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Nov 28, 2025
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Effect of Current 15% BMR Strategy and Cookie Cutter Consultant

Dear City Council Members and City Manager:

Thanks to all the City Council members, except Mayor Combs, Menlo Park
taxpayers have paid $165,000 for M-Group’s *COOKIE CUTTER* assessment of
the downtown parking initiative.

Did M-Group consultants talk to business owners or resident? Did they
follow state law contained in Government Code 65583(c)(7) that states:

*The local government shall make a diligent effort to achieve public
participation of all economic segment of the community in the development
of the housing element, and the program shall describe this effort. (Page
1-5, Introduction, Menlo Park 2023-2031 Housing Element)*

Did M-Group assess and make recommendations to the City Council to adjust
their 15% BMR strategy to a by volume sliding scale in the City’s
negotiations with developers?

The City Council’s current Below Market Rate (BMR) percent rate of 15%
strategy with developers creates a flooding of market rate housing that is *NOT
affordable*. It put *85%* of all new housing by developers at or above
market value, and our downtown business owners and their employees’
livelihoods are being threatened because they are taking the burden of the
poorly executed BMR strategy.

Some examples are as follows:


- 141 Jefferson: out of 483 housing units only 30 accommodate very low &
low income;
- Willow Village: out of 1730 units only 195 accommodate very low & low
income;
- Springline: out of 183 units only 20 were below market rate (BMR).

Additionally, did M-Group study the feasibility of alternative sites for
housing? I have calculated the numbers and we can meet the 1,012 very low
and low income Menlo Park Regional Housing Needs Allocation (RHNA) without
having to takeover the downtown parking lots. A variety of options are
available, but *COOKIE CUTTER CONSULTANTS* do not tend to put in the time
or effort to discover alternatives, but pull from their past files to earn
their money.

I implore the City Council to pass the ballot initiative with *3,928* Menlo
Park registered voter signatures and list to the voice of the people.

Rubye Cervelli, PhD, MA, MBA
BMR Stategy.docx
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