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Feb 19, 2020
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CEQA may not be not a valid reason to delay more downtown housing

Honorable Council Members, For several years, Menlo Park City Councils have agreed in principle that it would be good to review the Menlo Park El Camino Real / Downtown Specific Plan for the potential to add more housing including affordable housing, to help address the dire shortage, affordability crisis, and jobs/housing imbalance. The downtown area is rich in public transportation and services, making it a great place for housing at all income levels. Currently, the city allows 680 new homes downtown, most of which are being built or in the pipeline. Meanwhile, 4500 homes have been allowed in the Bayfront area near Belle Haven. But for several years, the city has not initiated a process of change, citing lack of staff capacity, is another way of saying that the Menlo Park City Council has not prioritized downtown housing over other issues. Now, a new set of reasons to defer action are being given in the discussion of the city’s 2020 goal-setting. If new housing would exceed the 680 units allowed by the El Camino Real/Downtown Specific Plan that was studied under the Environmental Impact Report for the downtown plan, then a new EIR would be needed, and this new EIR would take a long time. So, better to wait until the city goes through the upcoming process, as required by state law, to zone for housing for the next 8-year Regional Housing Needs Allocation cycle, which will start in 2024. But the CEQA rationale for delay seems to be decreasing. In the past, the biggest potential CEQA impact for infill development has been transportation. With infill development, drivers may drive more slowly, but people have more access to jobs and services, and will drive less. As of July, the new transportation impact criteria will be VMT (driving miles). Under the new rules, housing in a transit-rich area near services will almost certainly generate lower driving miles than the impact threshold and have “less than significant impact” based on the location. I am not a lawyer, but it seems that under the new rules, CEQA will be less of reason to put off exploring ways to add more homes downtown sooner rather than later. Therefore, we continue to urge the City Council prioritize the significant addition of housing, especially affordable housing downtown. Sincerely, Adina Levin Menlo Together https://menlotogether.org 650-646-4344 Received on Wed Feb 19 2020 - 08:47:35 PST