HomeMy WebLinkAbout2010-03-03 City Council Agenda Packet (2)
1 03/03/10
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Agenda posted according to PAMC Section 2.04.070. A binder containing supporting materials is available in the Council
Chambers on the Friday preceding the meeting.
Special Meeting
Council Chambers
March 03, 2010
7:00 PM
ROLL CALL
STUDY SESSION
1. Joint City Council/Planning & Transportation Commission Study
Session Regarding the Comprehensive Plan Amendment and Housing
Element Update
CMR 152:10 & ATTACHMENT
ORAL COMMUNICATIONS
Members of the public may speak to any item not on the agenda; three minutes per speaker. Council reserves the
right to limit the duration or Oral Communications period to 30 minutes.
ADJOURNMENT
Persons with disabilities who require auxiliary aids or services in using City facilities, services, or programs or who would like information on the City’s compliance with the Americans with Disabilities Act (ADA) of 1990, may contact
650-329-2550 (Voice) 24 hours in advance.
Brief summaries of each topic are provided in the report. At a follow-up study session, Council may
then provide direction to staff and the PTC regarding these and other work items. Staff anticipates
that the Concept Plans will be presented to Council in the spring or summer of 2010, a draft Housing
Element will be prepared shortly thereafter, and the entire Comprehensive Plan Amendment,
including the accompanying Environmental Impact Report, will be completed in early 2012.
PURPOSE AND RECOMMENDATION
The purpose of the study session is for staff and the Planning and Transportation Commission (PTC)
to update the City Council on progress in completing the work program for the Comprehensive Plan
Amendment and Housing Element. Key policy issues are identified as background for the study
session, and a follow-up session is planned to allow for City Council direction regarding the
implementation of the work program, most specifically in the areas of: a) the extent of revisions to
vision statements and key policies; b) proposed growth projections; c) the approach to identifying
housing opportunity sites in the housing element; and d) whether to expand the scope of the work
program. No Councilor Commission action is required or may be taken at a study session. Staff
recommends that the Council and PTC discuss the work program and key issues, and provide
questions and direction for a follow-up study session, to be scheduled within the coming two months.
BACKGROUND
The City's Comprehensive Plan and Housing Element are required planning documents under State
law. The Comprehensive Plan provides the basis for the City's zoning ordinance and development
decisions, the Capital Improvements Program (CIP) , transportation programs, economic
development efforts, environmental sustainability measures, and a host of other actions by staff,
various boards and commissions, and the City Council. State law requires that a general (or
comprehensive) plan include a minimum of seven elements, such as Land Use, Circulation, and
Housing. The Housing Element responds to State requirements to provide for adequate zoning to
accommodate housing for households of varying income levels, as well as programs and policies to
assure fair housing practices and housing services.
Evaluation of Palo Alto Comprehensive Plan 1998-2010
The City's existing Comprehensive Plan covers the timeframe of 1998 to 2010, and provides for all
State-mandated plan elements plus a Business and Economic Element. A Comprehensive Plan is
usually in need o! updating every 10 years or so, as circumstances change and policies and programs
become obsolete or new ones are required. Many of the current Plan's goals, policies and programs
remain relevant today and have been supported by improvements and projects over the past 12 years,
but changed conditions and less successful projects led to the Council's direction to update the Plan.
Examples of successful implementation of the existing Comprehensive Plan could include:
• Creation of a significant number of affordable and senior housing projects
• The redevelopment of the South of Forest Area (SOFA) to a mixed use, mixed housing,
pedestrian and bicycle-friendly community
• Additional recreation and cultural facilities, such as the Mayfield Soccer Complex, Heritage
Park, and the Jewish Community Center
• Preparation and initial implementation of the City's Climate Protection Plan
• Pedestrian and bicycle facilities such as the Homer Tunnel and the Waverley bridge
• The approval of three new neighborhood grocery stores
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• Preservation and restoration of several historic structures using transferable development
rights and other incentives
On the other hand, examples of other projects and improvements were less than successful with
some potential long-term adverse effects, such as:
• The loss of the Hyatt Rickey's Hotel and an attendant loss of transient occupancy tax revenue
• Conversion of other commercial and industrial sites to residential projects, again reducing the
City revenues and job base
• Lack of a cohesive planning framework for new projects in south Palo Alto, resulting in
development that is sometimes not well integrated into the community fabric of street
connections or urban design
• Lack of provision of commercial and public services commensurate with the new housing
development
• Little accommodation for significant economic development opportunities, particularly those
that enhance City revenues
Staff believes that the primary driver of some of these adverse changes was the 1998-2010
Comprehensive Plan focus on housing to the detriment of commercial and industrial uses. When that
Plan was prepared, the City had a very strong office market and a weak housing market, and the Plan
compensated by placing a priority on housing shortly before housing became a highly profitable land
use. Some of these concerns were addressed with zoning changes that arrested the change in land use
from commercial to housing, but the overall Comprehensive Plan approach remains to be refocused.
It will be important, as the City updates the Comprehensive Plan, to provide an appropriate balance
of land uses, services, and economic development to lead the City to 2020.
At the same time, climate change has become a major theme at the local, regional, statewide, and
national level, altering lifestyles and development patterns over the coming 10 years of the updated
Comprehensive Plan. State Senate Bill 375, in particular, will provide incentives (and possibly
regulation) to encourage measures to reduce vehicle miles traveled and to facilitate compact, higher
density development in walkable, transit adjacent areas.
Work Program
The City Council, in response to many of the changes and projects noted above, initiated the
Comprehensive Plan Amendment process in 2006 with approval of a Colleague's Memo that
outlined the general parameters of the work program. Funding for the project was allocated in 2007
and a consultant team selected in 2008. At a joint study session with the Planning and
Transportation Commission (PTC) held on July 28, 2008, City Council reviewed and finalized the
work program (Attachment A). The primary purposes of the amendment were stated as:
1. to extend the horizon year of the Plan to 2020;
2. to update baseline data and growth projections;
3. to modify the vision statements, policies and programs as needed to address the focus of the
Comp Plan Amendment;
4. to ensure the retention of sufficient land for neighborhood-serving retail uses and commercial
growth;
5. to adequately mitigate impacts of increased housing on community services such as parks,
libraries and schools; and
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6. to address the City's commitment to climate protection and sustainability.
The work program also called for the development of Concept Plans for the East Meadow
CirclelFabian W ay/ West Bayshore area and the California Avenue area (including the existing Fry's
Electronics site and adjacent properties) for inclusion in the amended Comprehensive Plan, to
determine appropriate future land uses, circulation, and services in these two areas. Finally, updating
the City's Housing Element was included as part of the work effort.
The Council indicated at the time the work program was adopted that the amendment was to
continue nluch of the direction of the 1998 Comprehensive Plan and to underscore its major themes,
including:
• Building Conlffiunity and Neighborhoods
• Maintaining and Enhancing Conlffiunity Character
• Reducing Reliance on the Automobile
• Meeting Housing Supply Challenges
• Protecting and Repairing Natural Features
• Meeting Residential and Commercial Needs
• Providing Responsive Governance and Regional Leadership
The Council allocated $850,000 for this work effort over a four year period, which has since been
extended one year due to budget constraints. This budget and timeframe is premised on retaining the
focused scope outlined at the time and further discussed below.
The City's update of the Housing Element was also part of the work scope, but consultant funding
was not provided, as the document is to be prepared by staff. Further background on the Housing
Element update is provided in the discussion below.
DISCUSSION
The joint City Council and Planning & Transportation Commission (PTC) study session provides an
opportunity for the City Council and the PTC to discuss the status of the major components of the
work progranl for the Comprehensive Plan amendment and the Housing Element update. At a
follow-up study session, Council may then provide direction to staff and the PTC regarding specific
work items that are in process. Staff has included a draft schedule (Attachment B) for the work
program that identifies the major work scope components and a timeframe for their completion.
Staff and the PTC have identified five primary areas of discussion for the study session:
1. Vision Statements, Policies and Programs
2. Growth Projections
3. Housing Element
4. Scope of Work
5. Concept Plans
Each of these topics is discussed below, and the PTC members will further explain some of their
specific concerns about the initial three key policy issues. Staff has identified the extent of the scope
of work as an additional issue requiring clarification fronl Council. The status of the Concept Plans
is also discussed below, and each will be coming forward to the Commission and Council in greater
CMR: 152:10 Page 4 of 12
detail in the spring and summer of this year. More information about these items will be provided to
the PTC and Council at the follow-up study session, along with responses to questions raised at this
meeting.
1. Vision Statements, Policies, and Programs
The PTC discussed the major themes and vision statements (Attachnlent C) of the existing
Comprehensi ve Plan during two separate nleetings, held in Septelnber and October of 2009, focusing
on the overall framework of the plan and the interrelationship between the vision statements of each
element of the Comprehensive Plan. Commissioners made specific recommendations for changes to
each element's vision statenlent (Attachment D) and also made general recommendations regarding
nlodifying the vision statements, including the following:
• The style of the vision statements should be more cohesive;
• Vision statements should be realistic and not overarching or too general;
• The language of the vision statement should be clearer; and
• The vision statements for each element should reflect a balance between existing
conditions and future growth.
As part of the review, the PTC has indicated that revisions to the Comprehensive Plan format should
be undertaken in order to create a clearer, nlore general, cohesive and less redundant policy
document. This could involve rearranging chapters and elements and substantially changing the
format of the existing plan and would result in significant additional staff work and costs. The work
program envisioned only limited changes to the existing format and focused policy changes only on
those specific areas identified by the work program. The staff and consultant resources allocated to
the work program are based on that direction from Council.
2. Growth Projections
Staff discussed draft popUlation, housing and employment growth projections to be considered in the
Comprehensive Plan through 2020 at three separate PTC meetings in late 2008 and early 2009.
Staff proposes to evaluate three different growth scenarios for jobs and housing development through
2020 and to evaluate those three scenarios in the Environmental Impact Report (EIR). One growth
scenario would use ABAG Projections 2009 data and a second growth scenario would use historic
growth rates and "pipeline" (in process) projects for residential development and employment
projections would be based on data developed by the economic consultant for the Comprehensive
Plan, Advanced Development Economics. Each of these scenarios is further described below. A
third scenario would be a low growth alternative that would be developed when the EIR for the
Comprehensive Plan Amendment is prepared and would result in no net new impacts.
ABAG Projections 2009, released last year, is the most recent edition of ABAG's long-term forecast
of population, households, and employment. ABAG Projections 2009 adjusted the regions and local
employnlent projections to reflect the economic climate during the last half of 2008. Table 1 shows
ABAG's projected employment, population and households for the City's jurisdictional boundary
and sphere of influence (SOl) through 2020.
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Table 1
ABAG Projections 2009
City of Palo Alto 2000 2010 2020 EMPLOYMENT
Jobs (City)* 86,960 76,480 77,010
Jobs (SOI)** 107,950 97,300 99,280
City of Palo Alto 2000 2010 2020 POPULATION AND HOUSEHOLDS ,
Population (City)* 58,598 61,600 70,400
Population (SOI)** 71,914 76,400 86,100
Households (City)* 25,216 26,700 29,910
Households (SOI)** 28,424 30,350 33,870
* City Jurisdiction
* * City Sphere of Influence
ABAG 2009 projects minimal "net" job growth from 2010-2020, indicating the slow recovery from
the current economic recession and that substantial employment growth will mostly occur after 2020.
Staff notes that the Stanford University Medical Center expansion is scheduled for completion after
2020.
Projections 2009 assumes a population growth rate of approximately 14% from 2010-2020, while
historical Census data shows the City of Palo Alto's population has only grown by approximately
4.7% over the last 30 years (1970-2000 Census data). Although Palo Alto experienced significant
new housing development from 2000 -2008, that growth rate has now decreased due to changing
economic conditions. Staff has consistently maintained to ABAG the accelerated growth in the
period from 1997-2008 is unlikely to be sustained given Palo Alto's limited land availability and
existing redevelopment potential, and thus proposes using the Population and Household growth in
ABAG Projections 2009 as the high-growth scenario for the EIR.
Based on historical development patterns, household and population estimates of the State
Department of Finance from 2001-2008, and known past and "pipeline" residential development,
staff forecasts a more modest population and household growth through 2020. Historical Census
data shows the City's population grew 1.2% from 1980 to 1990 and an additional 4.8% from 1990 to
2000. Known residential projects either in the entitlement process or entitled that have not received
building permits will generate approximately 400 dwelling units in the next several years. Table 2
shows staff's developed total population, household and housing unit forecasts through 2020.
. CMR: 152:10 Page 6 of 12
Table 2
Staff Population and Household Projections
Staff Projections for
City of Palo Alto Jurisdiction 2000 2010 2020
Total Population* 58,598 62,700 65,400
Households * * 25,216 26,913 27,978
Housing Units 26,048 27,800 28,900
* Total Population includes household population and persons living in group quarters.
** Staff projected Households data with the assumption that 3.2% of housing units in Palo Alto is unoccupied
or vacant derived from civilian vacancy rate based on Census 2000 benchmark.
I
Staff projects a 4.3% population increase from 2010-2020, which is indicative of historical
population growth trends and purposes to use these projections as the "mid-growth scenario" for
population and housing growth.
Staff anticipates further input from the City's economic consultant (Applied Development
Economics) regarding the potential for job growth through 2020 prior to further discussion by the
City Council and PTC. Previous forecasts prepared by the consultant did not reflect the full extent of
the recent economic downturn. Staff will develop the third scenado of low growth alternative that
would result in no new impacts during the preparation of the DEIR. A summary of the ABAG and
staff proposed growth is detailed in Table 3.
Table 3
Proposed High and Mid Growth Scenarios for Comprehensive Plan Amendment DEIR
City of Palo Alto
*EMPLOYMENT 2000 2010 2020
Staff Jobs Growth (based on 2008 data)**** 86,960 76,774 82,095
ABAG Jobs Growth 86,960 76,480 77,010
City of Palo Alto
*POPULATION and HOUSEHOLDS 2000 2010 2020
High Growth Population** 58,598 61,600 70,400
Mid Growth Population** 58,598 62,700 65,400
High Growth Households 25,216 26,700 29,910
Mid Growth Households*** 25,216 26,913 27,978
High Growth Housing Units 26,048 27,552 30,864
Mid Growth Housing Units 26,048 27,800 28,900
City of Palo Alto Jurisdictional Boundary.
Total Population includes household popUlation and persons living in group quarters.
*
**
*** Staff projected Households data with the assumption that 3.2% of housing units in Palo Alto are unoccupied
or vacant derived from civilian vacancy rate based on Census 2000 benchmark.
CMR: 152:10 Page 7 of 12
**** To be updated by economic consultant
3. Housing Element
Considerable progress has been made to update the City's Housing Element over the past year. Staff
work on the Housing Element has focused on updating the population, household and housing data
required for the Housing Element and evaluation of the effectiveness of the current element's
programs and policies. An ad hoc Housing Elenlent Technical Advisory Group (TAG), representing
stakeholders and organizations concerned about housing growth and policy, was formed in late 2008
and has met regularly to discuss housing issues and policies, to evaluate housing strategies and
programs, to assess impacts of various housing types and locations, and to enable ongoing public
involvement in the Housing Element process.
The PTC discussed the current Housing Element's vision, goals and key policies at two study
sessions last year. Main policy concerns for the commissioners that were not sufficiently addressed
in the current Housing Element included:
• focusing new housing opportunities on underserved needs;
• considering balancing housing needs with city and school resources and traffic capacity;
• ensuring preservation of neighborhood character, particularly single family homes; and
• changing the paradignl that housing is the preferred land use and should be located in most
areas of the City.
The latter concern is seen as implicit in the phrase "including converting non-residential lands to
residential or mixed use" from the existing Housing Element vision statement.
A critical component of the Housing Element is the housing sites inventory that identifies how the
City will meet its current Regional Housing Needs Allocation (RHNA). The State requires that
housing elements demonstrate how the jurisdiction can accommodate the RHNA allocation by
planning and zoning adequate sites, although the RHNA does not assume that the zoned residential
lands will be built. The PTC has specifically requested direction from Council regarding criteria to
identify sites to include in the RHNA inventory, and whether the City should attempt to comply with
the RHNA allocation. The City contested the RHNA process and appealed the resultant RHNA
allocation to ABAG in 2008 (Attachment E).
Currently the City would need to identify sites for approximately 2,100 units in order to meet its
RHNA allocation, as depicted in Table 4. There are approximately 315 units currently in the review
process that could be placed on the inventory, which would reduce the RHNA to about 1,800 units.
Staff has conducted a preliminary analysis of sites that have redevelopment potential and are zoned
for higher density residential uses or are zoned to allow higher density residential development in a
nuxed use configuration and could be included in the sites inventory without a zone change
(Attachment F). This excludes approximately 304 housing units from the Fry's site currently under
evaluation as part of the California Avenue Concept Plan, since the site would not be available for
redevelopment until after 2014, following the 2001-2014 housing evaluation period.
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Table 4
Status of Palo Alto's Regional Housing Needs Allocation (RHNA)
RHNA for City of Palo Alto (2007-2014 Housing Element) 2,860 units
Housing Built or Building Permit Issued (since Jan 2007) 786
Housing currently In Process* 315
Potential Housing on existing Residentially Zoned Sites 369
Potential Housing in Zoning Districts that could accommodate Mixed Use
Development 312
Total 1,782 units
RHNA Deficiency 1,078 units
* In process includes projects entitled without building permits, in the entitlement process or in the preliminary
entitlement process.
As Table 4 depicts, this leaves a deficiency of almost 1,100 units. Some options that could be
considered to address this shortfall include:
• Working with Stanford to reassign up to 600 units from the County to the City for housing
sites allowed under Stanford's Community Plan and General Use Permit, in conjunction with'
or following the Development Agreement for the Stanford University Medical Center
expansion;
• Increasing housing potential in the California Avenue area as part of the California Avenue
Concept Plan;
• Developing a concept plan for downtown and focusing higher density housing near the
University Avenue multi-modal transit station; and/or
• Evaluating other sites throughout the City for rezoning for higher density housing.
Lack of a State-certified housing element has several potential implications, including litigation
or loss of potential funding for affordable housing or transportation grants. Funding
consequences will likely increase over the coming years as SB375 is implemented, but at this
time are not seen as highly risky, given the lack of State funds available. Litigation is highly
unusual, and is generally not pursued so long as a city is making a sincere attempt to prepare its
housing element. Staff anticipates development of alternate housing scenarios and assessment of
related impacts for presentation to the PTC and Council in the summer of 2010.
4. Scope of Work
In addition to the potential to expand the work scope to provide extensive revisions to the
Comprehensive Plan format, policies, and programs, other potential work program elements have
been identified that are outside of the original scope of work and could add significant cost and time
to the planning effort. These include: 1) providing concept plans for the downtown and/or South El
Camino Real areas, 2) evaluating and incorporating High Speed Rail land use scenarios; and/or 3)
providing details of potential mitigation of sea level rise impacts. Staff expects to develop general
policy level guidance and future study of all of these items within the current work scope, but if a
greater level of analysis and discussion is desired, budget and schedule would be affected
substantially. Staff estimates that to fully address anyone of these work items would require
increased budget of $75,000-$100,000 and could be considerably more, depending on the level of
CMR: 152:10 Page 9 of 12
technical analysis required.
5. Concept Plans
Three neighborhood workshops and stakeholder meetings and interviews have been completed for
both the East Meadow Circle (Attachment G) and California A venue (Attachment H) Concept Plan
areas. A preferred land use alternative has been developed for the East Meadow Circle concept plan
area and the PTC reviewed and commented on that alternative on February 10,2010. The preferred
alternative focuses 011 enhancing non-residential development opportunities, limiting housing, and
providing for critical pedestrian and bicycle connections to residential areas and to the Baylands.
Staff will be returning to the PTC in April or May with additional information and revisions to the
alternative based on comments received at that meeting. It is anticipated that a PTC recommendation
for the East Meadow concept plan will be forwarded to City Council in late spring.
Three potential land use scenarios for the California A venue area were presented at a third and final
community workshop held on February 2,2010. The alternatives generally include some increased
housing density or mixed use development, but with different options regarding the level of intensity
and the treatment of the Fry's site. Options are also outlined to provide additional parking and open
space opportunities. These three land use alternatives for the California Avenue Concept Plan area
will be presented to the PTC this spring for their recommendation of a preferred land use alternative
with Council discussion anticipated this summer. The two draft Concept Plans will be incorporated
in the Draft Comprehensive Plan Amendment and evaluated in the Environmental Impact Report
(EIR). The Concept Plans also have inlplications for the Housing Element in that they will either
provide opportunities for additional housing or further limit housing options.
NEXT STEPS
Attachment B outlines an anticipated schedule for preparation of the Comprehensive Plan
Amendment and the Environmental Impact Report.
Concept Plans
The PTC is expected to complete its review and recommend to the City Council a preferred land use
alternative for both Concept Plan areas by mid 2010. The land use concept plan for each area that is
supported by the City Council will then be analyzed in the Environmental Impact Report for the
Comprehensive Plan Amendment.
Vision Statements, Policies, and Programs
The PTC will craft text changes to the goals, policies and programs for each individual elenlent,
including developing new policies and programs to address the areas of concern identified in the
work program. A major component of work in the next year will be to incorporate sustainability
concepts into the existing Comprehensive Plan.
Housing Element
To encourage broad participation, two community-wide meetings will be held in mid-2010 to gather
input from the general public on housing issues, goals, and policies and programs. Staff will also
convene a focus group, consisting of housing developers, commercial "mixed-use" developers,
architects and other housing development professionals, to discuss the effectiveness of existing and
proposed programs. The City Council will review the draft Housing Element in the summer of 20 1 0,
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following PTC review. The draft element would then be forwarded to the State for an initial review
for compliance with State regulations.
Citywide Community Workshops
The City will sponsor at least three citywide community workshops to engage the public in the
amendment process by presenting information regarding the vision of the Comprehensive Plan, the
fundamentals of sustainable growth and the availability of City services to accommodate future
growth. In addition, as mentioned above, the City will hold two workshops on the Housing Element.
These citywide community workshops will begin in the spring of 2010 and extend throughout the
year.
Speaker Series
In addition to the community workshops, staff will continue over the remainder of the year to invite
various experts in land use planning, transportation, and urban design to provide insight and
guidance to both decision makers and the public prior to completion of the Comprehensive Plan
amendment. The presentations include such topics as recent state legislation regarding climate
change, smart growth principles, infill development, urban design, and land use and transportation
linkages.
Draft Comprehensive Plan AmendmentJEIR
Staff anticipates PTC and City Council review of the draft Comprehensive Plan Amendment in 2011
with hearings on the Draft Environmental Impact Report (DEIR) in late 2011. The Comprehensi ve
Plan Amendment, including changes to the Housing Element, is scheduled to be adopted by the City
Council in mid 2012.
PUBLIC OUTREACH
As noted above, several community workshops and public meetings will be conducted to discuss the
Comprehensi ve Plan Amendment and the Housing Element update. The City also maintains a
website (www.paloaltocompplan2020.org) that provides information about the Comprehensive Plan
including the Housing Element. Meeting outreach will include neighborhood associations, business
groups, schools, and other interested parties. Staff also intends to integrate the Comprehensive Plan
effort into a City Facebook site to allow for real-time updates of Comprehensive Plan information.
POLICY IMPLICATIONS
Although this study sessions will result in no policy actions, the Comprehensive Plan amendment
process enables the Comprehensive Plan to be updated to focus on current City policy and to
adequately reflect the City's vision consistent with or modified from the goals of the existing
Comprehensive Plan. The updated plan is intended to provide an effective guide for future growth in
the City.
RESOURCE IMPACTS
There are no fiscal impacts resulting from this report. The Council approved a budget of $850,000 in
April 2008 for the amendn1ent process. The City Council's adoption of the 2010 budget extended
the Comprehensive Plan An1endment work schedule by one year and decreased the Comprehensi ve
Plan Amendment budget by $75,000 for fiscal years 2009/2010 and 2010/2011. Staff expects to
complete the Comprehensive Plan Amendment work program within the current staffing structure
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ATTACHMENT A
TO: HONORABLE CITY COUNCIL
FROM: CITY MANAGER DEPARTMENT: PLANNING AND
COMMUNITY ENVIRONMENT
DATE: JULY 28, 2008 CMR: 323:08
SUBJECT: JOINT CITY COUNCILIPLANNING & TRANSPORTATION COMMISSION
STUDY SESSION ON THE COMP REHENSIVE PLAN AMENDMENT
WORK PROGRAM
PURPOSE
The purpose of the study session is for staff to outline the scope, schedule and budget of the
Comprehensive Plan Amendment and the expected approach to each of the key work plan
components. Staff recommends that the City Council and Planning & Transportation Commission
provide comments and input to staff and the consultant team regarding implementation of the work
program.
BACKGROUND
On April 7, 2008, the City Council approved the selection of two consultants for conlpletion of the
Comprehensive Plan amendment contract work plan: Design, Community & Environment (DC&E),
the lead planning and design firm, and Applied Development Economics (ADE), an economic
consultant. In conjunction with approving'the consultant team, the Council also requested that staff
schedule a joint study session with the Planning & Transportation Commission within approximately
90 days to further discuss the components of the work program and to provide direction to staff and
the consultant team regarding its implementation. The City Council had initiated the amendment in
2006 with approval of a Colleague's Memo that outlined the general parameters of the work
program. The focus of the amendment is to ensure that sufficient public services are available to
serve new housing development, that sufficient land for neighborhood-serving retail uses is retained,
that impacts of increased housing on public services such as parks, libraries and schools are
nlitigated and that the City's commitment to reduce global warming is addressed.
The Council indicated at the time the work program was developed that the amendment was to
continue the direction of the 1998 Comprehensive Plan and underscore its major themes, including:
CMR: 323:08 Page 1 of5
• Building Community and Neighborhoods
• Maintaining and Enhancing Community Character
• Reducing Reliance on the Automobile
• Meeting Housing Supply Challenges
• Protecting and Repairing Natural Features
• Meeting Residential and Commercial Needs
• Providing Responsive Governance and Regional Leadership
The Council has allocated $850,000 for this work effort over a 3 to 4 year period. This budget and
time frame is premised on retaining the focused scope outlined below.
DISCUSSION
The joint City Council and Planning & Transportation Commission (PTC) study session provides an
opportunity for the City Council, the PTC and the public to review and comment on the process
developed by staff for implementing the Comprehensive Plan amendment work program, at the
initial stage of the process. The main work plan elements for the Comprehensive Plan amendment
approved by Council in 2006 are listed below. For each major element of the work program staff
has provided a summary of the proposed approach to implementation. Staff has also included a
detailed schedule for the work program (Attachment A) that identifies the major components and a
timeframe for their completion.
• Revise existing conditions and update growth projections
Recent trends in development patterns and new data will be incorporated into base
conditions staff and ADE will identify a realistic growth rate for development through 2015-
2020. ADE will review available projections from various data sources and evaluate historic
growth patterns to provide a context for the projections. ADE will prepare a housing needs
assessment, which will focus on local demographic and household characteristics that affect
local demand. ADE will also complete a comprehensive assessment of commercial growth
opportunities in Palo Alto. Policy L-8 of the Comprehensive Plan limiting non-residential
growth will be evaluated. Staff and the consultant team will present their recommendations
regarding growth projections at a Council/PTC study session(s) in early 2009.
• Prepare two area studies and update land use map
DC&E will prepare concept plans for the East Meadow CirclelFabian Way/ West Bayshore
area and the California Avenue PTOD area (including the existing Fry's Electronics site and
adjacent properties). These concept plans will address land use and circulation and provide
policy guidance for each area. Although the focus of the potential land use changes will be in
these two specific areas, an overall evaluation of land use patterns within an area generally
bounded by Highway 101, EI Camino Real, Embarcadero Road and San Antonio Road will
be completed. Three neighborhood workshops for each of the two study areas will be held to
identify issues, develop alternatives and select a preferred alternative. The resulting plans
will establish a vision for each area. Council and Commission input regarding the scope of
the area plans is appropriate at the study session.
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For th~ Cal Avenue PTOD/Fry's area, it is anticipated that the concept plan will also
include evaluation of the functionality of California A venue for autos, bicyclists and
pedestrians and potential for redevelopment or intensification near the transit station. The
designation of the Park Boulevard Bicycle Boulevard in the area plan will also be an
important component of this study. Staff anticipates that the preparation of the concept plan
may lead to a more specific plan for this area, with possible funding available from ABAG
as a designated Planned Development Area (PDA).
F or the East Meadow/Fabian Way/W est Bayshoreconcept plan, primary issues of concern
will be the balance of residential and non-residential uses and assuring that any new housing
in the area is adequately supported by infrastructure and community services, including
support retail, bikeways and trails, parks and community facilities. The actual boundaries of
this study have yet to be determined but could be expanded to incorporate the potential
Foothill College campus at Cubberley on Middlefield.
• Review and modify appropriate Comprehensive Plan text
Staff will carefully evaluate all policies and programs for relevance and clarity and review
potential changes with the PTC through a series of meetings in the fall/winter 2008/2009.
The vision statements will also be evaluated although it is anticipated that the current vision
statements will continue to serve as the framework for the amendment to the Comprehensive
Plan. Existing land use definitions will be evaluated and appropriate uses under each
definition will be further refined. After PTC review, staffwill review all of the policies and
programs with Council in early 2009. Policies that currently allow conversion of non-
residential land to residential uses will be modified to ensure sufficient retail potential and to
prevent loss of potential tax dollars. Policies and programs that limit the loss of retail
serving uses will be strengthened or added.
• Develop a Sustainability theme for inclusion in Comprehensive Plan
Sustainability will be addressed by adding an eighth major theme to the Comprehensive Plan
and incorporating relevant concepts throughout each chapter of the Plan from the City's
existing programs, policies and initiatives including the City's Climate Protection Plan. The
Comprehensive Plan will underscore the City's commitment to addressing climate change
concerns. At this time Staff and the consultants are proposing to incorporate sustainability
components into each of the existing Plan chapters, however, creating a new Sustainability
Chapter is another option.
• Retail Market AnalysislFiscal Study
ADE will evaluate the fiscal impacts of land-use options through use ofa fiscal modeL The
model will be useful for understanding how the past and present land use mix has affected
the City's fiscal conditions. ADE will also prepare a comprehensive assessment of
commercial opportunities in Palo Alto and Palo Alto's current retail market. Staff has
requested ADE to particularly focus on the viability of neighborhood serving retail areas and
potential opportunities for commercial growth.
• Housing Element and Housing Sites Inventory
CMR: 323:08 Page 3 of5
The Housing Element programs and polices will be reviewed and modified to address
recommendations from the Below Market Rate Study that was recently approved by Council
and from the May 14, 2008 PTC study session on housing. The focus of the changes is
likely to include policies that encourage more affordable, higher density, smaller units near
transit that appeal to lower income seniors, singles or couples. Staff will initially develop a
Housing Inventory that establishes criteria for recommending sites to place on the inventory.
These criteria may include: proximity to transit along a major transportation corridor,
existing zoning that allows higher density residential either alone or in a mixed use
configuration, and the site potential for redevelopment and/or intensification.
Staff will work closely with the community and the PTC over the next year to develop the
housing policies and programs and a list of potential sites for the Inventory, and will then
share those with the PTC and Council in early 2009 to solicit direction on the City's
approach to the Housing Element. After completion of the Area Studies, staff will add any
additional housing from those studies to the list of potential inventory sites. From this
expanded list, the PTC and Council will determine the composition of the inventory and
finalize the approach addressing housing needs. It is anticipated that the draft Housing
Element will be completed by the end of July 2009 and forwarded to the State for an initial
compliance review.
• Infrastructure and Community Facilities Analysis
The Comprehensive Plan Amendment will also provide a thorough analysis of levels of
service needs for schools, parks and libraries relative to current and projected growth
(particularly housing growth) through 2020. General areas for new parks and community
facilities will be identified based on unmet need. Policies to support neighborhood
connections to enhance and integrate a pattern ofwalkable neighborhoods will be developed
and potential connections identified. Staff and the consultants will coordinate with the Palo
Alto Unified School District (PAUSD) to identify school capacity constraints and thresholds
and potential options to accommodate an increased number of students.
• Public Outreach
The main components of the public outreach program for the Comprehensive Plan
amendment that have been identified consist of a variety of methods to engage public
participation and include:
1. A dynamic interactive website with blog that is frequently updated with project
status and a schedule of upcoming events;
2. Newsletters for periodic inclusion in residents' utility bills;
3. Stakeholder meetings for Area Plans;
4. Neighborhood Workshops for each Area Plan;
5. Community Workshops for overall plan discussion;
6. Integration with PAUSD outreach and programs;
7. A Youth Community Workshop; and
8. A series of PTC Comprehensive Plan meetings
Another major component of the work program will include preparation of an environmental impact
CMR: 323:08 Page 4 of5
report and integration of CEQA significance thresholds used in the EIR into an appendix to the
Comprehensive Plan amendment. Policies to support neighborhood connections to enhance and
integrate a pattern of waJkable neighborhoods will be developed and potential connections
identified.
• Schedule of Work
Attachment A provides a detailed draft time line for the entire Compo Plan amendment process. The
main components are:
• Completion of Background Studies -through December 2008
• Review of Conlp. Plan policies/programs -October 2008 to March 2009
• Area Concept plan preparation January 2009 to May 2010
• Draft Housing Element preparation August 2008 to July 2009
• Comprehensive Plan EIR Preparation July 2009 to May 2010
• Comprehensive Plan Amendment for Review and Adoption -June 2010 to December
2010
RESOURCE IMPACTS
There are no fiscal impacts resulting from the study session. The Council approved a budget of
$850,000 in April 2008 for the amendment process, to be spread over 4 years beginning in FY 07/08.
POLICY IMPLICATIONS
Although this study session will result in no policy decision, the Comprehensive Plan amendment
process enables the Comprehensive Plan to be updated to focus on current City policy and
adequately reflect the City's vision consistent with the goals of the existing Comprehensive Plan.
The updated plan is intended to provide an effective guide for future growth in the City.
PREPARED BY:
DEPARTMENT HEAD:
CITY MANAGER APPROVAL:
CMR: 323:08
JULIE CAPORGNO
Chief Planning & Transportation Official
CURTIS WILLIAMS
Interim Director of Planning & Community
Environment
KELL Y MORARIU/STEVE EMSLIE
Interim Deputy City Managers
Page 5 of5
Approved Comprehensive Plan Amendment
Work Program
1. Update Base Conditions and Growth Projections
ATTACHMENT A
• Incorporate recent planning studies/new data into base conditions
• Identify a realistic growth rate for development through 2020
2. Amend Land Use Map and Land Use Designations
• Prepare land use evaluation for East Meadow CirclelFabian Way/ West Bayshore
area; identify land use and zoning changes
• Prepare land use evaluation for existing Fry's Electronics site and adjacent
properties: identify land use and zoning changes
• Evaluate existing definitions for non-residential land use designations and
determine if housing should be restricted or disallowed under those designations
3. Review Pertinent Policies and Programs
• Scan all programs for relevance and clarity
• Focus on policies that allow conversion of non-residential land to residential uses
• Add or strengthen policies that limit the loss of retail serving uses
• Incorporate policies and programs addressing or strengthening provision of
services where applicable
• Incorporate Sustainability Goal with relevant policies and programs from City's
Climate Protection Plan underscoring City's commitment to reduce global
warming
• Identify general areas for new parks and community facilities
• Enhance and integrate a pattern of walkable neighborhoods
• Update Housing Sites Inventory/Housing Element
• Develop policy regarding design standards for private streets
4. Environmental Analysis
• Prepare Environmental Impact Report for amendment
• Provide thorough analysis of service needs to schools, parks and libraries
resulting from project growth through 2020
• Integrate CEQA significance thresholds used in EIR in appendix to
Comprehensi ve Plan amendment
October 2009
Community
Involvement:
Concept Plan
Neighborhood
Workshops
(at least 3 for each Concept
Plan Area)
Citywide Community
Workshops
(at least 3)
Growth Assumptions
(PTC Public Hearings)
Draft Comprehensive
Plan Amendment I DEI R
(PTC Public Hearings)
Final Comprehensive
Plan and EIR
(PTC Public Hearings)
Planning &
Transportation
Commission
Review Work Scope,
Work Program,
Background Reports
Review Programs and
Policies
Concept Plan Area Land
Use Alternatives
Growth Assumptions
Draft Comprehensive
Plan Amendment I DEIR
Final Comprehensive
Plan and EIR
City Council:
Review Work Scope and
Work Program
Concept Plan Area Land
Use Alternatives
Growth Assumptions
Draft Comprehensive
Plan Amendment I DEIR
Final Com prehensive
Plan and EIR
March 2010
ATTACHMENT B
COMPREHENSIVE PLAN AMENDMENT 2020
SCHEDULE & KEY MILESTONES
2008 2009 2010 2011
January -February-June December
April-
December
March January -March
October -
December
•
2008 2009 2010 2(U1
July -December January -July
September -January -
December March
February-June
March January -March
October -
December
.
2008 2009 2010 2011
July March
May -August
March March
October -
December
2012
January -June
....... :
20~;2
I' .
January -June
2012
January -June
I
ATTACHMENT C
Existing Comprehensive Plan Vision Statements
Land use and Community Design Element Vision Statement
Palo Alto will be a vital, attractive place to live, work, and visit. The elements that make
Palo Alto a great community-its neighborhoods, shopping and employment centers,
civic uses, open spaces, and natural resources-will be strengthened and enhanced. The
diverse range of housing and work environments will be sustained and expanded to
create more choices for all income levels. All Palo Alto neighborhoods will be improved,
each to have public gathering spaces, essential services and pedestrian amenities, to
encourage less reliance on the automobile.
Transportation Element Vision Statement
Palo Alto will provide accessible, attractive, economically viable and environmentally
sound transportation options that meet the needs of residents, employers, employees and
visitors for safe, convenient and efficient travel by a variety of methods. Streets will be
safe and attractive, and designed to enhance the quality and aesthetics of Palo Alto
neighborhoods. Emphasis will be placed on alternatives to the automobile, including
walking, bicycling, public transit, and car and van pooling. The adverse impacts of
automobile traffic on the environment in general and residential streets in particular, will
be reduced. Solutions that reduce the growth in the number of automobiles on City
streets, calm or slow traffic, and save energy will be supported. It is hoped that
individuals will reduce their automobile trips by 10 percent by 2010, as alternative
transportation methods are implemented. The City will seek out innovative funding
sources and approaches to construct and maintain needed transportation systems. Palo
Alto recognizes the regional nature of our transportation system, and will be a leader in
seeking regional transportation solutions through long-term planning.
Housing Element Vision Statement
Palo Alto will aggressively pursue a variety of housing opportunities that enhance the
character, diversity and vitality of the City. The City is committed to increasing the
development of affordable and market-rate housing, including converting non-residential
lands to residential or mixed use. Existing housing, particularly rental units will be
conserved and rehabilitated or replaced. Palo Alto will continue its strong commitment
to supporting agencies that assist households with special needs. The City will foster an
environment free of discrimination and the barriers that prevent choice in housing. It will
place special emphasis on family housing and 'housing that addresses the health care,
child care, transit, recreation and social service needs of all Palo Alto residents.
Natural Environment Element Vision Statement
Palo Alto will meet today' s needs without compromising the needs of future generations.
Palo Alto will respect and manage natural resources in a way that sustains the natural
environment and protects our foothills, baylands, creeks, parks, wildlife and open space
legacy. Elements of the natural environment will be conserved where they remain intact
and restored where they have been degraded by past development. A substantial portion
of the City will remain as open space. Even in built-up areas, a network of parks will
provide access to nature and an urban forest will provide ecological benefits and a
source of beauty for residents. Palo Alto will strive for cleaner air and cleaner water. Its
policies and programs will foster energy and water conservation, reduced solid waste
generation, and cleanup of contaminated sites. The City will be well prepared for natural
disasters and will grow and change in a way that minimizes public exposure to hazards
like fire, flood, and earthquake.
Community Services and Facilities Element Vision Statenlent
Palo Alto will provide high quality community services to its residents, businesses, and
visitors. Its schools, libraries, parks, community facilities, and performing arts and
cultural centers are treasured and will be enhanced to serve current and future
generations. Its police and fire services will be managed to provide consistently high
levels of public safety. The City will continue to provide services and programs that meet
the needs of special populations-including children, seniors, and people with
disabilities-as well as programs in recreation, lifelong learning, and the arts that
benefit all populations. Palo Alto's success in providing these services will be expressed
and measured by the satisfaction of its customers, the public at large. The City will
pursue new ways to deliver community services in the most efficient and cost-effective
way possible. It will coordinate its efforts with other public agencies, nonprofits, and the
private sector to reduce overlap and maximize the use of resources.
Business Element Vision Statement
Palo Alto's business environment will be exciting, dynamic and vital. Businesses will
have access to a wide array of support services and will enjoy positive relationships with
Palo Alto residents, officials, and City staff. The competing needs of residents and
businesses will be balanced so that neighborhoods are protected and enhanced while
business districts are competitive and attractive. The local economy will thrive, and a
diverse array of goods and services will be provided to Palo Alto consumers. Most
development will occur within Palo Alto's employment areas, and will be consistent with
the role and character designated for each area by this plan.
Governance Element Vision Statement
Palo Alto will maintain a positive civic image and be a leader in the regional, state, and national
policy discussions affecting the community. The City will work with neighboring communities to
address common concerns and pursue common interests. The public will be actively and
effectively involved in City affairs, both at the Citywide and neighborhood levels. Where
appropriate, the City Council will delegate decision-making responsibilities to local boards and
commissions. The Council will also assign advisory roles to these bodies as well as other
community groups. Residents, businesses, and elected and appointed officials will work
collaboratively to address the issues facing the City in a timely manner. This inclusive,
participatory process will help build a sense of community.
ATTACHMENT 0
PTC Feedback on Vision Statement Session 10/21/09
Land use and Community Design Element Vision Statement
Palo Alto will be a vital, attractive place to live, work, and visit. The elements that make Palo Alto a great
community-its neighborhoods, shopping and employment centers, civic uses, open spaces, and natural
resources-will be strengthened and enhanced. The diverse range of housing and work environments will
be sustained and expanded to create more choices for all income levels. All Palo Alto neighborhoods will
be improved, each to have public gathering spaces, essential services and pedestrian amenities, to
encourage less reliance on the automobile.
Suggestions made by PTC to be included in the Land Use Element Vision
• acknowledge relationship of City and Stanford;
• recognize that City is built out;
• identify generally where higher densities should be located;
• change last sentence of vision statement to indicate all neighborhoods should
have adequate public gathering spaces ....
• emphasize neighborhood preservation
• focus on "visit" Palo Alto as destination
• recognize there needs to be balanced growth -accommodate regional needs yet
preserve neighborhood characteristics
• HAll Palo Alto neighborhoods will be improved". Hwill be improved H is a vague
language.
Transportation Element Vision Statement
Palo Alto will provide accessible, attractive, economically viable and environmentally sound
transportation options that meet the needs of residents, employers, employees and visitors for safe,
convenient and efficient travel by a variety of methods. Streets will be safe and attractive, and designed to
enhance the quality and aesthetics of Palo Alto neighborhoods. Emphasis will be placed on alternatives to
the automobile, including walking, bicycling, public transit, and car and van pooling. The adverse impacts
of automobile traffic on the environment in general and residential streets in particular, will be reduced.
Solutions that reduce the growth in the number of automobiles on City streets, calm or slow traffic, and
save energy will be supported. It is hoped that individuals will reduce their automobile trips by 10 percent
by 2010, as alternative transportation methods are implemented. The City will seek out innovative funding
sources and approaches to construct and maintain needed transportation systems. Palo Alto recognizes the
regional nature of our transportation system, and will be a leader in seeking regional transportation
solutions through long-term planning.
Suggestions made by PTC to be included in the Transportation Element Vision
• Incorporate the word "safe" in the vision statement
• Enlphasize "alternative modes of transport" but also respect individuals'
automobile rights.
• Include and address in the vision statement, goals and policies the effect of High
Speed Rail and Caltrain growth.
• Acknowledge anticipated Regional Growth and its effect on the city.
• Reference to "safe routes to school" in the vision statement.
• Incorporate in the vision statement concepts of (GHS) Green House Gas
emissions, (VMT) Vehicle Miles Travel, (TDM) Travel Demand Management
even when there is no adequate development (Arthur Keller)
• Emphasize alternate transportation use for commercial uses eg carpool, vanpool
etc.
Business Element Vision Statement
Palo Alto's business environment will be exciting, dynamic and vital. Businesses will have access to a wide
array of support services and will enjoy positive relationships with Palo Alto residents, officials, and City
staff. The competing needs of residents and businesses will be balanced so that neighborhoods are
protected and enhanced while business districts are competitive and attractive. The local economy will
thrive, and a diverse array of goods and services will be provided to Palo Alto consumers. Most
development will occur within Palo Alto's employment areas, and will be consistent with the role and
character designatedfor each area by this plan.
Suggestions made by PTC to be included in the Business Element Vision
• Include the word "retail" in the vision statement.
• Use managing or balancing needs instead of "competing needs in the vision
statement.
• Use the word "transit areas" instead of "employment areas"
• Integrate the notion of neighborhoods, business and schools in the vision
statement.
Natural Environment Element Vision·Statement
Palo Alto will meet today's needs without compromising the needs of future generations. Palo Alto will
respect and manage natural resources in a way that sustains the natural environment and protects our
foothills, baylands, creeks, parks, wildlife and open space legacy. Elements of the natural environment will
be conserved where they remain intact and restored where they have been degraded by past development.
A substantial portion of the City will remain as open space. Even in built-up areas, a network of parks will
provide access to nature and an urban forest will provide ecological benefits and a source of beauty for
residents. Palo Alto will strive for cleaner air and cleaner water. Its policies and programs will foster
energy and water conservation, reduced solid waste generation, and cleanup of contaminated sites. The
City will be well prepared for natural disasters and will grow and change in a way that minimizes public
exposure to hazards like fire, flood, and earthquake.
Suggestions made by PTC to be included in Natural Environment Element Vision
• Mention Global Warming and rise in Sea-Level impacts.
• Include accessibility to open space
• Actively manage Open Space, and don't leave it as it is.
• Manage instead of respect the natural resources of Palo Alto.
• Make the natural environments more sustainable.
• Dedicate more resources to deal with needs to maintain the natural environment.
Community Services and Facilities Element Vision Statement
Palo Alto will provide high quality community services to its residents, businesses, and visitors. Its schools,
libraries, parks, community facilities, and performing arts and cultural centers are treasured and will be
enhanced to serve current and future generations. Its police and fire services will be managed to provide
consistently high levels of public safety. The City will continue to provide services and programs that meet
the needs of special populations-including children, seniors, and people with disabilities-as well as
programs in recreation, lifelong learning, and the arts that benefit all populations. Palo Alto's success in
providing these services will be expressed and measured by the satisfaction of its customers, the public at
large. The City will pursue new ways to deliver community services in the most efficient and cost-effective
way possible. It will coordinate its efforts with other public agencies, nonprofits, and the private sector to
reduce overlap and maximize the use of resources.
Suggestions made by PTC to be included in Community Services and Facilities Elen1ent
Vision
• Prominent mention of Palo Alto Schools
• Collect full impact fees mentioned in the terms in the Nexus Study to improve the
existing facilities.
• Add the term "neighborhoods "to: It will coordinate its efforts with other public agencies,
nonprofits, and the private sector to reduce overlap and maximize the use of resources.
• Mention City of Palo Alto's relationship to Stanford.
Housing Element Vision Statement
Palo Alto will aggressively pursue a variety of housing opportunities that enhance the character, diversity and vitality
of the City. The City is committed to increasing the development of affordable and market-rate housing, including
converting non-residential lands to residential or mixed use. Existing housing, particularly rental units will be
conserved and rehabilitated or replaced. Palo Alto will continue its strong commitment to supporting agencies that
assist households with special needs. The City will foster an environment free of discrimination and the barriers that
prevent choice in housing. It will place special emphasis on family housing and housing that addresses the health care,
child care, transit, recreation and social service needs of all Palo Alto residents.
Suggestions made by PTC to be included in Housing Element Vision
• Balance housing with commercial use and provide amenities
• Add livable, sustainable concepts
• Vision should be linked with green objectives.
General Comments:
• Styles of the vision statements should be more cohesive.
• Vision statements should be realistic and not overarching or too general.
January 9, 2008
ABAG Executive Board
c/o Henry Gardner, Secretary -Treasurer
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94604-2050
Dear Mr. Gardner:
ATTACHMENT E
~!iy~! PalOAI~
Department of Planning and
Community Environment
The City of Palo Alto thanks you for providing us with the opportunity to review and comment
on the revised Draft Regional Housing Needs Allocation (RHNA), which was adopted by the
ABAG Executive Board on November 15,2007.
The City acknowledges ABAG's modification to Palo Alto's R.HNA to address the City'S Sphere
of Influence circumstance with the County of SantaClara and Stanford Upiversity .. ·.However,
our City Council, the Planning and Transportation COIl:@ission anci staffhave all· determined that
the RHNA of 2,860, even after ili.e reduction of 645 units, is cOIl1pletely unachievable in Palo
Alto given the lack of available land, the high cost of land a~quisition, and the impacts of that.
amount of growth on the City's neighborhoods and infrastructure. Setting these requirements
that cannot be achieved threatens the credibility and viability of important public institutions and
beconles simply an exercise'infuti}ity. .
Palo Alto has an extensive and long history of leading and implemelltiug affordable housing in
an area highly impacted by 'the high cost of housing. Wewere<-the first to implement
inclusionary zoning in this· region and Palo Alto Housing Corpor~ti9.i1iwas established back in .
1970 as a non-profit affordab!e housing provider. Although the:Clt)i:6f Palo Alto has adopted"
zoning and programs s~pporting core concepts behind the allocatipl1 method such as smart
growth, infill development, protection of open space and rurat~e;ts:,.:~estricting urban sprawl,
and transit oriented development, there should be a reasonablee:kpe~t~ti9il!ofsuccess in meeting
goals when assigning allocations to cities. ..', .... " .....
.. ,,1,
Factors such as essential iliit·astrudtdre needs and service reqtil:f¢fne1l1~;:;~I~d:';lte~d to be taken into
consideration. Many components of the City's infrastructure~e:':a1i~ady ,a,t capacity and another'
critical factor is the capacity limitations of the Palo Alto Unifl.edSthpol tli~trict. Thecutrent
school popUlation has alreiuly pushed the prese~t facilities beyolld' capacity so that every
elementary school now has multiple portables. Students fr9m an additional 2,86Q housing 'units
simply cannot be accommodated. ~th:the eXistip.g· facilities: and budget." Given' thal'the' s«;'h001'
district is at capacity, and there is no .. avajJable· flUldi.ng 'to'aycommddate.the increased' studv;nt'
population' from the allocation, these requirements would amount to" an linfundedtnandate for
Palo Alto. ..
Planning
250 Hamilton Avenue
P.O. Box 10250
Palo Alto, CA 94303
650.329.2441
650.329.2154
Transportation
250 Hamilton Avenue
P.O. Box 10250
Palo Alto, CA 94303
650.329.2520
650.617.3108
Building
285 Hamilton Avenue
P.O. Box 10250
Palo Alto, CA 94303
650.329.2496
650.329;2240
Mr. Henry Gardner
Page 2 of4
January 9, 2008
As staffhas indicated previously in transmittals to ABAG, the population and household growth
projections for Palo Alto will not be realized and should be adjusted to reflect a population
growth rate of approximately 3.0 % over the next RHNA period within our jurisdictional
boundary.ABAG's Projections 2007 assumes a population growth rate of approximately 7%
during the next 7 years in our jurisdictional boundary. Historically, the City of Palo Alto's
population has grown only by approximately 4.7% over the last thirty years. We understand that
the methodology uses Sphere of Influence population projections but we believe that the
population trend within our Sphere of Influence is proportional to the historic jurisdictional
boundary population trends. Although the City has experienced a growth rate of approximately
8% during the last seven years, this has been a period when Palo Alto has constructed significant
new housing development well in excess of histori~ averages and that rate cannot be sustained
given Palo Alto's limited land availability and redevelopment potential. Therefore, it's very
likely that the. City's population growth will remain far below ABAG's projections since it will
be very difficult for Palo Alto to continue the housing development it has experienced in the last
seven years.
During the last RHNA period, the City' ~ population growth was largely attributable to a single
development of approximately 1,000 units on the City's only remaining vacant large residential
site. This City's housing growth occurred during a temporary period of substantial decline in the
market for commercial development and increasing demand for housing. Taking this anomaly
and extrapolating this into the future is not appropriate. By using its own overestimated
Projections 2007 population numbers, the RHNA methodology compounds this error by
assigning a 45% weight to the population projections that ABAG itself created. This logic
appears circular in that the driver behind this growth appears to be the mandate from ABAG.
Additionally, the City should receive credit in this RHNA cycle for the 1,036 units that were
built during that last RHNA period that exceeded the City's assigned allocation. The City
exceeded its above moderate allocation by 1,282 units and its low allocation by 14 units with a
deficit of 51 units in the very low category and 208 in the moderate category. Palo Alto has also
protected and retained existing units that are more affordable and should receive further credit to
offset the City's RHNA requirements.
The City also continues to oppose the inclusion of an additional Transit Oriented Development
(TOD) factor in the allocation methodology to the extent that it would disproportionately assign
housing to cities like Palo Alto that have shown a commitment to TOD, in effect penalizing
cities that have developed smart growth policies. Additional growth requirements for built out
cities like Palo Alto should be predominantly TOD housing, not the core ABAG allocation plus
TOD housing.
The emphasis of transit use in the methodology is unrealistic at least for Palo Alto. Transit at the
University and California Avenue stations is used more efficiently by commuters and not
Mr. Henry Gardner
Page 3 of4
January 9, 2008
.so efficiently by residents; many more people take transit TO Palo Alto than FROM Palo Alto.
A greater concentration of jobs in the vicinity of transit will promote mass transit in Palo Alto
more effectively than the concentration of housing. Furthermore, Palo Alto has been assigned
additional units' based on transit access from the San Antonio Avenue station. However, this
station is located in and serves primarily Mountain View, not Palo Alto. Also, Caltrain only
services the San Antonio Cal train station once per hour during rush hours further reducing its
TOD effectiveness.
Palo Alto has promoted smart growth in its Comprehensive Plan policies and its' Pedestrian and
Transit Oriented Development (PTOD) zoning all in the midst ofVTA reducing bus services to
Palo Alto neighborhoods and with little or' no proj ected additional funding for transit to support
the TOD aspects ofRHNA. However, Palo Alto's diligence and success in implementing smart
growth policies appear to have led ABAG to assume that the City has no limit to further
intensifying with infill development.
Given the RHNA mandate to provide housing for all income levels, it is impossible for the City
to provide the 1,875 units assigned for below market rate income levels. Palo Alto prioritized
affordable housing as one of the City's top five goals and built over 90 percent of the City's very
low and low income housing allocation for the last RHNA cycle. However, the current RHNA
methodology uses 2000 Census income distribution data for allocating housing based on
affordability, and does not reflect the City's success in building affordable housing over the last
seven years. Instead, the current methodology allocated more affordable housing to Palo Alto
compared to the region as a whole.
Additionally, due to the extraordinary cost of land in Palo Alto, all very low and low income
rental housing that has been developed recently has required significant City subsidy. The cost
of low and very low income projects in Palo Alto are averaging $400,000 to $500,000 per unit.
Recently the City has had to subsidize approximately 50% of the project cost for most low
income. and very low income projects .. This is in large part due to the exorbitant land costs in
Palo Alto which average $1 0 million an acre but have been as high as $16 million an acre. In
order to develop the assigned 1,234 units of low and very low income housing under current
funding conditions, the City would be expected to provide a subsidy of approximately $245 to
$310 million, which is clearly unrealistic and unattainable as the City struggles to maintain
revenues adequate to support basic services to its residents and businesses. Given state subsidy
restrictions, and because of the high land costs in Palo Alto, moderate income units are achieved
only through the City's inclusionary zoning program, which requires 15 -20% affordability. As
a result, approximately 70% of the ABAG allocation would need to be subsidized by Palo Alto.
In order to provide the assigned 641 moderate income level units, the City would have to
develop 3,205 -4,272 market rate units. The high cost to the City of providing this housing as
well as supporting services and facilities, schools, transit and parks, is an unfunded state
mandate. There may also be insufficient water resources available to serve this additional
popUlation. Until there is state
I
Mr. Henry Gardner
Page4of4
January 9, 2008
subsidy available for affordable units, identifying adequate sites to meet proposed RHNA
housing for lower income levels in communities like Palo Alto will be a paper exercise.
The City requests that you confinn that the job growth anticipated with the proposed Stanford
Shopping Center and Medical Facility expansions are included in ABAG's projections for the
City's job growth for the 2007-2014 period, and the City will not be assigned these jobs a second
time in a future RHNA regardless of those projects' occupancy dates.
Finally, much discussion has occurred about the impact of commute emISSIons on climate
change. Palo Alto has just concluded a comprehensive climate change impact analysis. A
significant finding of that report is that 11 % of Palo Alto's C02 emissions are attributable to trips
into Palo Alto. Consequently, the report indicates that even an additional 2,860 units with
similar commuting characteristics would impact Palo Alto C02 emissions by less that 0.1 % or
1/1000th Palo Alto's total C02
In closing, the City requests that ABAG revise Palo Alto's RHNA to reflect a 3% population
growth over the seven-year RHNA period, exclude the San Antonio station from our transit
factor, adjust the transit factor to eliminate any "double counting" and credit the City with the 1,
036 units the City built in excess of our last RHNA assignment. The City also urges ABAG to
consider factors such 'as land costs and availability as well as community needs to provide
adequate open space and essential services in developing a realistic RHNA. Given that there was
no representative from the 250,000 residents of North Santa Clara County on the Housing
Methodology Committee, we were not adequately represented and, therefore, unique factors
prevalent in our area were not sufficiently considered in the ABAG allocations. If ABAG adopts
more realistic and achievable RHNA allocation goals, this will enable cities to focus on actually
providing adequate housing for a diverse' population, a goal strongly supported by the City
Council and the Palo Alto community.
The City of Palo Alto appreciates your consideration of our appeal of the assigned allocation.
Sincerely,
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Larry Klein
Mayor
cc: Paul Fassinger, ABAG Research Director