to transit and city services, displacement of existing affordable housing units and clustering of affordable units.”
While the report indicates that development ratios to consider the likelihood of sites were included, no actual basis or numbers are provided. We need to understand how these numbers were created.
LIKELIHOOD OF DEVELOPMENT. Most cities rely on assumptions from planning staff on the likelihood of development. Such assumptions can easily reflect a “planner’s optimism” that development will inexorably flow from favorable zoning and adequately permissive land use regimes alone. The review of the study conducted by the UCLA Lewis Center for Regional Policy Studies publication “What Gets Built on Sites That Cities "Make Available" for Housing?” provides some key points, including that the probability of ‘officially’ selected sites in most
LAND USE SCENARIOS (PAGE 12 OF THE PDF)
Proximity to transit and city services should not be used to discourage housing in more affluent neighborhoods . Throughout the report, as of course recommended by HCD, proximity to these amenities are important. That said, the same, in particular, transit can be easily mis-used to exclude properties in the more affluent areas. Furthermore, let’s acknowledge that: public transit on the Peninsula currently is almost non-existent and limited to: (a) one train line and (b) buses. To get to the train most people have to drive to the station and the buses can be re-routed to serve any new development.
Same is true with respect to the comment regarding being in “walking distance” of 15-20 minutes to resources such a parks and transit. This same criteria can be mis-used to exclude more affluent areas from being developed.
SHARON HEIGHTS SHOPPING CENTER (PAGE 14 OF THE PDF)
While Sharon Heights Shopping Center is identified as potential site in Sharon Heights, there is no indication of its likelihood of development has been provided. There is nothing in the report to indicate that the owner has been contacted.
We must understand what policy changes are needed and what are the likelihood of those changes. There is only a reference to under-developed lots within the Sharon Heights neighborhood, near Sand Hill Road which requires policy changes.
Other commercial properties must be considered. There is no reference to all the other existing commercial properties along Sand Hill road or those tucked away behind the golf course.
OTHER (PAGE 14 OF THE PDF)
It was premature to allow the SRI application to be submitted. SRI property application was allowed between the Commission meeting and today’s meeting thus removing it from the 5th Cycle and adding it towards the 6th Cycle. This was shortsighted as we are still struggling to meet the 5th cycle.
LAND USE OPTIONS (PAGE 16 OF THE PDF)
We must first consider housing before adding more offices and mixed use. The City continues to allow the building of offices, expansion of the Facebook footprint, and hotels to support them which (a) Only leads to more housing demand which the City has been struggling to meet, (b) We need to curb the creeping footprint of the businesses.
2023-2031 HOUSING ELEMENT UPDATE SUMMARY OF COMMUNITY SURVEY (PAGE 25 OF THE PDF)
The engagement and surveys are not reliable. Menlo Park has about 3,000 residents. In conversations with the Staff and Consulting Firm, it was stated that we need at least about 5000 responses. We only had 763 respondents in total (keeping in mind that is for all surveys)
Furthermore, as stated in another email on October 4th, 2021, (a) responses regarding preferences as to where to build in surveys cannot be assumed to be reliable. It is important to keep in mind, that the polls, at least during the meeting, did not provide a correlation between the preferences and the respondents’ locations. That is, it is not clear from the poll alone whether residents in particular neighborhood favored development in their own or other neighborhoods. (b) responses are driven by questions. The poll was very limited as to potential sites. For example, it basically excluded other locations west of Alameda, except for the Sharon Heights’ Safeway property which we still don’t know if it is available and what is the probability that it will be built. Furthermore, certain types of potential sites, were repeated in all the questions (parking lots) which drove answers toward those answers.
2023-2031 HOUSING ELEMENT UPDATE SUMMARY OF COMMUNITY SURVEY (PAGE 26 OF THE PDF)
“About half of survey participants are from households with children (51 percent).”
We have not served the families in need of housing. While we know from this report and previously city-commissioned reports, many of our residents are families who also need housing.
That said, as I have commented several times before, the units allocated to BMR, are not adequately proportioned for families.
a. When it comes to size of BMR units to accommodate families, the numbers are not proportional to the numbers for the market and above market numbers. This is primarily because of the City’s “creativity” which allows BMR units to have a smaller square footage. I have requested and recommended a change to the City’s practice.
b. How do you plan to provide proportional units of similar size/family size moving forward so as to not discriminate against families?
