Honorable Mayor and Councilmembers:
I urge you to discuss the following topics and to authorize zoning changes recommended below.
QUESTIONS
1. How can zoning changes enhance the likelihood of achieving your development goals, instead of the rules merely making it possible for a determined developer to build more housing?
2. Why has the amount of Office space skyrocketed, in the Specific Plan area especially, and displaced restaurants, retail, and other community-serving uses while not providing commensurate growth in housing?
For example, the two large projects on El Camino Real (Middle Plaza and Springline) could have provided 360 more housing units had they maxed out the housing density allowed by current zoning when they maxed out the total FAR at their respective Base/Bonus levels. Instead, they built Offices and nominal community-serving uses and roughly half of the amount of housing units allowed.
I submit that the primary reasons are:
* There is no minimum amount of housing required in mixed use zones
* There is no tie between Office growth and housing growth except R-MU in the Bayfront area
* The amount of Office allowed is based on out-dated business practices when SF allotted per worker was two to six times the amount allotted now.
* The Specific Plan consultants were wrong when they stated there was no market for Office for the foreseeable future (2012-2040), so the amount of Office was increased from 40% of the lot area to 40% of the project FAR. Office demand was high, displacing many beloved community-serving uses instead of projects that increased retail/restaurants and housng.
3. What community-serving uses will be needed to support current residents as well as the projected large population growth? What might be the downside of the proposed zoning changes if there are not also new protections for uses that support a growing community?
Of particular concern ought to be:
* There are no requirements to preserve, much less to increase, restaurants or retail or other community-serving uses along El Camino Real and other neighborhood shopping areas?
Major community-serving centers such as the Big 5 and Safeway shopping centers have zero current requirement to retain even one SF of retail space. Just recently we are faced with losing the popular Jeffreys restaurant and a repair shop following the losses of myriad others.
* How would parking be provided to support patrons of local businesses if all the downtown parking lots are replaced fully with other uses? It appears that new state law might prohibit a requirement for any parking, even replacement of current parking on those lots..
Parking is essential. Local and regional transit serving Menlo Park is inadequate now and is unlikely to improve substantially to adequately serve new residents and other patrons.
* The SEIRs assumptions about environmental impacts likely would be inadequate about the impact of the proposed zoning changes because of the potential loss of community-serving uses. Growth, not a decrease, of community-serving uses was assumed in the Specific Plan EIR to offset new traffic from development growth.
The continued loss of community-serving uses would require residents and other shoppers/diners to patronize businesses in other communities, increasing traffic and decreasing city revenue. Public transit is not nearly good enough to support the transit needs within Menlo Park or to/from other cities.
RECOMMENDATIONS:
1. Modify zoning rules to promote housing and to minimize Office space by increasing housing density while also decreasing Office intensity such as:
* Require a minimum amount of housing units in mixed-use projects and as a percentage of the total project FAR
* Do not conflate the concepts of Office and community-serving uses into the term "commercial uses". Distinguish Office from the others.
* Allow a maximum amount of Office space in mixed use districts that reflects current business practices (e.g., no more than 1/6 of the FAR of a project, or arithmetically less where there is a community-serving overlay)
* Modify the counting of Office SF against the Maximum Allowable Development of non-residential uses in the Specific Plan area and the General Plan.
For example, lower that MAD by the amount of Office SF that is replaced by housing SF OR do not net out from the MAD the Office space that is replaced by housing or new retail/restaurants. This counting change should be applied to all development-to-date under the Specific Plan and General Plan.
2. Identify ways to provide adequate parking to support community-serving businesses and a growing population.
* Before removing all downtown parking lots for parking, be sure to evaluate future needs for parking. With potential reduction of parking on El Camino as well as fewer opportunities in new development on El Camino, a large parking structure downtown will be critical.
* Consider not rezoning at least one major parking lot so that a large parking structure could be built on it. I recommend retaining the large parking lot behind the downtown post office because it is conveniently located to support businesses on El Camino Real as well as Downtown.
3. Protect and expand community-serving businesses along El Camino Real, such as:
* Create an overlay for first-floor community-serving businesses (no office uses) along El Camino Real, exempting all-housing projects from this requirement
* Apply the zoning changes to all Specific Plan districts. Do not omit the ECR-SE and ECR-NER where the Middle Plaza and Springline projects and other opportunity sites are located.
Please authorize changes such as these in order to respond to the RHNA mandates as an opportunity to enhance the quality of life for a growing population rather than merely to react to a critical deadline.
Thank you for your service,
Patti Fry, long-time resident and former Planning Commissioner
