HomeMy WebLinkAboutStaff Report 7661
City of Palo Alto (ID # 7661)
City Council Staff Report
Report Type: Action Items Meeting Date: 3/27/2017
City of Palo Alto Page 1
Summary Title: Public Hearing: Housing Impact Fee Ordinance
Title: PUBLIC HEARING: Adoption of Two Ordinances to Update the City’s
Below Market Rate (BMR) Housing Program as Recommended by the Finance
Committee: (1) Repealing Municipal Code Section 16.47 (Non-residential
Projects) and 18.14 (Residential Projects) and Adding a new Section 16.65
(Citywide Affordable Housing In-lieu Fees for Residential, Nonresidential, and
Mixed Use Developments. The Proposed Ordinances are Exempt From the
California Environmental Quality Act (CEQA) per Sections 15378(b)(4), 15305
and 15601(b)(3) of the State CEQA Guidelines (FIRST READING: December
12, 2016 PASSED: 5-3 Kniss, Scharff and Wolbach no) Continued from January
9, 2017
From: City Manager
Lead Department: Planning and Community Environment
Recommendation
Staff recommends that the City Council conduct a second reading and adopt the attached
ordinances to amend the City’s Below Market Housing Program and update the housing impact
and in-lieu fees (Attachments A and B).
If Council wishes to make adjustments to one or both of the ordinances, staff recommends this
evening’s hearing be considered another first reading, and that the revised ordinances again be
placed on the Council’s consent agenda for a second reading. Possible adjustments include
changes to the fees listed in the second ordinance (Attachment B), and the addition of a
provision in the first ordinance (Attachment A) that would allow payment of in lieu fees rather
than provision of units for residential ownership projects with City Council authorization.
Executive Summary
The proposed ordinance included as Attachment A would rescind and replace sections of the
City’s Municipal Code governing inclusionary housing as well as the collection of the affordable
City of Palo Alto Page 2
housing impact fees charged to commercial development and the housing in lieu fees charged
to residential development. If adopted, the proposed ordinance and the associated fee
ordinance included in Attachment B would:
increase fees charged to new office/R&D development from $20.37 to $60 per square
foot;
increase fees charged to new hotel development from $20.37 to $30 per square foot;
maintain fees charged to retail/other commercial development at $20.37 per square
foot;
institute an impact fee for new market rate rental housing of $20 per square foot;
modify the in lieu fee for new market rate for-sale housing so that it is no longer
calculated at the time of sale (7.5% of the sale price), and is instead collected at the time
of building permit issuance, similar to an impact fee ($50 per square foot); and
modify the in lieu housing requirement for new market rate for-sale housing so that it is
triggered when a development includes three or more dwellings, rather than five or
more dwellings and so that there is clarity about when fees can be paid instead of
providing units on- or off-site.
The proposed fees are based on the two “nexus” studies which examined the relationship
between new commercial and residential development and the increased demand for
affordable housing. The Finance Committee of the City Council, the Planning and
Transportation Commission and City Council reviewed these nexus studies and each voted to
recommend slightly different fee amounts from those recommended by the consultant, as
shown in Tables 1 and 2, below. (The ordinance included as Attachment B would implement
the City Council’s recommendations.)
Table 1. Existing and Proposed Commercial Fees
City of Palo Alto Page 3
1The PTC recommended a phase-in of fees over a five-year period.
2Retail/Restaurant/Other was not studied as part of this nexus study and the staff’s recommendation is to maintain
the current fee of $20.37/new net square footage for this prototype based on the prior nexus study. The fee was
updated as part of the City’s budget process from $19.85/sf to $20.37/sf effective May 8, 2016.
Sources: Vernazza Wolfe Associates, Inc. & Strategic Economics, 2015 and City of Palo Alto Planning and
Community Environment, January 2017
Table 2. Existing and Proposed Residential Fees
Existing
Fees1
February
2016
Proposal
Finance
Committee
Recommended
Fees
PTC
Recommended
Fees
City Council
Recommended
Fees
Market Rate
Single Family
Detached
7.5 to 10%
of sales
price
$95/sf $50/sf $95/sf2 $50/sf
Market Rate
Single Family
Attached
7.5 to 10%
of sales
price
$50/sf $50/sf $50/sf $50/sf
Market Rate
Condo
7.5 to 10%
of sales
price
$50/sf $50/sf $50/sf $50/sf
Market Rate
Rental
Housing
None $50/sf $50/sf $10-$20/sf3 $20/sf
1Market rate ownership housing projects are currently subject to City’s Affordable housing in-lieu fees. Market rate
rental projects are exempt from this requirement.
2The PTC recommended setting a fee more commensurate with the cost of providing a unit.
3The PTC recommended setting the fee based on a comparison to nearby jurisdictions.
Sources: Vernazza Wolfe Associates, Inc. & Strategic Economics, 2015 and City of Palo Alto Planning and
Community Environment, January 2016
All fees would be adjusted by CPI on an annual basis. Further, all of the fees collected as a result
of the ordinance would be used for the preservation, rehabilitation, and development of
affordable housing, consistent with the City’s Affordable Housing Fund Guidelines available at
http://www.cityofpaloalto.org/gov/depts/pln/bmrhousing.asp.
City of Palo Alto Page 4
Background
In April of 2014, the City entered into a contract with Strategic Economics and Vernazza Wolfe
Associates, Inc., (the Consultants) to develop two nexus studies for commercial and residential
housing impact fees to mitigate the impact of new development on the demand for affordable
housing. This effort was partially motivated by the City’s need to address a series of court
decisions preventing the City from imposing inclusionary housing requirements on new rental
housing developments making it difficult for the City to impose rental housing fees without
economic justification. In addition, City policy requires that impact fees be periodically
reviewed to determine whether they are set at appropriate levels. The City’s updated Housing
Element (adopted November 2014) referenced these updated nexus studies in several
implementation programs and final drafts of the two studies were provided to City staff in late
November 2015.
An impact fee is a monetary exaction that is charged by a local governmental agency to an
applicant in connection with approval of a development project for the purpose of mitigating
impacts of the project. There must be a “nexus” or connection between the fee and the actual
impacts of the project. In general the fee must be “roughly proportional” to the impact the
project is creating. In order to establish a reasonable relationship between the development
project and the fee it is charged, cities typically commission “nexus studies.”
If a city has already established an impact fee through a nexus study, it is typical for a
municipality to periodically commission a new study to determine whether the fee level is
appropriately set.
City staff presented the results of the two nexus studies to the City Council Finance Committee
on February 16, 2016 and June 21, 2016. Staff reports for these meetings are available at:
http://www.cityofpaloalto.org/civicax/filebank/documents/50935 and
http://www.cityofpaloalto.org/civicax/filebank/documents/52827 respectively.
On June 21, 2016, The Committee voted 3-1 to direct staff to prepare an ordinance and a fee
schedule. In addition, a motion was made for staff and the PTC to explore options which would
allow Office, R&D and Hotels to proportionally reduce their impact fee payment by providing
Below Market Rate housing onsite or offsite or by deed restricting existing units as affordable.
Staff presented the Finance Committee’s recommendation along with the BMR Ordinance to
the PTC at meetings held on July 27, 2016, August 31, 2016 and November 30, 2016. Staff
reports for each of the three meetings are available at:
http://www.cityofpaloalto.org/civicax/filebank/documents/53215
http://www.cityofpaloalto.org/civicax/filebank/documents/53624 and
City of Palo Alto Page 5
http://www.cityofpaloalto.org/civicax/filebank/documents/54901.
Minutes from these PTC meetings are available at:
http://www.cityofpaloalto.org/civicax/filebank/documents/53622
http://www.cityofpaloalto.org/civicax/filebank/documents/54546 and
http://www.cityofpaloalto.org/civicax/filebank/documents/55402.
On December 12, 2016, the City Council reviewed and adopted (on first reading) two draft
ordinances updating the City’s Below Market Rate (BMR) Housing Program and establishing
housing impact fees and housing in-lieu fees for residential, nonresidential and mixed use
developments. The staff report from December 12th is available at:
http://www.cityofpaloalto.org/civicax/filebank/documents/55042.
Action minutes from this meeting are available at:
http://www.cityofpaloalto.org/civicax/filebank/documents/55464
The ordinance establishing housing impact fees and housing in-lieu fees (Attachment B) has
been modified to incorporate the Council’s amendment, which changed the Impact Fee
proposed per Square Foot of Net New Residential Floor Area for Apartments from $50 to $20 in
the table on p. 5.
Discussion
If the City Council is interested in revising their December 12, 2016 decision and modifying one
or more of the attached ordinances, the information provided in Tables 3, 4, and 5 below may
be of value. Table 3 shows impact fees charged to non-residential development in nearby
jurisdictions; Table 4 shows impact and in lieu fees charged to residential projects in nearby
jurisdictions; and Table 5 compares the cost of the residential in lieu fees proposed with the
City’s current fees; and Table 6 compares the cost of the residential in lieu fees proposed with
the cost of providing affordable units on site.
Also, if the Council is interested in addressing public comments expressing concerns regarding
the availability of funds for construction of new affordable housing, it may wish to consider
adding a new section to the ordinance in Attachment A making it easier for the City Council to
accept in lieu fees rather than inclusionary units in special situations. Staff’s recommended
language is provided below:
City of Palo Alto Page 6
Finally, if the Council is interested in addressing public comments (and PTC recommendations)
about phasing-in some of the fees, staff would recommend a single re-evaluation point
sometime in the next several years. Phasing-in fees over multiple years would take staff and
Council/PTC time away from other matters, pose something of an administrative burden, and
reduce predictabiliy for projects in the pipeline.
Table 3. Impact Fees on Non-Residential Development: Comparison with Other Jurisdictions
City Hotel Fee Office/R&D/
Medical Fee
Date Adopted/
Updated
Cupertino $10 $20 2015
Mountain View1 $2.50 $25 2015
Oakland2 N/A $5.44 2015
Redwood City3 $5 $20 2015
San Francisco4 $18 $16-$24 2015
Sunnyvale $7.50 $155 2015
Menlo Park6 $8.45 $15.57 2015
Notes:
1New gross floor area under 25,000 SF pays 50 percent of full fee.
2Oakland’s fee applies to office and warehouse/distribution development over 25,000 SF
3The fee applies to projects adding more than 5,000 SF of new commercial space. The fee is reduced by 25% if all
construction workers are paid prevailing wages.
4The fee for R&D is $16.01 and the fee for office is $24.03. The fee for a small enterprise is $18.89.
5The fee on the first 25,000 SF is discounted by 50 percent.
6The linkage fees are applied to commercial developments of 10,000 SF or more that do not include on-site
Section 16.65.080(B)(3):
Notwithstanding Section 16.65.080 (A) (5), the City Council may accept fees in lieu
of the alternatives in paragraph 1 provided it makes a finding that special
circumstances justify payment of fees over provision of ownership units, such as a
finding that the fees generated would result in more affordable units than those
required to be provided on site or that funds are needed to finance a pending
affordable housing project.
City of Palo Alto Page 7
affordable units.
Sources: City staff and websites; Nonprofit Housing Association of Northern California, 2015; Vernazza
Wolfe Associates, Inc. & Strategic Economics, May 2016
Table 4. Impact Fees on Market Rate Rental Housing: Comparison with Other Jurisdictions
Single Family
Detached
Single Family
Attached Condominiums Apartments
Date Adopted/
Updated
Berkeley N/A N/A N/A $31/SF (a) 2016
Cupertino $15/SF $16.50/SF (b) $20/SF $25/SF 2015
Daly City $14/SF $18/SF (c) $22/SF $25/SF 2014
East Palo Alto $22/SF $22/SF $22-$44/SF (d) $22/SF 2014
Emeryville N/A N/A N/A $33/SF (e) 2015
Mountain View N/A N/A N/A $17/SF 2015
Oakland (f) $8,000-
$23,000 $8,000-$20,000 $12,000-$22,000 $12,000-$22,000 2016 (proposed)
Redwood City
(g) $25/SF $25/SF $20/SF $20/SF 2015
San Carlos (h) $23.54-
$43.54/SF
$20.59-
$42.20/SF
$20.59-
$42.20/SF $23.54-$43.54/SF 2010
San Jose N/A N/A N/A $17/SF (i) 2014
Sunnyvale N/A N/A N/A $17/SF (j) 2015
Notes:
(a) Berkeley's affordable housing impact fee is $28,000 per unit. The per square foot fee is estimated based on the
prototype unit size.
(b) This fee applies to small lot single family and townhomes.
(c) This fee applies to townhomes.
(d) Fee ranges from $22 per square foot for for-sale housing without structured parking to $44 per square foot for
housing with structured parking.
(e) Emeryville's affordable housing impact fee is $28,000 per unit. The per square foot fee is estimated based on the
prototype unit size.
(f) Oakland's affordable housing impact fee for residential development are proposed only, with implementation
beginning in 2018.
(g) The fee applies to projects over 4 units, and is reduced by 25% if all construction workers are paid at prevailing
wage.
(h) Fees shown as ranges. Actual fees charged depend on project size.
(i) Fee goes into effect in 2016. Developments approved before July 2016 are exempt with a longer exemption for
downtown development.
(j) Smaller projects with between 4 and 7 units pay 50 percent of this fee.
City of Palo Alto Page 8
Sources: City staff and websites; Nonprofit Housing Association of Northern California, 2015; Vernazza
Wolfe Associates, Inc. & Strategic Economics, May 2016
Table 5. Comparison of Proposed Residential In Lieu Fees to the City’s Existing Fees on
Ownership Housing (16 Unit Single Family Detached Project)
Proposed In Lieu Housing Fees*
# Units Avg
SF/Unit
Est
Total SF
Fee/SF Fee/Unit Total
Fees
Fees per Staff & PTC 16 4,205 67,280 $95 $399,475 $6.39M
Fees per Council & Finance
Committee 16 4,205 67,280 $50 $210,250 $3.36M
*Includes basements in the calculation per the proposed ordinance.
Existing In Lieu Housing Fees
# Units Estimated Sales Price % of Sale
Price
Fee/Unit Total
Fees
16 $3,500,000 7.5% $262,500 $4.20M
Source: Palo Alto Planning & Community Environment, January 2017
Timeline
If the City Council chooses to adopt new housing impact fees on second reading this evening,
the ordinances and the fees would become effective in 60 days. If the City Council chooses to
make changes to one or both of the attached ordinances, tonight’s hearing would be
considered another first reading, and the ordinances would be placed on the Council’s consent
agenda for a second reading. The fees would become effective 60 days after that second
reading.
As currently drafted, the ordinances would apply the new fees to all pending and future
projects that have not obtained building permits prior to the effective date of the ordinance.
Environmental Review
The proposed ordinance is exempt from the California Environmental Quality Act (CEQA) per
Sections 15378(b)(4), 15305 and 15601(b)(3) of the State CEQA Guidelines. The new
ordinances are not expected to increase or decrease the number of newly constructed housing
units, but instead will regulate the unit’s affordability levels.
City of Palo Alto Page 9
City of Palo Alto Page 10
Table 6. Comparison of Proposed Residential In Lieu Fees to the Estimated Cost of Providing
Affordable Ownership Units on Site
Single-Family
Detached
Single-Family
Attached Condominium
Prototype Description
Number of Units in Prototype 20 10 35
Estimated Sales Price Market-Rate Unit $3,043,000 $1,666,000 $1,390,000
Average Unit Size (square feet) 3,000 2,100 2,100
Inclusionary Requirement
Percentage Inclusionary Requirement 15% 15% 15%
Number of Market-Rate Units 17 8 30
Number of Inclusionary Units Required 3.00 1.50 5.25
Number of Affordable Units Required (rounded) 3 2 5
Fractional Units1 - - 0.25
Cost to Developer if Existing In-Lieu Fees are
Paid
Total In-Lieu Fees $4,564,500 $1,249,500 $3,648,750
In-Lieu Fee Revenues per Market-Rate Unit $228,225 $124,950 $104,250
Cost to Developer if Units Provided on Site
Estimated Sales Price for Affordable Units2 $436,929 $436,929 $436,929
Foregone Revenue per Affordable Unit3 $2,606,071 $1,229,071 $953,071
Total Foregone Revenues $7,818,213 $2,458,142 $4,765,355
Total In-Lieu Fees for Fractional Units $0 $0 $26,063
Foregone and In Lieu Fee Revenues per
Market-Rate Unit $459,895 $307,268 $159,714
Cost to Developer if Proposed Housing Fees
are Paid
Maximum Fee per Market-Rate Unit (Maximum
Justified Fee per Nexus Study) $333,501 ($111/sf) $189,037 ($90/sf) $158,519 ($75/sf)
Recommended Fee per Market-Rate Unit
(Council & Finance Committee
Recommendation) $150,000 ($50/sf) $105,000 ($50/sf) $105,000 ($50/sf)
Recommended Fee per Market-Rate Unit
(PTC Recommendation) $285,000 ($95/sf) $105,000 ($50/sf) $105,000 ($50/sf)
NOTES:
1 If the BMR percentage results in a fractional unit, the developer has the option of paying the in-lieu fee on the fractional unit. 2 The affordable unit price is assumed to be affordable to a 5-person household at 110% Area Median Income in Santa Clara
County.
3 The foregone revenue per unit calculation is calculated as the difference between the market-rate sales price and the
affordable sales price.
City of Palo Alto Page 11
Sources: City of Palo Alto, November 2016; Vernazza Wolfe Associates, Inc. and Strategic Economics, 2016.
Attachments:
Attachment A: Below Market Rate Housing Ordinance (PDF)
Attachment B: Fee Ordinance (PDF)
Attachment C: Public Comments (PDF)
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161122 jb 0131520 1 December 20, 2016
Ordinance No. _____
Ordinance of the City of Palo Alto Repealing Chapter 16.47 (Approval of Projects with
Impacts on Housing) and Chapter 18.14 (Below Market Rate Housing Program) of the
Palo Alto Municipal Code and Replacing Them with a New Chapter 16.65 (Citywide
Affordable Housing Requirements)
The City Council of the City of Palo Alto hereby finds and declares as follows:
A. Under California Government Code Section 65580(d) all cities have a responsibility to
use the powers vested in them to facilitate the improvement and development of housing and to make
adequate provision for the housing needs of all economic segments of the community.
B. The provision of safe and stable housing for households at all income levels is essential
for the public welfare of the city. Housing in Palo Alto has become steadily more expensive and housing
costs have gone up faster than incomes. Federal and state government programs do not provide
enough affordable housing to satisfy the needs of very low, low, or moderate income households. As a
result, there is a severe shortage of adequate, affordable housing for extremely low, very low and
moderate income households, as evidenced by the following findings in the City's 2015-2023 Housing
Element:
1. Despite a high median income in Palo Alto, nearly 30 percent of all households
overpaid for their housing (more than 30 percent of their income) in 2010;
2. It is estimated that 63 percent of extremely low income renter households and
75 percent of extremely low income owner households overpaid for housing in 2010. Of the estimated
1,520 low income households, 75 percent of renter households and 44 percent of homeowner
households paid more than 30 percent of their income for housing.
3. Extremely low, very low and low income households in Palo Alto have almost no
affordable housing options without substantial subsidies. For moderate income households, adequately
sized and affordable rental housing options are very limited as well.
4. Homeownership is largely beyond the reach of most lower and moderate
income households in Palo Alto and low and very low income households have difficulty finding rental
properties in Palo Alto.
C. As stated in the City of Palo Alto's Housing Element, it is the City's policy to encourage,
foster, and preserve diverse housing opportunities for very low, low, and moderate income households.
The City can achieve its goals of providing more affordable housing and achieving an economically
balanced community only if part of the new housing built in the City is affordable to households with
limited incomes.
D. In order to meet the needs of moderate households, dwelling units will need to house a
variety of household types, incomes, and age groups.
E. The affordable housing ordinance codified in this chapter will substantially advance the
City's legitimate interest in providing additional housing affordable to all income levels and dispersed
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161122 jb 0131520 2 December 20, 2016
throughout the City by requiring construction of below-market rate housing and providing funds for
housing affordable to very low, low, and moderate income households.
F. New market-rate housing creates a demand for affordable housing, because new
residents of that housing purchase goods and utilize services in the community, increasing local
employment and attracting employees, of whom a quantifiable number will have very low, low, or
moderate incomes and cannot afford market-rate housing, as demonstrated in the Residential Impact
Fee Nexus Study dated October 2015, prepared by Strategic Economics and Vernazza Wolfe Associates,
Inc.
G. Because nonresidential projects also attracts employees, of whom a quantifiable
number will have very low, low, or moderate incomes, new nonresidential projects similarly increase the
demand for and exacerbate the shortage of housing available for people at these income levels, as
demonstrated in the Commercial Linkage Fee Nexus Study dated November 2015, prepared by Strategic
Economics and Vernazza Wolfe Associates, Inc.
H. Construction of market-rate housing and nonresidential projects that do not include
affordable units also aggravates the existing shortage of affordable housing by absorbing the supply of
available land.
I. Based on the findings above, the City desires to further the public health, safety and
welfare by requiring residential and nonresidential projects in the City to mitigate their impact on the
need for affordable housing in the City.
J. This ordinance implements Housing Element Program H3.1.2. In particular, this
ordinance:
1. Implements the inclusionary requirements, standards, and price limits
contained in Programs H3.1.2(a) and (b);
2. Contains standards for determining the feasibility of on-site BMR units, contains
BMR program priorities, and provides standards for alternatives, fractional units, and payment of in-lieu
fees as contained in Programs H3.1.2(c), (d), and (e), and after consideration of the possible policy
contained in Program H3.1.2(h);
3. Contains provisions for reviewing developer requests that the requirements in
the ordinance constitute a taking, consistent with Program H3.1.2(f);
4. Permits smaller or duplex BMR units in new single family residential subdivisions
after consideration of the possible policy contained in Program H3.1.2(g);
5. Evaluated and determined not to adopt the policy contained in Program
H3.1.2(i); and
6. Completed a nexus study to identify the impact of market rate housing on the
need for affordable housing, and developed policies for rental housing based on the results of the study,
consistent with Program H3.1.2(j). The nexus study also ensured that commercial developments
contribute to affordable housing through the payment of fees (Program H3.1.6).
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161122 jb 0131520 3 December 20, 2016
Based on the above, the City Council further finds that this ordinance is consistent with the Housing
Element and that any minor modifications in specific procedures are intended to better implement the
Housing Element’s purpose to “encourage, foster, and preserve diverse housing opportunities for very
low, low, and moderate income households.”
NOW, THEREFORE, the City Council of the City of Palo Alto, California, hereby ordains as follows:
SECTION 1: Chapter 16.47 (Approval of Projects with Impacts on Housing) of the Palo Alto
Municipal Code is hereby repealed.
SECTION 2: Chapter 18.14 (Below Market Rate Housing Program) of the Palo Alto Municipal
Code is hereby repealed.
SECTION 3: New Chapter 16.65 (Citywide Affordable Housing Requirements) is hereby
added to the Palo Alto Municipal Code to read in full as follows:
Chapter 16.65
CITYWIDE AFFORDABLE HOUSING REQUIREMENTS
Sections:
16.65.010 Purpose
16.65.020 Definitions
16.65.025 Exemptions
16.65.030 Basic Affordable Housing Requirements – Residential Ownership Projects
16.65.040 Basic Affordable Housing Requirements – Mixed-Use, Nonresidential and
Residential Rental Projects
16.65.060 Housing Impact Fee and In-Lieu Fee
16.65.070 Requirements for Residential Projects Containing Ownership and Rental Units
and for Mixed Use Projects
16.65.075 Provision of Affordable Units
16.65.080 Alternative Means of Compliance
16.65.090 Application and Review Procedures
16.65.100 Affordable Housing Funds
16.65.110 Administrative Relief
16.65.120 Enforcement
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161122 jb 0131520 4 December 20, 2016
16.65.010 Purpose. The purposes of this chapter are to:
A. Enhance the public welfare by establishing policies to provide affordable housing, meet
the City's regional share of housing needs, and implement the goals and objectives of
the comprehensive plan and housing element.
B. Mitigate the impacts of residential rental and nonresidential projects on the need for
affordable housing by imposing a housing impact fee whereby developers of residential
rental and nonresidential projects will contribute to the supply of housing for
households with very low, low, and moderate incomes.
C. Increase funds available to support the preservation and production of new affordable
housing in the City of Palo Alto.
D. Ensure that developers of new nonresidential square footage provide funding to
mitigate the impacts of new employment on the demand for affordable housing.
E. Ensure that developers of new market-rate rental housing provide funding to mitigate
the impacts of new residents on local employment and the resultant increased demand
for affordable housing.
F. To create incentives for developers to build new affordable units on- or off-site instead
of paying impact fees or in lieu fees.
G. To provide affordable housing that serves qualifying Palo Alto residents and those who
work in the City.
16.65.020 Definitions. The definitions set forth in this section shall govern the application and
interpretation of this chapter. Words and phrases not defined in this section shall be interpreted so as
to give this chapter its most reasonable application.
A. "Affordable housing agreement" means an agreement in conformance with Section
16.65.090(B) between the City and an applicant, governing how the applicant shall
comply with this chapter.
B. "Affordable housing guidelines" means the requirements for implementation and
administration of this chapter adopted by the planning and community environment
director in accordance with Section 16.65.090(D).
C. "Affordable housing plan" means a plan containing all of the information specified in
and submitted in conformance with Section 16.65.090(A) specifying the manner in
which affordable units will be provided in conformance with this chapter and the
affordable housing guidelines.
D. "Affordable rent" means the total monthly housing expenses for a rental affordable unit
not exceeding the rents specified by Section 50053 of the California Health and Safety
Code and California Code of Regulations Title 25, Sections 6910-6924. As used in this
Chapter, "affordable rent" shall include the total of monthly payments by the tenant for
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161122 jb 0131520 5 December 20, 2016
all of the following: (1) use and occupancy of the affordable unit and land and all
facilities associated with the affordable unit, including but not limited to parking, bicycle
storage, storage lockers, and use of all common areas; (2) any additional separately
charged fees or service charges assessed by the owner, other than security deposits; (3)
an allowance for utilities paid by the tenant as established by the City, including garbage
collection, sewer, water, electricity, gas, and other heating, cooking, and refrigeration
fuel, but not telephone service or cable TV; and (4) any other interest, taxes, fees or
charges for use of the land or affordable unit or associated facilities and assessed by a
public or private entity other than the owner, and paid by the tenant.
E. "Affordable sales price" means the maximum purchase price that will be affordable to
the specified household at the specified income level, calculated in accordance with
California Health and Safety Code Section 50052.5. The affordable sales price shall
include a reasonable down payment, and monthly housing payments (including interest,
principal, mortgage insurance, property taxes, homeowners insurance, homeowners
association dues, property maintenance and repairs, and a reasonable allowance for
utilities), all as determined by the City.
F. "Affordable unit" means a dwelling unit affordable to very low, low, or moderate
income households.
G. "Applicant" or "developer" means a person, persons, or entity that applies for a
residential or nonresidential project and also includes the owner or owners of the
property if the applicant does not own the property on which development is proposed.
H. "Area median income" or "AMI" means the annual median income for Santa Clara
County, adjusted for household size, as published periodically in the California Code of
Regulations, Title 25, Section 6932, or its successor provision, or as established by the
City of Palo Alto in the event that such median income figures are no longer published
periodically in the California Code of Regulations.
I. "Building permit" includes full structural building permits as well as partial permits such
as foundation-only permits.
J. "Common ownership or control" refers to property owned or controlled by the same
person, persons, or entity, or by separate entities in which any shareholder, partner,
member, or family member of an investor of the entity owns ten percent (10%) or more
of the interest in the property.
K. "Commercial housing fund" means a fund or account designated by the City to maintain
and account for all monies received from nonresidential project applicants pursuant to
this chapter.
L. "Decision-making body" means the City staff person or body authorized to approve or
deny an application for a planning or building permit for a residential, mixed use or
nonresidential project.
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M. "Density bonus units" means dwelling units approved in a residential project pursuant to
California Government Code Section 65915 that are in excess of the maximum allowable
residential density otherwise permitted by the City of Palo Alto.
N. "First approval" means the first of the following approvals to occur with respect to a
residential project: planning permit or building permit.
O. "Housing impact fee" or "housing fee" means the fee paid by developers of residential
and nonresidential projects to mitigate the impacts that such developments have on the
demand for affordable housing in the City.
P. "Low income households" are those households whose income does not exceed the low
income limits applicable to Santa Clara County as defined in California Health and Safety
Code Section 50079.5 and published annually pursuant to Title 25 of the California Code
of Regulations, Section 6932 (or its successor provision) by the California Department of
Housing and Community Development, generally households with incomes between
fifty percent (50%) and eighty percent (80%) of area median income.
Q. "Market rate unit" means a new dwelling unit in a residential project that is not an
affordable unit.
R. “Mixed use project” means an application for a planning permit or building permit that
includes the creation of one or more new dwelling units and the construction of net new
gross square footage of non-residential space or the conversion of a residential use to a
nonresidential use.
S. "Moderate income households" are those households whose income does not exceed
the moderate income limits applicable to Santa Clara County as defined in California
Health and Safety Code Section 50093 and published annually pursuant to Title 25 of the
California Code of Regulations, Section 6932 (or its successor provision) by the California
Department of Housing and Community Development, generally households with
incomes between eighty percent (80%) and one hundred twenty percent (120%) of area
median income.
T. "Nonresidential project" means an application for a planning permit or building permit
that includes the new construction of net new gross square feet of nonresidential space,
the conversion of a residential use to a nonresidential use, or the conversion of exempt
space (as provided in Section 16.65.025) to non-exempt space.
U. "Planning permit" means any discretionary approval of a residential project, including
but not limited to a comprehensive or specific plan adoption or amendment, rezoning,
tentative map, parcel map, conditional use permit, variances, or architectural review.
V. "Residential housing fund" means a fund or account designated by the City to maintain
and account for all monies received from residential project applicants pursuant to this
chapter.
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W. "Residential ownership project" means any residential project that includes the creation
of one or more new dwelling units that may lawfully be sold individually. A residential
ownership project also includes the conversion of a residential rental project to a
residential ownership project.
X. "Residential project" means any development for which a planning permit or building
permit is required that includes the creation of one or more new dwelling units,
conversion of nonresidential uses to dwelling units, or the conversion of a use from a
residential rental project to a residential ownership project.
Y. "Residential rental project" means any residential project on property under common
ownership and control that creates one or more net new dwelling units that cannot be
lawfully sold individually.
Z. "Very low income households" are those households whose income does not exceed
the very low income limits applicable to Santa Clara County as defined in California
Health and Safety Code Section 50105 and published annually pursuant to Title 25 of the
California Code of Regulations, Section 6932 (or its successor provision) by the California
Department of Housing and Community Development, generally households with
incomes less than fifty percent (50%) of area median income.
16.65.025. Exemptions. The following development projects are exempt from the provisions of
this chapter:
A. Residential projects consisting of the construction of one or two units, unless included in
a mixed use project.
B. Accessory dwelling units.
C. Junior accessory dwelling units.
D. Places of worship;
E. Colleges and universities
F. Commercial recreation;
G. Hospitals and convalescent facilities;
H. Private clubs, lodges, and fraternal organizations;
I. Private education facilities;
J. Public Facilities;
K. Retail service, eating and drinking service, personal service, or automotive service when
the total additional service related square footage is 1,500 square feet or less. This exemption shall
apply only when the additional square footage of new development does not exceed 1,500 square feet.
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New development that is larger than 1,500 square feet shall pay a fee or otherwise comply with this
Chapter for all square footage, including the first 1,500 square feet;
L. New gross square footage used for (1) an on-site cafeteria, recreational facility, or day
care facility provided for employees or their children and not open to the public; or (2) a hazardous
materials storage facility;
M. Projects that have established a vested right not to be subject to this chapter; and
N. Any nonresidential project otherwise determined to be exempt pursuant to City Council
resolution.
If a development project is exempt from this Chapter at initial construction, but later converts to a use
subject to this Chapter, the converted square footage will be deemed net new square footage or
dwelling units, as applicable, subject to the requirements of this Chapter.
16.65.030 Basic Affordable Housing Requirement – Residential Ownership Projects. The
provisions of this section shall apply to all residential ownership projects, including the residential
ownership portion of any mixed use project containing three or more units, except for any residential
ownership project exempt under Section 16.65.025.
A. Unless an alternative is approved as described in Section 16.65.080, residential
ownership projects shall provide the following:
a. For projects on sites of less than five acres, fifteen percent (15%) of the dwelling
units in the project shall be made available at affordable sales price to very low,
low, and moderate income households;
b. For projects on sites of five acres or more, twenty percent (20%) of the dwelling
units in the project shall be made available at affordable sales price to very low,
low, and moderate income households; and
c. For projects that convert existing rental housing to condominiums, other
residential ownership or nonresidential space or that remove existing rental
housing, twenty-five percent (25%) of the dwelling units in the project shall be
made available at affordable sales price to very low, low, and moderate income
households.
d. Calculations of the number of affordable units required by this Section shall be
based on the number of dwelling units in the residential project, excluding any
density bonus units. Projects shall not receive a credit for any existing dwelling
units demolished as part of the project.
B. The affordable units shall be made available at the following affordable sales prices:
1. For projects subject to subsections 16.65.030(A)(1) and (2), at least two-thirds
of the required affordable units must be made available at affordable sales price
to households earning eighty percent (80%) to one-hundred percent (100%) of
the area median income, and one-third may be made available at affordable
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sales prices to households earning between one-hundred percent (100%) and
one-hundred twenty percent (120%) of the area median income.
2. For projects subject to subsection 16.65.030(A)(3), at least four-fifths of the
required affordable units must be made available at affordable sales price to
households earning eighty percent (80%) to one-hundred percent (100%) of the
area median income, and one-fifth may be made available at affordable sales
prices to households earning between one-hundred percent (100%) and one-
hundred twenty percent (120%) of the area median income.
C. When the affordable housing requirements described in this Section result in a
fractional unit, an in-lieu payment as specified in Section 16.65.060 may be made for the
fractional unit instead of providing an affordable unit, except that, if the project
contains thirty (30) or more units, an additional affordable unit shall be provided for
each fractional unit of 0.50 or more. The in-lieu fee for a fractional unit shall be
calculated as described in the city’s affordable housing guidelines.
16.65.040 Basic Requirement – Mixed Use, Nonresidential and Residential Rental Projects.
Unless the mixed use, nonresidential or residential rental project is exempt under Section 16.65.025 or
an alternative is approved as described in Section 16.65.080, all mixed use, nonresidential and
residential rental projects shall pay housing impact fees as specified in Section 16.65.060 to mitigate the
projects’ impacts on the need for affordable housing; except that the residential ownership portion of a
mixed use project containing three or more units shall comply with Section 16.65.030.
16.65.060 Housing Impact Fee and In-Lieu Fee.
A. Fees. The amount of any housing impact fees and in-lieu fees shall be established from
time to time by ordinance or resolution of the City Council. Housing impact fees shall
not exceed the cost of mitigating the impact of mixed-use, nonresidential and
residential rental projects on the need for affordable housing in the City.
B. Fee Payment. Housing impact fees and in-lieu fees, if required, shall be paid prior to
issuance of any building permit for a development project subject to this chapter or at a
time otherwise specified by City Council ordinance or resolution.
16.65.070 Requirements for Residential Projects Containing Ownership and Rental Units and for
Mixed Use Projects
A. Residential Projects Containing Ownership and Rental Units. When a residential
project includes both ownership and rental dwelling units, the provisions of this chapter
that apply to ownership residential projects shall apply to that portion of the
development that consists of ownership dwelling units, while the provisions of this
chapter that apply to rental residential project shall apply to that portion of the
development that consists of rental dwelling units.
B. Mixed Use Projects Containing Residential Units. When a mixed use project contains
three or more dwelling units, either residential rental or residential ownership, the
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provisions of this chapter that apply to residential ownership and residential rental
projects shall apply to those portions of the development that consist of residential
ownership or residential rental units, as applicable, while the provisions of this chapter
that apply to non-residential projects shall apply to that portion of the development
that consists of non-residential uses. When a mixed use project contains fewer than
three dwelling units, impact fees shall apply to those units.
16.65.075 Provision of Affordable Units.
A. Standards for Affordable Units.
1. Affordable units shall be comparable in exterior appearance and overall quality
of construction to market-rate units in the same housing development. Interior
finishes and amenities must equal those provided in the base model market-
rate units.
2. The number of bedrooms and the size of the affordable units shall be
comparable to the average number of bedrooms in the market-rate units,
except that in a single-family detached development, the decision-making body
may allow smaller affordable units or duplex affordable units, if permitted in the
zoning district, when this furthers the provision of on-site affordable units. The
affordable units shall be reasonably dispersed within the residential project,
with unit locations comparable to those of the market-rate units, or, subject to
the approval of the Planning and Community Environment director, may be
clustered within the residential project when this furthers affordable housing
opportunities.
3. The affordable units shall have the same amenities as the market rate units,
including the same access to and enjoyment of common open space, parking,
storage, and other facilities in the residential project.
B. Timing of Construction. The affordable units shall be constructed in proportion to
construction of the market-rate units. No building permit shall be issued for any
market-rate unit unless a proportional number of building permits have been issued for
affordable units, and no certificates of occupancy or final inspections shall be issued for
any market-rate units unless a proportional number of certificates of occupancy or final
inspections have been issued for affordable units. An alternative phasing plan may be
approved as part of the approval of the affordable housing plan described in Section
16.65.090.
C. Continued Affordability.
1. All affordable units provided under Section 16.65.030 or Section 16.65.080 shall
be subject to a resale restriction, deed of trust, and/or regulatory agreement
recorded against the property for execution by the city manager, in a form
approved by the city attorney, to ensure the continued affordability of the
affordable units.
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2. Notwithstanding Section 18.15.040, to be considered as affordable units under
this chapter, all affordable units shall remain affordable to the targeted income
group for 99 years, except in the case of affordable housing developments
provided as an alternate means of compliance pursuant to Section 16.65.080,
the City may authorize a 55 year affordability restriction if required to maintain
eligibility for tax credit financing.
3. Any household that occupies an affordable unit must occupy that unit as its
principal residence, unless otherwise approved in writing for rental to a third
party for a limited period of time due to household hardship, as determined by
the City.
4. No household may begin occupancy of an affordable unit until the household
has been determined to be eligible to occupy that unit by the City or designee.
16.65.080 Alternative Means of Compliance. The developer of a mixed use, residential or
nonresidential project may request an alternate means of compliance, as described in this section, as a
component of the affordable housing plan required by Section 16.65.090.
A. Provisions Applicable to All Alternatives. The following provisions apply to all
alternative means of compliance described in this Section 16.65.080.
1. The applicant shall bear the burden of presenting substantial evidence to
support a finding of infeasibility under Section 16.65.080(B) and to support the
feasibility of any proposed alternative. The applicant shall set forth in detail the
factual and legal basis for any request under this section.
2. Any request under this section shall be submitted to the Planning and
Community Environment Director together with an economic analysis, if
required, or other supporting documentation and shall be acted upon by the
City Council.
3. When the affordable housing alternative results in a fractional unit, fees shall be
paid as specified in the affordable housing guidelines for any fractional units.
4. All affordable units shall conform with the provisions of Section 16.65.075.
5. The city council may approve or conditionally approve any alternative set forth
in this section if it makes all of the following findings and any additional findings
required for the selected alternative:
(a) The number of affordable units provided by the alternative equals or
exceeds that provided by on-site units or by the payment of impact
fees, as applicable to the project;
(b) The level of affordability provided by the alternative is the same or
lower as provided by on-site units or by the payment of impact fees, as
applicable to the project; and
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161122 jb 0131520 12 December 20, 2016
(c) The alternative is consistent with the comprehensive plan and housing
element and the provisions of this chapter.
B. Residential Ownership Projects.
1. If the provision of affordable ownership units under Section 16.65.030 is
infeasible, an applicant for a residential ownership project may request, in order
of priority, to: (a) provide on-site affordable rental units as provided in
subsection C below; (b) provide off-site affordable units as provided in
subsection D below; (c) dedicate land for affordable housing as provided in
subsection D below; (d) rehabilitate and convert existing residences to
affordable housing, or preserve existing affordable housing, as provided in
subsection E below; or (e) pay the in-lieu fee adopted as described in Section
16.65.060. The applicant must demonstrate that each of the higher priority
options is infeasible before the City will consider a lower priority option.
2. For the purposes of this section, "infeasible" means either that: (a) the
affordable sales price would be less than the cost of constructing the affordable
unit, including financing but excluding all other costs, including land, marketing,
improvements, and profit; or (b) provision of the units would produce a
confiscatory or unconstitutional result.
C. Affordable Rental Units in a Residential Ownership Project or a Residential Rental
Project.
1. An applicant for a residential ownership project or a residential rental project
may elect to make available dwelling units in the residential project at
affordable rent rather than provide on-site for-sale affordable units or pay
housing impact fees, as applicable. The city council may by ordinance or
resolution specify the percentage and affordability level of rental affordable
units that are equivalent to provision of on-site for-sale affordable units or
payment of housing impact fees, as applicable.
2. To ensure compliance with the Costa-Hawkins Act (Chapter 2.7 of Title 5 of Part
4 of Division 3 of the Civil Code), the City may approve such a proposal only if
the applicant agrees in a rent regulatory agreement with the City to limit rents
in consideration for a direct financial contribution or a form of assistance
specified in Chapter 4.3 (commencing with Section 65915) of Division 1 of Title 7
of the Government Code.
3. Any rent regulatory agreement for rental units in a residential ownership project
shall include provisions for sale of the affordable units and relocation benefits
for tenants of the affordable units if the owner of the residential ownership
project later determines to offer the affordable units in the residential project
for sale to moderate income households at an affordable sales price.
D. Dedication of Land and Off-Site Construction of Affordable Units.
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1. The applicant may submit an affordable housing plan that proposes either to
dedicate vacant land suitable for affordable housing or to construct affordable
units on another site. Two or more applicants may also jointly propose the
provision of vacant land suitable for affordable housing or the construction of
off-site affordable units on a single site.
2. Construction of the off-site affordable units may not commence prior to the first
approval of the residential project, and construction of the off-site units must
occur concurrently with construction of the market-rate units in the residential
project as described in Section 16.65.075.
3. The city council may approve or conditionally approve the dedication of land or
off-site construction if it makes all of the following findings in addition to making
the findings in subsection (A)(5) above:
(a) Financing or a viable financing plan, which may include public funding, is
in place for the off-site affordable units; and
(b) The off-site location is suitable for the proposed affordable housing,
consistent with any affordable housing guidelines and the Housing
Element, and will not tend to cause residential segregation.
4. No building permit shall be issued for any units in the residential project until
committed funding is available for the off-site units, or units to be constructed
on land to be dedicated.
5. Off-site construction of affordable units does not qualify the residential project
for a density bonus or other regulatory incentives allowed by Government Code
Section 65915 unless the off-site development includes the dedication of land
conforming to the provisions of Section 65915(g). No off-site alternative may be
approved by the City if a density bonus or other regulatory incentive is
requested for the site on which the affordable housing is to be built. Any off-
site alternative must comply with the density, intensity and other development
standards that are permitted under the zone for the site.
E. Rehabilitation and Conversion of Existing Market-Rate Housing.
1. The applicant may submit an affordable housing plan that proposes the
rehabilitation and conversion of existing market-rate housing to affordable
housing, or the preservation of existing affordable housing that is not deed
restricted as affordable.
2. The market-rate units to be converted to affordable units shall be located in a
residential project that is not subject to any existing affordability covenants
except covenants restricting other units in the development.
3. The affordable housing plan shall include a plan for long-term financial
sustainability of the market-rate units to be converted to affordable units, which
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incorporate, among other things, provisions to accommodate increases in
homeowners’ association fees, special assessments and maintenance costs.
4. Any existing tenants in the market-rate units to be converted to affordable
units shall be eligible to remain in the units; or the applicant shall provide
relocation assistance pursuant to Cal. Gov’t Code §§ 7260 et seq.
5. The city council may approve or conditionally approve the proposal if it makes
all of the following findings in addition to making the findings in subsection
(A)(5) above:
(a) The proposal includes substantial rehabilitation of the existing housing
equal to at least 25 percent of the after-rehabilitation value of the
property, inclusive of land value, and the units shall be in decent, safe
and sanitary condition and in compliance with all codes;
(b) Financing or a viable financing plan is in place for the units to be
converted to affordable units; and
(c) The off-site location is suitable for the proposed affordable housing,
consistent with any affordable housing guidelines and the Housing
Element, and will not tend to cause residential segregation.
6. No building permit shall be issued for any units in the residential project until
regulatory agreements approved by the city have been recorded for the existing
units to be converted to affordable housing.
F. Mixed Use Projects. An applicant for a mixed use development may submit an
affordable housing plan that proposes to mitigate the affordable housing impacts of the
non-residential and residential rental portions of the development through any of the
options listed above or through on-site provision of affordable units conforming with
applicable provisions of Section 16.65.075. In addition to making the findings in
subsection (A)(3) above, the city council may approve or conditionally approve such an
alternative if it determines, based on substantial evidence, that such alternative will
provide equal or greater public benefit than would payment of the housing impact fee.
G. Nonresidential Projects. An applicant for a nonresidential development may submit an
affordable housing plan that proposes to mitigate the affordable housing impacts of the
development through any of the options listed above or through on-site provision of
affordable units conforming with applicable provisions of Section 16.65.075. In addition
to making the findings in subsection (A)(5) above, the city council may approve or
conditionally approve such an alternative if it determines, based on substantial
evidence, that such alternative will provide equal or greater public benefit than would
payment of the housing impact fee.
16.65.090 Application and Review Procedures.
A. Affordable Housing Plan.
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1. All residential ownership projects and any mixed use, residential rental or
nonresidential project proposing to provide affordable units under the
provisions of Section 16.65.080 shall submit an affordable housing plan
concurrently with the application for the first approval of the project. The city
shall provide an application form specifying the contents of the affordable
housing plan. If an affordable housing plan is required, no application for a first
approval the project may be deemed complete until a complete affordable
housing plan is submitted. The cost of reviewing any proposed alternative,
including but not limited to the cost to the City of hiring a consultant to review
the application, shall be borne by the applicant.
2. No affordable housing plan is required for a mixed use, residential rental project
or a nonresidential project if the applicant proposes to pay housing impact fees,
or if the project is exempt under Section 16.65.025.
3. Any affordable housing plan shall be processed concurrently with all other
permits required for the development project. Before approving the affordable
housing plan, the decision-making body shall find that the affordable housing
plan conforms to this chapter. A condition shall be attached to require
recordation of an affordable housing agreement, as described in subsection B of
this section below, prior to the approval of any final or parcel map or building
permit for the development project.
4. The approved affordable housing plan may be amended prior to issuance of any
building permit for the development project. A request for a minor
modification of an approved affordable housing plan may be granted by the
Planning and Community Environment Director if the modification is
substantially in compliance with the original affordable housing plan and
conditions of approval. Other modifications to the affordable housing plan shall
be processed in the same manner as the original plan.
B. Affordable Housing Agreement.
1. Affordable housing agreements acceptable to the city manager or designee and
approved as to form by the city attorney shall be recorded against the
residential or nonresidential project prior to approval of any final or parcel map,
or issuance of any building permit, whichever occurs first, unless the project is
required only to pay impact fees.
2. The affordable housing agreement shall specify the number, type, location, size,
and phasing of all affordable units, provisions for income certification and
screening of potential purchasers or renters of units, and resale control
mechanisms, including the financing of ongoing administrative and monitoring
costs, consistent with the approved affordable housing plan and any affordable
housing guidelines, as determined by the city manager or designee.
C. The City Council, by resolution, may establish fees for the ongoing administration and
monitoring of the affordable units, which fees may be updated periodically, as required.
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D. The Planning and Community Environment Director may adopt affordable housing
guidelines to implement this chapter, and may update those guidelines periodically as
required.
16.65.100 Affordable Housing Funds.
A. All housing impact fees or other funds collected under this chapter shall be deposited
into the City’s Commercial and Residential Housing Funds.
B. The monies in the Commercial and Residential Housing Funds and all earnings from
investment of the moneys in the Funds shall be expended exclusively to provide housing
affordable to very low income, lower income, and moderate income households in the
City, consistent with the goals and policies contained in the City’s Housing Element and
for administration and compliance monitoring of the affordable housing program.
16.65.110 Administrative Relief.
A. As part of an application for the first approval of a residential or nonresidential project,
a developer may request that the requirements of this chapter be waived or modified
by the city council, based upon a showing that applying the requirements of this chapter
would result in an unconstitutional taking of property or would result in any other
unconstitutional result.
B. The request for a waiver or modification shall set forth in detail the factual and legal
basis for the claim.
C. Any request for a waiver or modification shall be reviewed and considered at the same
time as the project application or any affordable housing plan.
D. The waiver or modification may be approved only to the extent necessary to avoid an
unconstitutional result, based upon legal advice provided by or at the behest of the City
Attorney, after adoption of written findings, based on legal analysis and substantial
evidence. If a waiver or modification is granted, any change in the project shall
invalidate the waiver or modification, and a new application shall be required for a
waiver or modification under this section.
16.65.120 Enforcement.
A. Penalties. Persons employed in the following designated employee positions are
authorized to exercise the authority provided in the California Penal Code Section 836.5
and are authorized to issue citation for violations of this chapter: development services
director, director of planning and community environment and their designees.
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B. The city attorney shall be authorized to enforce the provisions of this chapter and all
affordable housing agreements, regulatory agreements, and all other covenants or
restrictions placed on affordable units, by civil action and any other proceeding or
method permitted by law.
C. Failure of any official or agency to fulfill the requirements of this chapter shall not
excuse any developer or owner from the requirements of this chapter. No permit,
license, map, or other approval or entitlement for a residential project shall be issued,
including without limitation a final inspection or certificate of occupancy, until all
applicable requirements of this chapter have been satisfied.
D. The remedies provided for in this section shall be cumulative and not exclusive and shall
not preclude the city from any other remedy or relief to which it otherwise would be
entitled under law or equity.
SECTION 4. Severability. If any section, subsection, sentence, clause, phrase or word of this
Ordinance is for any reason held to be invalid by a court of competent jurisdiction, such decision shall
not affect the validity of the remaining portions of this Ordinance. The City Council hereby declares that
it would have passed and adopted this Ordinance, and each and all provisions hereof, irrespective of the
fact that one or more provisions may be declared invalid.
SECTION 5: CEQA. This ordinance is exempt from the California Environmental Quality Act
(CEQA) under State CEQA Guidelines Section which 15061(b)(3) providing an exemption for
administrative actions that do not result in physical changes to the environment; Section 15378(b)(4)
providing an exemption for government funding mechanisms which do not involve a commitment to
any specific project and Section 15305 (Minor Alterations in Land Use Limitations), a categorical
exemption that applies to code amendments that will not have any significant environmental effects.
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SECTION 6: Public Notice and Effective Date. This Ordinance shall take effect 31 days after
its adoption by the City Council or concurrent with Ordinance ___, whichever occurs later.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
__________________________ _____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
___________________________ _____________________________
Senior Asst. City Attorney City Manager
_____________________________
Director of Planning and Community
Environment
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Ordinance No.
Ordinance of the Council of the City of Palo Alto Establishing Housing Impact
Fees and Housing In‐Lieu Fees for Residential, Nonresidential, and Mixed Use
Developments
The Council of the City of Palo Alto ORDAINS as follows:
A. On November 10, 2014 the City Council of the City of Palo Alto adopted its 2015‐
2023 Housing Element which includes the policy of encouraging, fostering, and preserving
diverse housing opportunities and which contemplates, among other things, an amendment of
the City's below market rate program to promote this policy and to be consistent with case law
related to inclusionary rental housing; and
B. To implement the affordable housing goals, policies and programs of the City's
2015‐2023 Housing Element, the City Council has considered and introduced on this same date
Ordinance No. repealing Chapters 18.14 and 16.47 of the Palo Alto Municipal Code and adding
a new chapter 16.65, Citywide Affordable Housing Requirements (the "Affordable Housing
Ordinance"), which provides, among other things, that the City Council shall establish, from
time to time, housing impact fees that may be applicable to residential rental projects, mixed
use projects, and nonresidential projects and housing in‐lieu fees that may be applicable to
residential ownership projects. The Affordable Housing Ordinance further provides that the
City Council may specify the percentage and affordability level of rental affordable units that
are equivalent to provision of on‐site for‐sale affordable units or payment of housing impact
fees.
C. To ensure that future development projects mitigate their impact on the need
for affordable housing in Palo Alto, and to ensure that any adopted housing impact fees or in‐
lieu fees do not exceed the actual affordable housing impacts attributable to the development
projects to which the fees relate, the City Council has received and considered two reports from
Strategic Economics and Vernazza Wolfe Associates dated October and November 2015 and
entitled "Residential Impact Fee Nexus Study" and "Commercial Linkage Fee Nexus Study",
respectively (collectively, the "Nexus Studies"), and the findings of the Nexus Studies are
incorporated into this Ordinance by this reference.
D. The Nexus Studies use widely used, appropriate methodology to determine the
maximum amount needed to fully mitigate the burdens created by residential, nonresidential
and mixed‐use development on the need for affordable housing and establish that there is a
reasonable relationship between the need for affordable housing and impacts of development
for which a fee is charged, and that there is also a reasonable relationship between the impact
fee’s use and the type of development for which the fee is charged.
E. To ensure that development projects remain economically feasible, the
recommended housing impact fees and in‐lieu fees as shown in the attached Exhibit A are
161122 jb 0131543 1 Nov. 28, 2016
2161122 jb 0131543 Nov.28,2016
lower than the maximum amount needed to fully mitigate the burdens created by new
development on the need for affordable housing as determined by the Nexus Studies.
F. The City Council now desires to adopt housing impact fees and in‐lieu fees for
certain residential, nonresidential, and mixed‐use development projects as authorized by the
Affordable Housing Ordinance, which fees do not exceed the justified fees needed to mitigate
the actual affordable housing impacts attributable to the development projects to which the
fees relate, as determined by the Nexus Studies; and further desires to specify the percentage
and affordability level of rental affordable units that are equivalent to provision of on‐site for‐
sale affordable units or payment of housing impact fees. The City Council further finds that the
housing impact fees for retail, restaurant and other non‐residential uses (excluding hotels,
office, medical office and research and development uses) analyzed in the May 2002 Nexus
Study and set forth in the 2016‐17 Municipal Fee Schedule are sufficient to mitigate the actual
affordable housing impacts attributable to the development projects to which the fees relate.
G. The housing in‐lieu fees adopted by this ordinance provide an alternative
method for calculating the in‐lieu fees described by Program H3.1.2 of the City's 2015‐2023
Housing Element which, as described in the record, will in most instances provide equivalent or
greater total revenue to the Residential Housing Fund.
H. In compliance with the Affordable Housing Ordinance, all in‐lieu fees and impact
fees collected shall be deposited into the City’s Commercial and Residential Housing Funds to
be used only for those purposes included in the Affordable Housing Ordinance.
I. At least ten days prior to the date this ordinance is being heard, data was made
available to the public indicating the amount of cost, or estimated cost, required to provide the
service for which the fee or service charge is levied and the revenue sources anticipated to
provide the service, including general fund revenues, in accordance with Government Code
Section 66019.
J. At least fourteen days prior to the date this ordinance is being heard, notice was
provided to any persons or organizations who had requested notice, in accordance with
Government Code Sections 66004 and 66019.
K. Notice of the hearing on the proposed fees was published twice in the manner
set forth in Government Code Section 6062a as required by Government Code Sections 66004
and 66018.
L. The City Council has reviewed the information contained in this Ordinance and
the accompanying staff report and all written and oral testimony at a meeting held on ,
2016.
NOW, THEREFORE, the Council of the City of Palo Alto does ORDAIN as follows:
3161122 jb 0131543 Nov.28,2016
SECTION 1. The foregoing recitals are true and correct and incorporated by this
reference.
SECTION 2. The City Council hereby repeals the housing impact and housing in lieu
fees contained in the 2016‐2017 Municipal Fee Schedule as adopted by City Council Ordinance
5386.
SECTION 3. The City Council hereby amends the Municipal Fee Schedule by adopting
housing impact fees and in‐lieu fees for residential ownership development projects, for
residential rental development projects, residences in mixed‐use projects, and nonresidential
development, as shown on Exhibit "A", attached hereto and incorporated by this reference.
SECTION 4. The City Council may review housing impact and in‐lieu fees from time to
time. For any annual period during which the City Council does not review the housing impact
and in‐lieu fees, fee amounts shall be adjusted in accordance with Chapter 16.64.
SECTION 5. As provided in Section 16.65.080(C)(1) of the Affordable Housing
Ordinance, the City Council hereby determines that the following percentages of rental
affordable units that are equivalent to provision of on‐site for‐sale affordable units or payment
of housing impact fees:
Required Affordable Rental Units
(Where rental alternative requested under 16.65.080(C))
Rental Alternative to For‐Sale
Units
(Sites Less than 5 Acres)*
Rental
Residential
(no condo map)
Income Category
Very Low Income
Low Income 15%
Moderate Income 15%
TOTAL 15%15%
*Rental alternative equivalents for projects over 5 acres will be subject to Council approval on a case by
case basis.
SECTION 6. The City has determined that the housing mitigation fees should be
adopted and administered consistent with the requirements applicable to fees for public
facilities in California Government Code Section 66000 et seq., commonly referred to as the
Mitigation Fee Act, without determining that it is required to do so.
4161122 jb 0131543 Nov.28,2016
SECTION 7. Adoption of this ordinance is exempt from the California Environmental
Quality Act because the proposed fee increase is not a project, in that it is a government
funding mechanism which does not involve any commitment to any specific project (CEQA
Guidelines Section 15378(b)(4)).
SECTION 8. Severability. If any section, subsection, sentence, clause, phrase or word of
this Ordinance is for any reason held to be invalid by a court of competent jurisdiction, such
decision shall not affect the validity of the remaining portions of this Ordinance. The City
Council hereby declares that it would have passed and adopted this Ordinance, and each and all
provisions hereof, irrespective of the fact that one or more provisions may be declared invalid.
SECTION 9. This Ordinance shall be effective upon the sixtieth (60th) day after its passage
and adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
City Clerk Mayor
APPROVED AS TO FORM:
Senior Asst. City Attorney
APPROVED:
City Manager
Director of Planning and Community
Environment
Director of Administrative Services
5161122 jb 0131543 Nov.28,2016
Not Yet Approved
EXHIBIT A
Housing Impact Fees and In‐Lieu Fees
Residential Projects:
" Residential Floor Area" for Single‐Family Detached and Attached Homes includes all horizontal
areas of the several floors of such buildings measured from the exterior faces of exterior walls
or from the center line of party walls separating two (2) buildings, minus the horizontal areas of
such buildings used exclusively for parking. Basements shall be included in this measurement
when they include livable area.
"Residential Floor Area" for Apartments and Condominiums includes all horizontal areas of the
several floors of such buildings measured from the exterior faces of exterior walls or from the
center line of party walls separating two (2) buildings, minus the horizontal areas of such
buildings used exclusively for covered porches, patios, or other outdoor space, amenities and
common space, parking, elevators, stairwells or stairs between floors, hallways, and between‐
unit circulation.
“Net New Residential Floor Area” for Rental Projects (Apartments) means the Residential Floor
Area for the net new units.
Residential Ownership Projects and
Residential Ownership Units in Mixed Use
Projects *
(For fractional units & where in‐lieu fee
approved under 16.65.080(B))
In‐Lieu Fee per Square Foot of
Residential Floor Area
Single‐Family Detached Home $50
Single‐Family Attached Home $50
Condominiums $50
Residential Rental Projects and Residential
Rental Units in Mixed Use Projects*
Impact Fee per Square Foot of Net New
Residential Floor Area
Apartments $5020
*The residential ownership portion of a mixed use project containing three or more units shall
comply with Section 16.65.030 unless an alternative means of compliance is authorized under
Section 16.65.080(F). The residential rental portion of a mixed use project containing three or
more units shall comply with Section 16.65.040 unless an alternative means of compliance is
authorized under Section 16.65.080(F). The residential component of mixed use projects
containing fewer than three dwelling units shall be subject to the housing impact fees shown in
this table.
6161122 jb 0131543 Nov.28,2016
Residential projects may be exempt from payment of housing impact and housing in‐lieu fees
as provided in Section 16.65.025.
Nonresidential Projects and Nonresidential Square Footage in Mixed‐Use Projects
“Nonresidential Floor Area” includes all horizontal areas of the several floors of such buildings
measured from the exterior faces of exterior walls or from the center line of party walls
separating two (2) buildings, minus the horizontal areas of such buildings used exclusively for
parking.
If no non‐residential use existed on the site within one year prior to the issuance of a building
permit for the project, the Housing Impact Fee is calculated by multiplying the Nonresidential
Floor Area contained in the project by the relevant Housing Impact Fee.
Where another non‐residential use existed on the site within one year prior to the issuance of a
building permit for the project, the Housing Impact Fee is calculated by:
1. Multiplying the Nonresidential Floor Area contained in the project by the relevant
Housing Impact Fee;
2. Multiplying the Nonresidential Floor Area of the former use by the relevant Housing
Impact Fee shown in this table; and
3. Subtracting the amount calculated in Step 2 from the amount calculated in Step 1.
Nonresidential Use Housing Impact Fee per Square Foot of
Nonresidential Floor Area
Hotel $30
Retail, Restaurants and Other Non‐
Residential* Uses
$20.37**
Office, Medical Office and
Research and Development
$60
*Hotels and Office, medical office and research and development uses are not included in
“other non‐residential uses.”
**This rate is carried over from the 2016‐17 Municipal Fee Schedule as analyzed in the May
2002 Nexus Study and adjusted for inflation.
Nonresidential projects may be exempt from payment of housing impact fees as provided in
Section 16.65.025.
1
Murillo-Garcia, Eloiza
From:Gitelman, Hillary
Sent:Monday, January 09, 2017 7:57 AM
To:Murillo-Garcia, Eloiza; Silver, Cara
Subject:FW: Consent Calendar Item 14 - January 9, 2017, Regular Meeting
Attachments:LWVPA LTR 2017Council Housing Fees.docx
FYI
Hillary Gitelman | Planning Director | P&CE Department
250 Hamilton Avenue | Palo Alto, CA 94301
T: 650.329.2321 |E: hillary.gitelman@cityofpaloalto.org
Please think of the environment before printing this email – Thank you!
From: LWV of Palo Alto [mailto:lwvpaoffice@gmail.com]
Sent: Saturday, January 07, 2017 2:26 PM
To: Council, City
Subject: Consent Calendar Item 14 - January 9, 2017, Regular Meeting
Dear City Council,
Attached please find a letter from the League of Women Voters of Palo Alto requesting that Item No. 14 be removed from the Consent Calendar for the January 9, 2017, City Council regular meeting.
Thank you.
Bonnie Packer President
--
League of Women Voters of Palo Alto
3921 E. Bayshore Road, Suite 209
Palo Alto, CA 94303
(650) 903-0600
January 7, 2017 Greg Scharff, Mayor, and City Council Members 250 Hamilton Ave Palo Alto, CA 94301 Re: January 9, 2017, Consent Calendar Item No. 14: Housing Impact Fee Ordinance - Second Reading Dear Mayor Scharff and City Council Members, The League of Women Voters of Palo Alto (LWVPA) requests that Consent Calendar Item No. 14, Housing Impact Fee Ordinance - Second Reading, be removed from the Consent Calendar to give the Council an opportunity to further consider the recommendations of the Planning and Transportation Commission (P&TC). While the Council did accept one of the P&TC recommendations regarding the impact fee for new rental housing, LWVPA urges the Council to consider the other recommendations of the P&TC for the reasons in LWVPA’s December 7, 2016, letter to the Council on these ordinances as set forth below. The League of Women Voters of Palo Alto (LWVPA) applauds the City’s continuing efforts to provide mechanisms for the provision of housing for those with very low, low and moderate incomes. LWVPA has historically supported both Palo Alto's inclusionary housing program and the assessment of housing impact fees on non-residential development for the Affordable Housing Fund. These programs have provided many below market rate (BMR) rental and for-purchase homes and have been a valuable source of funding for very low, low and moderate income housing developments in Palo Alto. For this reason, LWVPA supports the proposed Citywide Affordable Housing Requirements Ordinance and the housing impact fees recommended by the Planning and Transportation Commission (P&TC). In our comments to the P&TC on this ordinance, LWVPA noted the difficulty in balancing the desire to ensure there is a robust Affordable Housing Fund to support development of multi-unit housing for those with very low, low and moderate incomes versus the desire to have a certain amount of below market rate housing units sprinkled throughout the City. The Commissioners’ thoughtful discussions on this and other important policy issues were the basis for their fee recommendations regarding the ordinance and the associated fee schedule. LWVPA supports the P&TC impact fee recommendations that differ from the staff recommendation for the following reasons:
• An impact fee on new rental housing that is comparable to neighboring cities – between $10-20 per square foot – would alleviate the negative impact to renters who are already struggling to pay the current exceedingly high rental rates.
• An impact fee of $95 per square foot on new detached market rate housing would help maintain a robust Affordable Housing Fund. LWVPA realizes that the effect on the City’s affordable housing policies and goals of the fee schedule is unknown; therefore, we support the P&TC proposals that the impact fees for the non-residential developments be phased in over five years and that all the impact fees be reviewed annually by the P&TC.
THE LEAGUE
OF WOMEN VOTERS
OF PALO ALTO
3921 E. BAYSHORE RD., SUITE 209 • PALO ALTO, CALIFORNIA 94303 • 650-903-0600 • www.lwvpaloalto.org
While LWVPA supports the proposed Citywide Affordable Housing Requirements Ordinance, we still have concerns that the thrust of the ordinance is to favor on-site below market rate units as opposed to the payment of fees. We noted in our letter to the P&TC: While LWVPA supports policies that allow for the provision of units for those with moderate incomes where it is feasible for a developer to do so, LWVPA notes that this ordinance may have the consequence of producing much less cash for the Affordable Housing Fund. Today, cash from this Fund can be leveraged to obtain other sources of funding (for example through the federal Tax Credit program) for the development of many more units for those with very low and low incomes, than can otherwise be produced when a developer provides units on or off site rather than housing impact fees. Thank you for considering our comments. Very truly yours, Bonnie Packer President League of Women Voters of Palo Alto
1
Murillo-Garcia, Eloiza
From:Gitelman, Hillary
Sent:Monday, January 09, 2017 7:56 AM
To:Murillo-Garcia, Eloiza; Silver, Cara
Subject:FW: Consent item 14 impact fees
FYI
Hillary Gitelman | Planning Director | P&CE Department
250 Hamilton Avenue | Palo Alto, CA 94301
T: 650.329.2321 |E: hillary.gitelman@cityofpaloalto.org
Please think of the environment before printing this email – Thank you!
‐‐‐‐‐Original Message‐‐‐‐‐
From: Steve Levy [mailto:slevy@ccsce.com]
Sent: Sunday, January 08, 2017 10:04 AM
To: Council, City
Subject: Consent item 14 impact fees
I support removing the item from the consent calendar and scheduling a later hearing to review the previous decisions.
As Chair of the League of Women Voters Housing and Transportation committee, I strongly support the letter(s) sent to
you on this issue by Bonnie Packer.
I believe two principles established by council in the minimum wage discussion are useful guides for reviewing impact
fee decisions:
1‐‐comparability with neighboring jurisdictions and
2‐‐phasing
These issues have been raised by council members, PTC members and the League.
I know that the fees are designated for housing assistance for low income resident and I know also that the past five
years have been so strong in job growth that it seemed that any level of fess would not deter the desire to build in Palo
Alto.
But I also know professionally that job growth is entering a period of dramatic slowdown regionally and will become
much more competitive.
Finally I know that many council members have mentioned fiscal stability and sustainability as important goals.
2
As the year proceeds I encourage the council to 1) revisit the city economic development policy statement of January
2013 and consider the economic and fiscal implications of decisions on fees and other policies.
Stephen Levy
365 Forest 5A
Palo Alto CA 94301