HomeMy WebLinkAbout2021-05-18 City Council Summary MinutesCITY COUNCIL
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Special Meeting
May 18, 2021
The City Council of the City of Palo Alto met on this date in virtual
teleconference at 5:01 P.M.
Participating Remotely: Burt, Cormack, DuBois, Filseth, Kou, Stone; Tanaka
arrived at 7:00 P.M.
Absent:
Agenda Changes, Additions and Deletions
Mayor DuBois noted an at-places memorandum regarding Agenda Item
Number 5 and Council Member questions regarding Agenda Item Number 3.
Study Session
1. 955 Alma St [21PLN-00013]: Request for Prescreening of a Proposal to
Rezone the Subject Site From RT-35 to Planned Community/Planned
Home Zoning (PHZ) and Redevelop the Site With a new 4-Story Mixed-
use Development That Includes 36 Residential Studios, 6,348 Square
Feet of Office Space, and a Below Grade Parking Facility.
Environmental Assessment: Not a Project; any Subsequent Formal
Application Would be Subject to California Environmental Quality Act
(CEQA) Review. Zoning District: RT-35 (Residential Transition District)
South of Forest Avenue (SOFA) II Coordinated Area Plan (CAP).
Amy French, Chief Planning Official, reported the Applicant proposed
rezoning a parcel located in the South of Forest Area (SOFA) II Coordinated
Area Plan (CAP) to Planned Community (PC) or Planned Home Zone (PHZ).
The concept fulfilled the initial qualifying criteria for a PHZ. The site was
currently zoned Residential Transition District (RT-35) and abutted an RT-35
zone, a one-story gym, and an RT-50 zoned, one-story office building. An
affordable housing development was located in the same block as the
subject site. The site contained a single-story, 8,000-square-foot office
building with four parking spaces off Alma and approximately 11 parking
spaces off the alley. The Applicant proposed a four-story, mixed-use
building with 36 residential studios, 6,300 square feet of office space, a
below-grade parking facility, and two surface parking lots. Where the SOFA
II CAP allowed a 1.15 floor area ratio (FAR) for non-PC development, it
allowed a 1.5 FAR for PC development. The project proposed an FAR of
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2.68. As proposed, the stair and elevator exceeded the 50-foot height limit.
The development was not going to increase the number of jobs and reduced the existing office floor area by slightly more than 1,700 square feet. The
development provided 20 percent inclusionary housing. The Applicant
requested Option 2 affordability and a 30-percent parking reduction. The
four parking spaces off Alma created a vehicle/pedestrian conflict,
encroached into the sidewalk, and were hazardous for vehicles backing into traffic on Alma. The Applicant was able to request a 41 percent parking
reduction if it eliminated the four parking spaces along Alma or redesigned
the parking facility to maintain a 30 percent parking reduction. There was
sufficient room for additional bicycle parking. The Applicant requested a text
amendment to the SOFA II CAP so that it was consistent with Municipal Code
Chapter 18.38.
Heather Young, Applicant, advised that the project site was located on the
edge of Downtown and more than 160 feet from a single-family residential
(R-1) neighborhood. As one moved closer to Downtown, building heights
increased and buildings became more dense. The Applicant proposed a
ground-floor office use, three floors of residential units, a central courtyard,
and a roof terrace. Each floor contained 12 micro studios. The residential
entrance and ramp to the garage were located off the alley. The Applicant
proposed using triple-stack parking machines and providing storage lockers
and bike storage in the garage. Bicycle parking was located near the office
and residential entrances. The reduction in office space and the addition of
residential units resulted in a net housing gain of 41 units. Residential unit
size ranged from 329 square feet to 407 square feet. A portion of the roof
terrace was available for office tenants' use. The Applicant proposed a galley kitchen, a full bath with a stacked washer and dryer, a living space
with sleeper sofa, office storage unit, and media storage unit, and an
outdoor balcony for each residential unit. Components of the media unit
converted to a coffee table and dining table.
Laura Beaton, speaking on behalf of Allan Akin, Neilson Buchanan, Mary
Dimmit, Wolfgang Dueregger, Scott Van Duyne, John Guislin, Michael Hodos,
Christian Pease, Carol Scott, and Geethan Srikantan, commented that the
Council needed to ensure the project reflected a real and equitable approach
to affordable housing by providing Below Market Rate (BMR) units and
ensure the project was not included in the existing Downtown Residential
Permit Parking Program (RPP). The applicant proposed market rates or
almost market rates for more than half of the affordable units. The
Applicant did not identify affordable units within the development or the
units' access to amenities. Because of the requested parking waiver and the
opportunity for unbundled parking, the risk of parking intrusion into
surrounding neighborhoods was real.
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Becky Sanders, Palo Alto Neighborhoods (PAN), noted the density of the
proposed development was about 149 units per acre. Only three of the seven affordable units were truly affordable. She asked the Council to
require 12 low-income housing units.
Scott O'Neil noted that the project was located near a Caltrain station and
potentially acted as a sound barrier for noise from the Caltrain Corridor. He
urged the Council to support the project and allow similar development
along Alma.
Winter Dellenbach opposed the project. As the Applicant proposed the
project, a tenant was going to pay $27 less per month for an affordable
housing unit than a market-rate unit. Only three of the proposed affordable
housing units were legitimately BMR units.
Elan Loeb supported the project and any other actions that increased
affordable housing. The project's proximity to the Caltrain station was
important and a huge feature of the development.
Rohin Ghosh supported the project and appreciated its location next to
public transit.
Linda Hibbs, Webster House Health Center Executive Director, supported the
concept and project. The small size of micro units was a worthy tradeoff for
workers' long commutes into Palo Alto.
Adam Schwartz supported the project and three- and four-story buildings
along Alma.
Kelsey Banes urged the Council to support the project. Taller buildings
provided more housing units.
Anne Paulson supported the project as suitable for young people who did not
own vehicles. All of the proposed units were inexpensive because of their
small size.
Frances Capompili supported the project as a way to empower renters and
create jobs. More housing options benefited long-term residents.
Noelle Langmack supported the project, taller housing projects, and infill
projects.
Terry Holzemer suggested the Council consider the developer's proposed
public benefits in light of the requested bonuses. The developer vastly
overstated the number of affordable units.
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Rebecca Eisenberg remarked that the Council's refusal to tax businesses to
raise affordable housing funds resulted in affordable housing projects with
units one-third the size of hotel rooms.
Council Member Cormack indicated a wide variety of housing was important
for people at all stages of life. Some people were going to find that the
small units worked well for their lifestyles. The built-in furniture was clever.
The location was within walking distance of services and shops. The Staff Report and Applicant presentation did not indicate whether parking spaces
were going to be assigned or charged for, but that was something to
consider in conjunction with an RPP. She asked if the Council approved
Option 2 unanimously.
Mr. Lait replied yes.
Council Member Cormack felt the location was good, and a building height of
50 feet was acceptable in the environment and neighborhood.
Vice Mayor Burt believed these projects were important. This housing type
was in the mix of housing types that the Council wanted in the community.
The affordable housing project at 801 Alma provided even smaller units.
The project's design, both internally and externally, was good. Common
space in the courtyard and roof terrace was good. Providing very small units
seemed to be the easiest way to comply with the PHZ affordable housing
formula; therefore, there could be a proliferation of housing projects with
very small units. The Council needed to clarify that approval of a parking
reduction did not condone parking intrusion into surrounding neighborhoods.
He inquired whether the project was eligible for participation in the RPP.
Molly Stump, City Attorney, advised that Staff held an initial discussion of
the issue. It appeared that the building site as currently drawn fell within the Downtown RPP District. The Council had some discretion in drawing the
RPP districts and amending them over time. However, the Council was not
permitted to distinguish between multifamily and single-family residences in
designing and administering a program such as the RPP.
Council Member Filseth requested the height of the project at 801 Alma.
Ms. French responded approximately 50 feet.
Council Member Filseth indicated that rent of $3,000 per month did not
enable renters to live in Palo Alto unless they were already able to afford the
rent. The affordable percentage needed to actually be 20 percent rather
than three units. Most residents parked at home at night, and the RPP was
not applicable at night. Tenants for the project were likely to park on the
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first block of Addison Street, which was not fair to Addison Street residents.
The point of walkability and locations near transit was to get people out of their cars. Free parking in the neighborhoods and constraints on parking
were not going to get people out of their cars. The affordability of housing
units and parking had to be figured out before the project was allowed to
proceed.
Mayor DuBois liked the design and the studio units. He expressed concern about residents and office workers mixing on the roof terrace, but his
primary concern was parking. The minimum requirement for parking under
the State Density Bonus Law was one parking space per housing unit.
Excess parking spaces were provided for the office use, and the office use
was required to provide a Transportation Demand Management (TDM) Plan.
Perhaps a development agreement was the best way to ensure the project
did not affect parking permits elsewhere. He was less interested in a text
amendment for the entire SOFA II CAP. Perhaps a 50-foot height limit along
Alma was the answer.
Council Member Stone appreciated the ingenious interior design. The
project was compatible with the neighborhood and walkable to shopping,
restaurants, retail, and the Caltrain station. Three of the seven units were
affordable for households with 140 percent of the Area Median Income
(AMI), which fulfilled the letter of the law but not the spirit of the law. He
hoped the Applicant redesigned the project to provide more truly affordable
units. He asked if the rental rate was approximately $3,000 per month and,
if so, he requested the rental rate for the affordable units.
Ms. Young responded yes. Rent, which included utilities, for very-low-
income tenants was $1,382, $1,963 for low-income tenants, and $2,973 for
moderate-income tenants.
Council Member Stone noted the average rental rate for apartments in Palo
Alto ranged from $2,100 to $2,700.
Ms. Young understood the Council's desire was to obtain as many very-low-
income units as possible. The Applicant tailored the project to provide as
many very-low-income units as possible within the formula component but
was willing to reevaluate the unit mix and return with an option.
Council Member Kou concurred with comments regarding parking and
affordability. Perhaps the City Attorney's Office and the Office of
Transportation were willing to review San Francisco's RPP Ordinance because
it excluded developments of higher density.
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Ms. Stump advised that she received an update from San Francisco's lead
transportation attorney earlier in the day. Council Member Kou's comment was not descriptive of San Francisco's RPP Ordinance. The City Attorney's
Offices for Palo Alto and San Francisco held similar views of what State law
allowed. An update regarding Council discretion was going to be provided to
the Council.
NO ACTION TAKEN
2. 2239 Wellesley (21PLN-00045): Request by Cato Investments, LLC for
Prescreening of Their Proposal to Rezone the Properties at 2239 and
2241 Wellesley from R-1 (Single Family Residential) to Planned
Community/Planned Home Zoning (PHZ) and to Redevelop the Site
With a 24-Unit Multi-family Development. Environmental Assessment:
Not a Project; any Subsequent Formal Application Would be Subject to
California Environmental Review Act (CEQA) Review.
Claire Raybould, Senior Planner for Planning and Development Services,
reported the Applicant requested rezoning of two single-family residences
(R-1) located at 2239 and 2241 Wellesley to Planned Home Zoning (PHZ).
The Applicant proposed demolition of the two existing residences, merger of
the two lots, and construction of a 24-unit multifamily residential
development. The project was going to provide more housing than jobs as it
was exclusively residential. The project included five affordable housing
units with two of the units affordable for very-low-income households and
three of the units affordable for low-income households. The Applicant also
requested a 33 percent parking reduction. The project did not appear to
comply with Council direction not to rezone sites within an R-1 Zone District
to PHZ and direction for moderate adjustments to the base zoning. The project exceeded R-1 Zone District requirements for building height, floor
area, daylight plane, setbacks, and density. The project required an
amendment of the Land Use Map because it did not comply with the
Comprehensive Plan Land Use Designation for single-family residential.
Matt Larson, Applicant representing Cato Investments, advised that the
project targeted rents that were affordable for essential workers. Of the 24
units, 19 were going to be offered at rates affordable for moderate-income
households, three for low-income households, and two for very-low-income
households. The project did not need a public subsidy to provide affordable
housing. The location was surrounded by many multifamily apartment
buildings and walkable to transportation, job centers, Stanford University,
grocery stores, and retail shops. In 1978, the parcels were zoned R-3. The
proposed building height was only 2 feet 10 inches higher than the adjacent
single-family home.
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Nick Gomez, Applicant representing Cato Investments, indicated that the
project proposed 16 parking spaces on the ground floor and a mix of studio and one-bedroom units. The ground floor also included two accessible units,
a lobby, and a trash and utility space. The size of units ranged from 350
square feet to slightly less than 800 square feet. The building was taller
than the adjacent residence due to the modular design. Massing was broken
up with vertical, wood-sided bays, and horizontal wood siding provided warmth and articulation. Decks were included with studio units to provide
some outdoor space. Green screens and wood slats screened the parking
area from the street and adjacent residence.
Mr. Larson explained that reducing the number of units increased rent
amounts. A development with 12 units increased the average rent by more
than 50 percent, which exceeded the goal for moderate-income households.
The Applicant was willing to build the project, commit to no profits for 20
years, and enter into a development agreement with the City.
Becky Sanders remarked that the project did not belong in an R-1 Zone
District. If the Council approved the project and other developers received
the same rezoning, it was theoretically possible to convert 2,700 acres of R-
1 parcels to 191,000 residences. The project was worthy of consideration
for a commercially zoned parcel.
Rachel Cox viewed the project as a precedent. Residences were required to
comply with development standards. The project provided very little
outdoor space. Approving the project was not logical given existing parking
issues and the proposed building height.
Andrew Fetter commented regarding the developer's profit motives and land
purchases. The project violated development standards for building height, daylight plane, setback, maximum site coverage, residential density, floor
area ratio (FAR), and parking. The Applicant did not maintain the property
while it was vacant.
Scott O'Neil remarked that achieving the Regional Housing Needs Allocation
(RHNA) meant more housing whether residents wanted that housing as infill
development or development of open space. Developing open space created
more traffic, a greater carbon footprint, and more risk from wildfires.
Mark Whiteley opposed the project because it was not fit for the site. The
project was going to obstruct views for children walking and biking to school
and add traffic to an already busy street.
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Susan C. noted that the project proposed greater density than allowed under
the former R-3 zoning. An out-sized residence was not compatible with the
College Terrace neighborhood.
Michael Quinn related that the City was not going to achieve its RHNA goals
if residential construction did not occur in R-1 Zone Districts. The project
was tasteful and good.
Kelsey Banes stated the Council needed to fix R-1 zoning because the status
quo was exclusionary.
Adam Schwartz indicated that R-1 zoning was a barrier to new housing
needed in the community. The project was appropriate for the College
Terrace neighborhood.
Anne Paulson believed Palo Alto had to allow more housing but not in open
space.
Rohin Ghosh felt approval of the project indicated there was a place for the
younger generation in Palo Alto while denial of the project indicated the
younger generation was not welcome in Palo Alto.
Truc commented that opposition to the project did not serve the demand for
more housing units. One block from the proposed site was a parcel better
suited for the project.
Noelle Langmack supported the project because it was a great opportunity
for affordable housing. The neighborhood was filled with apartment
buildings.
Laura Forrest suggested the project was better suited to the former Fry's
location or parcels along El Camino Real.
Rebecca Eisenberg commented regarding differences in development
standards between San Francisco and Palo Alto.
Vice Mayor Burt encouraged the Applicant to pursue housing projects in
areas designated for them. The Applicant was allowed to construct an
Accessory Dwelling Unit (ADU) and Junior Accessory Dwelling Unit (JADU) on
its R-1 lots. The Council previously supported projects that increased base
zoning beyond the moderate level.
Council Member Kou inquired regarding the parking reduction.
Ms. Raybould advised that the Applicant hoped to utilize a concession under
the State Density Bonus Law; however, the concession was unnecessary
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because the Council determined the appropriate number of parking spaces
for a PHZ project.
Council Member Kou asked if the Applicant proposed to restrict the units to
people already working in Palo Alto and require tenants to provide proof of
their jobs.
Mr. Larson reported the Applicant was willing to work with Staff, experts,
and the community to ensure as much as legally possible that the policy
preferences for tenants were met.
Council Member Kou asked if the Applicant was willing to deed restrict units.
Mr. Larson indicated that the Applicant was open to suggestions but had to
comply with fair housing laws.
Council Member Kou remarked that the Applicant's divisive approach was not
welcomed. Construction of affordable housing projects was possible without
subsidies, but the projects needed to be located in suitable areas.
Council Member Filseth advised that the proposed project included five BMR
units while previous PHZ proposals included 23 BMR units, 58 BMR units,
and 110 BMR units. Five BMR units were better than none, but achieving
the target BMR units was difficult with five units per project. The proposed
units fit in the existing status quo for Palo Alto's market-rate housing. The
project seemed to be a conventional apartment building except for its
location in an R-1 zone and its need for parking. He encouraged the
Applicant to explore other zones in Palo Alto.
Council Member Cormack noted the use of charged communications by both
proponents and detractors of the project and acknowledged the emotional
intensity generated by the project. Modular construction techniques reduced
construction costs and construction time. She inquired whether there were
many two-story apartment buildings located near the project site.
Jonathan Lait, Planning and Development Services Director, reported many
duplexes and fourplexes were located in the area.
Ms. Raybould added that a six-unit development and an eight-unit
development were located across the street from the project site.
Council Member Cormack remarked that the Council previously increased
building height to obtain a floor of affordable housing. The additional story
did not feel comfortable adjacent to one-story and two-story homes.
Accepting the project was possible if it complied with the building height and
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daylight plane. If the project complied with development standards, more
affordable units were going to be eliminated.
Council Member Stone asked the Applicant to address the distribution of
affordable units across the site.
Mr. Gomez advised that the Code required an equal distribution of affordable
units across unit types.
Council Member Stone asked if the two very-low-income units were going to
be a studio unit and a one-bedroom unit.
Mr. Larson answered yes.
Council Member Stone concurred with Council Member Filseth regarding the
affordability of the proposed affordable units. The project did not comply
with many development standards and was not consistent with the
Comprehensive Plan.
Council Member Tanaka commented that small units were generally more
affordable. Because of the number of variances requested for the project,
neighborhood support of the project was important. Based on comments
offered during his office hours, the community did not support the project.
Mayor DuBois noted that an Applicant was allowed to utilize an incentive
program, the PHZ, or the State Density Bonus Law. He inquired whether an
Applicant was allowed to utilize only one of those options.
Mr. Lait reported combining the PHZ and State Density Bonus Law was not
possible.
Mayor DuBois believed the modular design appeared square and
commercial. A residential design was appropriate for a residential zone.
The project in the current location was not supported.
NO ACTION TAKEN
Oral Communications
Gail Price, Palo Alto Forward, hoped the Council took actions to support the
Proclamation for Affordable Housing Month. Increasing Impact Fees for
multifamily housing projects, limiting Planned Home Zone applications, and
restricting new affordable housing proposals on single-family lots signaled
non-support or creative roadblocks for housing projects with almost 600
units, some of which were Below Market Rate (BMR) units.
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Winter Dellenbach looked forward to hearing the results of tests conducted
in Matadero Creek following the fuel spill. The public wanted data rather than assurances. Fuel remained in the creek downstream from the
containment site.
Becky Sanders related her impressions of Council and Applicant comments
regarding the project located at 2951 El Camino Real and asked the Council
to deny zoning conversions of single-family residential (R-1) parcels.
Jonathan Erman recommended the community support the arts by attending
the Palo Alto Players' play.
Michael Quinn explained that not only was more housing needed but the
number of new units needed to be large enough to reduce rents.
Kelsey Banes commented regarding exclusion and segregation in Palo Alto.
Rebecca Eisenberg believed construction of low-income housing was going to
improve the community.
Council took a break at 7:26 P.M. and returned at 7:37 P.M.
Consent Calendar
MOTION: Mayor DuBois moved, seconded by Council Member Cormack to
approve Agenda Item Number 3.
3. Adoption of Ordinances Responding to State Housing Bills Regarding
Density Bonus and Affordable Housing. Environmental Assessment:
Exempt Pursuant to California Environmental Quality Act (CEQA)
Guidelines Section 15061(b)(3).
MOTION PASSED: 7-0
Action Items
4. PUBLIC HEARING / QUASI-JUDICIAL: 181 Addison Avenue
[20PLN-00300] Request for Review of a Preliminary Parcel Map With Exception and Variance to Subdivide one Existing lot Into two Parcels
With Less Than the Minimum 60 Foot Frontage. Environmental
Assessment: Consistent With Previously Adopted Environmental
Impact Report (EIR) for the City's Comprehensive Plan. Zoning
District: R-2 (Two Family Residential) Within the South of Forest
Avenue (SOFA) II Coordinated Area Plan (CAP).
Mayor DuBois disclosed no ex parte communications.
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Council Member Kou disclosed no ex parte communications.
Amy French, Chief Planning Official, reported the lot was located at the corner of Addison and Emerson in the South of Forest Area (SOFA) II
Coordinated Area Plan (CAP). The Applicant proposed demolition of an
existing house, garage, and carport, subdivision of an oversized lot into two
standard-sized lots, and requested an exception from the requirement for a
60-foot lot-width minimum. A variance was required to process the exception. The home, garage, and carport were built in 1914. The City's
consultant evaluated the site in 2019 and determined that the site was not
eligible for the California Register and, therefore, not a California
Environmental Quality Act (CEQA) resource. The lot currently exceeded the
minimum and maximum allowed site area. Mature redwood trees obscured
one side of the home and were located within setbacks but outside the
buildable area of the lot. Key considerations were lot width and building
height. The Planning and Transportation Commission (PTC) unanimously
recommended approval of the planning application. The lot was one of 14
lots in the SOFA II CAP that accommodated subdivision and resulted in two
standard-sized lots. The project was consistent with the General Plan and
provided additional housing opportunity, complied with Zoning requirements
with the exception of the lot width requirement, and was not viewed as
detrimental to the vicinity.
Public Hearing opened at 7:46 P.M.
Rebecca Eisenberg remarked that the Council was allowed to eliminate
requirements for planning projects. Zoning requirements made lots and
homes inaccessible for the vast number of people.
We Need More Homes indicated that public hearings for housing projects
were a waste of time.
Public Hearing closed at 7:49 P.M.
Council Member Cormack was perplexed by scheduling the Agenda Item for
1¼ hours when the PTC held a brief discussion and voted unanimously. She
inquired about the requirement for a gas meter.
Mr. Lait related that the Conditions of Approval needed to be revised to align
with Building Code requirements for electrification.
Council Member Cormack was able to make the findings for the variance.
Mayor DuBois inquired regarding the Comprehensive Plan's support for
combining lots where possible.
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Mr. Lait advised that Comprehensive Plan policies and perhaps SOFA II
policies supported lot consolidation to promote greater development.
Ms. French clarified that policies encouraged greater development in zones
that allowed multifamily and other developments. The nonconforming lot
size was the issue in the current project.
Mr. Lait added that the project was not inconsistent with those policies.
Mayor DuBois was able to make the findings.
Council Member Kou asked which R-2 lot was the smallest in the area.
Ms. French agreed to review the issue and respond shortly.
Council Member Kou asked if the SOFA II CAP contained a minimum
requirement for the size of a lot.
Ms. French stated the minimum lot size requirement was contained in R-2
zoning standards.
Council Member Kou noted that the two resulting lots were reasonably sized.
The frontages were acceptable even though they did not comply with the
requirement. She asked if the two resulting lots were going to retain R-2
zoning.
Ms. French replied yes.
Council Member Kou inquired whether the Applicant intended to construct
duplexes.
Ms. French understood the Applicant intended to construct a single-family
residence on each lot, perhaps with Accessory Dwelling Units (ADU). The
PTC Chair encouraged the Applicant to consider providing more units on the
lots.
Khoi Le, Applicant, reported the plan was to construct a single-family
residence and ADU on each parcel.
Council Member Kou asked if the Applicant wanted R-1 or R-2 zoning for
each lot.
Mr. Le preferred R-2 zoning.
Ms. French advised that the smallest R-2 lot in the area was 37.5 feet wide
and contained 4,222 square feet.
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Vice Mayor Burt recalled the rationale for encouraging the consolidation of
lots. The Council needed to consider policy incentives that encouraged more
housing in transitional areas.
Council Member Stone requested the Applicant's plans for the trees on the
site.
Mr. Le advised that the trees were going to be preserved.
MOTION: Council Member Kou moved, seconded by Council Member Stone to adopt a Record of Land Use Action (RLUA) approving the request for a
Preliminary Parcel Map with Exception and Variance based on findings and
subject to conditions of approval.
MOTION PASSED: 7-0
5. Direction to Staff Regarding 2023-31 Regional Housing Needs
Allocation Appeal.
Jonathan Lait, Planning and Development Services Director, reviewed the
Regional Housing Needs Allocation (RHNA) and the sixth cycle allocation for
the City. The Association of Bay Area Governments (ABAG) was scheduled
to consider the final RHNA methodology and draft allocations on May 20,
2021 and recommended its Administrative Committee act as the hearing
body for appeals. State law provided three bases for an appeal. The bases
regarding methodology and changes in circumstances were raised in the
City's comment letters to ABAG. Based on decisions from the Southern
California Association of Governments (SCAG), only two of fifty-two appeals
in the sixth cycle were partially successful. In the fifth cycle, only three of
14 appeals to ABAG were successful.
Mark Mollineaux suggested filing an appeal may lead to a review and
increase of the City's allocation or to other jurisdictions appealing the City's
low allocation.
Gregory Schmidt remarked that the draft allocation was an astounding
number and was going to result in rents of $5,000 per month for studios, a
huge increase in income inequality, and a dramatic decline in childcare. The
Government Code called for an open public discussion of the consequences
of concentrated job and housing growth. If the Council found a record of
such a discussion in ABAG meetings over the past 18 months, it needed to
accept the allocation. Otherwise, the Council needed to appeal the
allocation.
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Rebecca Eisenberg commented that limited resources was not a viable
grounds for appeal and that limited resources were better spent on housing.
Michael Quinn believed an appeal was going to fail. The California
Department of Housing and Community Development (HCD) was going to
interpret an appeal as a bad faith action.
Terry Holzemer supported an appeal of the allocation because the Plan Bay
Area 2050 process was flawed.
Mayor DuBois inquired regarding the issue with the Plan Bay Area 2050
forecast.
Mr. Lait explained that Plan Bay Area 2050 and ABAG's methodology were
not the issues. Sites used in assumptions regarding future household
growth were not likely to redevelop or even within the City's control.
Attributing a certain number of housing units to those sites was not proper.
If an appeal of this issue was successful, it was going to reduce the City's
allocation by approximately 200 housing units.
Mayor DuBois asked if concerns raised in previous cycles regarding Stanford
University remained valid for the sixth cycle.
Mr. Lait noted the concerns were not successful in the City's appeal of the
fifth cycle allocation. The City's allocation increased due to its proximity to
job centers, and Stanford University was a job center. Based on the
methodology, Staff was not able to isolate the number of housing units
attributed to Palo Alto as a result of its proximity to Stanford University.
Mayor DuBois requested clarification of the appeal and the transfer of
housing units to the County of Santa Clara (County).
Mr. Lait understood that ABAG denied the City's appeal but supported a
transfer of units if the City and County reached an agreement to do so.
Mayor DuBois asked if the City needed to file an appeal and reach an
agreement with Stanford University.
Mr. Lait was unsure if that process existed for the sixth cycle. Early
discussion of a subregion where jurisdictions were allowed to trade units was
not realized. The County's allocation increased from 300 units in the fifth
cycle to 3,000 units in the sixth cycle. The County too was looking to
transfer some of its units.
Albert Yang, Assistant City Attorney, reported a recent change in State law
removed the option to transfer units between a city and county.
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Mayor DuBois expressed interest in some of the Stanford University issues
raised in prior cycles. He inquired whether the City was accepting the
allocation by not filing an appeal.
Mr. Lait answered yes. Staff's engagement with ABAG and work to add new
strategies to the Plan Bay Area resulted in the City's allocation decreasing
from 10,000 units.
Council Member Stone asked if there was any real risk of the City's allocation
increasing if it filed an appeal.
Mr. Lait raised a concern about increasing the allocation need not be a factor
in the Council's decision to file an appeal. Any jurisdiction and HCD were
allowed to appeal the City's allocation regardless of the City filing an appeal.
Council Member Stone inquired whether ABAG's model assessed any type of
systemic changes caused by a pandemic.
Mr. Lait advised that comment letters raised a concern about the inability to
forecast for a pandemic that changed commutes and job locations. An
appeal based on changes in circumstances caused by a pandemic probably
was not viable because HCD considered ABAG's methodology and found it to
be consistent with Plan Bay Area and its projections.
Tim Wong, Senior Planner of the Planning and Development Services, added
that ABAG indicated the pandemic was a short-term impact while RHNA and
Plan Bay Area projected over longer periods.
Mr. Yang interpreted Mayor DuBois' earlier question as did the City need to
exhaust administrative remedies by appealing the allocation if the City later
wished to file suit in court. Because statutes did not contain a provision for
a city to seek judicial review through a lawsuit, the City was not able to file a
lawsuit.
Vice Mayor Burt believed the City needed to file an appeal on principle.
Rather than balancing jobs and housing and distributing job growth, HCD
supported high job concentration and housing keeping up with job growth.
The City needed to continue its policy for moderating office growth and
accelerating housing growth, particularly growth of moderate-income and
low-income housing. RHNA was political in nature.
Council Member Cormack requested clarification of other jurisdictions' ability
to appeal the City's allocation.
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Mr. Lait reported any jurisdiction that was part of ABAG and HCD was able to
appeal another jurisdiction's RHNA allocation.
Council Member Cormack expressed concern that an appeal was going to
divert Staff's attention from the Housing Element Update.
Mr. Lait related that Staff was working on a number of policy initiatives for
the Council. If the appeal focused on technical discrepancies, the appeal
was probably going to have a small impact on other work. If the appeal focused on issues outside the statutory bases, it was going to require more
work and delay other work.
Molly Stump, City Attorney, advised that the small number of Staff limited
their ability to shift work and to address discretionary items. The appeal
was subject to a deadline, and other work was going to have to wait.
Council Member Cormack acknowledged the existing queue of work for Staff.
Pursuing futile actions was not wise. Data indicated an appeal was not going
to be successful.
Ed Shikada, City Manager, noted the emotional impact of a futile action on
everyone who was working diligently to produce housing. Perhaps a political
defense was more appropriate.
Council Member Filseth discussed below-market-rate (BMR) housing
production and RHNA allocations across the Bay Area. Large mixed-use
projects exacerbated regional housing problems. ABAG needed to track new
demand creation in addition to new supply creation. The only strategy was
to balance jobs and housing growth and to shift as much housing growth as
possible to affordable housing. The City needed to do this despite HCD and
RHNA.
Council Member Kou inquired whether the City Attorney contacted other jurisdictions regarding the basis for their appeals and the ability of the City
to join their appeals.
Ms. Stump understood one lawsuit was filed in the San Diego region, and the
cities did not prevail. One jurisdiction in Southern California decided not to
pursue legal action after consulting with attorneys.
Mr. Wong added that one appeal in Southern California was partially upheld
due to a housing site's location below a dam.
Council Member Kou suggested Staff look into the designation of high-
quality transit as a basis for an appeal. The Council needed to consider all
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bases for appeal as a matter of due diligence. RHNA allocations were a
political matter. She supported filing an appeal.
Mayor DuBois felt the Council had a responsibility to protect the City from
State override. ABAG assigned aspirational numbers. The City needed to
attempt to develop realistic numbers based on pace of development and
development locations. He supported an appeal based on technical issues
and the pandemic and possibly public transit.
Vice Mayor Burt reviewed potential arguments for an appeal listed in the
Staff Report. He inquired whether the Staff Report contained most of the
arguments for an appeal such that they only needed some modification to be
included in an appeal.
Mr. Lait related that if the Council directed, Staff planned to utilize the
arguments in the Staff Report and specific technical deficiencies for an
appeal.
Vice Mayor Burt remarked that the transformation in work patterns
accentuated and reinforced the arguments raised more than a year ago.
ABAG and HCD were not accepting the transformation or predictions for it to
continue into the future.
Council Member Kou proposed adding the public transportation issue to the
appeal.
Mr. Lait suggested that addressing the transportation issue may be more
appropriate in a conversation with ABAG Staff rather than in a RHNA appeal.
Council Member Kou asked if ABAG increased the City's allocation based on a
designation of high-quality public transportation.
Mr. Wong indicated that the City was not defined as a high-quality transit
area, which partially reduced the City's allocation.
Council Member Kou requested Staff pursue a conversation with ABAG.
Council Member Filseth was not comfortable with filing an appeal simply to
transfer housing units to another jurisdiction. He wanted to understand the
ultimate goal of filing an appeal.
Council Member Stone felt Staff's arguments were strong and provided a
reasonable opportunity for an appeal.
MOTION: Mayor DuBois moved, seconded by Vice Mayor Burt to direct
Staff to prepare and file an appeal of the City’s Regional Housing Needs
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Allocation, based on Staff’s identified technical errors and elements from the
January 21, 2021 letter sent to the Association of Bay Area Governments
(ABAG) Executive Board Members.
Mayor DuBois indicated that legal requirements stated in a letter from the
public may be a way to map elements of the letter to real issues.
Council Member Stone felt an appeal ensured ABAG followed the proper
process and utilized the correct methodology in assigning RHNA allocations.
Council Member Kou felt HCD and ABAG needed to provide meaningful
examination of improving inter-regional jobs/housing balance.
Mayor DuBois related that the request for jurisdictional data and regional
growth strategies covered Council Member Kou's point.
Council Member Kou wanted to understand whether HCD and ABAG
strategies actually balanced jobs and housing in the region and the State
and whether housing appreciated more due to up-zoning. Basically, she
wanted HCD and ABAG to reexamine their methodologies and historical data
and determine whether the strategies were successful or created more
poverty and homelessness.
Mr. Lait asked if the Council intended to authorize the City Manager to sign
the appeal.
Vice Mayor Burt proposed the Mayor review and sign the appeal on behalf of
the Council.
INCORPORATED INTO THE MOTION WITH THE CONSENT OF THE
MAKER AND SECONDER “… with the letter read, approved, and signed by
the Mayor.”
MOTION AS AMENDED: Mayor DuBois moved, seconded by Vice Mayor
Burt to direct Staff to prepare and file an appeal of the City’s Regional Housing Needs Allocation, based on Staff’s identified technical errors and
elements from the January 21, 2021 letter sent to the Association of Bay
Area Governments (ABAG) Executive Board Members, with the letter read,
approved, and signed by the Mayor.
MOTION AS AMENDED PASSED: 5-2 Cormack, Tanaka no
Council Member Questions, Comments and Announcements
Mayor DuBois reported he met with the Chairs of City Boards and
Commissions to discuss meeting management and work plans.
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Adjournment: The meeting was adjourned at 9:40 P.M.
ATTEST: APPROVED:
____________________ ____________________
City Clerk Mayor
NOTE: Action minutes are prepared in accordance with Palo Alto Municipal
Code (PAMC) 2.04.160(a) and (b). Summary minutes (sense) are prepared in accordance with PAMC Section 2.04.160(c). Beginning in January 2018, in
accordance with Ordinance No. 5423, the City Council found action minutes
and the video/audio recordings of Council proceedings to be the official
records of both Council and committee proceedings. These recordings are
available on the City’s website.