Dear Council
A couple of weeks ago the Almanac published a story on the status of the Housing Element Community Engagement and Outreach Committee and the resignation of several of its members.
Today, for the first time, I had a chance to quickly write my comments to this poorly presented article.
Please find my comments below which is also provided beneath the published article.
Link to the Article:
https://www.almanacnews.com/news/2021/11/04/a-committee-tasked-with-publicizing-menlo-parks-housing-plan-is-falling-apart
Regards
Soody Tronson
Menlo Park resident
Former member of CEOC
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As indicated earlier, below is a more detailed write up about the interaction between CEOC, the Staff, and the Mayor.
Due to the limits on number of characters I will be submitting this in a few submissions.
WHAT IS WRONG WITH THIS ARTICLE?
Unfortunately, despite having received objective and factual comments regarding CEOC, the reporter represented them mainly as the members having had their feelings hurt, boiling down the issues to street term soundbites.
There is so much background to this disaster brought on by the City that it is difficult to write it all down even in this long comment. So, I write about a few of my own distinct observations, all of which point to a system failure on the part of the City. And fortunately for the reader, that is all the time I have today. I have a much longer list. I am happy to discuss these issues with any member of the community, provided they fully identify themselves first.
The process with CEOC started very late even though the City has knew it was coming, it ignored some of the other critical aspects of Housing Element which focus on Safety Element update and the new Environmental Justice Element. It was a lot of rush, rush, and then silence.
I would also suggest that the Staff and certain members of the Council, instead of referring to volunteers who take time out of their busy professional and personal lives as "trouble makers" or "disruptors," take the time to actively engage and listen.
Please note that my reference to CEOC and members is not a reference to a formal CEOC position or any particular group of members.
POLICY V. ENGAGEMENT
The article references the Mayor stating that the CEOC wanted to ‘do policy’ instead of carrying out its designated role of “community engagement.” This is a massive red herring that the City has offered repeatedly to distract from the real issues. And sadly, the article, without research (they were sent the link to the recording of the meeting and other write-ups), does not push back on this false narrative.
For anyone who still does not understand or has been led to believe that CEOC thought "they were going to engage in policy" versus "engaging in outreach with the community," let me make that clear: That is furthest from the truth. I direct you to the recording of the CEOC meeting on June 10th, 2021, in which Mayor Combs and other senior Staff were in attendance. During the June 10th meeting, the Policy versus Engagement was first made an issue by the Staff and the Mayor. Several CEOC members, including me, clarified the distinction. At that time, the Mayor appeared to acknowledge that what he had heard was not correct (watch the video). As a side note, the only good that came out of that meeting had the City start publishing the recordings of various committees that I, along with others, for several years had been advocating for.
Yet, the Mayor continues to make this point even though he acknowledged at the June 10th CEOC meeting that we were not asking to do policy but rather receive the necessary information to do what was needed for outreach, the results of which would lead to policy by the appropriate groups. So, to continue to state the CEOC wanted to 'do policy' is intellectually dishonest.
The video recording of the June 10th, 2021 CEOC meeting can be found here:
https://tinyurl.com/5e6pxjms
STRUCTURE
California Government Code 65583(c)(7) requires: "The local government shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort." I would encourage you to read further.
The City of Menlo Park is required, by law, to have an engagement process. In the past RHNA cycle (the 5th cycle), the composition of the Housing Element (HE) group was different. It comprised community volunteers, members from the Staff, members from Council, and members from the Housing Commission (HC). The fact that it was poorly implemented is a separate issue.
This time, in its infinite wisdom, the City decided to bifurcate the HE effort. It created a separate engagement group that had no designed interaction with the Housing Commission. So, basically, if this were a Venn diagram, there was no overlap between HC and CEOC. This point was raised several times at various CEOC meetings. By way of example, the neighboring City of Palo Alto has an integrated Housing Element Working Group.
Even with this built-in defect in Menlo Park's Housing Element initiative, you have to remember that housing policy is not meant to be created in a vacuum. For City (HC, Council) to make policy, they need input from the community – i.e., CEOC, or at least that is what the law requires. The role of Menlo Park's CEOC (with all of its defects), according to the City's own website, was: "Committee members help guide and provide feedback on the types and frequency of activities/events/meetings and the strategies and methods for communicating with the various stakeholders in the community." (Please note the language around "the strategies and methods")
The Staff agenda for the Mary 27th meeting provided: "We bring this draft outline (Attachment A) and schedule (Attachment B) to the CEOC to garner feedback, ideas, and potential shifts in approach and strategy. We are looking forward to discussing any and all aspects of the draft community engagement plan with the CEOC." (Please note the language around "potential shift”)
Neither the role nor the goal was ever followed by the City, the Staff, or the Consulting firm the City hired at the cost of close to $1M (or so I am told). At the same time, no resources were ever allocated to the actual engagement recommendations by the CEOC (e.g., hiring local community members to distribute surveys).
Menlo Park Housing Commission Priority. Among the enumerated priorities of the HC is to "Review and recommend on the Housing Element of the General Plan." How does the "Housing Element" itself get produced so that the Housing Commission can review and make recommendations? Presumably, community engagement and feedback are instrumental in developing the HE. Yet, the content was never included in the CEOC proposed plan. There was a large gap in the process which neither included the Housing Commission nor the Committee (the missing overlap in the Venn diagram).
CEOC understood that despite being a flawed design, its role was not to set policy. Its function was to engage the stakeholders to gather and provide actionable feedback to the City Council (and perhaps the Housing Commission) to affect policy.
EXAMPLES
There were many communications between CEOC and Staff/Consultants, whether during meetings or by email. I provide some examples below.
Activity without more is not Productivity. The stated role of the CEOC fails to provide the ultimate purpose for such engagement: (1) Why are we reaching out to the community, (2) Why should the community engage, and (3) How will this engagement bring value to the City?
The meaningful Impact is Based on Meaningful Engagement. The Staff invested considerable time suggesting various forms of engagement (e.g., pin on the map, surveys, in-person events) into the engagement plan, which was acknowledged by CEOC. However, none included any content as to approach and the information to be shared with the community. I like to point out that by information, we are not talking about policy. Instead, what goes into the engagement that informs the community so the meaningful exchange can take place. This was clearly within the scope of CEOC.
When Form Affects Substance, it is Substance. We all know that survey design and questions will significantly impact the results. Anyone with the most modest experience in survey design, experimental design, marketing, etc., is aware of this concept. We see that daily in political campaigns and the sale of SAAS products. However, although we had a few meetings discussing the survey, most of the recommendations made by the CEOC were ignored by the Staff and the Consulting firm.
In an early CEOC meeting, I asked the Consultants, "How many unique respondents do you consider sufficient to have meaningful feedback for HE?" I was told at least 5000. Yet, according to the Staff Report, the number of 'total' respondents is under 800.
The survey results presented at the HC meeting on this topic, subsequently presented to the Council (see Staff Report 21-048-PC discussed during the Planning Commission and Housing Commission meeting Oct. 4th), had at least the following flaws.
SEPTEMBER 23RD POLLS CONDUCTED BY THE STAFF/CONSULTANTS WERE NOT RELIABLE:
a. Preferences Where to Build. It is essential to keep in mind that the presented polls did not correlate between the respondent’s preferences and the respondents’ locations. In other words, it was not clear from the poll alone whether residents in a particular neighborhood favored development in their own or other areas.
b. Answers 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 Safeway property. We still do not know this property is available and the likelihood of its development (a key criterion in the HE plan, according to the State). Furthermore, certain types of potential sites were repeated in all of the questions (e.g., parking lots) for all neighborhoods. Parking lots are the least controversial type of site and thus drove the answers toward them.
c. While Sharon Heights was the first choice for the prioritization of housing development in Commercial Areas, other than the Safeway property, no other sites were even presented in the surveys. There are other opportunities in West Menlo, which should have been included in the surveys. Furthermore, the HE process favors housing near amenities. Even if the Safeway property were available and had a likelihood of development, how would removing the amenities affect the need to be near amenities?
3. The number of developed or under development moderate housing units has been deficient in the 5th RHNA cycle (8% of stated goal). It is still unclear why that is and the City's plan to fix this issue for the remaining part of the 5th and not repeat the same in the 6th RHNA cycle . CEOC asked the Staff numerous times to provide the results of a postmortem of the 5th cycle RHNA – an integral part of any good project development process. But Staff refused to give this information. As a resident, if someone from the City or CEOC reached out to me, that would be one of my first questions: "So what makes this process different than the last one?" This is not policymaking, rather applicable content for engagement.
4. The construction has been primarily lump-sided east of El Camino and close to Bay Front, with hardly anything on the West side. This only leads to continuous segregation of the City. All types of housing must be proportionally built throughout the City.
WHILE WE ARE AT IT.
While we are on the topic, here are some other points to keep in mind.
5. Proportional units
When it comes to the size of BMR units to accommodate families, the numbers are not proportional to the numbers for the market and above market numbers. This is because the City management (Staff) decided to add “creativity” (Staff's own words), allowing for sizes to be disproportional. How does the City plan to provide proportional units of similar size/family size moving forward to not discriminate against families? I wrote and shared this with the Staff during my time with CEOC.
6. Out of control building of offices, Facebook campuses, and hotels to support them. This overbuilding only leads to more housing demand which the City has been struggling to meet. The City has allowed a lot of commercial buildings without addressing the demand for housing. In fact, in 2015, Almanac reported that Facebook was giving its employees a $10,000 bonus to move to Menlo Park. We need to curb the creeping footprint of the businesses until we address the adequacy of housing. Studies have also repeatedly shown that Silicon Valley tech firms are exacerbating inequality and that many local workers do not make enough to support a family.
7. El Camino Real and Downtown Specific Plan
Reviewing this Plan again, one notes the use of the phrase “guidelines that work together to establish a district’s unique character and identity.” Looking at this 2012 document, much of what was ‘imagined’ is still lacking. The Plan states a need to "preserve the small village character" of the city-owned property in the Oak Grove area. Not sure what a bunch of track strip mall type of units makes them of "small village character." Rather, it seems to act as a buffer to shield the affluent areas from higher-density housing. The Plan also states that the downtown plan provides an opportunity for local businesses. Yet, many of the businesses are not local businesses rather chains.
8. Non-profit agencies.
Non-profit status is an “accounting practice.” Non-profits make a lot of money and make a lot of profits, directly and indirectly.
And don't forget that Greystar Real Estate Partners (a for-profit developer) tore down and built high-priced apartments/commercial space in San Jose on a property that formerly provided housing to lower-income renters. Menlo Park is better off retaining or acquiring the titles to properties, having them developed by a developer and maintained by a firm.
9. Proximity to public transit.
There is no evidence to support the notion that "prioritizing housing sites close to transit, businesses, and public services" is critical, at least not in Menlo Park. While I wish we did have robust public transportation, that is not the case. Caltrain is very limited – one line North or South - and people still have to drive to it to use it. Most people have access to cars, buses can be re-routed, and highways are equally distanced from 101 and 280. This criterion seems more like another unspoken reason to minimize high-density housing in the more affluent areas.
