Loading...
HomeMy WebLinkAboutStaff Report 3798 City of Palo Alto (ID # 3798) City Council Staff Report Report Type: Action Items Meeting Date: 5/20/2013 City of Palo Alto Page 1 Summary Title: Housing Element Update Title: Adoption of a Resolution Adopting the 2007-2014 Housing Element of the Comprehensive Plan and Approving a Negative Declaration From: City Manager Lead Department: Planning and Community Environment Recommendation Staff, the Planning and Transportation Commission, and the Regional Housing Mandate Committee recommend a City Council MOTION to approve a Resolution (Attachment A) adopting the revised Housing Element 2007-14 of the Comprehensive Plan and approving a Negative Declaration. Executive Summary California State Housing Element law requires each city and county to update its housing element every five years to ensure that all localities provide adequate development sites for sufficient new housing to be built to meet their fair share of the regional housing need. Housing element law is the State’s primary strategy to increase housing supply, choice and affordability. The housing element identifies the existing and projected housing needs of all economic segments of the community and promotes a variety of housing types. The housing element also defines the policies and programs that the community will implement to achieve its housing goals and objectives developed to address its housing needs. Cities and counties without compliant housing elements may be faced with legal challenges pursuant to housing element law and/or fair housing law. On July 9, 2012, the City Council authorized staff to submit the Draft 2007-2014 Housing Element to HCD for review. On October 18, 2012, HCD issued a letter indicating the items that needed to be addressed in order to comply with State Housing Element law and qualify for certification. City staff has been working with HCD staff to address the issues, and provided HCD with a Response to Comments on January 29, 2013. An iterative process of Housing Element review and revision continued with HCD through March 26, 2013. On March 29, 2013, HCD City of Palo Alto Page 2 issued a letter indicating that HCD finds that the Revised Draft Housing Element will comply with State Housing Element law when it is adopted by the City Council and submitted to HCD for certification (Attachment B). The draft has been reviewed and recommended by the Planning and Transportation Commission and the Council’s Regional Housing Mandate Committee. Background The City of Palo Alto is required to update its Housing Element per State Housing Element Law. The State deadline to complete the update process, which concludes with the State Department of Housing and Community Development (HCD) certification, was June 30, 2009, but cities may continue to request review and certification through the end of the planning period. California State Housing Element law requires each city and county to update its housing element every five years to ensure that all localities provide adequate development sites for sufficient new housing to be built to meet their fair share of the regional housing need. As part of the Regional Housing Needs Allocation (RHNA) process overseen by the Association of Bay Area Governments (ABAG), the City of Palo Alto was assigned a quantified goal of 2,860 units, which represents the City’s “fair share” of projected housing need for the 2007-2014 planning period, distributed among the following income groups: very low (690 units), low (543 units), moderate (641 units) and above moderate (986 units) income categories. Housing Element law is the State’s primary strategy to increase housing supply, choice and affordability. The housing element identifies the existing and projected housing needs of all economic segments of the community, including the homeless and persons with disabilities, and promotes a variety of housing types, including multifamily rental units, transitional and other types of supportive housing. The housing element also defines the policies and programs that the community will implement to achieve its housing goals and objectives developed to address its housing needs. It is important to note that Housing Element law only requires the City to provide residential zoning opportunities to accommodate its RHNA allocation. It does not require the City to approve or construct such housing. Cities and counties without compliant housing elements may be faced with legal challenges pursuant to housing element law and/or fair housing law. If the City fails to identify or make available adequate sites to accommodate its RHNA assignment, the City may be required to carry those units over into the next planning cycle, thus increasing the number of sites required to be identified in the upcoming cycle. In addition, many State housing, transportation and infrastructure funding programs available to local governments require a certified housing element as one of the eligibility criteria. The State’s sustainable communities law (known as SB 375) to reduce greenhouse gases contains further incentives for City of Palo Alto Page 3 cities to submit compliant housing elements by conditioning key transportation grants to compliant elements and by extending the housing cycle for cities with certified elements. On July 9, 2012, the City Council authorized staff to submit the Draft 2007-2014 Housing Element to HCD for review, and the document was submitted to HCD on August 21, 2012. Based on Council direction, the Draft Housing Element included the Housing Inventory Sites (HIS) list to identify sites to accommodate the City’s RHNA (identification of 2,860 units on potential housing sites) and policies and programs to encourage developers in the production of housing. The sites selected are concentrated in the Downtown, the California Avenue area, and the El Camino Real corridor. The Housing Element emphasizes providing incentives for housing development using existing zoning rather than up-zoning single family and low density residential parcels or converting commercial or retail uses to residential use. On October 18, 2012, HCD issued a letter indicating the items that needed to be addressed in order to comply with State Housing Element law and qualify for certification. City staff has been working with HCD staff to address the issues, and provided HCD with a Response to Comments on January 29, 2013. An iterative process of Housing Element review and revision continued with HCD through March 26, 2013. On March 29, 2013, HCD issued a letter indicating that HCD finds that the Revised Draft Housing Element will comply with State Housing Element law when it is adopted by the City Council and submitted to HCD for certification. Planning and Transportation Commission Review The Planning and Transportation Commission reviewed and recommended that the City Council approve the revised Housing Element by a vote of 6-0 (Tanaka absent) at their April 10, 2013 meeting. There were questions about the proposed goals, policies and programs, but most of the comments centered on how the 2007-2014 Housing Element would affect the review and approval process for the 2015-2022 Housing Element, which is due to the State by December 2014. There was also discussion about the City’s RHNA number for this cycle and for the next RHNA cycle. The final portion of the hearing was focused on the environmental document. The April 10, 2013 Meeting minutes have been included as Attachment K. Regional Housing Mandate Committee Review and 567 Maybell Avenue On May 9, 2013, the Regional Housing Mandate Committee reviewed the revised Housing Element. A number of residents were in attendance to speak to Program 2.2.8, which addresses the rezoning of 567-595 Maybell Ave. Palo Alto Housing Corporation (PAHC) submitted a Planned Community (PC) rezone application for 567 Maybell Ave. to develop 15 single family homes and 60 affordable senior rental units. Staff included the potential affordable housing project in the Housing Element as Program 2.2.8. The RHMC, as part of its motion, strongly emphasized that their recommendation for the City Council to approve the City of Palo Alto Page 4 Housing Element does not indicate support for approval of the Maybell Avenue project and it should not have any bearing on the Planning and Transportation Commission deliberations of the PC rezone request. The P&TC is scheduled to hear the 567 Maybell Planned Community rezone application on May 22, 2013. The RHMC recommended that the City Council approve the revised Housing Element by a vote of 3-0 (Holman absent). The Committee also directed staff to evaluate the potential to identify an additional 30 units (the difference between the proposed project and the existing zoning) in the event that the Maybell project is not approved. Staff noted that, if the project is not approved and the City’s Housing Element has been certified, the City will need to report back to HCD next year and likely provide a modification to account for the incremental units. Public Process Extensive public outreach was conducted in the preparation of the Housing Element. A Technical Advisory Group (TAG) was formed with representatives from the Palo Alto Unified School District, neighborhood groups, both affordable and market rate housing developers, and interested residents serving on the TAG. In addition, multiple meetings were held to educate the public about the Housing Element and the Regional Housing Mandate Committee conducted public hearings. Discussion HCD Review of Draft Housing Element On August 21, 2012, the Draft Housing Element was submitted to HCD for review and determination if it complies with State Housing Element Law. On October 18, 2012, HCD issued a letter indicating the items that needed to be addressed in order to comply with State Housing Element law and qualify for certification (refer to Attachment E from HCD dated October 18, 2012). Over the course of the last six months, staff has been working with HCD staff to address the issues, and provided HCD with a Response to Comments on January 29, 2013. City staff and HCD continued to review and revise the Housing Element through March 26, 2013 (refer to Attachment C, Response to HCD comments on Palo Alto Draft Housing Element dated March 26, 2013). This response includes the proposed revisions to the Housing Element that address the concerns raised by HCD. The Revised Draft Housing Element is attached (see Attachment D, and available to the public at: <http://www.paloaltocompplan2020.org/> On March 29, 2013, HCD issued a letter indicating that HCD finds that the Revised Draft Housing Element will comply with State Housing Element law when it is adopted by the City Council and submitted to HCD for certification based on the submitted responses from staff. The letter notes that any significant changes to the proposed programs or text may require additional HCD review or may no longer comply with State Housing Element law. City of Palo Alto Page 5 Following is a summary of the issues raised by HCD and changes made to the Housing Element to address the comments, as outlined in more detail in the Response to HCD Comments document. Progress in Meeting RHNA and Affordability of Units: HCD has asked for more information on how the affordability of the units that are approved or under construction was determined. Text was added to page 71 of the Housing Element describing that all of the affordable units will be deed restricted units, either through the City’s Below Market Rate (BMR) program or created with financial assistance from the City. Previous Unaccommodated Need: In the last Housing Element cycle, there was one site identified to accommodate housing that was not rezoned prior to the current cycle. Per State law, this unaccommodated need must be addressed in the current cycle, above what is required by the Regional Housing Needs Allocation. On Page 162 of the Draft Housing Element has been amended to indicate that the unaccommodated 15 units from the previous cycle can be accommodated on a site located at 3877 El Camino Real, which with current zoning can provide the required 15 units. Realistic Capacity, Suitability of Non-vacant Sites, and Small Sites (less than one-half acre): HCD had expressed concern that since many of the sites selected for potential residential development on the Housing Inventory Sites (HIS) table are mixed use sites or commercial sites allowing residential uses, the sites may not yield as many residential units as indicated on the table. Page 78 of the Housing Element was revised to include a description of mixed use projects that have occurred in the last few years that achieved the densities shown in the HIS table. A description is also included of the commercially zoned sites on the HIS table as being along our major transit corridors, which are ideally suited for mixed-use development as proposed. It should be noted that on these parcels, the realistic capacity listed in the HIS table is lower than the maximum density allowed (typically realistic capacity is listed at 20 units per acre, where the zoning would allow 30 to 40 units per acre). In addition, a description of the sites has been added to the Housing Element indicating that many of the commercial sites in these corridors are typically low-intensity, one-story and two story buildings, surrounded by surface parking, constructed in the late 1960’s and 1970’s with relatively little development or improvements in the past decade. To address the issue of smaller sites, text was added to Page 84 of the housing element indicating that mixed use and residential projects have occurred on small parcels, and a map was provided that shows areas where there are opportunities for lot consolidation. The following program was added to encourage development of small lots: H2.2.7 PROGRAM Amend the Zoning Code to create zoning incentives that encourage development on and consolidation of smaller lots, such as development review streamlining, City of Palo Alto Page 6 reduction in required parking for smaller units, setback modifications, or graduated density when consolidated lots are over one-half acre. HCD staff was still concerned that some of the sites might not achieve the densities outlined in the HIS table, or that a commercial site on the list might be developed with a non-residential use. HCD staff has requested that the following program be added to the Housing Element: H2.2.9 PROGRAM To maintain adequate sites are available throughout the planning period to accommodate the City’s RHNA, on a project basis, pursuant to Government Code Section 65863, the City will monitor available residential capacity and evaluate development applications on Housing Inventory Sites in mixed use zoning districts. Should an approval of development result in a reduction of capacity below the residential capacity needed to accommodate the remaining need for lower-income households, the City will identify and zone sufficient sites to accommodate the shortfall. Clarify Affordability of projects proposed by the Mayfield Agreement: A description of the development proposed by the Mayfield Agreement with Stanford University was added to the Housing Element at the end of Page 82 to clarify the number of units proposed and the units that are designated as affordable per the agreement. Hotel Condominiums: HCD has asked for additional analysis to determine that the proposal in the Housing Element for hotel condominiums as a part of a hotel project would meet the census definition of a housing unit. Upon further analysis of the proposal, staff determined that these units would not meet the Census definition of a housing unit, and this proposal was removed from the Housing Element. This program may be revisited in the next (2014-2022) housing element cycle to see if modifications can be made to qualify such units. Emergency Shelters: HCD has indicated that in order to meet the requirements of State law, a zone or zones must be identified where emergency shelters would be permitted without a conditional use permit of other discretionary action. It is required that the element specifically identifies the zone or zones and demonstrates sufficient capacity to accommodate the need for emergency shelters within the community. The Housing Element has been revised to include the following program which would allow emergency shelters in the ROLM(E) (Research, Office and Limited Manufacturing - Embarcadero) zone district. The zoning code amendment would include performance standards for the emergency shelters to ensure compatibility with the surrounding area. Additional discussion about the ROLM(E) zone district was added to Page 157 of the housing element. It should be noted that this provision does not require that an emergency shelter be built, but only requires that the zoning is in place to accommodate the use. City of Palo Alto Page 7 H3.5.2 PROGRAM Amend the Zoning Code to allow emergency shelters by right with appropriate performance standards to accommodate the City’s unmet need for unhoused residents within an overlay of the ROLM(E) zone district located east of Highway 101. Land Use Controls, Local Processing and Permit Procedures, and Inclusionary Housing: HCD requested more information about the City’s ordinances and procedures related to permits and processing, as well as the Inclusionary Housing program, specifically an analysis of how these procedures might be considered a constraint to housing development. The Housing Element has been revised to include a better description of the development process and the inclusionary housing program. In addition, the following program has been added to evaluate the Below Market Rate (BMR) program: H3.1.14 PROGRAM Evaluate the provisions of the Below Market Rate (BMR) Program to determine if additional incentives are needed to encourage development of housing given current market conditions. Reasonable Accommodation: State law requires that provisions be available accommodate housing to make it suitable for persons with disabilities. Generally, this would allow persons with disabilities to add a ramp, handrail, lift or elevator to a residence. This can be an issue when installation of these improvements on an existing residence would not meet development standards such as setback and lot coverage. The following program has been added to the Housing Element that would establish a process where individuals with disabilities can make requests for reasonable accommodation to allow installation of the necessary improvements. H4.1.6 PROGRAM Amend the Zoning Code to provide individuals with disabilities reasonable accommodation in rules, policies, practices and procedures that may be necessary to ensure reasonable access to housing. The purpose of this program is to provide a process for individuals with disabilities to make requests for reasonable accommodation in regard to relief from the various land use, zoning, or building laws, rules, policies, practices and/or procedures of the City. Developmentally Disabled: State law requires that the Housing Element include an analysis of the special housing needs of persons with developmental disabilities. This analysis has been added to the Revised Housing Element. In addition, the following program was added that requires that the City work with the San Andreas Regional Center on outreach regarding housing resources available to persons with developmental disabilities: City of Palo Alto Page 8 H4.2.2 PROGRAM Work with the San Andreas Regional Center to implement an outreach program that informs families in Palo Alto about housing and services available for persons with developmental disabilities. The program could include the development of an informational brochure, including information on services on the City’s website, and providing housing- related training for individuals/families through workshops. Analysis of Existing Assisted Housing Developments At-risk of Conversion: HCD requested additional analysis regarding the preservation of at-risk affordable housing units to include units that may be at-risk of conversion to market rate units for a period of ten years from the start of the planning cycle (2009-2019). A discussion has been added in Chapter 2, and the only affordable housing development determined to be at-risk of converting to market rate is the Terman Apartments. A description of the City’s efforts to work with the owners of this property is now included in the Housing Element. Programs - Timelines and Implementation: HCD has requested that the programs outlined in the Housing Element be revised to include quantified objectives and timelines indicating when the programs would be implemented. In addition, HCD has asked for amendments to some of these programs to describe specific actions or describe the City’s role in implementation. All of the policies have been revised to include objectives and timelines, and clarification was added where requested (refer to Attachment F, Palo Alto Revised Draft Housing Element, 5.2 Housing Goals Policies and Programs). Identify Adequate Sites, Rezoning Program: HCD has required additional information in order to determine that the City had met its Regional Housing Needs Assessment requirements for all income levels. Revisions have been made to the Housing Inventory Sites (HIS) table (Attachment F) to identify those sites which qualify to meet the lower income housing need. It was determined that a rezoning program is not required to accommodate the City’s lower income housing need, the needs for the low and very low income units can be accommodated on sites that are already zoned to allow densities of 20 units per acre or greater. While reviewing the HIS table as well as the Table 2-58, List of Housing Unit Production by Income Categories, it was determined that the lists needed to be updated both to include new projects which have been submitted and to address changes to projects that have occurred since the Draft Housing Element was published. As a result, a recent project submitted at 567- 597 Maybell Avenue was moved from the HIS table to the List of Housing Unit Production, which includes those units entitled or in process as well as those for which building permits have been issued. In addition, two projects were removed from that list because the revised projects submitted no longer include housing. The two projects removed from the entitled projects list were 355 Alma Avenue (14 units) and 200 San Antonio Road (35 units). City of Palo Alto Page 9 As a result of these changes, Table 2-57 was also revised to reflect the actual number of units either built/permitted or entitled/in process. This left a higher unmet need to be accommodated by the HIS table than was previously anticipated. Since the HIS table was also modified to remove the Maybell site, there was now a shortage of housing sites to accommodate the unmet need. In order to accommodate this shortage, the site at 340 Portage Avenue (Fry’s Site) was added to the HIS table. Although the maximum capacity that could be accommodated on this 12.47 acre site would be 374 units, the realistic capacity listed on the HIS table is only 75 units. While the site is now zoned RM-30, one of the alternatives for the California Avenue Area Concept Plan now under consideration anticipates mixed use development on this site. With this change to the HIS table, the total number of units that can be accommodated by housing inventory sites is 1,680, where the unmet need is for 1,643 units. The following program has been added to provide for the rezoning of the 595 Maybell site: H2.2.8 PROGRAM Rezone property at 595 Maybell Avenue from the RM-15 and R-2 zone districts to the PC zone district to allow for development of 60 units of extremely-low to low income senior affordable rental housing units and 15 market rate units. Two other programs have been added to the Housing Element to provide for the rezoning of the CN and GM zones to increase the allowable density to be consistent with the realistic capacity as outlined in the HIS Table: 2.2.5 PROGRAM Revise the Zoning Ordinance to increase the density of up to 20 units per acre on CN-zoned parcels included in the Housing Inventory Sites. 2.2.6 PROGRAM Revise the Zoning Ordinance to allow for residential uses with the density of up to 30 units per acre on GM parcels included in the Housing Inventory Sites. Mixed Use Development: Because the City is relying on underutilized sites and the potential for mixed use development to accommodate the housing needs of lower income households, HCD has required that there be programs to promote redevelopment of these sites, such as incentives for lot consolidation, financial assistance, or regulatory concessions. To meet this requirement, the following program has been added to the Housing Element: H2.1.11 PROGRAM Promote redevelopment of underutilized sites and lot consolidation by providing information about potential housing sites on the City’s website, including the Housing Inventory Sites and information about financial resources available through City housing programs. City of Palo Alto Page 10 Programs to Meet the Needs of Extremely Low-, Very-Low- and Moderate-Income Households: HCD has indicated that although the element includes actions to assist in the development of housing for very-low and low-income households, it is required to include programs that specifically assist in the development of a variety of housing types to address the needs of extremely low income (ELI) households, such as prioritizing some funding for this type of development, or providing financial incentives or regulatory concessions to address the needs of this income group. Staff responded that the Housing Element already includes a program to amend the zoning code to allow Single Room Occupancy (SRO) units in commercial and high density residential zoning districts, noting that these units are generally seen to be affordable to ELI household. In addition, the following two programs were added to address this requirement: H3.1.15 PROGRAM When using its Housing Development funds for residential projects, the City shall give a strong preference to those developments which serve extremely low-income (ELI) households. H3.1.16 PROGRAM Amend the Zoning Code to provide additional incentives to developers who provide extremely-low income (ELI) housing units, above and beyond what is required by the Below Market Rate (BMR) program, such as reduced parking requirements for smaller units, reduced landscaping requirements and reduced fees. Housing Units At-Risk of Conversion to Market Rate: HCD has requested that the Program in the Housing Element that addresses affordable housing units at-risk of conversion to market rate housing be revised to include specific actions. Following is the revised Program H3.1.5, and an added program to address the concerns raised by HCD: H3.1.5 PROGRAM Preserve affordable housing stock by monitoring compliance, providing tenant education, seeking other sources of funds for affordable housing developments at risk of market rate conversions. The City will continue to renew existing funding sources supporting rehabilitation and maintenance activities. H3.1.17 PROGRAM Any affordable development deemed a high risk at market rate conversion, within two years of the expiration of the affordability requirements, the City will contact the owner and explore the possibility of extending the affordability of the development. Quantified Objectives: HCD has requested that add a table that outlines the number of housing units by income category that can be constructed, rehabilitated, and conserved over a five-year City of Palo Alto Page 11 time period. This table has been added to the Housing Element. Public Comments Submitted During the HCD Review Two letters were submitted via email regarding the Draft 2007-2014 Housing Element. On September 10, 2012, an email from Sam Tepperman-Gelfant, Senior Staff Attorney for Public Advocates, Inc. (Attachment G) was sent to State HCD and referred to City staff for review. On September 24, 2012, staff received a letter from Melissa A. Morris, Senior Attorney for Public Interest Law Firm (Attachment H). Staff also discussed the issues raised in the letters with Sam Tepperman-Gelfant and Melissa Morris via conference call on two occasions. A summary of the issues raised and how they were addressed follows. Lower Income Housing Needs and Previous Unaccommodated Need: Public Advocates has asked for more clarity in determining how the housing needs for the lower income populations were being met as outlined in the HIS table, and expressed concern that it appeared that there was unaccommodated need from the previous housing element cycle because not all sites were rezoned as required. As noted in the response to HCD comments, the HIS table was modified to clearly identify those properties that meet the requirement to qualify to satisfy the RHNA requirements for low and very-low income households. Sites with an allowed density of twenty units per acre or more qualify by default to meet this need. Sites have been identified to accommodate 1,056 low and very-low income units, and the City is required to accommodate 982 low and very low income units. Also noted in the response to HCD comments is an explanation of how the unaccommodated need from the last housing element cycle has been met in this cycle. There was one parcel identified in the last cycle to be rezoned to accommodate 15 units. Staff has identified a site on the HIS table which provides a replacement for these units, over and above what is required by the RHNA for this cycle. Mayfield Agreement: Public Advocates has noted that the inventory includes 250 units which are a part of the Mayfield Agreement with Stanford University, expressed concern that the units would not all be constructed before the end of the planning period (2014), and questioned how many of the units would be market rate versus affordable units. On Page 83, text has been added to the housing element to clarify the terms of the agreement and to indicate that 70 of the units are required to be affordable. The agreement stipulates that an application for the affordable units be submitted by December 2013, and the remaining units be proposed no later than December 2020. However, the sites are now available for development, and nothing precludes an application being submitted prior to the deadline. Therefore, it is appropriate to leave these units on the HIS Table. City of Palo Alto Page 12 Reliance on Small Sites (less than one-half acre) and sites with existing uses: Both Public Advocates and Public Interest Law Firm have expressed concern that many of the sites on the inventory are less than one-half acre in size, and thought these small sites would not be suitable for lower income housing. In addition, concern was expressed that many of these sites are now developed and wanted information to be added to the HIS Table describing the potential for redevelopment on sites with existing uses. The Housing Element has been amended to provide a description of projects that have been built on sites of less than one-half acre, and programs have been added to encourage lot consolidation as well as offer incentives for development on smaller sites. In addition, information has been added to the HIS Table, as well as in the description of the existing commercial areas identified to explain why these sites are suitable. In many cases, the sites identified with existing commercial uses are now developed with older, single story buildings. There have been successful developments built on similar parcels within these areas, and it is expected that this trend will continue. Hotel Condominiums: Public Advocates also has expressed concern with including hotel condominiums as potential housing sites, indicating that developers of hotel projects have not proposed these types of units. As discussed above, it has been determined that hotel condominiums do not meet the Census definition of housing units, and these sites have been removed from the HIS table. Secondary Dwelling Units: Public Advocates has commented on the assumption that 15 second units would be added during the planning period, indicating that second units recently built were affordable to moderate income, and any added units should not be assumed to be affordable to lower income households. Public Interest Law Firm was also concerned with the parking requirement for second units, given that second units were a potential source for affordable units. Upon further study, it was determined that secondary dwelling units in Palo Alto generally fall in the moderate income level, and it is now assumed that any new units would be at this income level, and second units are not being counted towards the lower income RHNA requirement. Programs: Public Interest Law Firm has expressed concern that the Housing Element’s programs did not have enough detail to determine if the programs will be effective, asking that quantified objectives and timeframes be added, as well as an indication of which department is responsible for implementation. The list of programs in the Housing Element has been modified to include timeframes, quantified objectives and responsible agencies (refer to Attachment E). Affordability of Units Permitted, Entitled or Constructed: Public Interest Law Firm asked for more information about the units included on Table 2-57 to clarify the level of affordability of the units being counted toward the low and very-low income RHNA obligation. The Housing City of Palo Alto Page 13 Element has been amended and Tables 2-57 and 2-58 have been revised to show which units are affordable and to indicate that these are deed restricted units either provided through the City’s Below Market Rate (BMR) program, or created with financial assistance from the City. Constraints to the Development of Housing for People with Disabilities: Public Advocates asked for a more comprehensive analysis of constraints to development of housing for people with disabilities, and asked that a reasonable accommodation policy be added to facilitate development of housing for people with disabilities. As noted above in the response to HCD comments, a discussion of the needs for disabled persons, as well as a reasonable accommodation policy have been added to the Draft Housing Element. Next Steps Once the 2007-2014 Housing Element is adopted by the City Council, a copy will be forwarded to the State Department of Housing and Community Development (HCD) for certification. This will bring Palo Alto’s Housing Element into compliance with State Housing Element Law. Environmental Review An initial study and Negative Declaration have been prepared for the Draft 2007-2014 Housing Element. The Negative Declaration is included as Attachment J. Based on the findings of the Initial Study, the Negative Declaration did not identify any potential significant impacts as the bulk of the City’s RHNA can be accommodated without significant zone changes. Most of the sites identified for housing are already zoned for that use and are located in infill areas. The Planning and Transportation Commission reviewed the Negative Declaration and recommended the Council approve it. The review period will end on May 15, 2013, prior to consideration by the City Council. No comments have been received to date. Attachments:  Attachment A: Resolution Adopting 2007-2014 Housing Element (PDF)  Attachment B: HCD Letter dated March 29, 2013 (PDF)  Attachment C - City Response to HCD Comments dated March 26, 2013 (PDF)  Attachment D - Revised Draft 2007-2014 Housing Element (PDF)  Attachment E - HCD Response Letter dated October 18, 2012 (PDF)  Attachment F - Revised Housing Element Goals, Policies and Programs (PDF)  Attachment G - Housing Element Sites Inventory (PDF)  Attachment H - Email received from Public Advocates dated September 10, 2012 (PDF) City of Palo Alto Page 14  Attachment I - Letter received from Public Interest Law dated September 24, 2012 (PDF)  Attachment J - Initial Study (PDF)  Attachment K: April 10 2013 Planning and Transportation Commission Meeting Minutes (PDF) Not Yet Approved  1    130506 jb S://013/Planning/Reso Housing Element 2007‐14  Resolution No. _____  Resolution of the Council of the City of Palo Alto Adopting the Revised Draft  Housing Element 2007‐2014 of the Comprehensive Plan and Approving a  Negative Declaration    R E C I T A L S    A. The City of Palo Alto is required to update its Housing Element per State  Housing Element law every five years to ensure adequate development sites for  sufficient new housing be built to meet the fair share of the Regional Housing Needs  Allocation (RHNA).    B. Palo Alto was assigned a quantified goal of 2,860 units, which represents  the City’s “fair share” of projected housing need for the 2007‐2014 planning period.    C. The Housing Element identifies the existing and projected housing needs  for all economic segments of the community, including the homeless and persons with  disabilities.    D. The Housing Element defines the policies and programs that the  community will implement to achieve its housing goals and objectives developed to  address its housing needs.     E. On July 9, 2012, the City Council authorized staff to submit the Draft  2007‐2014 Housing Element to the Department of Housing and Community  Development (HCD) for review.    F. The draft Housing Element included the Housing Inventory Sites (HIS) list  to identify sites to accommodate the City’s RHNA and policies and programs to  encourage developers in the production of housing.    G. On October 18, 2012, the HCD indicated the items that needed to be  addressed in order to comply with State Housing Element law and quality for  certification.    H. On March 29, 2013, the HCD issued a finding that the Revised Draft  Housing Element 2007‐2014 will comply with State Housing Element Law when adopted  by the Council.    I. On April 10, 2013, the Planning and Transportation Commission  conducted a hearing on the 2007‐2014 Housing Element and recommended that the  City Council adopt the Element.    Not Yet Approved  2    130506 jb S://013/Planning/Reso Housing Element 2007‐14  J. The Council desires to adopt the Revised Housing Element 2007‐2014 of  the Comprehensive Plan to comply with State Housing Element law.    The Council of the City of Palo Alto RESOLVES as follows:     SECTION 1. The City of Palo Alto Housing Element 2007‐2014, revised March 29,  2013, is hereby adopted and incorporated into the Palo Alto Comprehensive Plan.  This  Element supersedes the December 2, 2002 Housing Element.    SECTION 2. The City Council adopted a Negative Declaration for this project in  accordance with the California Environmental Quality Act.      INTRODUCED AND PASSED:    AYES:    NOES:    ABSENT:    ABSTENTIONS:    ATTEST:            APPROVED:      _________________________      ____________________________  City Clerk            Mayor      APPROVED AS TO FORM:        ____________________________  City Manager    _________________________  Senior Asst. City Attorney        ____________________________  Director of Planning   and Community Environment    Response to HCD comments on Palo Alto Draft Housing Element ATTACHMENT B March 26, 2013 A. Housing Needs, Resources, and Constraints 1. Inventory of Land Suitable for Residential Development: Palo Alto has a regional housing need allocation (RHNA) of 2,860 housing units, of which 1,233 are for lower-income households. To address this need, the element relies on non-vacant and mixed use sites along transit corridors. To demonstrate the adequacy of these sites and strategies to accommodate the City’s RHNA, the element needs to include complete analyses: Progress in Meeting the RHNA: The element indicates (page 66) that 168 units affordable to very low-income households and 21 units affordable to low-income households have been built or are under construction or approved, but provides no information documenting how affordability of the units was determined. As you know, the City’s RHNA may be reduced by the number of new units built since January 1, 2007; however, the element must describe the City’s methodology for assigning these units to the various income groups based on the actual sales price or rent level of the units and demonstrate their availability in the planning period. Response: The following text has been added to Page 66 of the housing element to describe the affordability of the units built including revised Table 2-57 and Table 2-58: A Planned Community (PC) rezone application was submitted for 595 Maybell Avenue to develop 60 units of extremely low to low income senior affordable rental housing and 15 market rate units by right, for a total of 75 units. Program 2.2.8 has been added to the Housing Element to emphasize the City’s need for affordable senior housing. Table 2-57 and Table 2-58 have been updated to include the Maybell Avenue application since the application review is in process. Conversely, the Maybell site was originally included in the City’s Housing Inventory Sites (HIS) list as a potential development site. However, since the 60 affordable units have been included in Table 2-57 and Table 2-58, it has been removed from the HIS list. The revised Tables 2-57 and 2-58 are included as Exhibit A of this letter. Therefore, the City now has 251 low or very low income units in process, entitled or built. All 251 very-low and low-income units will be/are deed restricted units. Of the 251 affordable units, 34 very low and low income rental units were created through the City’s Below Market Rate program. Those units are restricted to low income households as established by the State for Santa Clara County for a period of 59 years. The remaining 217 affordable units were created with financial assistance from the City and deed restricted to low, very low and extremely low income households. The City has loaned out over $22 million for the creation of these units. Those units carry a minimum 55-year affordability term, consistent with tax credit financing requirements. However, City documents include options to extend the affordability period. If the 251 entitled/ built low and very low income units are subtracted from the City’s need of 1,233 units, the City’s remaining need for very low and low income households is 982 housing units. State law establishes a density of 20 units per acre as the minimum density necessary to make affordable housing economically feasible in Palo Alto. The City must show that it can Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 2 - accommodate the remaining 982 low and very low income units on sites that have a density of 20 units per acre or higher. In the City’s Housing Inventory Sites (HIS) list, all parcels with an existing zoning density of 20 units per acre or higher have been highlighted. The total number of units provided by the highlighted parcels is 1,056. While the City does have proposed programs that will revise the Zoning Ordinance to increase densities to be consistent with Housing Element law, the City can meet its low and very low needs with existing zoning. Previous Unaccommodated Need: While the element now includes an analysis to identify the unaccommodated need based on the total unmet need from the previous planning period, it does not identify the unaccommodated need by income group. Pursuant to Chapter 614, Statutes of 2005 (AB 1233), as the City of Palo Alto failed to implement Program H-14 to rezone sites in the prior planning period, the City must zone or rezone sites to accommodate any unaccommodated need within the first year of the 2009-2014 planning period. The element must include an analysis by income group to determine if there is a remaining unaccommodated need that must be accommodated in the current planning period. Response: The following text has been added to Page 151 of the housing element to describe how the City is fulfilling the AB 1233 requirements: Of the City parcels that were proposed to be rezoned in Program H-14, the City rezoned all but one parcel as specified in the City’s 1999-2006 Housing Element. The total estimated yield of the one unzoned parcel is 15 units. Therefore, the City’s unmet need is 15 units. In the Draft Housing Element in Appendix 5.3, (1999-2006 Accomplishments Matrix), the City originally reported for Program H14, that it had three unzoned parcels, rather than one. The yield of the two additional parcels originally reported to be unzoned for housing was estimated to be 20 units. Based on further research, the City has determined that the two previously reported unzoned parcels were in fact rezoned. The City will update Appendix 5.3 to reflect this. The explanation of the zoning history of the two parcels is set forth below. At the time of Housing Element adoption in 2002, the City was in the process of adopting the South of Forest Avenue Coordinated Area Plan, Phase 2 (SOFA2) in which two of the parcels are located. The parcels were rezoned from Commercial Downtown-C (community) or CD-S (service), which allowed for mixed use development, to the SOFA 2 land use designation of Residential Transition-50 (RT-50) when SOFA 2 was adopted in December 2003. The RT-50 zone also allows for mixed-use residential developments. The difference between CD and RT- 50 zoning is that CD density is measured by units per acre while RT-50 determines residential density by Floor Area Ratio (FAR). In addition, if it is a proposed residential rental development, the RT-50 zone provides a higher FAR to achieve a more dense development. However, because the City did not rezone the one parcel within the planning period, the City must meet the site suitability requirements of Government Code Section 65583.2 [AB2348]. To fulfill the requirements of AB 2348, the City has selected 3877 El Camino Real as the designated site to accommodate the 15 “carry over” units. This .75 acre site is a mix of Service Commercial (CS) and RM-30 zoning. Approximately 30% of the site (.22 acres), the area fronting El Camino Real, is covered by the CS zone district. CS zoning allows for mixed use development with a maximum density of 30 units. Using the City’s realistic capacity of 20 Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 3 - units per acre, the CS portion could have a capacity of 4 units. The remaining .53 acres of the parcel is zoned RM-30, which at 20 units per acre, could provide 11 residential units. The site is adjacent to a .28 acre, vacant RM-30 parcel (405 Curtner Avenue) that is currently being used as a parking lot. 405 Curtner Avenue is also on the City HIS list which could provide for the potential of a lot merger to achieve a greater yield of housing. Below is a table showing the AB 2348 requirements with an explanation of how the site at 3877 El Camino Real meets each requirement: AB 2348 Requirement 3877 El Camino Real 1. Must meet the 100 percent shortfall The City’s shortfall is 15 units. This site accommodates the entire shortfall of 15 units. 2. The zoning allows owner-occupied and rental multifamily residential uses “by right” Both the RM-30 and CS zoning allows for residential uses by right. The codes do not differentiate by tenure. 3. The site provides development that permits at least 16 units per site based on minimum density Based on the realistic capacity estimate of 20 units per acre, the site can accommodate 15 units. However, as described in page 75 of the draft Housing Element, the realistic capacity is much more conservative than the densities achieved in built or approved developments. The average density of those developments is almost 28 units per acre. Therefore, this site could easily accommodate an additional unit to meet the 16 unit per site requirement. 4. Suburban and metropolitan jurisdictions must provide sites that allow at least 20 dwelling units per acre. Both the RM-30 and CS zoning have a maximum zoning density of 30 units per acre. However, a realistic capacity of 20 units per acre is used to estimate the potential yield for this site. 5. At least 50 percent of the low and very low-income need be accommodated on sites designated exclusively residential uses Seventy percent of the site is zoned RM-30 thus providing more than half of the unaccommodated need in exclusive residential zoning with a density of greater than 20 units per acre. Realistic Capacity: For mixed-use or commercial sites allowing residential uses, the residential capacity estimate should account for potential development of non-residential uses and could consider any performance standards mandating a specified portion of a mixed-use site as non- residential (e.g., first floor, front space as commercial). The element could also describe any existing or proposed regulatory incentives and standards to facilitate housing development in the mixed-use or commercial zones and on the identified non-vacant sites. Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 4 - Response: The following paragraph will be added on Page 76 of the Housing Element following the discussion the Housing Inventory Sites – Mixed Use Development in Existing Commercial Zoning Districts: Many of the City’s commercially zoned parcels which allow residential uses have specific requirements, mainly that the project include a ground floor retail component. There have been many successful mixed use projects developed in the City’s commercial areas which have included ground floor retail and residential units. Following is a list of recently completed projects on smaller sites which yielded projects with residential components at densities ranging from 16 to 28 units per acre: • 420 Cambridge Avenue, 4 units on 6,012 square foot parcel (28 units/acre) • 2180 El Camino Real, 4 units on 22,365 square foot parcel (16 units/acre) • 102 University Avenue, 3 units on 7920 square foot parcel (16 units/acre) • 2051 El Camino Real, 2 units on 4800 square foot parcel (18 units/acre) The commercially zoned parcels selected in the City Housing Inventory Sites (HIS) list were based on parcels within the City’s transit corridors of El Camino Real, University Avenue and California Avenue. However, there are number of other mixed use sites throughout the City that would be equally suitable candidates for mixed use redevelopment. There have been numerous mixed use projects on similar sites that have occurred throughout the City. Based on development trends and to account for the potential for some non-residential uses (as a part of a mixed use development), the realistic capacity used in the HIS list is estimated at 66 per cent of the maximum capacity. Many of the identified sites are commercial uses along the El Camino Real and California Avenue corridors are typically low-intensity, one-story and two story buildings, surrounded by surface parking, constructed in the late 1960’s and 1970’s with relatively little development or improvements in the past decade. These corridors have seen less development than other areas of the City, such as the University Avenue corridor. However, since many of the sites have not been improved and with the City real estate market returning to pre-2008 levels, the identified sites seem more appropriate for redevelopment opportunities. In addition, the California Avenue corridor has been designated by the City Council as a Priority Development Area, through ABAG’s FOCUS program, to provide incentives and attract greater investment in the California Avenue corridor. Note also these projects largely occurred in a down market and we can expect this trend to continue with signs of a significant uptick in the local real estate market. In addition, as incentive to facilitate mixed use developments, the City has proposed Program H 2.2.2 which will expedite permit processing if the development meets certain requirements. It is also anticipated that there will be greater use of the density bonus ordinance, which will allow for projects at greater density that take advantage of the incentives which allow for relaxation of parking standards. Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 5 - In addition, the following program is being added to monitor the Housing Inventory Sites. If nonresidential development occurs on a mixed use zoned Housing Inventory Site, the program would require that a replacement site be identified. H2.2.9 PROGRAM To maintain adequate sites are available throughout the planning period to accommodate the City’s RHNA, on a project basis, pursuant to Government Code Section 65863, the City will monitor available residential capacity and evaluate development applications on Housing Inventory Sites in mixed use zoning districts. Should an approval of development result in a reduction of capacity below the residential capacity needed to accommodate the remaining need for lower-income households, the City will identify and zone sufficient sites to accommodate the shortfall. Five-Year Objective: Maintain Residential Capacity of sites suitable for lower income households. Responsible Agency: Planning & Community Environment Time Frame: Ongoing Suitability of Non-Vacant Sites: a. While the element describes market trends, and potential for redevelopment for the corridor areas identified in the sites inventory, it provides minimal descriptions of existing uses of identified sites. The element should describe the existing uses of non- vacant sites sufficiently to demonstrate the potential for redevelopment during the planning period and evaluate the extent to which existing uses impede additional residential development. For example, the element lists several indicators used to determine if a site was suitable for residential or mixed-use development including if a property was “underdeveloped” pursuant to a windshield survey (page 74). The element could describe the factors the city used in determining if a property was underutilized. In addition, the inventory could generally describe whether the use is operating, marginal or discontinued, and the condition of the structure or could describe any expressed interest in redevelopment. Response: The City used a number of criteria to evaluate suitability of a non-vacant site. On Page 74 of the draft Housing Element, the evaluating criteria will be revised to include: • Improvement on sites at least 20 years old • Site of 10,000 sq. ft. or more with a yield of 5 units or more • Site with an A/V of less than 1.5, or with A/V ratios of greater than 1.5 that were determined to have an artificially low assessed land value (parcels under the same ownership for more than 10 years), with the assessed land value is far below current market land values. The improvements on these parcels are much older and are candidates for redevelopment. Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 6 - • Windshield survey of underdeveloped residential or commercial sites consisting of 1 or 2 story structures. Underdeveloped commercial sites were defined as Class B office space structures or older buildings with wood construction. The above criteria were chosen based on the types of sites that had been redeveloped with mixed use or residential projects within the past several years. In the Housing Inventory Sites list, greater detail has been added to each of the listed properties including the specific commercial use and owner of the site. All of the commercial sites identified on the inventory are now operating and there are no marginal or discontinued uses. However, due to the vibrancy of the Palo Alto housing and mixed use market, this has not been a disincentive to reuse of sites for residential or mixed use development. As noted in the response to the comment on realistic capacity, there are many examples of mixed use development occurring on smaller sites similar to those listed in the inventory. b. Several sites in the inventory are part of the Mayfield Agreement with the University of Stanford. Part of this agreement is to provide a portion of the sites for housing affordable to lower-income and the remaining to market rate housing over a 20 year period. Pursuant to conversations with staff, proposed development plans have been submitted for these sites including a Bridge Housing proposal for the lower-income portion. The element should include a description these plans including the proposed affordability and timeframes in order to determine the portion of the housing need for lower-income households these sites can accommodate within the planning period. Response: The following text has been added to the Housing Element following the last paragraph on page 81 to describe the details of the Mayfield Agreement: The City’s executed Mayfield Agreement requires the construction of 250 dwelling units on identified housing sites described in the Agreement. Of the 250 units to be developed, 70 units are required to be affordable rental units to very-low and low income households. The Agreement with Stanford University requires that the University submit a building permit application for 185 units by the end of December 2013 with a specific requirement that an application for Architectural Review be submitted by December 2013 for the 70 affordable units. The agreement stipulates that the remaining units be proposed no later than December 2020. However, nothing precludes the University from submitting applications prior to that deadline. The Agreement establishes the absolute deadline, and the sites are now available for development. Therefore, at a minimum, the 70 affordable units will begin the permit approval process by 2014. c. In addition, most of the sites in the inventory are small (less than 0.5 acres). If the small sites are necessary to accommodate the City’s regional housing need for lower-income households, the element must include analyses that demonstrates these sites can realistically accommodate new residential development, particularly new multifamily rental development and housing affordable to lower income households. While it may be possible to build housing on small parcels, the nature and conditions necessary to construct the units often render the provision of affordable housing infeasible. For Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 7 - example, assisted housing developments utilizing State and federal financial resources typically include 50-80 units. The analysis could describe existing and/or proposed policies or incentives the City will offer to facilitate small lot development, including lot consolidation, and include an evaluation of the financial feasibility of development for lower-income households on smaller sites, given necessary economies of scale. Response: The following text will be added to the Housing Element on Page 82, regarding commercially zoned sites that can accommodate mixed use development: Because the City of Palo Alto is primarily built out, the available sites for new development are limited. Over the past five years, there have been three projects on sites less than one acre that accommodated 128 units at densities ranging from 50 to 83 units per acre. These projects included a total of 85 units affordable to low income households. The City has a good history of mixed use residential developments. Of the 49 residential land use approvals since 2006, 19 of the approvals were approved as mixed use projects. Of the 19 mixed use projects, 11 of the projects were done on parcels of less than half an acre. Residential densities on the 11 projects ranged from 2 units per acre up to 28 units per acre. There was some affordable housing created on the smaller sites. One affordable rental unit was approved as part of a three residential unit development on a .18 acre parcel. And while actual affordable units would not be provided on these smaller mixed use lots, with the City proposing to lower its BMR threshold to three residential units, it anticipates capturing additional housing fees from these smaller developments. These fees would be used to finance future affordable housing developments. In order to encourage more dense housing yields, the City is proposing a number of lot consolidation programs. The advantages of lot consolidation include a potential higher yield of units. Typically, based on the City’s density calculations, the maximum density of a smaller lot always contain a “fractional” unit. By encouraging lot consolidation, these smaller lots would be able to add together the fractional units to create a whole unit. Also, with the removal of a setback requirement, it allows for greater site design flexibility, including parking, which would also yield more units. The City chose smaller parcels, generally less than .25 acres, as potential candidates for lot consolidation. As mentioned , the City has had a number of mixed use development on parcels less than .5 acres, however consolidating these smaller parcels provide a greater feasibility of a higher yield mixed use development. Although smaller parcels were chosen for lot consolidation, it does not preclude larger lots from consolidating. As shown in the City’s HIS maps, there are a number of adjacent sites of varying sizes throughout the City. Those sites also present good lot consolidation opportunities. In addition, in order to encourage development at higher densities on the smaller parcels identified in the inventory, the following programs have been revised and/or added to the list of Goals, Policies and Programs beginning on Page 152 of the Housing Element (text in Bold Italics indicates revisions: Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 8 - H2.2.2 PROGRAM Implement an incentive program within a year of Housing Element adoption for small properties identified as a Housing Inventory Site to encourage housing production on those sites. The incentive would eliminate Site and Design Review if the project meets the following criteria: • The project has 9 residential units or fewer • A residential density of 20 units per acre or higher • Maximum unit size of 900 square feet Five year objective: Streamline processing for identified small Housing Inventory Sites. Funding Source: City Funds Responsible Agency: Planning and Community Environment Time Frame: Adopt program within one year of Housing Element adoption H2.2.7 PROGRAM Amend the Zoning Code to create zoning incentives that encourage development on and consolidation of smaller lots, such as development review streamlining, reduction in required parking for smaller units, setback modifications, or graduated density when consolidated lots are over one-half acre. Five-Year Objective: Provide opportunities for lot consolidation to increase availability of suitable sites for affordable housing. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Within one year of adoption of Housing Element Second Units: While the element anticipates 15 new second units will be built in the planning period based on development trends, it must also include an analysis of the anticipated affordability of the second units to demonstrate the appropriateness of this strategy to accommodate the housing needs of low- and moderate-income households. The element should also describe whether or not the units are permitted by right, the need for the units in the community, and the resources or incentives available for their development. Response: The following text has been added to Page 98, following the first paragraph describing Second Units/Cottages: In a review of online rental rates for cottages, attached and detached residential second units in Palo Alto, their rental rates are in the range of moderate income rents as determined by the Tax Credit Allocation Commission (TCAC). Therefore, the anticipated 15 second units will be listed as moderate income. The R-1 District regulations include provisions for second dwelling units by right on properties which meet certain lot size criteria and subject to a list of development standards. The requirements include a minimum parcel size, a maximum living area, a requirement for a covered parking space, and a maximum height of one story. As noted above, Planning staff Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 9 - reviews the project through the building permit process, and if the criteria are met, a building permit is issued. The City has a substantial need for rental housing, and these units provide for an additional type of housing which is attractive to seniors and for multi-generational accommodations. They also offer a way to increase housing stock without using additional land or infrastructure. Hotel Condominiums: The element appears to utilize the potential for new hotels to develop 25 percent of their units for condominium us pursuant to the City’s Service Commercial (CS) Ordinance. While the element states 113 residential units could be provided for residential use based on the approval of three hotels, no information is provided on whether these hotels are actually creating the condominium units as part of the hotel development and whether the housing provided by these hotels meet the census definition of a unit. Should the City rely on these units to accommodate a portion of the housing need for lower-income, the element must include analysis to demonstrate affordability. The analysis should account for all applicable costs such as taxes and insurance and any condominium fees. Response: After a review the requirements for Hotel Condominiums to count towards the City’s RHNA requirements, it appears that the City’s Hotel Condominium ordinance does not meet the census definition of a unit. Therefore, the City will revise Table 3-9 (page 101) and remove the 113 Hotel Condominiums units from the RHNA numbers. In addition, the paragraph describing Hotel Condominiums on Page 96 has been removed from the Housing Element document. Sites with Zoning for a Variety of Housing Types: Emergency Shelters: The element proposes to establish year-round shelters in churches to address the housing need for the homeless population (Program H.3.5.1). However, Chapter 633, Statutes of 2007 (SB 2), requires the identification of a zone(s) where emergency shelters are permitted without a conditional use permit or other discretionary action with sufficient capacity to accommodate at least one year-round shelter. The element must specifically identify the zone(s) or potential zones and demonstrate sufficient capacity to accommodate the need for emergency shelters. The element should also describe the characteristics and suitability of the zone(s) for emergency shelters. Response: The Housing Element has been revised to include the following paragraph on Page 146 describing the zone where emergency shelters will be allowed by right, and to include a Program H3.5.2 which would require that the zoning code be amended to allow emergency shelters by right in this zone within one year of Housing Element adoption (see below). The Research, Office and Limited Manufacturing-Embarcadero (ROLM)(E) zone district was selected to accommodate the homeless shelter. The ROLM(E) zone district is the appropriate district for the emergency shelter for the following reasons: 1. Based on the City’s unmet need of 107 beds, staff calculates that approximately a half acre will be necessary for the shelter. The ROLM(E) district has a greater number of parcels of more than .5 acre to be better able to site the shelter on one parcel. It also has larger parcels that would be appropriate for consolidation to create a .5 acre parcel. Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 10 - 2. The per square footage costs of industrial or light manufacturing uses is much less than residentially or commercially zoned parcels making the emergency shelter more cost efficient. In addition, there are existing buildings in this area which are of an appropriate size to be converted to an emergency shelter. 3. Although not in the downtown area, accessibility to the downtown is available through the City’s free Palo Alto Shuttle. This free crosstown shuttle service begins at the Palo Alto CalTrain station, passes through the downtown area with the final destination in the Embarcadero area. The shuttle operates in the morning through the early evening throughout the work week. Added to Page 146, Emergency and Transitional Housing, paragraph two: The City of Palo Alto has identified the portion of the Research, Office and Limited Manufacturing-Embarcadero (ROLM)(E) zone district east of Highway 101 as having potential sites to accommodate emergency shelters. This area is a light industrial zone, which contains such uses as office use, research facilities and light manufacturing. It is also accessible by transit, and there are retail support services located nearby. The identified area can accommodate a shelter large enough to have capacity for the City’s unmet homeless need. The City has an unmet need of 107 beds. This could translate into a shelter of 107 beds, or the need could be accommodated in two or more shelters of smaller size. Depending on the size of the site required, and other amenities provided in a homeless shelter, an adequately sized facility could be accommodated in this zone. Based on the need for 107 beds, it has been determined that a one-half acre site could accommodate the need for a shelter, or two shelters could be accommodated on smaller sites. There are several sites in this area which are one half acre or more. In addition, there are opportunities for site consolidation. The ROLM(E) district is also appropriate because the square footage costs of industrial or light manufacturing property is much less than residentially or commercial zoned parcels, making the emergency shelter use in this area more cost efficient. Also, there are existing buildings in this area which are of an appropriate size to be converted to an emergency shelter. Accessibility to the downtown from this area is available through the City’s free Palo Alto shuttle, which operates in the morning through the early evening throughout the work week. H3.5.2 PROGRAM Amend the Zoning Code to allow emergency shelters by right with appropriate performance standards to accommodate the City’s unmet need for unhoused residents within an overlay of the ROLM(E) zone district located east of Highway 101. Five-Year Objective: Provide appropriately zoned sites for emergency shelters. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption 2. Government Constraints: Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 11 - Land-Use Controls: The element states the City adopted form-based codes in 2006 (page 123). The element should include a description of the requirements of the code including the following: • The relationship between General Plan land-use designations and the code; • Performance and processing standards; and • Development standards regulating housing including a description of how the code controls form, bulk, building types, performance standards (e.g., ground floor commercial, 30 percent commercial, etc.), uses, density, and any related design criteria. Response: The City’s adopted form-based codes requirements are more similar to contextual based than form based. This means that in addition to the typical list of uses found in traditional zoning regulations, context based design criteria are included for multi-family, commercial, mixed use and pedestrian/transit oriented development. The following text has been added to the Housing Element on Page 123 to further explain the context based standards as they apply to residential development. In multi-family and mixed use zones, the development standards are presented in table format to clearly identify the setback, height, and floor area ratio requirements. In addition, the multi-family and mixed use design criteria offer a framework to guide development that is compatible with adjacent development. These guidelines provide clear direction to developers to help streamline the development review process. The guidelines are illustrated to offer examples of how parking can be integrated in to site design, appropriate locations for open space, as well as recommendations for sustainable building design. When these standards were adopted in 2007, the intent was to bring the zoning regulations into compliance with the adopted Comprehensive Plan. Local Processing and Permit Procedures: The element indicates architectural review is required as part of the approval procedure for residential development (page 142). The element should include a description and analysis of the design criteria review guidelines and process, including identifying requirements and approval procedures and analyzing the impact of the guidelines and process on housing costs and approval certainty. Response: In addition to the discussion on Page 142 of the Housing Element, the following discussion has been added to this section: Architectural review is an important and necessary procedure to insure that new development is consistent and compatible with the existing surrounding developments. All new construction projects of 5000 square feet or more, and all multi-family projects with 3 or more units are required to be reviewed by the Architectural Review Board (ARB). A preliminary meeting with Planning staff is recommended to help streamline the process by identifying any potential issues up front. Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 12 - The design criteria found in the updated zoning code also provides clear guidelines for residential and mixed use projects. Generally, standards are related to measurable criteria such as setback, height and floor area. Once an application is submitted, it is routed to other City departments to obtain a comprehensive review of all code requirements. Once an application is deemed complete, it is scheduled for ARB review, and a recommendation is made. The municipal code findings for Architectural Review include that the design should be consistent with applicable elements of the comprehensive plan, consistent with the immediate environment, promote harmonious transitions in scale and character between different land uses, and that the design incorporates energy efficient elements. The final decision is made by the Planning and Community Environment Director, and this decision may be appealed to the City Council. The timeline for this process can range from 3 to 6 months. In order to expedite processing of applications, the Council recently approved a process revision that establishes that the Architectural Review Board has a maximum of three meetings to approve or deny an application. Because guidelines have been established for this process, there is a fair degree of certainty in the review process. In addition, the draft Housing Element proposes Program 2.2.2 (page 157) to provide an incentive to streamline the development review process by avoiding Planning and Transportation Commission and City Council review in the application process if certain requirements are met. Inclusionary Housing: While the Element generally describes the inclusionary housing ordinance framework (Page 111 and 124), it does not include an evaluation of those requirements for their potential impact on the cost and supply of housing. For example, the element should analyze the types of options and incentives the City offers to provide flexibility and facilitate compliance with the inclusionary requirements. Analyzing the inclusionary provisions is particularly important given current market conditions and the cumulative impact of local regulations. The element could include a program to evaluate the inclusionary ordinance within the next year based on current market conditions and engage the development community to facilitate this analysis. Response: The following paragraph was added to Page 24 of the Housing Element, under the discussion of Below Market Rate Housing Program: Given the high land costs and availability of land suitable for residential development within Santa Clara County and adjacent San Mateo County, most communities in the area have adopted inclusionary housing programs in order to provide affordable housing options. Palo Alto has had a Below Market Rate housing program since 1973. Although this could be seen as a constraint to housing development, from 2000 to 2008, Palo Alto produced an average of 100 units per year, and permits were issued for a total of 921 housing units between 2007 and 2011. The fact that most jurisdictions in the area have similar inclusionary housing programs, and that housing, including the required BMR units, continues to be produced, the City’s BMR program does not hinder housing production. Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 13 - In order to evaluate the program’s impact on housing production, Program H3.1.14 has been added to evaluate the provisions of the BMR program to determine if additional incentives are needed to encourage development of housing given current market conditions. H3.1.14 PROGRAM Evaluate the provisions of the Below Market Rate (BMR) Program to determine if additional incentives are needed to encourage development of housing given current market conditions. Five-Year Objective: Engage in discussions with the development community and determine if additional incentives are needed to improve the BMR Program. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Evaluate the Program within one year of Housing Element adoption Constraints on Persons with Disabilities: While the City has adopted a reasonable accommodation ordinance in respect to the Below Market Rate Program, the ordinance does not apply citywide. The element must include a detailed analysis of zoning and development standards including the City’s reasonable accommodation procedure for the development of housing for persons with disabilities to identify any constraints, and if necessary include programs to address this need. To address this requirement, the element could include a program to apply the current reasonable accommodation procedure beyond the BMR program. Response: The following discussion regarding zoning regulations which may be a constraint to persons with disabilities has been added to Page 147, under the discussion of Reasonable Accommodations Requests: Zoning regulations may be a constraint to development or conversion of housing to make it suitable for persons with disabilities. Physical improvements needed to accommodate a person’s disability may consist of ramps, handrails elevators, lifts, or other physical improvements. Particularly when retrofitting existing housing, it may not be possible to build these improvements within the setbacks, lot coverage and other standards required in a specific zoning district. The City is proposing to amend the zoning code to provide a procedure which would allow a request for modification to these rules, standards and practices for siting, development and use of housing-related facilities to eliminate regulatory barriers and provide a person with a disability equal opportunity to housing of their choice. In addition, Program H.4.1.6 has been added to the Goals, Policies and Programs: H4.1.6 PROGRAM Amend the Zoning Code to provide individuals with disabilities reasonable accommodation in rules, policies, practices and procedures that may be necessary to ensure reasonable access to housing. The purpose of this program is to provide a process for individuals with disabilities to make requests for reasonable accommodation in regard to relief from the various land use, zoning, or building laws, rules, policies, practices and/or procedures of the City. Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 14 - Five-Year Objective: Allow for reasonable accommodation for persons with disabilities in interpreting land use regulations. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Amend the Zoning Code within one year of Housing Element adoption 3. Special Housing Needs: Developmentally Disabled Population: Chapter 507, Statutes of 2010 (SB 812), amended State housing element law to require an analysis of the special housing needs of persons with developmental disabilities. The term developmental disability refers to a severe and chronic disability attributable to a mental or physical impairment, such as cerebral palsy, epilepsy, or autism, which begins before individuals reach adulthood (Welfare and Institutions Code, Section 4512). The analysis should include the following: • a quantification of the total number of persons with developmental disabilities; • a description of the types of developmental disabilities; • a description of the housing need, including a description of the potential housing problems; and • a discussion of resources, policies and programs including existing housing and services, for persons with developmental disabilities. Response: The Housing Element has been revised to include the following paragraph on Page 31 describing the developmentally disabled population and their housing needs, and to include a Program H4.2.1 which would require that Palo Alto Work with the San Andreas Regional Center to implement an outreach program that informs families in Palo Alto about housing and services available for persons with developmental disabilities (see below). Added to Page 31, following the discussion on persons with disabilities: Developmentally Disabled: The Developmentally Disabled are a separate population identified by the State of California, with differing housing needs from others with disabilities. The Lanterman Developmental Disabilities Act ensures that “patterns and conditions of everyday life which are as close as possible to the norms and patterns of the mainstream of society” are available to these individuals. Furthermore, the Olmstead v. L.C and E.W. United States Supreme Court case required an “Integration Mandate” that “States are required to place persons with mental disabilities in community settings rather than institutions…when determined to be appropriate.” Despites these laws, people with developmental disabilities are finding it increasingly difficult to find affordable, accessible, and appropriate housing that is inclusive in the local community. A developmental disability is defined by the State as “a lifelong disability caused by a mental and/or physical impairment manifested prior to the age of 18 and are expected to be lifelong.” The conditions included under this definition include: • Mental Retardation, • Epilepsy, Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 15 - • Autism, and/or • Cerebral Palsy, and • “Other Conditions needing services similar to a person with mental retardation.” Source: Background Report, 2008, Developmental Disabilities Board Area 5 The State Department of Developmental Services (DDS) currently provides community based services to approximately 243,000 persons with developmental disabilities and their families through a statewide system of 21 regional centers, four developmental centers, and two community-based facilities. The San Andreas Regional Center is one of 21 regional centers in the State of California that provides point of entry to services for people with developmental disabilities and serves the Santa Clara County area. According to the San Andreas Regional Center, there are 219 persons with developmental disabilities living in Palo Alto in 2012. There is some overlap between the developmentally disabled population and the mentally and physically disabled populations (approximately 10 and 15 percent, respectively). Individuals with developmental disabilities are often independent and can live in their own apartments or homes with little support. Others who have more severe disabilities may require 24 hour assistance in homes that can accommodate their needs as individuals. The housing need for the individuals in Palo Alto with developmental disabilities translates to about 70 units. This number is derived based on the age of the population. As the younger individuals approach adulthood, they will need independent or assisted living; and similarly, as the adults age, they too will need assisted living. There are a number of housing types appropriate for people living with a developmental disability: rent subsidized homes, licensed and unlicensed single-family homes, inclusionary housing, Section 8 vouchers, special programs for home purchase, HUD housing and SB 962 homes. The design of housing-accessibility modifications, the proximity to services and transit, and the availability of group living opportunities represent some of the types of considerations that are important in serving this need group. Incorporating barrier-free design in all new multifamily housing (as required by California and Federal Fair Housing laws) is especially important to provide the widest range of choices for disabled residents. Special consideration should also be given to the affordability of housing, as people with disabilities may be living on a fixed income. The most severely disabled persons may require an institutional environment where medical attention and physical therapy are provided. Because developmentally disabilities exist before adulthood, supportive housing for the developmentally disabled should focus on the transition from the person’s living situation as a child to an appropriate level of independence as an adult. In order to assist in the housing needs for persons with Developmental Disabilities, the City of Palo Alto will implement programs to coordinate housing activities and outreach with the Regional Center and to facilitate additional housing opportunities in Palo Alto for persons with disabilities, especially persons with developmental disabilities. Add Program H4.2.2: Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 16 - H4.2.2 PROGRAM Work with the San Andreas Regional Center to implement an outreach program that informs families in Palo Alto about housing and services available for persons with developmental disabilities. The program could include the development of an informational brochure, including information on services on the City’s website, and providing housing- related training for individuals/families through workshops. Five-year objective: Provide information regarding housing to families of persons with developmental disabilities. Funding Source: General Fund Responsibility: Planning and Community Environment Time frame: Develop outreach program within two years of adoption of the Housing Element. 4. Analyze existing assisted housing developments that are eligible to change to non-low- income housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Sections 65583(a)(8) through 65583(a)(9)(D)). While the element includes an identification and analysis of units at risk between 2004-2014, the element must identify and analyze units at-risk during ten years following the beginning of the planning period (2009-2019). If units are found to be at-risk, the element must estimate the total cost of replacing and preserving these units and include a list of entities with the capacity to acquire multifamily developments at-risk. For a listing of units at-risk in Palo Alto, contact the California Housing Partnership Corporation http://www.chpc.net/. Response: The Housing Element has been revised as follows to expand on the discussion of the preservation of at-risk housing. The section discussing at-risk housing begins on Page 62 of the Housing Element. Many of the City’s affordable housing agreements are in place through 2019. However, some affordable housing developments are dependent on Section 8 vouchers to assist in the project cash flow. While difficult to predict the direction of federal funding for the Section 8 program and affordable housing funding in general, the City will continue to advocate for maintaining or increasing funding for affordable housing. Of the City’s affordable housing developments, only one development, the Terman Apartments, was found to be a high risk of reverting to market rate housing. The Terman Apartments were financed using the Section 8 221(d)(3) mortgage insurance program. The development has been at risk for some time and the City has approached the owner a number of times about the possibility of purchasing the unit. However, the owner has not been receptive to selling the development. The City will work with the owner and other non-profit affordable housing developers in preserving this project which serves moderate income households. In 2008, the City and Palo Alto Housing Corporation, Inc. (PAHC), a non-profit housing developer, approached the owner of the Terman Apartments about the possibility of selling the units to PAHC but the owner was not willing. In addition to PAHC, the City has worked with a number of affordable housing developers in the City including Eden Housing and Bridge Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 17 - Housing Corporation, both established affordable housing developers in the Bay Area. Based on recent development proformas of affordable housing projects in the City, the total estimated cost of replacing 92 total units, with land acquisition and developments costs, at the Terman Apartments would be approximately $45 million. C: Housing Programs 1. Programs – Timelines and Implementation: To address the program requirements of Government Code Section 65583 (c) (1-6), and to facilitate implementation, all programs should include: (1) a description of the City’s specific role in implementation; (2) definitive implementation timelines; (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials. Programs with clear, quantifiable objectives will assist the City in evaluating the effectiveness of program actions and appropriateness of goals, objectives and policies as required in the review and revise section of State housing element law for future updates. Programs to be revised include, but are not limited to, the following: Programs H1.1.2, H1.1.3, H2.1.1, H2.1.9, H3.3.1, H3.4.4, and H4.2.1: Describe the specific actions and timeframes the City will take to implement these programs. Where applicable, estimate the number of units or households that will be assisted within the planning period. Program H2.1.4: Describe the incentives the City will provide to encourage the development of smaller housing units. Programs H3.3.6, H3.3.7, H4.1.1, and H4.1.2: Describe the City’s specific role in implementation of these programs. Response: All of the programs have been revised to include five-year objectives, funding sources, responsible agencies and time frames. Where appropriate, the five-year objective includes quantifiable objectives, including an estimate of the number of units or households to be assisted within the planning period. Attached is a revised list of programs which replace the programs beginning on Page 150 through Page 161 of the Draft Housing Element. It includes the additional programs added as a result of HCD comments above. Revised and new policies are indicated in bold italic type. Comments on Specific Programs: Listed below are clarifications regarding the specific programs mentioned above: Program H1.1.2 (Second Unit Amnesty) – now includes a time frame that creation of the amnesty program would be implemented within one year of adoption of the housing element. Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 18 - Program H1.1.2 (Incentives to retain rental cottages) – Clarifies the types of incentives to be considered and indicates that the program will be implemented within one year of Housing Element adoption. Program H2.1.1 (Amend zoning code to allow high density residential in mixed use projects near rail & limited exceptions to height limit) – includes timeframe that zoning code amendments will be considered within one year of Housing Element adoption. Program H2.1.9 (Transfer of Development Rights program) – establishes time frame that program will be considered within two years of Housing Element adoption. Program H3.3.1 (Expedite processing for affordable housing projects) – indicates program will continue to be implemented upon adoption of the Housing Element and will be ongoing. Program H3.4.4 (Work with affordable housing developers to acquire, rehabilitate and convert existing multi-family development) – added an objective that the City will identify potential sites and provide this information to developers within one year of Housing Element adoption. Program H4.2.1 (Evaluate zoning code to facilitate construction of housing for special needs households) – Added a time frame that the zoning code will be evaluated within one year of Housing Element adoption. Program H2.1.4 (Encourage the development of smaller housing units) – Program has been amended to indicate the types of incentives which would be provided for creating smaller, more affordable housing units. Describe the City’s specific role in the implementation of the following programs: Program H3.3.6 (Participate in the Santa Clara County Homeless Collaborative) – A five-year objective was added that indicates that City staff will continue to participate as members of the Collaborative’s CDBG and HOME Program Coordinators Group. Program H3.3.7 (Participate with support agencies addressing homelessness) – a five-year objective was added which indicates that City staff will continue to participate in the prioritization of funding for County-wide programs. Program H4.1.1 (Work with agencies to ensure fair housing laws are enforced) – a five-year objective was added that indicates that City staff will continue to coordinate with state and federal agencies to support programs to eliminate housing discrimination. Program H4.1.2 (Support groups that provide fair housing services) – a five-year objective was added which clarifies that the city provides financial support through CDBG finding to the Mid- Peninsula Citizens for Fair Housing and Project Sentinel. 2. Identify Adequate Sites Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 19 - As noted in Finding A1, the element does not include a complete site analysis and therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows: Rezoning Program: Please be aware should the element rely on sites which are expected to be rezoned in the CN zoning district to accommodate the lower-income housing need (Page 71), it must include a program to rezone sites in accordance with Government Code Sections 65583(a)(3) and 65583.2(h) for 100 percent of the remaining lower-income housing need. The sites must be zoned to permit owner-occupied and rental multifamily uses by-right during the planning period and include minimum density and development standards that permit at least 16 units per site at a density of at least 20 units per acre. Also, at least 50 percent of the remaining need must be planned on sites that exclusively allow residential uses. Response: The City does not require rezoning additional sites to meet its lower income housing need. After subtracting the 251 lower income units approved or built during the 2007-2014 cycle from the City’s low and very low requirement of 1,233 units, the City has an unmet need of 982 low and very low income units. In order to accommodate the very low and low income needs, State law requires the City to identify sites that have a density of 20 units per acre or higher, as per the density assigned to the City per State law. In the City’s Housing Inventory Sites (HIS) list, all parcels with a density of 20 units per acre or more have been highlighted. The total number provided by the highlighted parcels is 1,056 housing units. Therefore the City can accommodate its unmet low and very low income housing need for the 2007-2014 RHNA cycle by right. While the City does have proposed programs that will revise the Zoning Ordinance to allow up to 20 dwelling units per acre for certain zoning districts, the City can meet its low and very low needs with existing zoning. In addition, an application has been submitted to rezone the site to Planned Community (PC) to allow 60 units of extremely low to low income senior affordable rental housing and 15 market rate units by right, for a total of 75 units for 595 Maybell Avenue. There are now four units on the site, so the net yield will be 71 units. This site, with the proposed rezoning will meet the criteria for accommodating the identified unaccommodated need: the zoning will allow multiple family residential uses by right, the site is large enough to accommodate more than 16 units, and the density will be about 30 units per acre. Although the City does not plan to use this property to meet its unaccommodated need requirements, the rezoning will provide additional affordable housing to help the City meet its RHNA numbers. The following Program 2.2.8 has been added to the Housing Element to provide for the rezoning of this site to accommodate this proposal within one year of Housing Element adoption. H2.2.8 PROGRAM Rezone property at 595 Maybell Avenue from the RM-15 and R-2 zone districts to the PC zone district to allow for development of 60 units of extremely low to low income senior affordable rental housing units and Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 20 - 15 market rate units. Five-Year Objective: Provide an opportunity for development of 60 units affordable to extremely low and low income senior residents and 15 market rate units. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption Two other programs have been added to the Housing Element to provide for the rezoning of the CN and GM zones to be consistent with the realistic capacity as outlined in the City Housing Inventory Sites list. The rezones will occur within a one year of Housing Element adoption. 2.2.5 PROGRAM Revise the Zoning Ordinance to increase the density of up to 20 units per acre on CN-zoned parcels included in the Housing Inventory Sites. Five-Year Objective: Provide opportunities for affordable units on CN zoned Housing Inventory Sites. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Amend zoning code within one year of Housing Element adoption. 2.2.6 PROGRAM Revise the Zoning Ordinance to allow for residential uses with the density of up to 30 units per acre on GM parcels included in the Housing Inventory Sites. Five-Year Objective: Provide opportunities for affordable units on GM zoned Housing Inventory Sites. Funding Source: City funds Responsible Agency: Planning & Community Environment Small Sites/Lot Consolidation: The element relies on the potential of small sites to be consolidated to accommodate the City’s share of the RHNA, particularly for lower-income households. As a result, the element must include specific programs to facilitate lot consolidation and development of housing on small sites. Response: Program H2.2.7 has been added to amend the zoning code to create zoning incentives to encourage lot consolidation (see above). The program will be implemented within one year of Housing Element adoption. Mixed Use Development: As the City is relying on underutilized sites and the potential for mixed use development to accommodate its RHNA for lower-income households, the element must include specific program actions to promote redevelopment of underutilized sites and lot consolidation including financial assistance, regulatory concessions or incentives to encourage and facilitate additional or more intense residential development on non-vacant and underutilized sites. Examples of incentive include: 1) organizing special marketing events Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 21 - geared toward the development community; 2) posting the sites inventory on the local government’s webpage; 3) identifying and targeting specific financial resources; and reducing appropriate development standards. Response: In addition to Program H2.1.10 noted above, which establishes zoning incentives for lot consolidation on identified Housing Inventory Sites, the following program has been added: H2.1.11 PROGRAM Promote redevelopment of underutilized sites and lot consolidation by providing information about potential housing sites on the City’s website, including the Housing Inventory Sites and information about financial resources available through City housing programs. Five-Year Objective: Provide information to developers about potential housing sites and opportunities for lot consolidation. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Post information on website within one year of Housing Element adoption 3. Programs to Meet the Needs of Extremely Low-, Very Low-, Low- and Moderate- Income Households While the element includes some actions proposed to assist in the development of housing for very-low and low-income households, it must include programs that specifically assist in the development of a variety of housing types to address the needs of extremely low-income (ELI) households. To address this requirement, the element could revise programs to prioritize some funding for the development of housing affordable to ELI households, and/or offer financial incentives or regulatory concessions to encourage the development of housing types, such as multifamily, single-room occupancy units, and supportive housing, which address some of the needs of this income group. Response: Program H3.1.7 (Page 156 of the Housing Element, proposes to amend the Zoning Code to allow Single Room Occupancy (SRO) units in commercial and high density residential zoning districts. These units are generally seen to be affordable to ELI households. In addition, in order to further address the housing needs of ELI households, the following two programs have been added to the Housing Element: H3.1.15 PROGRAM When using its Housing Development funds for residential projects, the City shall give a strong preference to those developments which serve extremely low-income (ELI) households. Five-Year Objective: Provide funding opportunities for development of housing for Extremely Low Income (ELI) households. Funding Source: City Housing funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 22 - H3.1.16 PROGRAM Amend the Zoning Code to provide additional incentives to developers who provide extremely-low income (ELI) housing units, above and beyond what is required by the Below Market Rate (BMR) program, such as reduced parking requirements for smaller units, reduced landscaping requirements and reduced fees. Five-Year Objective: Provide incentives for development of housing for Extremely Low Income (ELI) households. Funding Source: City Housing funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption 4. Removal of Governmental Constraints: As noted in Finding A2, the element requires a complete analysis of potential government constraints. Depending on the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. Response: As noted above in the response to comment A2 above regarding analysis of government constraints, additional analysis has been provided for the following topics: Land Use Controls, Local Processing and Permit Procedures, Inclusionary Housing and Constraints on Persons with disabilities. As a result of this additional analysis for the City’s inclusionary housing program, Program H3.1.14 was added to the Housing Element, which would require an evaluation of the City’s Below Market Rate (BMR) Program to determine if additional incentives are needed to encourage development of housing. In addition, as a result of the additional analysis regarding the Developmentally Disabled population, Program H4.2.2 has been added to implement an outreach program, working with the San Andreas Regional Center. 5. Housing Units At-Risk of Conversion to Market-Rate: The element identifies housing units at-risk of converting to market-rate. Therefore, program H3.1.5 should be revised to include specific and proactive actions. For example, the program should ensure compliance with noticing requirements and include a tenant education component and consider pursuing funding on at least an annual basis. The program should also commit the City to contacting non-profits immediately to develop a preservation strategy by a date certain to be ready to act quickly when notice of conversion is received. Response: Program H3.1.5 has been revised to contain pro-active and specific actions preserve affordable housing at-risk of converting to market rate (see below). In addition, please see discussion about Terman Apartments on Page 13 and 14 of this letter. 3.1.5 Preserve affordable housing stock by monitoring compliance, providing tenant education seeking other sources of funds for affording housing developments at risk of market rate conversions. The City will continue to renew existing funding sources supporting rehabilitation and maintenance activities. Response to HCD comments on Palo Alto Draft Housing Element March 26, 2013 - 23 - In addition, the following program has been added as Program 3.1.17 H3.1.17 PROGRAM Any affordable development deemed a high risk at market rate conversion, within two years of the expiration of the affordability requirements, the City will contact the owner and explore the possibility of extending the affordability of the development. Five-Year Objective: To protect those affordable developments deemed a high risk to converting to market rate. Funding Source: City Housing funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption D. Quantified Objectives: Include quantified objectives estimating the number of housing units by income category that can be constructed, rehabilitated, and conserved over a five-year time period. This requirement could be addressed by utilizing a matrix like the one illustrated below: Income New Construction Rehabilitation Conservation/ Preservation Extremely Low- 45 100 Very Low- 65 175 Low- 20 75 Moderate- 10 600 92 Above Moderate- 650 2400 TOTAL 790 3350 92 Response: The City will add a Quantified Objectives table in Chapter 3 following Table 2-57 demonstrating the estimated numbers of housing units that will constructed, rehabilitated and conserved. The following text will accompany the table: As required by Section 65583 of the California Government Code, the goals, policies and actions identified in this document seek to meet quantified housing objectives. Table 2-57 summarizes these findings, which result in a total estimated construction of 790 new housing units. The estimates for Rehabilitation and Conservation were based on City Planning and Building Department permit data. City of Palo Alto Housing Element 2007-2014 Submitted to HCD: August 16, 2012 Revised: March 29, 2013 ACKNOWLEDGEMENTS City Council Gregory Scharff, Mayor Nancy Shepherd, Vice Mayor Marc Berman, Councilmember Patrick Burt, Councilmember Karen Holman, Councilmember Larry Klein, Councilmember Liz Kniss, Councilmember Gail A. Price, Councilmember Greg Schmid, Councilmember Planning and Transportation Commission Eduardo Martinez, Chair Mark Michael, Vice Chair Michael Alcheck Arthur Keller Carl King Alex Panelli Greg Tanaka Technical Advisory Group Susan Fineberg Tony Carrasco Melissa Baten Caswell Sherrie Furman Tom Jordan Carol Lamont Doug Moran Adam Montgomery Jean McCown Janet Owens Deborah Pappas Steve Raney Fran Wagstaff City Staff Curtis Williams, Director of Planning and Community Environment Aaron Aknin, Assistant Director of Planning and Community Environment Steven Turner, Advance Planning Manager Roland Rivera, Senior Planner Tim Wong, Senior Planner Chitra Moitra, Planner Cara Silver, Senior Assistant City Attorney Maureen Brooks, Consultant I Table of Contents Chapter 1 Introduction 1 1.1 Community Context 1 1.2 Purpose and Scope of the Housing Element 2 1.3 Relationship to the General Plan 2 1.4 Data and Information Sources 4 1.5 Community Involvement 4 1.6 Adoption 5 Chapter 2 Housing Needs Assessment 6 2.1 Demographic Profile 6 Population Growth and Trends 6 Age and Gender Characteristics 7 Race and Ethnicity 8 2.2 Employment Characteristics and Trends 9 Employment Trends 9 Local Employment Growth 10 Jobs-Housing Balance 13 2.3 Household Characteristics and Trends 13 Household Type and Size 14 Households by Tenure 16 Household Income 17 Overpaying and Overcrowded Households 19 Overpaying 19 Overcrowding 22 2.4 Special Needs Groups 25 Senior Households 26 Persons with Disabilities 29 Developmentally Disabled 31 Large Households 39 Single Parent and Female Headed Households 34 Farmworkers 35 Homeless Persons 37 i) Prevention Services 39 ii) Emergency Shelters 40 iii) Transitional Affordable Housing 45 Extremely Low Income Households 46 Projected Needs 48 2.5 Housing Characteristics 49 Housing Development 49 Vacancy Rates 51 II Housing Types 52 Housing Age and Conditions 55 Housing Cost 57 Housing Affordability 58 Foreclosures 60 Assisted Housing At-Risk of Conversion 61 Expiration of Section 8 Project Based Subsidies 63 Section 221(d)(4) Projects 63 Section 8 Moderate Rehabilitation Program Projects 63 Cost Analysis 64 2.6 Regional Housing Needs 65 Housing Needs Allocation Process 65 Units Approved and Remaining Need 66 Chapter 3 Housing Resources and Inventory 72 3.1 Land Inventory 72 Zoning Appropriate to Accommodate Housing for Lower-Income Households 72 Vacant and Infill Redevelopment Opportunities to Accommodate Residential Development 73 3.2 Other Sources of Affordable Housing 108 3.3 Available Sites Conclusions 109 3.4 Financial Resources 109 Federal Funds 111 State Funds 111 Local Funds 112 3.5 Opportunities for Energy Conservation 113 Integrated Land Use and Transportation 114 Energy Conservation 116 Building Design and Construction 121 3.6 Other Programs 121 Chapter 4 Housing Constraints 123 4.1 Non-Governmental Constraints 123 Housing Market Conditions 123 Land Costs 124 Hard/Construction Costs 124 Financing/Soft Costs 125 Affordable Housing Development 127 Environmental Constraints 128 Infrastructure Constraints 129 Small Sites 130 Schools 130 4.2 Governmental Constraints 131 Land Use Controls 131 III Context-Based Design Codes 133 Density Bonus Provisions 134 Second Units 134 Below Market Rate Housing Program 134 Growth Control or Similar Ordinances 134 Zoning for a Variety of Housing 135 Height Limits 140 Parking 141 4.3 Development Review Process 142 Fees and Exactions 142 Nexus Requirements 149 Parks, Community Center, and Libraries Development Fee 150 Housing Development Fee 150 Building Codes and Enforcement 150 On/Off-Site Improvement Standards 150 Development Review Process 151 4.4 Constraints to Housing for Persons With Disabilities 155 Special Needs Housing 156 Emergency and Transitional Housing 157 Reasonable Accommodations Requests 158 Building Codes and Development Regulations 158 Chapter 5 Past Accomplishments and New Housing Goals, Policies and Programs 160 5.1 1999-2006 Housing Plan Accomplishments 160 Summary Evaluation of Past Accomplishments 161 Response to AB 1233 162 5.2 Housing Goals, Policies and Programs 163 5.3 1999-2006 Accomplishments Matrix 171 Figures 1-1 Regional Location of Palo Alto (Map) 1 2-1 Senior and Preschool Population Trends in Palo Alto, 1980-2008 8 2-2 Racial Characteristics of Population in Palo Alto and Santa Clara County, 2008 9 2-3 Total Household Growth in Palo Alto, 1980-2008 14 2-4 Housing Stock by Unit Type in Palo Alto, 2008 55 2-5 Housing Tenure by Structure of Year Built 56 2-6 Housing Stock by Tenure and Number of Bedrooms, 2008 57 2-7 Housing Stock of Palo Alto by Year Built, 2008 58 2-8 Comparison of Achievements in Reaching ABAG Goals in the Past and Current Cycle by Income Level 70 IV Tables 2-1 Historical Population Growth in Palo Alto, 1980-2008 7 2-2 Population Trends of Neighboring Jurisdictions, 1990-2008 7 2-3 Population Increase by Age Cohorts in Palo Alto, 1980-2008 7 2-4 Employment Projections by Industry for Palo Alto, 1980-2020 10 2-5 Major Employers in Palo Alto, 2008 11 2-6 Typical Hourly Wage and Mean Wages of the Some Jobs of Palo Alto Residents, 2008 12 2-7 Commute Patterns of Palo Alto Residents, 2008 12 2-8 Type of Household Growth in Palo Alto, 1980-2008 15 2-9 Average Household Size in Palo Alto, 1970-2008 16 2-10 Tenure of Occupied Housing in Palo Alto Residents, 2000-2008 16 2-11 Tenure by Household Size in Palo Alto, 2008 17 2-12 HUD Annual Household Income Limits, 2008 Santa Clara County 18 2-13 Household Income Distribution by Age for Santa Clara County and Palo Alto, 2008 19 2-14 Affordability of Rental Housing Cost by Area Median Income, 2009 20 2-15 Affordability of Ownership Housing Cost by Area Median Income, 2009 20 2-16 Palo Alto Households Paying More than 30 Percent of Household Income for Housing, 2008 21 2-17 Palo Alto Housing Cost as Percentage of Household Income, 2008 21 2-18 Average Household Size of Occupied Units in Palo Alto, 2008 23 2-19 Household Size by Tenure in Palo Alto, 2008 23 2-20 HUD Established Fair Markets Rents, 2008 24 2-21 Overcrowded Households in Palo Alto, 2008 24 2-22 Senior Population Increase in Palo Alto, 1980-2008 25 2-23 Senior Household Income Distribution for Santa Clara County and Palo Alto, 2008 26 2-24 Senior Households by Tenure in Palo Alto, 2008 27 2-25 Independent Living Facilities for Elderly in Palo Alto, 2008 27 2-26 Residential Care Facilities (Assisted Living) for Elderly Population in Palo Alto 28 2-27 Number of Non-institutionalized Disabled Civilian by Age Group 30 2-28 Licensed Community Care Facilities in Santa Clara County Serving Palo Alto 33 2-29 Larger Households by Tenure in Palo Alto, 2008 34 2-30 Occupied Housing Stock by Number of Bedrooms in Palo Alto, 2008 34 2-31 Female-Headed Households in Palo Alto, 2008 35 2-32 Total Number of Sheltered and Unsheltered Homeless Persons, 2009-2011 38 2-33 Lists of Organizations Providing Prevention Services for the Homeless in Palo Alto 39 2-34 List of Emergency Shelters in Santa Clara County Serving Palo Alto Residents 41 2-35 List of Emergency Shelters in Santa Clara County Serving all Residents 43 V 2-36 Transitional Housing Shelters Serving Palo Alto 45 2-37 Supportive Share Housing Facilities in Palo Alto 46 2-38 HUD Annual Income Limit Santa Clara County, 2008 46 2-39 Median Gross Rent in Palo Alto,1990-2008 46 2-40 Affordability of Rental Housing Cost by Income, 2009 47 2-41 Households with Housing Problems Palo Alto by Income, 2000 48 2-42 ABAG’s New Construction Need by Household Income Level in Palo Alto, 2007-2014 49 2-43 Progress in Meeting Palo Alto’s Fair Share of the Regions 2007-2014 Housing Need by Income Level 49 2-44 Total Number of Housing Units in Palo Alto, 1970-2008 49 2-45 Annual Rate of Housing Production Since 1970 50 2-46 Housing Vacancy in Palo Alto, 2000-2008 51 2-47 Housing Vacancy Type in Palo Alto, 2008 52 2-48 Housing Stock by Type by Type of Housing Since 2000 53 2-49 Regional Median Home Values Since 2000 58 2-50 Rental Housing Affordability, 2009 59 2-51 Ownership Housing Affordability, 2009 59 2-52 Median Rent and Home Value of Palo Alto Since 1990 60 2-53 Median Rents by Number of Bedrooms, 2009 60 2-54 Summary of Government Assisted Units “At Risk” for Conversion 62 2-55 Santa Clara County Housing Needs Allocation, 2007-2014 66 2-56 ABAG’s New Construction Need by Household Income Level in Palo Alto, 2007-2014 66 2-57 Progress in meeting Palo Alto’s Fair Share of the Region’s 2007-2014 Cycle Housing 67 2-57a Quantifiable Objectives 67 2-58 List of Projects with Building Permit Issued and Planning Entitlement Issued by Income Categories as of December 2011 69 3-1 Allowed Residential Densities per Zoning District 74 3-2 Residential Densities of Multifamily Residential or Mixed Use Project Built or Approved 76 3-3 “Realistic Capacity” Density Factor Compared to Allowed Residential Densities per Zoning District 77 3-4 Table of Commercially Zoned Housing Inventory Sites 86-97 3-5 Table of SOFA 2 Housing Inventory Sites 100-103 3-6 Table of Existing Residential Zoning with Existing Commercial uses on HIS 105-107 3-7 Summary of Housing Unit Production from January 2007 to December 2011 109 3-8 Summary of RHNA need and Housing Inventory Sites 110 3-9 Total Capacity of Housing Inventory Sites at 20 DU/AC 111 3-10 List of Integrated Land Use and Transportation Programs in Palo Alto 115 3-11 List of Environmental Sustainability Programs in Palo Alto 117-121 4-1 Disposition Table of Applications for Conventional Home Purchase Loans, 2007 126 4-2 Existing Land Use Category Distribution of Palo Alto 131 VI 4-3 Housing Types Permitted by Zoning Districts 136 4-4 Existing Residential Development Standards 137 4-5 R-1 Districts and Minimum Site Areas 138 4-6 Zoning Category Distribution of Palo Alto 140 4-7 Parking Requirements for Residential Zones 142 4-8 Palo Alto Residential Development Impact Fees 143 4-9 Palo Alto Development Impact Fee Exemptions 144 4-10 City of Palo Alto Planning Division Application Fee Schedule Effective August 27, 2010 146-148 4-11 Building Permits and Other Department Fees 149 4-12 Typical Processing Procedures by Project Type 155 4-13 Timelines for Permit Procedures 155 EXHIBITS A. Map of Parcels in the Housing Inventory Sites a. HIS City Wide Map b. Enlarged HIS map of University Ave. c. Enlarged HIS map of California Ave. d. Enlarged HIS map of El Camino Real B. Goals, Policies, and Programs Disposition C. Technical Assistance Group (TAG) Roster Chapter 1 1 CHAPTER 1 INTRODUCTION 1.1 COMMUNITY CONTEXT Incorporated in 1894 and located 35 miles south of San Francisco and 14 miles north of San Jose, the City of Palo Alto is a community of approximately 63,000 residents. Part of the San Francisco Metropolitan Bay Area and the Silicon Valley, Palo Alto is located within Santa Clara County and borders San Mateo County. The City‘s boundaries extend from San Francisco Bay on the east to the Skyline Ridge of the coastal mountains on the west, with Menlo Park to the north and Mountain View to the south. The City encompasses an area of approximately 26 square miles, one-third of which is open space. Palo Alto’s main transportation corridors are Interstate 280, Highway 101, Highway 84 - the Dumbarton Bridge and Highway 92 - the Hayward-San Mateo Bridge. Air transportation is provided by San Francisco, San Jose and Oakland international airports. Within the City, commuter rail stations include the Palo Alto University Avenue stop, one of the most used in the CalTrain system and the California Avenue station. Alternative transportation options include bike paths throughout the City, and an internal shuttle service. Figure 1-1 Regional Location of Palo Alto Chapter 1 2 The City of Palo Alto can be described as a suburban residential community with a vibrant economy in the high technology and medical sectors. Its housing stock provides a number of housing types, including single family homes, townhomes, condominiums and one mobile home park. Of the approximate 27,000 housing units in the City, approximately 63% of the housing units are single family residential units. As with many other Silicon Valley jurisdictions, the demand for housing exceeds housing supply, thus escalating housing prices. In 2006, the median sales price for a single family home was $1,365,000. Even with the downturn of the economy and its affects on the real estate market, current housing prices have rebounded to nearly equal the pre-downturn housing prices. Even with the gradual recovery of its housing market, Palo Alto faces important challenges. The City is nearly built out with only .5% of the City’s developable land vacant with no opportunities to annex additional areas to accommodate the City’s future housing needs. The high cost of the land coupled with the smaller lot sizes in the City makes residential development difficult. With the high median sales price, providing housing affordable to all segments of the population is an issue. In addition, while Palo Alto is fortunate to have a surplus of jobs in the City, the City’s circulation infrastructure is taxed by the large amount of daily commuters, impacting its streets and neighborhoods. 1.2 PURPOSE AND SCOPE OF THE HOUSING ELEMENT The California State Legislature has identified the attainment of a decent home and suitable living environment for every citizen as the State’s major housing goal. Recognizing the important role of local planning programs in the pursuit of this goal, the Legislature has mandated that every city and county prepare a Housing Element as part of its comprehensive General Plan. The State currently requires each city and county to update its Housing Element every five years to ensure that it addresses its changing housing needs and identifies sufficient opportunities to provide housing for all economic segments of the community. The current Housing Element will serve the planning period that began January 1, 2007 to June 30, 2014 and builds on the progress made under previous Palo Alto Housing Elements. This is a seven year period instead of the usual five due to a request by the Association of Bay Area Governments (ABAG) to coincide the Regional Needs Housing Allocation (RHNA) process with the 2008 Regional Transportation Plan update. The City has previously adopted four Housing Elements, the most recent being the 1999-2006 City of Palo Alto Housing Element adopted in 2002. This current Housing Element shows how the City proposes to address its fair share of the regional housing need that ABAG approved in May 2008. This document was prepared pursuant to Article 10.6 of the Government Code (State Housing Element Law) and presents a comprehensive set of housing policies and actions for the years 2007–2014. It builds on an assessment of Palo Alto’s housing needs including the regional housing needs allocation and an evaluation of existing housing programs, available land for future housing, and constraints on housing production. 1.3 RELATIONSHIP TO THE GENERAL PLAN Cities and counties in California are required to develop comprehensive General Plans, which are long-range planning documents to guide future growth and development. A community's Chapter 1 3 General Plan typically provides an extensive and long-term strategy for the physical development of the community and any adjoining land. There are seven subject areas that a community’s General Plan must address, although other subjects can be added based on the community’s needs and objectives. This Housing Element is intended to serve as the seventh mandated Element of Palo Alto’s General Plan (known as the Comprehensive Plan.). The other “Elements” that the Plan must contain are Land Use, Circulation, Conservation, Open Space, Noise, and Safety. The Palo Alto Comprehensive Plan addresses the requirements of State law through the following elements:  Land Use and Design  Housing  Transportation  Natural Environment  Community Services and Facilities  Business and Economics In addition to revising the Housing Element, the City of Palo Alto is undertaking a Comprehensive Plan Amendment to update the Comprehensive Plan adopted in 1998. The purpose of the Amendment is to extend the horizon year of the existing Comprehensive Plan from 2010 to 2020, revise base conditions and growth projections, modify policies and programs, and update the land use map as well as revise the Housing Element. A focus of the amendments will be to ensure that sufficient public services will be available to serve new housing development and that sufficient land is preserved to provide neighborhood-serving retail uses. State law requires the Housing Element to include the following:  Evaluation of existing housing needs;  Estimates of projected housing needs;  Review of previous Housing Element goals and programs that evaluates how well they achieved the City’s objectives;  Inventory of adequate sites with an analysis that assesses the jurisdiction’s ability to accommodate its share of the regional housing need in light of environmental and infrastructure issues and conditions;  Identification of governmental and non-governmental constraints to the production and maintenance of housing:  Specific proposals to address identified needs, remove or reduce governmental constraints; and conserve and improve existing affordable housing; and  Quantifiable objectives that estimate the maximum number of units by income level for construction, rehabilitation and conservation of housing during the planning period. Chapter 1 4 The State law also requires communities to submit their housing elements for review by the State’s Department of Housing and Community Development (HCD), to determine if they comply with State Housing Element Law (Article 10.6 of the Government Code). 1.4 DATA AND INFORMATION SOURCES The information for this Housing Element Update came from a variety of sources. The primary sources used were U.S. Census (Census 1990 and 2000), America Community Survey (ACS) Data 2006-2008, California Department of Finance, Association of Bay Area Governments (ABAG) Projections (primarily 2007), and Palo Alto Planning Department’s Building Permit data. Other data sources include Claritas Inc., Real Facts, various private real estate rents, marketing data, and the HUD Comprehensive Housing Affordability Strategy (CHAS) data systems. For data analysis of the Housing Needs Assessment the City has used ACS 2006-2008 data. Although more recent ACS data is available, ACS 2006-2008 data has been determined to be more accurate and reliable. 1.5 COMMUNITY INVOLVEMENT The 2007-2014 Palo Alto Housing Element is being prepared with the assistance of considerable community participation. Public outreach conducted as part of this Housing Element update included:  Technical Advisory Group (TAG) meetings  Community Workshops  Developer Focus Group Meetings  Meeting with Property Owners of Housing Inventory Sites  Planning and Transportation Commission Meetings  City Council Meetings An ad hoc Technical Advisory Group (TAG) was formed consisting of seventeen members representing a variety of community groups and public entities that had an interest both in the housing problems facing Palo Alto and in finding solutions to those problems. The group included a member of the Planning and Transportation Commission, a representative from Palo Alto Housing Corporation, a member of Palo Alto Unified School District Board, a representative from the Human Relations Commission, a representative from the League of Women Voters, a Mixed Use Developer/ Architect, a Housing & Homelessness Needs Advocate, a Senior Housing developer, a Palo Alto Neighborhood (PAN) representative, and representatives from the business and real estate sectors. The TAG represented the different housing interests of various segments of the community and provided a forum for the representatives of each group on the TAG to share their knowledge and perspectives regarding housing needs and solutions. Although each TAG member represented the views of their respective groups, they also consulted with other individuals in the community. All TAG Chapter 1 5 meetings were open to the public. The City held more than a dozen TAG meetings between November 2008 and December 2010 to get input and advice on future housing needs and policy recommendations. The TAG provided comments and advice on the City’s housing needs and the policies the City proposed to use to address those needs. It also reviewed draft versions of the Housing Elements Goals, policies and programs. The TAG recommendations were forwarded to the Planning Commission and the City Council. In addition to the work of the TAG, the City held two community workshops for the purposes of collecting input from members of the public who were not members of the TAG. These meetings were held on August 31 and September 7, 2010 in community facilities at locations in the northern and southern areas of Palo Alto. Identical agendas were prepared for each meeting. Discussion topics included:  An overview of the Housing Element;  The housing challenges facing Palo Alto, and  The City’s current affordable housing efforts. At the community meetings, participants were organized into small groups to identify the most critical housing needs in Palo Alto and suggest how the City should address these needs. The small groups then provided a summary of the issues and solutions back to the large group. Information received during these two meetings helped to define the work of City staff in the identification of housing opportunity sites and development of revised goals, policies and programs. These meetings also provided opportunities for members of the public to ask questions of staff in a less formal setting. Staff also met with a group of developers to better understand constraints on developing higher density housing in the City. After generating a draft inventory, staff also held two meetings with property owners of proposed sites to explain the inventory process, address concerns of property owners and to understand development constraints of individual sites. Throughout the Housing Element development process, the Planning and Transportation Commission and City Council have held formal public meetings to obtain updates and progress reports regarding City staff’s efforts and to provide direction and feedback. The Planning and Transportation Commission met ten times to discuss the Housing Element prior to its review of the complete draft element in April of 2012. These meetings also provided opportunities for members of the public to provide comment to the Planning and Transportation Commission, City Council, and City staff. 1.6 ADOPTION The City Planning and Transportation Commission first reviewed the draft Housing Element on April 11, 2012. After some program revisions, on May 9, 2012, the PTC recommended the City Council forward the draft Housing Element onto HCD for their review. The City Council approved submitting the draft Housing Element for HCD review on July 9, 2012. The draft Housing Element was submitted to HCD review on August 16, 2012 with comments received from HCD on October 18, 2012. City staff has been working with HCD in revising the draft Housing Element to meet State requirements. Chapter 2 6 CHAPTER 2 HOUSING NEEDS ASSESSMENT 2.1 DEMOGRAPHIC PROFILE Population Growth and Trends Historical review of Palo Alto population data reveals that population growth from 1980-1990 was relatively low, around 1 percent growth rate. During the decade from 1990-2000, Palo Alto's population grew by almost 5 percent from 55,900 to 58,598, compared to a 12 percent increase for Santa Clara County. This was one of the lowest rates of population growth for communities in Santa Clara County for that decade. From 2000 to 2008, however, Palo Alto’s population grew faster than all of the cities in the County except for Gilroy and Cupertino, recording an 8 percent increase in total population to 63,370. The total Santa Clara County population increased by 3 percent during the same period. Table 2-1 Historical Population Growth in Palo Alto, 1980-2008 Palo Alto’s growth was due to both an increase in the number of dwelling units and an increase in household size. Table 2-2 Population Trends of Neighboring Jurisdictions, 1990-2008 Year Population Numerical Change Percent Change 1980 55,225 741 1% 1990 55,900 675 1% 2000 58,598 2,698 5% 2007 63,752 5,154 9% 2008 63,370 -382 -1% Source:US Census 1980, 1990 and 2000, the 2005-2007 ACS and 2006-2008 ACS three-year estimates. Jurisdiction 1990 2000 2007 2008 Name Number Percent Gilroy 31,487 41,464 46,956 48,064 6,600 15.92% Cupertino 40,263 50,546 56,592 55,623 5,077 10.04% Los Gatos 27,357 28,592 29,928 30,963 2,371 8.29% Palo Alto 55,225 58,598 63,752 63,370 4,772 8.14% Santa Clara 93,613 102,361 109,363 110,376 8,015 7.83% Los Altos 26,303 27,693 28,727 29,812 2,119 7.65% MountainView 67,460 70,708 71,153 73,847 3,139 4.44% Sunnyvale 117,229 131,760 136,162 136,352 4,592 3.49% San Jose 782,248 894,943 898,901 905,180 10,237 1.14% Total County 1,497,577 1,682,585 1,722,819 1,734,756 52,171 3.10% Source:US Census 1990 and 2000, the 2005-2007 ACS and 2006-2008 ACS three-year estimates. Change (2000-2008) Chapter 2 7 Age and Gender Characteristics The median age of Palo Alto's population has increased dramatically over the last three decades. In 1970, the median age was 29.5 years for males and 33.7 years for females. By 1990, the median age of Palo Alto residents had increased by approximately 6.5 years from 1970, climbing to 36.0 years for males and 40.0 years for females. In the year 2000, the median age for the entire population of Palo Alto was 40.4 years, which was considerably higher than the County median age of 34 years. From 2000-2008 the median age of Palo Alto’s population increased from 40.4 to 42.0 whereas the Santa Clara County median age increased from 34 to 36.4 years. The City of Palo Alto is continuing to experience two trends in the population age breakdown since the 1980’s. Between 2000 and 2008, there has been a dramatic increase in the pre-school age (under 5 years) population, with an approximately 29 percent increase, which continues a trend that started in the 1980’s. In addition, there is a continued decrease in the childbearing population age group (18-44 years) from the 1980’s to present. "Aging" of the population is evident in the increase in Palo Alto's senior population. In 1970, the number of persons age 65 and over was 5,789, constituting 10.3 percent of the City's total population. By 2000, the population aged 65 and over had increased by 3,351 to 9,140 persons, constituting 15.6 percent of the City's total population. From 2000-2008 there has been an additional increase of 13 percent in the population of this group, bringing the total up to 10,300, approximately 16 percent of Palo Alto’s total population. Overall, Palo Alto's senior population increased nearly 39 percent over the 1980-2008 period. Given the extensive senior oriented resources in Palo Alto, it is expected that seniors will continue to reside in Palo Alto, but will begin shifting from single family homes to smaller units. This Housing Element begins planning for this demographic shift. The City of Palo Alto has a slightly higher female population 51 percent (approx.) as compared to 49 percent (approx.) male population. This trend is also associated with an aging population. Table 2-3 Population Increase by Age Cohorts in Palo Alto, 1980-2008 Age 1980 1990 2000 2007 2008 Group Number Number Number Number Number Number Percentage Pre-School (Under 5) 2,168 2,764 2,970 3,893 3,828 858 28.89% School Age (5-17) 8,998 6,999 9,436 10,879 11,025 1,589 16.84% Child Bearing (18-44) 24,004 24,863 21,872 21,468 20,307 -1,565 -7.16% Middle Age (45-64) 12,647 12,527 15,180 17,858 17,910 2,730 17.98% Senior (65 and Over) 7,408 8,747 9,140 9,654 10,300 1,160 12.69% Median Age 35.2 38.2 40.4 42.1 42.0 0.01 3.96% TOTAL PERSONS 55,225 55,900 58,598 63,752 63,370 4,772 8.14% Change (2000-2008) Source:US Census 1980, 1990 and 2000, the 2005-2007 ACS and 2006-2008 ACS three-year estimates. Chapter 2 8 Figure 2-1 Senior and Pre-School Population Trends in Palo Alto, 1980-2008 Source: US Census 1980, 1990 and 2000, the 2005-2007 ACS and 2006-2008 ACS three-year estimates. Race and Ethnicity In evaluating Palo Alto's racial distribution, the 2000 U.S. Census data indicated that a majority of Palo Alto's population was composed of white persons, which continues to hold in 2008. Approximately 73 percent of the population identified themselves as white in 2000. That number fell to 65 percent in 2008. The next largest population group by race in the City is Asian. They comprised 17.3 percent of the City’s population in 2000. In 2008 their proportion increased to 25 percent. The Hispanic population in the City increased in 2008 by 1.3 percent to 5.9 percent. The African-American population fell slightly from 2 percent in 2000 to 1.7 percent in 2008. Although Palo Alto’s population has become somewhat more diverse between 1990 and 2008, its share of minority racial groups is still less than the countywide average in all categories. For example, 26 percent of Santa Clara County's population is Hispanic while only 5.9 percent of the City's population identified themselves as Hispanic in 2008; however, Palo Alto’s Asian population is increasing towards the countywide average of 30 percent for that group. The following figure graphically illustrates the City's ethnic/racial proportions in comparison to Santa Clara County with statistics from the 2006-2008 ACS three-year estimates. Population Trends in Palo Alto 7,408 8,74 7 9,140 9,654 10300 2764 2970 3893 38282,168 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000 1980 199 0 2000 200 7 2008 Senior (65 and Over)Pre-School (Under 5) Chapter 2 9 Figure 2-2 Racial Characteristics of Population in Palo Alto and Santa Clara County, 2008 Source: ACS 2006-2008 three-year estimates. 2.2 EMPLOYMENT CHARACTERISTICS AND TRENDS Employment Trends To assess employment trends and analyze recent changes in the jobs and housing market, this document relies on the same employment and job estimates that are being used to update the City of Palo Alto’s Comprehensive Plan. These data are considered to be more current and accurate than Census 2000 data. Applied Development Economics (ADE), the City’s Economic Consultant for the Comprehensive Plan update, estimated the 2008 baseline numbers and the projection values for population and employment growth. Applied Development Economics used Association of Bay Area Governments (ABAG) 2007 Projections data as a starting point for their analysis but modified the data based on the land use categories used to update the City’s Comprehensive Plan. ADE estimates the current 2008 employment total to be 76,684 jobs, and projected it to reach 76,774 jobs in 2010. Using the same growth assumptions, total employment growth between 2008 and 2020 within the City is estimated to increase by 5,411 jobs. The Stanford University Hospital expansion projects are anticipated to create 3,076 permanent jobs and other known non-residential projects are anticipated to create the remainder of the jobs. Because the 2020 projected total employment of 82,095 is lower than the year 2000 peak of 86,960, it is assumed that much of this additional employment would be absorbed in existing building space. In 2008, about 36 percent of the total jobs were in the Health, Educational and Recreational sector and 27 percent in the Financial and Professional Services sector. The Manufacturing, Wholesale and Transportation sector is estimated to continue to have slightly 65% 2% 6% 25% 3% 38% 2% 26% 30% 3% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% City of Palo Alto Santa Clara County White Black Hispanic Asian Others Chapter 2 10 less than 20 percent of the jobs through 2020. The Retail and Other Services sector accounts for 8 percent of the total jobs in 2008 and is expected to increase marginally after the completion of the Stanford projects. Table 2-4 Employment Projections by Industry for Palo Alto, 2008-2020 Local Employment Growth Palo Alto is one of the main economic drivers of Silicon Valley, home to more than 6,000 businesses employing more than 76,600 people. Stanford Research Park on Page Mill Road is a major research and office area while Sand Hill Road is a hub for many venture capitalists. Many renowned companies and research facilities have their headquarters in Palo Alto including: Amazon.com's A9.com, VmWare, Genencor, Hewlett-Packard, SAP, Space Systems/Loral, Wilson Sonsini Goodrich & Rosati and Tesla Motors. Stanford Hospitals and Clinics and Stanford Shopping Center continue to be the largest employers in the City, employing close to 10,000 people. The three major hospital groups employ most of the employees in the Health, Educational sector: Palo Alto Medical Foundation, Veterans Health Administration Hospital and Stanford Hospitals Group. Chapter 2 11 Table 2-5 Major Employers in Palo Alto, 2008 The most commonly listed occupations of Palo Alto residents are software engineers and developers (mid level to senior level), upper management level jobs of Silicon Valley companies, product managers, attorneys, physicians, registered nurses and physical therapists and educators. Computer and computer support systems related jobs provide an hourly rate of $45-$55 and above. Medical and health technicians, therapist and other health service related professionals earn from $30-$45 per hour. Upper management of various companies, attorneys and physicians are the highest paid section of the population. A typical hourly and mean wage list of different occupations of Palo Alto is shown below. The median household income of the City of Palo Alto is $126,741 based on 2006-2008 ACS Data. Stanford Hospital and Clinics /Lucile Packard Children's Hospital/ Stanford Univ. School of Medicine/ Stanford Shopping Center 9943 Hewlett-Packard Company 7500 Veterans Health Administration 3500 VMware 2500 Palo Alto Medical Foundation 2000 Varian Medical Systems Inc 1710 Space Systems Loral 1700 Communication and Power Industry 1610 Wilson Sonsini Goodrich & Rosati 1100 City of Palo Alto 1076 Source: Reference USA Data 2008, Stanford University Expansion EIR and Local newspaper Employers Approximate Number of Employees Chapter 2 12 Table 2-6 Typical Hourly and Mean Wages of Some of the Jobs of Palo Alto Residents, 2008 Table 2-7 Commute Patterns of Palo Alto Residents, 2008 Estimated Travel Time to Work Number of Commuters 2007 Number of Commuters 2008 0-14 Minutes 9,758 9,363 15-29 Minutes 12,566 12,087 30-44 Minutes 3,342 3,710 45+ Minutes 2,425 2,453 Worked at Home 2,439 2,351 Source: 2005-2009 ACS and 2006-2008 ACS three-year estimates. Occupational Title Mean Hourly Wage Mean Annual Wage Management Occupations $69.42 $144,407 Business and Financial Operations Occupations $41.48 $86,285 Computer Software Engineers, Hardware Engineers Applications and Mathematical Occupations $51.55-$55.90 $110,110 Architecture and Engineering Occupations $48.17 $100,189 Life, Physical, and Social Science Occupations $43.80 $91,099 Community and Social Services Occupations $25.60 $53,251 Legal Occupations $69.89 $145,365 Education, Training, and Library Occupations $28.57 $59,423 Arts, Design, Entertainment, Sports, and Media Occupations $32.72 $68,054 Healthcare Practitioners and Technical Occupations $49.01 $101,949 Retail Sales and Related Occupations $10.66 $50,696 Source: California Employment Development, Occupational Employment statistics. 2007 and 2008 first quarter data. Chapter 2 13 The table above shows the commute travel time to work for Palo Alto residents 16 years of age and above, who work away from home. About 40 percent of the total employed residents of Palo Alto (12,087 people) commute between 15-29 minutes to go to work, while only 8 percent commute for more than 45 minutes. About 8 percent of employed residents in the City work from home. Jobs-Housing Balance These employment trends indicate that Palo Alto will continue in the future to maintain a jobs/housing imbalance heavily skewed to the jobs side of the ratio. Palo Alto currently houses only about 4 percent of Santa Clara County’s population but contains approximately 9 percent to 10 percent of all the County’s jobs. Palo Alto is expected to have a job/housing ratio of 2.4 jobs for every employed resident by the year 2020. This means that Palo Alto will continue to import most of its workers to meet the needs of business and industry resulting in a large unmet need for worker housing in the City. Since many of Palo Alto’s workers cannot afford to live in the City, the imbalance creates negative impacts such as long commutes for workers both inside and outside the region, substantially increased traffic congestion during peak commute periods, and increased air pollution and energy consumption. The production of additional affordable housing would help to reduce or even avoiding these impacts. Over the years, the City has attempted to address its jobs/housing imbalance. In 2007, the City updated its Zoning Code, incorporating changes recommended by the 2002 Housing Element to encourage housing production. The updated code encourages mixed-use development which would include retail and service uses with residential developments. This enables a good mix of land uses conducive to improving the jobs and housing imbalance. The changes in the code introduced the concept of Pedestrian Transit Oriented Development zoning (PTOD) that allows higher density residential dwellings on commercial, industrial and multifamily parcels within a walkable distance of transit stations, while protecting low density residential parcels and parcels located in or adjacent to the areas. Housing developments in a PTOD district will encourage the following:  Use of public transportation;  A variety of housing types, commercial retail and limited office uses;  Project design that achieves an overall context-based development for the PTOD overlay area;  Streetscape design elements that are attractive to pedestrians and bicyclists; and  Connectivity to surrounding existing and planned pedestrian and bicycle facilities. 2.3 HOUSEHOLD CHARACTERISTICS AND TRENDS For purposes of evaluating housing supply and demand, it is useful to translate information from population figures to household data. The change in the number of households in a city is one of the prime determinants of the demand for housing. Households can form even in periods of static population growth as adult children leave home, through divorce, and with the aging of the population. According to the 2006-2008 American Community Survey (ACS) three-year estimate there were 63,370 persons living in Palo Alto. Of this total, 410 were living in group quarters and the remaining 62,960 persons were living in households. There were a total of 25,528 households in the City in 2008. Chapter 2 14 Figure 2-3 Total Household Growth in Palo Alto, 1980-2008 Source:US Census 1980, 1990 and 2000, the 2005-2007 ACS and 2006-2008 ACS three-year estimates. Household Type and Size Household size and type of household (Family and Non-Family Households) are important considerations when addressing housing issues. A family household is one in which a householder lives with one or more persons related to him or her by birth, marriage or adoption. A non-family household is one in which a householder lives alone or only with non-relatives. In evaluating these data from a historical perspective, the percentage of people living in family households increased by 11 percent from 1980 to 2008 with 15 percent increase in total population, whereas the number of non-family households has declined since 1990. Currently family households account for 61 percent of total households in Palo Alto. Family households are typically larger than non-family households because family households consist of a minimum of two persons while non-family households can be single person households. In Palo Alto there are more persons living in family than non-family households. Of the total 63,752 persons in Palo Alto in 2008, approximately 78.7 percent were living in family households (49,902 persons) and 20.6 percent (13,058 persons) in non-family households. The remaining 0.65 percent of the population (410 persons) was living in-group quarter facilities. Household Growth Since 1980 22,000 22,500 23,000 23,500 24,000 24,500 25,000 25,500 26,000 1980 1990 2000 2007 2008 Year To t a l H o u s e h o l d s Chapter 2 15 Table 2-8 Type of Household Growth in Palo Alto, 1980-2008 Between 1990 and 2000, there was also a reversal in the trend toward fewer households with children under the age of 18 years at home. In 2008, approximately 15,670 children under the age of 18 years lived in married family households, and 2,360 children under the age of 18 lived in other family households. Although the number of children in other family households is less than married family household, their number is increasing gradually. In 1990, 7 percent of the family households were single parent households (primarily female-headed) with children under the age of 18 years at home. By 2000, the percentage increased to 12 percent. In 2008 female-headed households with children under 18 years is 10 percent of family households. This significant change in male or female-headed household numbers will affect the demand for housing based on type and affordability for future housing in Palo Alto. The number of people occupying a housing unit and the type of occupants affects the size and condition of the unit, as well as the demand for additional units in the housing market. For example, a continued decrease in household size with an increase in population would indicate a demand for additional smaller housing units to accommodate the decreased household sizes. On the other hand, dramatic increases in household size could indicate a number of situations such as "unrelated" members of households living together or an increase in the number of households with children, indicating the need for larger housing units. The 2000 household size in Palo Alto was 2.3 persons per household, which was a slight increase from the 1990 household size of 2.2 persons per household. In 2008, the average household size reached 2.47. Year Family Household Percentage of Total Household Non-Family Household Percentage of Total Household 1980 13,594 58.84% 9,508 41.16% 1990 13,835 56.01% 10,865 43.99% 2000 14,593 57.87% 10,623 42.13% 2007 16,006 62.80% 9,480 37.20% 2008 15,673 61.40% 9,855 38.60% Source:US Census 1970, 1980, 1990, 2000, the 2005-2007 and 2006-2008 ACS three-year estimates. Chapter 2 16 Table 2-9 Average Household Size in Palo Alto, 1970-2008 The increase in persons per household indicates that the population of Palo Alto has increased at a faster pace than the household formation between 1970 and 2008. Increases in the number of children and households with extended families contributed to the increase in average household size in Palo Alto. This also could indicate that extended families are sharing housing due to the high housing costs of the region , which could lead to overcrowding situations in the future. Households by Tenure Tenure and the ratio of homeowner to renter households are typically influenced by many factors, such as: housing cost (interest rates, economics, land supply, and development constraints), housing type, housing availability, and job availability. About 57 percent of the households in Palo Alto owned their homes in 2000 and 43 percent were renters. The number of renters in Palo Alto fell by 4 percent in 2008 and the ownership rate also increased by 4 percent. This reflects the steady demand for housing in Palo Alto with only 8 percent increase in population since 2000. Table 2-10 Tenure of Occupied Housing in Palo Alto Residents, 2000-2008 Year Household Size (Persons per Household) 1970 2.70 1980 2.30 1990 2.20 2000 2.30 2007 2.48 2008 2.47 Source:US Census 1970, 1980, 1990, 2000, the 2005- 2007 and 2006-2008 ACS three-year estimates. Tenure Type Number Percent Number Percent Number Percent Owner 14,420 57% 15,326 60% 15,485 61% Renter 10,796 43% 10,160 40% 10,043 39% TOTAL 25,216 100% 25,486 100% 25,528 100% 2008 Source:US Census 2000, the 2005-2007 ACS and 2006-2008 ACSdata. 2000 2007 Chapter 2 17 Table 2-11 Tenure by Household Size in Palo Alto, 2008 An overwhelming 93.7 percent of owners and renters live in one- to four-person households in Palo Alto. Only 6.3 percent of both renters and owners live in larger households. This reflects the average size of the housing stock of Palo Alto, which is mainly two- to four-bedroom homes. The average household size for owner occupied housing units in Palo Alto according to ACS 2006-2008 data is 2.71 and for renter-occupied housing units is 2.10. An assumption can be made from this data that rental housing units are smaller in size than ownership units. Household Income Palo Alto households have significantly higher incomes than households in the County as a whole. The 1990 Census data indicated that the median family household income in Palo Alto was $68,737 or 28 percent higher than the median family household income of $53,670 for the County of Santa Clara for the same period. The 2000 Census data showed a slight reduction in the difference to a little over 21 percent between the median family household income for Santa Clara County of $74,335, and the City of Palo Alto’s median family household income of $90,377. However, income estimates from the 2006-2008 ACS Survey data indicate that difference between households in Palo Alto and the County has increased significantly to about 45 percent with the median household income (inflation adjusted dollar amount) for Palo Alto growing to $126,741 compared with $87,287 for Santa Clara County. According to the 2000 Census, while there were many high-income households in Palo Alto, there were also households on more limited incomes. An interesting statistic from the 2000 Census data revealed that 14 percent of all Palo Alto households reported that their annual household income was less than $25,000. This percentage was similar to the countywide average of 13 percent of all Santa Clara County households reporting incomes of $25,000 or less. According to 2006-2008 ACS data, the number of households earning less than $25,000 decreased to 11 percent in Palo Alto while the share of the County remained the same. In other words, Palo Alto has reduced its proportion of households with limited incomes compared to the County through 2008. However, Palo Alto also has more than twice as many households whose incomes are over $200,000 in 2008 than the rest of the County. It should be noted, however, that a $25,000 annual income is not an accurate reflection of the number of lower or “limited” income households in Palo Alto. The federal Department of Housing and Urban Development (HUD) considers a family of four earning $53,050 or less and a single person earning $31,850 or less to be very low-income households. The definition of income level varies depending on the government entity or the program. For housing purposes, the jurisdictions in Santa Clara County, including Palo Alto, use HUD’s Total Number Percent Number Percent Number Owner 14,358 60.01% 1,127 70.39%15,485 Renter 9,569 39.99% 474 29.61%10,043 TOTAL 25,528 23,927 93.73% 1,601 6.27%25,528 5+ PersonsHousehold Tenure 1-4 persons Source:The 2006-2008 ACS. Chapter 2 18 determination of County median income ($105,500 for a family of four in 2008) and its definition of household income levels described below: Extremely Low Income: Households with incomes between 0-30 percent of County median family income: 2008 limit for a family of 4: $31,850 Very Low-income: Households with incomes between 31-50 percent of County median family income: 2008 limit for a family of 4: $53,050 Low-income: Households with incomes between 51-80 percent of County median family income: 2008 limit for a family of 4: $84,900 Table 2-12 HUD Annual Household Income Limits, 2008 Santa Clara County Using 2008 ACS Survey data with 2008 inflation rates adjusted, there were 5,289 households earning less than $50,000 (approximately 21 percent of Palo Alto households) with an additional 21 percent of households earning between $50,000-$100,000. The following table shows the median household income by age of householders. Persons in Household Extremely Low (30% of Median Income) Very Low- income Maximum (50% of Median Income) Low-income Maximum (80% of Median Income) 1 $22,330 $37,150 $59,400 2 $25,500 $42,450 $67,900 3 $28,650 $47,750 $76,400 4 $31,850 $53,050 $84,900 5 $34,400 $57,300 $91,650 6 $36,950 $61,550 $98,450 Source:HUD published Area Median Income (AMI). Note: 2008 Santa Clara County area median income for a family of four is $105,500 Chapter 2 19 Table 2-13 Household Income Distribution by Age for Santa Clara County and Palo Alto, 2008 Overpaying and Overcrowded Households Overpaying Housing is generally the greatest single expense item for California families. Current standards measure housing cost in relation to gross household income: households spending more than 30 percent of their income, including utilities, are generally considered to be overpaying or cost burdened. Severe overpaying occurs when households pay 50 percent or more of their gross income for housing. . In a 2006 study done by the National Low Income Housing Coalition, low-income households in California can only afford monthly rents of up to $827, while the fair market rent for a two bedroom unit was $1,189. Low-income households who are overpaying for housing frequently have insufficient resources for other critical essentials including food and medicine. This is a significant hardship for too many workers, families and seniors, but it also impacts local economies as money that might otherwise be spent in local stores generating sales tax revenues are being spent on housing. The impact of high housing costs falls disproportionately on extremely low, very low-income and low-income households, especially renters. While some higher-income households may choose to spend greater portions of their income for housing, the cost burden for lower-income households reflect choices limited by a lack of a sufficient supply of housing affordable to these households. Though Palo Alto had a median household income of $126,741 (in 2008 inflation- adjusted dollars), for owner-occupied households, the median income was $157,421. For renter-occupied households, the median income was substantially lower, about $80,708. During the same time, for owner-occupied households the median income for Santa Clara County was $111,040, and for renter-occupied households, median income was $58,472. The following tables show affordability of rental and ownership housing costs by income. The affordability calculations were based on the 2009 HUD Area Median Income for a family of four. The amount indicates the maximum families could afford to pay for housing to have sufficient resources for other critical essentials. Age Distribution Santa Clara County Palo Alto Total Median Household Income 87,287 126,741 Householder under 25 years: 37,889 37,798 Householder 25 to 44 years: 98,119 156,736 Householder 45 to 64 years: 100,010 152,664 Householder 65 years and over:48,867 67,455 Source:The 2006-2008 ACS three-year estimates. Chapter 2 20 Table 2-14 Affordability of Rental Housing Cost by Area Median Income, 2009 Table 2-15 Affordability of Ownership Housing Cost by Area Median Income, 2009 ACS 2006-2008 data indicates that over 35 percent of all renter households in Palo Alto were “cost burdened” or overpaid for housing in 2008 (i.e., paid more than 30 percent of household income for rent). This figure has increased from 2000 Census data where about 30 percent renters paid more than 30 percent of their income for housing. As shown on the chart below, renters were more likely to overpay for housing than homeowners. Income Group Median Income Maximum Housing Cost (30% of Income) Extremely Low (30% of Median Income) $31,850 $620 Very Low-income Maximum (31%- 50% of Median Income) $53,050 $1,150 Low-income Maximum (51%- 80% of Median $84,900 $1,947 Source: City of Palo Alto Consolidated Plan 2010. Affordablity calculations based on 2009 HUD Area Median Income for family of four. Income Group Median Income Maximum Affordable Home Price Percent of Single Family Homes in North Santa Clara County within the Price Range Extremely Low (0- 30% MFI)$31,850 $132,600 1.4 Very Low (31-50% MFI)$53,050 $220,900 1.8 Low (51-80% MFI) $84,900 $353,500 5.0 Source: City of Palo Alto Consolidated Plan 2010. Affordablity calculations based on 2009 HUD Area Median Income for family of four. Chapter 2 21 Table 2-16 Palo Alto Households Paying More Than 30 percent of Household Income for Housing, 2008 Historically a large proportion of the City’s low and moderate-income households of all types overpaid for housing, particularly very-low and low-income renter households. In 2008, the Median Family Income was $105,50, but still 30 percent of all households severely overpaid for their housing (more than 30 percent of their income). The following ACS 2006-2008 data reveals 27 percent of the owners and 35 percent of the renters paid more than 30 percent of their income for housing. This group of households is least able to devote 30 percent or more of their income to housing without significantly affecting other aspects of family health and quality of life. Further, since lower income rental households are more likely to pay much higher rents proportionally than other households, the City has focused most of its affordable housing efforts towards increasing the supply of affordable rental housing. Table 2-17 Palo Alto Housing Cost as Percentage of Household Income, 2008 Renters Owners All Households Number Overpaying % of Renter Households Number Overpaying % of Owner Households Number Overpaying % of All Households 3,532 35.17% 4,211 27.19% 7,743 30.33% Source:The 2006-2008 ACS three-year estimates. Income Range Total Households % of Total Households 0-20% of HH Income 20-29% of HH Income 30+% of HH Income 0 84 0.33% - - 0 $1-19,999 707 2.77%65 117 525 $20,000-34,999 868 3.40%355 119 394 $35,000-49,999 507 1.99%190 104 213 $50,000 +13,319 52.17%7,093 3,147 3,079 Subtotal 15,485 60.66%7,703 3,487 4,211 Income Range Total Households % of Total Households 0-20% of HH Income 20-29% of HH Income 30+% of HH Income 0 32 0.13% $1-19,999 1,334 5.23%85 241 1,008 $20,000-34,999 733 2.87%71 0 662 $35,000-49,999 853 3.34%42 157 654 $50,000 +6,877 26.94%3,324 2,345 1,208 No Cash/No Rent 214 0.84% Subtotal 10043 39%3,522 2,743 3,532 TOTAL 25,528 100%11,225 6,230 7,743 Source:The 2006-2008 ACS three-year estimates. Note: Some households are not accounted for; therefore, figures may slightly differ for other U.S. Census estimates for Total Households. OWNER-OCCUPIED UNITS: RENTER-OCCUPIED UNITS: Chapter 2 22 Overcrowding The Census defines an overcrowded unit as one occupied by 1.01 persons or more per room (excluding bathrooms and kitchens). Units with more than 1.5 persons per room are considered severely overcrowded. On a statewide basis, in 1989 an estimated 7 percent of all California households lived in overcrowded housing. (Source: California Statewide Housing Plan Update, 1990, State of California Dept. of Housing and Community Development). The Census 2000 Data indicated that approximately 15 percent of all California households lived in overcrowded housing. Overcrowding increases health and safety concerns and stresses the condition of the housing stock and infrastructure. Overcrowding is strongly related to household size, particularly for large households and especially very large households and the availability of suitably sized housing. Overcrowding impacts both owners and renters; however, renters are generally more significantly impacted. In 2000, renter households were three times more likely to be overcrowded than owner households, regardless of household size. Overcrowding levels generally declined as renter incomes rose, particularly among family renters. According to the 2000 Census, the rate of overcrowding for very-low-income households (50 percent of median income) was nearly three times greater than for households with incomes over 95 percent of median for the state of California. High overcrowding levels were geographically dispersed, including both metropolitan and non-metropolitan areas. More than four-fifths of extremely low- income residents of 17 counties lived in overcrowded conditions in 1990, including such wealthy counties as Santa Clara, San Mateo, and Orange. Overcrowding is particularly exacerbated where there is a mismatch between the number of large family households, defined as households of five or more persons, and the number of available family-sized housing units. According to the 1990 U.S. Census, approximately 655 units or 2.7 percent of Palo Alto’s total occupied housing units were overcrowded with more than one person per room. The 2000 U.S. Census indicates that approximately 4 percent or 1,057 of the City's total occupied housing units were overcrowded with more than one person per room. Of these 1,057 units, 516 were "severely overcrowded" with more than 1.51 persons per room. The majority (425 units) of these severely overcrowded units were occupied by renters. In fact, renter households are more likely to have a higher incidence of overcrowding than owner households. Approximately 76 percent of the total 1,057 overcrowded units are occupied by renter households. As related to the age of the residential structure, overcrowded households are found in both older as well as newer housing units in the City. While 89 percent of the overcrowded households live in units that were built since 1940, this proportion reflects the fact that 84 percent of the units in the City were built since 1940. Therefore, the age of the housing units is not statistically significant in regard to overcrowded households in Palo Alto. Overcrowding is not as serious a housing problem in Palo Alto as it is in Santa Clara County as a whole or as it is in nearby cities such as Mountain View and San Jose. For comparison, approximately 23 percent of all rental units in Santa Clara County (52,993 overcrowded rental units out of 227,227 rental units), 17 percent of all rental units in Mountain View (3,039 overcrowded rental units out of 18,250 rental units), and 29 percent (30,939 overcrowded rental units out of 105,592 rental units) of all rental units in San Jose are considered overcrowded by 2000 Census. Chapter 2 23 Table 2-18 Average Household Size of Occupied Units in Palo Alto, 2008 Households do not typically choose to be overcrowded but end up in that situation because they cannot afford a housing unit that is of size appropriate to their needs. Traditionally, large households have difficulty securing and/or affording housing units of three or more bedrooms partially because of an insufficient supply of these larger units. Large renter families, in particular, have difficulty in finding rental housing stock that is appropriate for their household size and also affordable. The 2000 Census data indicated that there were 1,576 households in Palo Alto that had 5 or more persons. That number went up to 1,601 in 2008 by the estimates of ACS Data. Approximately 4 percent of the owner-occupied units housed more than 5 person households (1,127 households) and another 2 percent of renter-occupied households housed more than 5 person households. Moreover, even small households in Palo Alto have difficulty in finding appropriate size rental housing due to the high cost of housing. Census data confirms that a combination of factors including increase in household size, increase in the number of households with children, and substantial increase in housing costs in the 1990s and 2000’s may have led to increased overcrowding. Table 2-19 Household Size by Tenure in Palo Alto, 2008 The 2006-2008 ACS data indicate that there were 431 occupied rental units that had 3+ or more bedrooms in the City of Palo Alto. These 431 units represent 4 percent of all rental units in the City. The number of 3+ bedroom rental units decreased from 7 percent to 4 percent from 2000 to 2008. Although the percentage of Palo Alto households living in overcrowded conditions is relatively small, this indicates that there is still a need for larger rental units. The same data source reported that there were 1,601 large households (households of five or more persons) and that 474 of these households were renter households. Therefore, the raw statistics would indicate that there appear to be sufficient existing units that are appropriate in size for large households. However the cost to rent these units may be prohibitive for some households. In 1990, 78 percent of these 3+ bedroom rental units had monthly gross rents in excess of $1,800 per month. In March 2001, the average rent for a three-bedroom apartment increased to $2,992 per month (Source: REAL FACTS). By 2008, the median rental price for a Average Household Size California Santa Clara County Palo Alto Total: 2.92 2.91 2.47 Owner occupied 3.01 3.01 2.71 Renter occupied 2.8 2.74 2.1 Source: U.S. Census Bureau, 2006-2008 American Community Survey Number Percent Number Percent Number Percent Owner 14,358 56% 1,127 4%15,485 61% Renter 9,569 37% 474 2%10,043 39% TOTAL 23,927 94% 1,601 6% 25,528 100% 1-4 persons 5+ Persons Total TOTAL HOUSEHOLDS 25,486 Source: U.S. Census Bureau, 2006-2008 American Community Survey Chapter 2 24 Efficiency 1 BR 2 BR 3 BR 4 BR Single Room Occupancy (SRO) Mobile Home Space Rents $928 $1,076 $1,293 $1,859 $2,047 $696 $575 Fair Market Rents, 2008 Fair Market Rents (FMR) are established by HUD and are used by Housing Agencies to establish the Voucher Payment Standards used in the Section 8 Housing Choice Voucher Program. The Fair Market Rents are also used as the maximum allowable gross rents, including utility allowances, for certain special programs, like the Project-Based Voucher Program. Unit condition and location are a consideration in determining rent reasonableness. These FMRs apply to the following cities: Campbell, Cupertino, Gilroy, Los Altos, Los Altos Hills, Los Gatos, Milpitas, Monte Sereno, Morgan Hill, Mountain View, Palo Alto, San Jose, San Martin, Santa Clara, Saratoga, and Sunnyvale. http://www.huduser.org/portal/datasets/fmr/fmrs/2008summary.odn 3 bedroom residence was approximately $3,500. In contrast, the 2008 Fair Market Rent (FMR) for a three-bedroom house, as determined by HUD is $1,859. This is significant considering FMR’s are established by HUD to determine the payment standards for its Section 8 Payment Voucher program. The program will not pay more than the established FMR. This situation makes it extremely difficult for lower income families to find adequate housing. Table 2-20 HUD Established Fair Market Rents, 2008 The most obvious need for over crowded households in Palo Alto is large housing units that are adequately sized for large families. Typically there is a need for three, four and five-bedroom housing units for households that are overcrowded due to family size. Developers in the City of Palo Alto, in the past decade, have typically built three and four bedroom units, though these units are usually expensive to rent or buy. Small households in Palo Alto are sometimes also overcrowded because of the high cost of housing. Affordable housing, primarily affordable rental housing, can help further reduce overcrowded households. The City of Palo Alto, however, experiences a relatively small percent of overcrowding compared to the County, Statewide and in nearby cities. There are units in some of the assisted housing developments in the City that are both larger size and affordable. As an example, the Arastradero Park development includes fourteen three-bedroom units and four four-bedroom units. However, given the rapid rise in the rents of large apartments, more family sized apartments are needed to help keep rental costs down as well as reduce overcrowding. Additionally, affordable housing developers Eden Housing and Community Working Group are constructing a 50 unit affordable family housing development at 801 Alma Street. Table 2-21 Overcrowded Households in Palo Alto, 2008 Persons per Room Households Percent Households Percent Households Percent 1.00 or less 15,369 99.25% 9,539 94.98% 1.01 to 1.50 116 0.75% 379 3.77% 495 1.94% 1.51 or more 0 0.00% 125 1.24% 125 0.49% TOTAL 25,528 15,485 100.00% 10,043 100.00% 620 2.43% Source:The 2006-2008 ACS three-year estimates. Owner Renter Total Overcrowded Chapter 2 25 2.4 SPECIAL NEEDS GROUPS There are certain specific demographic or occupational groups that have special needs which require specific program responses. They include Disabled Households, Senior Households, Female Headed Households, Single Parent Households, Large Family Households, Overcrowded Households, Farm Worker households and Homeless Households. State law identifies these groups as Special Needs households. Thorough analyses of these special needs helps a locality identify groups with the most serious housing needs in order to develop and prioritize responsive programs. In Palo Alto, all of the above mentioned special needs households groups exist, except for farm worker households. Information about each of these households is described in more detail in the paragraphs that follow. A general description of each of these household types is provided as well as a summary of the current resources available and a summary of their more significant housing needs. Senior Households Seniors are defined as persons age 65 and over. Seniors are considered a special needs group, as they tend to have more health problems than the population at large. These health problems may make it more difficult for seniors to live in typical housing and to live independently. Seniors with serious health problems may need to live in licensed community care facilities or similar facilities. Also, low and moderate-income senior households are potentially in particular need for housing assistance. Many seniors live on fixed incomes such as Social Security and pensions. Increases in living expenses would make it more difficult for seniors to afford needed housing. Financially strained senior homeowners may have to defer their home maintenance needs. The number of elderly persons in the City of Palo Alto has increased over the last three decades. In 1970, elderly (persons age 65 years and older) comprised 10 percent of the population but, by 2000, that percentage had increased to 15.6 percent of the total population. The total number of elderly persons residing in Palo Alto in 2008 was 10,300, approximately 16 percent of the total population. Between 1980 through 2008, Palo Alto's senior population increased nearly 39 percent. With longer life spans and age expectancies, it is anticipated that the proportion of elderly in Palo Alto's population will continue to increase in future years, particularly given the substantial increase in the City’s middle age population over the last decade. Table 2-22 Senior Population Increase in Palo Alto, 1980- 2008 In 2000, approximately 96 percent of the people 65 years or older in Palo Alto lived in household situations and the remaining 4 percent were living in group quarters or were institutionalized. There were 6,349 households in Palo Alto that contained individuals 65 years or older. These households represented 25.5 percent of all Palo Alto households in 2000. Approximately 36 Age Group 1980 Senior Population 1990 Senior Population 2000 Senior Population 2007 Senior Population 2008 Senior Population Total Population 55,225 55,900 58,598 63,752 63,370 4,772 8.14% Senior (65 and Over) 7,408 8,747 9,140 9,654 10,300 1,160 12.69% Source:US Census 1980, 1990 and 2000, the 2005-2007 ACS and 2006-2008 ACS three-year estimates. Percentage Change (2000-2008) Chapter 2 26 percent of persons 65 years old or older were in non-family households, and 64 percent were in family households. In 2000, approximately 65 percent of all elderly non-family households were single females living alone representing approximately 22 percent of all elderly Palo Alto residents. There were 2,591 65-year old householders living alone in 1990. This number increased to 2,736 in 2000, an increase of 5.6 percent. Approximately 5 percent of all elderly (450 persons total) had incomes below the poverty level in 1999. The majority of those persons (254) were over the age of 75 years old. While the percentage of elderly persons living below the poverty level is low, the fact that many elderly households in Palo Alto live on limited incomes is of concern. The 2000 Census data indicate that approximately 54 percent of all elderly households had incomes that were at the low- or very low-income level according to HUD’s income standards. There were approximately 2,382 elderly households with incomes that could be classified as very low-income and another 841 households that were classified as low-income. In 2008, approximately 38 percent of senior households had incomes lower than $50,000 per year while 26 percent had annual incomes between $50,000 and $100,000. The median household income for seniors living in Palo Alto is, however, substantially higher than the median for seniors in Santa Clara County as a whole. Table 2-23 Senior Household Income Distribution for Santa Clara County and Palo Alto, 2008 The majority of Palo Alto elderly households are homeowners. In 2000, approximately 70 percent of all elderly households lived in owner-occupied housing units. 16 percent of elderly households living in owner occupied housing units were paying more than 30 percent of their income for housing. The remaining 30 percent of all elderly households were renters and approximately 65 percent of these renters were paying more than 30 percent of their income for housing in 2000. In 2008, the majority of the elderly (about 4,770) were homeowners and 18 percent of Palo Alto’s senior populations were renters. Housing problems are more prevalent among elderly renter households than owner households. Approximately 60 percent of elderly renter households experienced housing problems, compared to 31 percent of owner households in the county. The 2000 Census confirmed that the number of elderly renter households overpaying for housing has increased given the increase in both the number of elderly households and the increase in housing costs since 1990. With the continued increase in the number and proportion of senior households in Palo Alto, the need for providing affordable housing for the elderly will gain importance. As reported in the City’s current Consolidated Plan 2010-2015, the need for more affordable senior housing facilities is also illustrated by the long waiting lists at existing subsidized developments. Age Distribution Santa Clara County Palo Alto Householder 65 years and over:$48,867 $67,455 Source:The 2006-2008 ACS three-year estimates. Chapter 2 27 Table 2-24 Senior Households by Tenure in Palo Alto, 2008 There are nine housing projects in Palo Alto that include 681 units that are specifically designed for elderly households. Table 2-25 Independent Living Facilities for Elderly in Palo Alto, 2008 The supportive living facilities for Palo Alto’s elderly include nursing care facilities as well as non-profit and for-profit residential care facilities. Lytton III provides skilled nursing care for approximately 145 elderly persons. Lytton III is part of the Lytton Gardens complex (Lytton I, II, III and IV [Lytton Courtyard]), which is the only development in Palo Alto that provides a full range of living options for lower income elderly ranging from independent living to assisted living to skilled nursing care. The Fabian Way Senior Housing project at 901 San Antonio Road has 56 subsidized units for seniors. Additionally, Taube-Koret Campus for Jewish Life at 899 Charleston Road has 24 Below Market Rate Units currently under construction. Table 2-26 lists the existing residential Development Total Units Senior Units Income Level Served Independent Living (No Meals or Other Services) Palo Alto Gardens 156 units 128 units Very Low-Income only Sheridan Apartments 57 units 57 units Low-Income Terman Apartments 92 units 24 units Very Low-Income only Webster Wood 68 units 4 units Low-Income Arastradero Park 66 units 13 units Low-Income Colorado Park 60 units 8 units Low-Income Independent Living (Some Meals Provided) Stevenson House 128 units 128 units Low-Income Only Lytton I and 11 268 units 268 units Low-Income Only Lytton Courtyard 51 units 51 units Low-Income Only TOTAL 946 units 681 units Source: City of Palo Alto, Consolidated Plan Householder Age Owners Renters Total 65-74 years 2,563 724 3,287 75 plus years 2,207 1,121 3,328 TOTAL SENIOR HOUSEHOLDS 4,770 1,845 6,615 Source: 2006-2008 ACS three-year estimates. Chapter 2 28 care facilities available currently for seniors. Although the City has been active in the creation of additional senior housing facilities, there still is a great need for senior housing. As the senior population continues to increase, coupled with the fact that 38% of Palo Alto seniors earn less than $50,000 annually, the demand will continue to increase. Many of the Housing Element’s programs are focused on this escalating need. Table 2-26 Residential Care Facilities (Assisted Living) for Elderly Population in Palo Alto Name of Facility Persons Served Type of Facility Casa Olga 103 Intermediate Nursing Care Channing House 21 Nursing Facility Channing House 285 Residential Care Facility (Asst. Living) Lytton Gardens Community Care 55 Residential Care Facility (Asst. Living) Lytton Gardens 145 Nursing Facility Webster House 74 Residential Care Facility (Asst. Living) Palo Alto Nursing Center 66 Residential Care Facility (Asst. Living) Palo Alto Commons 150 Residential Care Facility (Asst. Living) Pleasant Manor 6 Residential Care Facility (Asst. Living) Sandy Oak Place 6 Residential Care Facility (Asst. Living) The Birches Residential Care 6 Residential Care Facility (Asst. Living) May Care 6 Residential Care Facility (Asst. Living) Sevely Manor Guest Home 6 Residential Care Facility (Asst. Living) Sweet Little Home 6 Residential Care Facility (Asst. Living) Source: City of Palo Alto, Consolidated Plan Chapter 2 29 Persons with Disabilities Disabled households include households with family members who have physical disabilities, or mental illness or disability. Some individuals have both a physical and mental disability but Census data does not provide that level of specificity. According to the 2006-2008 ACS data, approximately 92.3% and 93% of the household population of Santa Clara County and Palo Alto respectively, do not have disabilities. The City of Palo Alto has 4,400 non-institutionalized disabled civilians. The percentages of disabled population in all age groups in the City and County are comparable, only differing in the 75+ age cohort where City of Palo Alto has more disabled seniors in this age range than the County. Chapter 2 30 Table 2-27 Number of Non-institutionalized Disabled Civilian by Age Group Percentage of Santa Clara County Residents Disabled Palo Alto Percentage of Palo Alto Residents Disabled 100.00%63,349 100% 7.12% 3,834 6.05% 0.03% 0 0.00% 0.01% 0 0.00% 7.08% 3,834 6.05% 17.17% 11,671 18.42% 0.32% 295 0.47% 0.14% 0 0.00% 16.70% 11,376 17.96% 24.17% 11,154 17.61% 0.44% 150 0.24% 0.28% 92 0.15% 23.44% 10,912 17.23% 40.84% 26,340 41.58% 1.66% 661 1.04% 1.16% 426 0.67% 38.02% 25,253 39.86% 5.85% 5,263 8.31% 0.64% 220 0.35% 0.56% 294 0.46% 4.65% 4,749 7.50% 4.85% 5,087 8.03% 0.88% 886 1.40% 1.60% 1,401 2.21% 2.37% 2,800 4.42% Source: 2008-2010 American Community Survey 3-Year Estimates No disability 41,520 With one type of disability 15,466 With two or more types of disability 27,979 No disability 81,589 75 years and over:84,965 With one type of disability 11,158 With two or more types of disability 9,841 No disability 666,571 65 to 74 years:102,588 With one type of disability 29,116 With two or more types of disability 20,266 No disability 411,006 35 to 64 years:715,953 With one type of disability 7,755 With two or more types of disability 4,973 No disability 292,837 18 to 34 years:423,734 With one type of disability 5,687 With two or more types of disability 2,539 No disability 124,147 5 to 17 years:301,063 With either a vision or hearing difficulty but not both 456 With both hearing and vision difficulty 194 Total Household Population 1,753,100 Under 5 years:124,797 Santa Clara County Chapter 2 31 Individuals with physical disabilities are in need of housing units that have been modified to improve accessibility. Examples of modifications that are helpful include widened doorways and hallways, bathroom and kitchen modifications (lowered counter heights, accessible tubs/ showers and toilets, etc.) entry and exit ramps, modified smoke detectors and alarm systems for individuals with visual or hearing impairments, and other improvements. A priority need for households with disabilities is housing near transit and jobs. Persons with physical disabilities may need housing that is connected to the provision of individualized services including training, counseling, information and referral services, and rent subsidy services that allow the physically disabled to live in the community. For individuals with a disability that affects their ability to work or who live on a fixed income, affordable housing is a high priority. Agencies that provide supportive services to the disabled population have been discouraged by the high cost of rental housing in Palo Alto. In fact, the City has continued to provide funding to several agencies to help acquire housing units for the disabled in nearby communities because of the lack of affordable housing units in Palo Alto. Palo Alto has a few subsidized housing units specifically designed for persons with physical disabilities. Implementation of Title 24 of the California Building Code relating to disabled accessibility and the federal Americans with Disabilities Act (ADA) have resulted in an increase in these opportunities. Subsidized projects that have units specifically designed and adapted for persons with physical disabilities include California Park Apartments (1 unit), the Barker Hotel (5 units), and 330 Emerson Street (1 unit). Other projects, such as Lytton Courtyard, include units that can readily be adapted for persons with physical disabilities. The Alma Place Single Room Occupancy facility has 101 units adaptable for the disabled and 6 fully accessible units. Page Mill Court housing for the developmentally disabled has 16 of 24 units fully accessible and the remaining 8 units adaptable. A few older projects have had units adapted within the limitations of their existing construction including Webster Woods, Terman Park and Sheridan Apartments. The first floor of the Oak Courts Apartments is also fully accessible. Units available at the Opportunity Center are also fully ADA accessible. Table 2-28 lists the number of beds in licensed community care facilities in Santa Clara County that are available to serve Palo Alto residents. Developmentally Disabled The Developmentally Disabled are a separate population identified by the State of California, with differing housing needs from others with disabilities. The Lanterman Developmental Disabilities Act ensures that “patterns and conditions of everyday life which are as close as possible to the norms and patterns of the mainstream of society” are available to these individuals. Furthermore, the Olmstead v. L.C and E.W. United States Supreme Court case required an “Integration Mandate” that “States are required to place persons with mental disabilities in community settings rather than institutions…when determined to be appropriate.” Despites these laws, people with developmental disabilities are finding it increasingly difficult to find affordable, accessible, and appropriate housing that is inclusive in the local community. A developmental disability is defined by the State as “a lifelong disability caused by a mental and/or physical impairment manifested prior to the age of 18 and are expected to be lifelong.” The conditions included under this definition include:  Mental Retardation,  Epilepsy,  Autism, and/or Chapter 2 32  Cerebral Palsy, and  “Other Conditions needing services similar to a person with mental retardation.” Source: Background Report, 2008, Developmental Disabilities Board Area 5 The State Department of Developmental Services (DDS) currently provides community based services to approximately 243,000 persons with developmental disabilities and their families through a statewide system of 21 regional centers, four developmental centers, and two community-based facilities. The San Andreas Regional Center is one of 21 regional centers in the State of California that provides point of entry to services for people with developmental disabilities and serves the Santa Clara County area. According to the San Andreas Regional Center, there are 219 persons with developmental disabilities living in Palo Alto in 2012. There is some overlap between the developmentally disabled population and the mentally and physically disabled populations (approximately 10 and 15 percent, respectively). Individuals with developmental disabilities are often independent and can live in their own apartments or homes with little support. Others who have more severe disabilities may require 24 hour assistance in homes that can accommodate their needs as individuals. The housing need for the individuals in Palo Alto with developmental disabilities translates to about 70 units. This number is derived based on the age of the population. As the younger individuals approach adulthood, they will need independent or assisted living; and similarly, as the adults age, they too will need assisted living. There are a number of housing types appropriate for people living with a developmental disability: rent subsidized homes, licensed and unlicensed single-family homes, inclusionary housing, Section 8 vouchers, special programs for home purchase, HUD housing and SB 962 homes. The design of housing-accessibility modifications, the proximity to services and transit, and the availability of group living opportunities represent some of the types of considerations that are important in serving this need group. Incorporating barrier-free design in all new multifamily housing (as required by California and Federal Fair Housing laws) is especially important to provide the widest range of choices for disabled residents. Special consideration should also be given to the affordability of housing, as people with disabilities may be living on a fixed income. The most severely disabled persons may require an institutional environment where medical attention and physical therapy are provided. Because developmentally disabilities exist before adulthood, supportive housing for the developmentally disabled should focus on the transition from the person’s living situation as a child to an appropriate level of independence as an adult. In order to assist in the housing needs for persons with Developmental Disabilities, the City of Palo Alto will implement programs to coordinate housing activities and outreach with the Regional Center and to facilitate additional housing opportunities in Palo Alto for persons with disabilities, especially persons with developmental disabilities. Chapter 2 33 Table 2-28 Licensed Community Care Facilities in Santa Clara County Serving Palo Alto Facilities Beds Facilities Beds Facilities Beds Facilities Beds Facilities Beds Cupertino 10 985 2 12 6 961 2 12 - - Gilroy 29 419 19 127 6 244 4 48 - - Mountain View 20 184 2 18 16 152 2 14 - - Palo Alto 10 1,785 - - 10 1,785 - - - - San Jose 490 4,572 220 1,677 234 2,553 35 336 1 6 Santa Clara 29 285 12 72 15 187 2 26 - - Sunnyvale 50 852 6 60 42 782 1 6 1 4 Urban County - - - Campbell 17 309 2 16 14 284 1 9 - - Los Altos Hills - - - - - - - - - - Los Altos 5 295 - - 5 295 - - - - Los Gatos 10 792 1 6 8 756 1 30 - - Morgan Hill 14 236 5 109 5 103 2 12 2 12 Monte Sereno - - - - - - - - - - Saratoga 5 509 - - 5 509 - - - - Unincorporated County 8 86 4 24 3 56 1 6 - - Urban County Total 59 2,227 12 155 40 2,003 5 57 2 12 Entitlement Jurisdiction 697 11,309 273 2,121 369 8,667 51 499 4 22 Santa Clara County Total 715 11,412 283 2,178 371 8,677 57 535 4 22 Notes: (d) Small Family Homes provide twenty-four hour care in the licensee's family residence for six or fewer children who require special care and supervision due to mental or developmental disabilities or physical handicap Sources California Community Care Licensing Division, 2009, BAE, 2009 Cities (a) Adult Residential Facilities provide 24-hour non-medical care or adults who are unable to provide for their own daily needs (b) Residential Care Facilities for the Elderly provide care, supervision, and assistance with dialy living activities (c ) Group homes provide non-medical care and supervision to children Group Homes (c ) Small Family Home (d)TOTAL Adult Residential (a) Residential Care for the Elderly (b) Chapter 2 34 Large Households Large households are defined as households with five or more members. By this definition, Palo Alto has about 1,601 households with more than five members, approximately 6 percent of total households in 2008. These households are considered to have special needs, due to limited availability of large size affordable units. In Palo Alto, large size units are often very expensive thereby forcing large families to rent small, less expensive units. This often leads to overcrowding to avoid higher housing expenses. In Palo Alto, 70 percent of the large households live in owner occupied units and 30 percent live in rental units. Table 2-29 Larger Households by Tenure in Palo Alto, 2008 Table 2-30 Occupied Housing Stock by Number of Bedrooms in Palo Alto, 2008 Forty-three percent of Palo Alto’s owner-occupied housing stock contain three-bedrooms and approximately 38 percent contain four or more bedrooms. Most of the rental housing, however, contains one or two bedrooms (71 percent) and 11 percent are studio units. Only 18 percent of the rental housing contains three or more bedrooms. Because Palo Alto has a limited supply of larger rental units to accommodate large family households, most large families face an above- average level of difficulty in locating adequately sized, affordable housing. Single Parent and Female Headed Households Over the years, the number of women rearing children alone in America has increased steadily. There were 12 million single mothers in this country in 1993, 86 percent of whom maintained homes for their families. About 8 percent of American households were categorized as female- headed households with children in 2003. In 2006, about 1.5 million single mothers in California Total Number Percent Number Percent Number Owner 14,358 60.01%1,127 70.39%15,485 Renter 9,569 39.99%474 29.61%10,043 TOTAL 25,528 23,927 93.73%1,601 6.27%25,528 5+ PersonsHousehold Tenure 1-4 persons Source:The 2006-2008 ACS. Owner Households Renter Households All Households Number Number Number 0 BR 63 0%1,091 11% 1,154 5% 1 BR 399 3%3,478 35% 3,877 15% 2 BR 2,538 16%3,596 36% 6,134 24% 3 BR 6,585 43%1,447 14% 8,032 31% 4 BR 4,295 28%312 3% 4,607 18% 5+ BR 1,605 10%119 1% 1,724 7% TOTAL 15,485 100% 10,043 100% 25,528 100% Source:The 2006-2008 ACS three-year estimates. Percent Percent PercentBedroom Type Chapter 2 35 were rearing their children by themselves. Single parent households, particularly female-headed households, generally have lower-incomes and higher living expenses. Providing decent, safe and affordable housing is more difficult oftentimes for single mothers because of low incomes and high expenditures. These households also typically have additional special needs relating to access to day care/childcare, health care and other supportive services. Almost 40 percent of female-headed households in the U.S. have incomes below the poverty rate. In the U.S., about one-half of never-married mothers are unemployed. Fifty-five percent of families headed by never-married females receive public assistance as well as 20 percent of families headed by divorced/separated mothers. The 2000 Census reported that there were 1,220 female-headed households in Palo Alto. These households represented 6.7 percent of all households in the City. Lower household income is one of the more significant factors affecting single parent households. For example, married couple families in Palo Alto reported a median family income of $101,537 annually for 1990 census purposes. However, for female-headed households, the annual median household income was $58,625, or 57.7 percent of the median income of a married couple family. Limited household income levels affect the ability of single parent households to locate affordable housing. 2006-2008 ACS data reveal that of the 5 percent of total households living under the poverty level close to 48 percent of them are female-headed households. Table 2-31 Female -Headed Households in Palo Alto, 2008 Single parent household as used in this document is defined as a family household with one or more children under the age of 18 years and headed by either a female or a male head of household with no spouse present. In 2000, single parent households in Palo Alto represented 8.2 percent of all family households, an increase over the 7 percent from 1990. There were 1,201 single parent households in 2000. A male parent headed 293 single parent households and 908 had a female-head of household. In 2007, there were 2,359 single parent families (826 male headed families and 1533 female headed families) residing in Palo Alto, 15 percent of the total family households. Single-family households typically have a higher than average need for day care and affordable housing. Male single parent households have higher annual incomes than female single parent Householder Type Number Percent Total Households 25,528 100% Total Female Headed Householders 6,978 27% Total Households Under Poverty Level 1293 5% Total Female Headed Households Under the Poverty Level 619 2% Total Households Above Poverty Level 24,235 95% Female Headed Households Above the Poverty Level 6,359 25% Source:The 2006-2008 ACS. Chapter 2 36 households in Palo Alto. In 1990, the annual mean household income for female single parents in Palo Alto was $36,651 or slightly over one-third that of a married couple family.; the same trend continued through 2008. Limited household income levels affect the ability of these households to locate affordable housing and, consequently, this is one of the more significant housing problems of this household category. Single mothers have a greater risk of falling into poverty than single fathers due to factors such as the wage gap between men and women, insufficient training and education for higher-wage jobs, and inadequate child support. Households with single mothers also typically have special needs related to access to day care/childcare, health care, and other supportive services. Limited household incomes constrain the ability of single parent households to "afford" housing units. Consequently, these households may have to pay more than they can afford for housing for themselves and their children; or, they may have to rent a housing unit that is too small for their needs because it is the only type of housing they can afford. Other housing related needs that affect single parent households include assistance with security deposits, locating housing that is close to jobs, availability of child care services and proximity to transit services. Clearly the need for more affordable housing for single parent households has grown since the number of these households increased by about 49 percent over the last decade. Without affordable housing and supportive services, many single parent households are at a higher risk of becoming homeless. Single parent families are the fastest growing segment of the homeless population. The City of Palo Alto supports resources that are available to female head-of-households and single parent households. The City’s Community Development Block Grant (CDBG) program has regularly provided funds to InnVision for the operation of the Opportunity Center (located in Palo Alto), including programs for at-risk families. The Opportunity Center serves singles and families with small children by providing a broad range of services, including family housing in the Bredt Family Center. Services include adult education classes and workshops, child development activities, computer/Internet access, health care, case management, and information and referral. Farmworkers State law requires every jurisdiction in California to assess the need for farmworker housing. In Palo Alto’s case, there is no significant need for farmworker housing since there is no significant farmworker or mining population in the City. The 2000 Census data indicate that there are no farmworker households or mining operations in Palo Alto. There are no large agricultural areas in Palo Alto that are devoted to field crops, orchards or other agricultural uses that would require farmworker labor nor are there any active mining uses that would typically require mining labor; however, there may be Agriculture and Mining sector jobs in Palo Alto related to aspects of this sector not associated with field crops or orchard work or extractive mining work. Large open space areas that could accommodate farming or mining are located within the baylands or hillsides of Palo Alto and its Sphere of Influence and are set aside for park use, conservation purposes, or open space preserves. Finally, no housing advocate or low-income housing provider in Palo Alto has indicated there is an unmet need in the City for farmworker or mineworker housing. Since there does not appear to be a significant number of farmworkers in Palo Alto, the City has not identified or set aside any special housing resources for farmworkers. Housing for farmworkers, to the extent that there are any, would be provided through the City’s policies and programs that address the needs of lower income households in general. Chapter 2 37 Homeless Persons Homelessness in California is a continuing crisis that demands the effective involvement of both the public and private sectors. California has the highest population of homeless, 12 percent of the nation’s population. Throughout California, each county is making an effort through various programs to address this issue. Despite major efforts on the part of many agencies and non-profit organizations, homelessness remains a significant problem in Santa Clara County. Thousands of people experience an episode of homelessness here each year, including families with children; adults employed at lower wage jobs; people with disabilities such as severe mental illness, addiction disorders, HIV/AIDS, and/or developmental disabilities; runaway or "throwaway" children; victims of domestic violence; and veterans. Homelessness currently exists in all parts of the County, whether urban, suburban, or rural, but may be especially prevalent where there are pockets of persistent poverty. It is very difficult to develop a precise and realistic description of homeless households in a community. This is primarily due is the lack of good data on the number and type of homeless households. Because many of the communities in Santa Clara and San Mateo Counties share boundaries, the best approach to address the issue of homelessness is on a regional basis, with coordination of efforts between the two counties, the individual communities and the non-profit agencies which serve these communities. There are two data points available for estimating homeless count: yearly estimates based on a HUD-recommended formula that considers population estimates from State of California Department of Finance data, previous years’ Santa Clara County Homeless Census and survey data. The other source is point-in-time or daily counts performed by Santa Clara County Homeless Census and Survey. The 2007, Annual Estimated Homeless count in Santa Clara County indicated that there were 14,921 homeless individuals in the County and by 2009, their number increased to 18,549 individuals. The 2011 Annual Estimated Homeless count for Santa Clara County recorded 18,272 homeless individuals. The decrease in the annual estimate for 2011 was due to a lower percentage of homeless individuals who had become homeless within the 7 days prior to the survey. The point-in-time daily count of January 2009 by Santa Clara County Homeless Census and Survey estimated 7,086 self-declared homeless as per the HUD definition. These people were found either sleeping in a place not fit for human habitation or in emergency or transitional housing for homeless people. The survey found the greatest number of homeless in San José, with approximately 4,300 homeless people counted, or 60 percent of the County’s total homeless population. Gilroy had the second largest count of homeless people among the jurisdictions, with nearly 660 people living without permanent shelter. Palo Alto had 178 homeless individuals. The 2011 Santa Clara County Homeless Census and Survey showed the total number of sheltered and unsheltered homeless count decreased by 15 percent (178 to 151) for the City of Palo Alto compared with a decline of less than 1 percent (7086 to 7045) for the County. Although the total number of unsheltered homeless individuals rose from 2009 to 2011, the number of individuals living in shelters fell by 10 percent for the City. In 2011, none of the homeless individuals counted in Palo Alto lived in families compared with 23 homeless persons living in families in 2009. Chapter 2 38 Table 2-32 Total Number of Sheltered and Unsheltered Homeless Persons, 2009-2011 Santa Clara County Homeless Census and Survey 2009 2011 2009 2011 2009 2011 2009 2011 Santa Clara County 6,078 6,171 1,008 874 2067 0 7,086 7,045 Palo Alto 129 151 23 0 26 0 178 151 Santa Clara County Homeless Census and Survey 2009 2011 2009 2011 2009 2011 2009 2011 Santa Clara County 4,917 5,113 66 56 2067 0 4,983 5,169 Palo Alto 79 106 0 0 26 0 105 106 Santa Clara County Homeless Census and Survey 2009 2011 2009 2011 2009 2011 2009 2011 Santa Clara County 1,161 1,058 942 818 0 0 2,103 1,876 Palo Alto 50 45 23 0 0 0 73 45 * It should be noted that some changes in the shelter count do not represent a loss of inventory in the County or City capacity, but rather a re-classification of the bed “type” that reflects a programming or funding change for the shelter organization. This report does not attempt to analyze all longitudinal changes in homeless bed and family unit inventory nor their potential changing funding sources. All shelter reporting is the result of agency self-reporting, HMIS comparison and follow-up by ASR staff and the Census project committee’s County and jurisdictional representatives. This includes a thorough comparison of the current inventory to previous reports including the annual HUD eSNAPS Housing Inventory Chart required of all Continuums. Unsheltered Homeless Census Population by Jurisdiction and Family Status* Sheltered Homeless Census Population by Jurisdiction and Family Status* Person In Families Total Persons Individuals in Vehicles,Encampment s, Abandoned Buildings, or Parks Individuals in Vehicles,Encampment s, Abandoned Buildings, or ParksIndividuals Person In Families Total Persons Total Unsheltered and Sheltered Homeless Census Population by Jurisdiction and Family Status Individuals Person In Families Total Persons Individuals in Vehicles,Encampment s, Abandoned Buildings, or Parks Source: Applied Survey Research. (2009). 2007, 2009 and 2011 Santa Clara County Homeless Census. Individuals Chapter 2 39 Despite the fact that the number of homeless individuals in Palo Alto has decreased, the very small decline countywide indicates that the demand for services and shelters in Silicon Valley will likely continue. Moreover, for the current Housing Element cycle, the continued high cost of housing in the City, coupled with the current economic downturn and closure of nearby shelters have created unmet need, which the City needs to address. In an effort to meet the City of Palo Alto’s homeless needs, the 2007-2014 Housing Element through policy implementation is proposing to establish permanent emergency shelter space within one year of adoption of the Housing Element (H.3.5.1). The local homeless services providers throughout the County, reporting an increase in clients seeking assistance, have felt the demands from the increased number of unsheltered homeless individuals. The City of Palo Alto participates in the Santa Clara County Collaborative on Housing and Homeless Issues, which represents homeless shelters, service providers, advocates, non-profit housing developers and local jurisdictions. The City and the Collaborative follow a "Continuum of Care" approach in addressing the needs of homeless persons. The continuum consists of the following steps in providing homeless resources:  Prevention Services  Emergency Shelter  Transitional and Permanent Affordable Housing. Listed below is a description of the resources available to Palo Alto households through the City’s association with the County Collaborative on Housing and Homeless Issues. i) Prevention Services: The goal of this first level of resources is to prevent households from becoming homeless. Households who are "at risk" for becoming homeless are those who are lower income and who have a difficult time paying for their existing housing. Traditionally, these include households who "overpay" for housing (paying more than 30 percent of their income for housing) as well as households who experience job termination, salary reduction or marital separations. The prevention resources include the provision of emergency food and clothing funds as well as emergency rent funds and rental move-in assistance. In Palo Alto, the Opportunity Service Center (OSC), operated by InnVision, is the primary provider of services to homeless persons. The OSC coordinates the provision of supportive services, counseling, job labor referral, transportation vouchers, shower passes, mental health services and maintains a message and mails system. From 100 to 120 persons visit the drop-in center on a daily basis. The OSC drop-in center is located near a major inter-County transit terminal; therefore it is reasonable to assume that some of their clients have connections to other communities and do not solely represent Palo Alto households. The OSC also coordinates the provision of groceries for needy individuals through the Food Closet located at All Saints Episcopal Church in downtown Palo Alto. The Food Closet serves an average of 79 persons daily. Inn Vision’s “Breaking Bread” program also coordinates a daily hot meal program at various church locations. The American Red Cross distributes emergency assistance funds to families and individuals who are threatened with homelessness. The Red Cross is the local distributor of County Emergency Assistance Network Funds. Chapter 2 40 Table 2-33 Lists of Organizations Providing Prevention Services for the Homeless in Palo Alto ii) Emergency Shelters: An emergency shelter as defined by HUD is any facility the primary purpose of which is to provide temporary or transitional shelter for the homeless in general or for specific populations of the homeless. One of the major causes of homelessness is the lack of affordable housing. Most homeless households are on limited or fixed incomes and cannot afford a housing unit in the City’s housing market. Emergency homeless shelters in Palo Alto address the immediate shelter needs of homeless persons who reside, or who once resided, in Palo Alto, but the current economic downturn and the historic high cost of real estate in Palo Alto has prevented construction of any new emergency shelter in Palo Alto by any non-profits even with considerable City contribution. As a result, many of Palo Alto’s homeless, families and individuals, have to receive emergency shelter outside of the City limits, in either Santa Clara County or San Mateo County, a factor that most likely contributes to the relatively lower number of homeless counted in Palo Alto compared with surrounding communities. Currently the Opportunity Service Center (OSC), through InnVision, operates the "Hotel de Zink" emergency shelter out of twelve churches, using a different church each month of the year. A maximum of 15 adults each night can be provided with emergency shelter under this program. Meals are also provided as part of their service. Inn Vision Hotel de Zink is Palo Alto's only emergency shelter for homeless individuals and they are planning to open another 15-bed shelter exclusively for women. The nonprofit organization has modeled the new shelter to follow the original 15-bed Hotel de Zink plan, which rotates among Palo Alto faith communities and is open to all genders. Hotel de Zink Women's Shelter will be open between mid-January and mid-April 2012 and will be a pilot program for 2012 with evaluation by Inn Vision staff. To address the need of the homeless in the City, the City of Palo Alto, in conjunction with other CDBG entitlement jurisdictions throughout the Santa Clara and San Mateo Counties has Service Provider Target Population Services Provided Number of Palo Alto Residents Served Opportunity Service Center (OSC)Individuals and Families Supportive services, counseling, job labor referral, transportation vouchers, shower passes, mental health services, maintains a message, and mails system. 100-120 The Food Closet Individuals and Families Food provision 79 Inn Vision’s “Breaking Bread” program Individuals and Families Hot Meals All The American Red Cross Individuals and Families Emergency assistance All Source: City of Palo Alto Prevention Services Chapter 2 41 Service Provider Target Population Services Provided Capacity/Housing Type Number of Palo Alto Residents Served "Hotel de Zink" Individuals Emergency Shelter 15 adults per night 15 individuals "Hotel de Zink" ( New Proposed Women's Shelter opening in 2012) Individuals (Women Only)Emergency Shelter 15 adults per night 15 individuals Emergency Housing Consortium’s Homeless Reception Center (San Jose) Individuals and Families Provides intake and assessment services 185 year round beds Data not recorded Santa Clara County Children’s Shelter (San Jose)Youth Emergency Shelter 90 beds Data not recorded New County Children’s Shelter (San Jose)Youth Emergency Shelter 130 beds Data not recorded Emergency Housing Consortium’s Sobrato Youth Center Youth Emergency Shelter 10 year round beds Data not recorded Bill Wilson Center in Santa Clara. Youth Emergency Shelter 20 year round beds Data not recorded YWCA Silicon Valley Domestic Violence and Support Network at San Jose Individuals and Families Emergency Shelter, legal assistance and counseling services 16-20 year round beds 27 individuals Source: City of Palo Alto Emergency Shelter Services financed the development of different homeless facilities that serve the Palo Alto homeless population. However, individual emergency shelter service providers do not keep track of the origin of the residents so it is difficult to quantify the actual number of Palo Alto homeless residents receiving these services. Thus, the City cannot take credit for these funded services and apply towards its unmet need of 94 beds. The following is a list of past and present City funded emergency shelters benefitting Palo Alto residents. Table 2-34 List of Emergency Shelters in Santa Clara County Serving Palo Alto Residents Within the County of Santa Clara, there are approximately 791 emergency year round shelter beds and 346 seasonal (winter months) beds. None of these facilities are located in the City of Palo Alto. The City of Palo Alto, through its CDBG entitlements, has helped finance the development of the Emergency Housing Consortium’s Homeless Reception Center in San Jose. The Reception Center operates 185 year-round beds (250 beds during the winter months) and provides intake and assessment services to its clients to ensure that they receive the appropriate level of care. The largest shelter for youth in San Jose is the Santa Clara County Children’s Shelter, providing emergency shelter for wards of the court (usually victims of abuse or neglect) from newborn to 18 years of age. The facility has a 90-bed capacity, which serves Palo Alto’s youth homeless population. The New County Children’s Shelter with a capacity of 130 beds and located in San Jose also serves Palo Alto’s youth. Other shelters for youth including the Bill Wilson Center in Santa Clara serves Palo Alto’s homeless youths. Chapter 2 42 The primary provider for shelter for victims of domestic violence for Palo Alto citizens is the YWCA Silicon Valley, Domestic Violence Department located in San Jose. Statistics from the agency indicate that within FY 09-10 five clients and their accompanying children from Palo Alto were provided emergency shelter and transitional housing for a total of 106 bed-nights and counseling services and legal assistance were provided to 47 residents. In FY 10-11, the number dropped down to 1 Palo Alto individual for shelter and transitional housing, and 36 residents received crisis counseling and legal assistance. The following is a comprehensive list of all Emergency Shelters in Santa Clara County serving all residents. Chapter 2 43 Table 2-35 List of Emergency Shelters in Santa Clara County Serving All Residents Total Family Family Individual Total Year Seasonal Beds Units Beds Round Beds Beds Current Inventory West Valley Community Services Rotating Shelter Cupertino SM 0 0 15 15 Community Solution La Isla Pacifica Gilroy HC DV 14 3 0 14 0 EHC Lifebuilders Armory - Gilroy Gilroy SMF 0 0 0 0 48 Support Network for Battered Emergency Shelter Mountain View HC DV 16 0 6 16 InnVision Hotel de Zinc Palo Alto SMF 0 0 15 15 0 Asian Americans for Community Asian Women's Place San Jose HC DV 12 4 0 0 12 Involvement City Team Ministries City Team Rescue Mission San Jose SM 0 0 50 50 125 Community Homeless Alliance First Christian Church San Jose SMF+HC 19 1 2 21 0 Ministry EHC Lifebuilders Boccardo Regional Receiption Center San Jose SMF 0 0 185 185 0 EHC Lifebuilders Boccardo Regional Receiption Center San Jose SMF 0 0 17 17 0 Medical Respite Center Family Supporting House San Jose Shelter Center San Jose HC 143 35 0 143 0 InnVision Commercial Street Inn San Jose SFHC 40 12 15 55 0 InnVision Montgomery Street Inn Community Inns San Jose SM 0 0 46 0 0 InnVision Julian Street San Jose SMF 0 0 60 0 0 Next Door Solutions to Domestic Next Door Solutions San Jose HC DV 19 7 0 19 48 Violence/Salvation Army Hospitality House (Overnighter) San Jose SM 0 22 22 0 0 Bill Wilson Center Runaway and Homeless Youth Shelter Santa Clara YMF 0 0 20 20 125 EHC Housing Consortium dba EHC Armory - Sunnyvale Sunnyvale SMF 0 0 0 0 0 Lifebuilders EHC Lifebuilders Boccardo Family Living Center in Santa Clara County HC 0 0 0 0 0 San Martin Provider Facility Name City A Target Population (a) All Year-Round Beds/Units B Chapter 2 44 Table 2-35 List of Emergency Shelters in Santa Clara County Serving Palo Alto, Continued Total Family Family Individual Total Year Seasonal Beds Units Beds Round Beds Beds InnVision Clara Mateo Shelter Santa Clara County SMF+HC 18 6 40 58 0 EHC Lifebuilders Boccardo Family Living Center Santa Clara County HC 0 0 0 0 0 Migrant Worker Program (7 Month: March to November) EHC Lifebuilders Sobrato House Youth Center San Jose YMF 0 0 10 10 0 EHC Lifebuilders Veterans Dorm at the Boccardo San Jose YMF VET 0 0 10 10 0 Receiption Center Subtotal 281 74 507 788 346 Under Development Next Door Solutions to Domestic Volie ND Solutions San Jose HC DV 3 1 0 3 0 Total 284 76 507 791 346 Notes: (a) Target Population Key HC:Household with Children SM: Single Males YM:Youth Males SF: Single Females YF:Youth Females SFM: Single Males and Females YMF: Youth Males and Females CO:Couples Only no Children SMF+HC:Single Males and Females Plus Household with Children SMHC:Single Males and Households with Children DV:Domestic Violence Victims only SFHC:Single Female and Households with Children VET:Veterans only HIV:HIV/AIDS Population only Source: Santa Clara County, Continuum of Care Application, 2009, BAE, 2009 All Year-Round Beds/Units Provider Facility Name City Target Population (a) A B Chapter 2 45 iii) Transitional Affordable Housing: Transitional housing facilitates movement of homeless individuals and families to permanent housing within a reasonable amount of time, usually 24 months. Palo Alto has several transitional housing facilities to meet the demand of the homeless population. These facilities are either administered by different Countywide agencies or the Palo Alto Housing Corporation. The Shelter Plus Care Program, administered by the County Office of Homelessness, provides Section 8 rental subsidies to eligible, case-managed homeless persons with a disability. The program has been successfully implemented in both the Barker Hotel (a rehabilitated 26-unit single room occupancy hotel) and Alma Place (a 107-unit single room occupancy residency hotel). In addition to the case-management provided under the Shelter Plus Care Program, the Palo Alto Housing Corporation provides additional, extensive counseling and supportive services to its residents at the Barker Hotel, the majority of whom were previously homeless, or at-risk of becoming homeless. The program, funded with Palo Alto CDBG funds, has significantly reduced the turnover rate at the Barker Hotel, keeping at-risk persons in their homes. The Opportunity Service Center (OSC), provides 88 SRO permanent and transitional units for individuals and families to serve Palo Alto residents. In addition, the Opportunity Center operates a day use and service center for homeless adults and families. Table 2-36 Transitional Housing Shelters serving Palo Alto Source: City of Palo Alto Service Provider Target Population Capacity/Housing Type Number of Palo Alto Residents Served Shelter Plus Care Program at Barker Hotel Homeless with disability 26 SRO units 26 Alma Place Homeless with disability 107 SRO units 107 Opportunity Service Center (OSC) Individuals and Families 88 SRO units 88 Haven Family House (Menlo Park)Families 23 beds As needed Redwood Family House (Redwood City)Families 40 beds As needed Illinois St. House (East Palo Alto)Individuals 8 beds As needed Transitional Supportive Housing Services Chapter 2 46 Table 2-37 Supportive Share Housing Facilities in Palo Alto Extremely Low Income Households Extremely low-income households are those households with income less than 30 percent of area median income. HUD published area median income for Santa Clara County for a family of four is $105,500. This results in an income of $31,850 or less for a four-person household or $22,330 or less for a one-person household as extremely low income. Table 2-38 HUD Annual Household Income Limit Santa Clara County, 2008 Most families and individuals receiving public assistance, such as social security insurance (SSI) or disability insurance (SSDI) are considered extremely low-income households. At the same time, a minimum wage worker could be considered an extremely low-income household with an annual income of approximately $24,000 or less. Following are examples of occupations with wages that could qualify as extremely low-income households. Employment Development Department data shows in the San Jose-Santa Clara-Sunnyvale MSA, occupations like childcare workers and housekeepers earn around $12.00 per hour; manicurists, pedicurists, and hair stylists earn from $10 to $14 per hour; waiters and servers $10-$12 per hour; and food preparation and serving related workers earn $10 per hour. The area median rent for housing has increased considerably over the last two decades making it practically impossible to survive on the above-mentioned wages in Palo Alto. Table 2-39 Median Gross Rent in Palo Alto, 1990-2008 Name Operator Capacity Clientele Pine St. House Palo Alto Housing Corporation 3 Households Small families or individuals Source: City of Palo Alto, Consolidated Plan Rent 1990 2000 2007 2008 1990-2008 Percent Change Median Gross Rent 825 1,349 1,579 1625 97% Sources: Census 1990, 2000, 2005-2007 and 2006-2008 American Community Survey Persons in Household Extremely Low (30% of Median Income) Very Low- income Maximum (50% of Median Income) Low-income Maximum (80% of Median Income) 1 $22,330 $37,150 $59,400 2 $25,500 $42,450 $67,900 3 $28,650 $47,750 $76,400 4 $31,850 $53,050 $84,900 5 $34,400 $57,300 $91,650 6 $36,950 $61,550 $98,450 Source:HUD published Area Median Income (AMI). Note: 2008 Santa Clara County area median income for a family of four is $105,500 Chapter 2 47 The following table shows the affordability of rental housing cost by income level, based on the calculations of 2009 HUD area median income. Table 2-40 Affordability of Rental Housing Cost by Income 2009 About 11 percent of Palo Alto’s households, a total of 2,784, earned less than $25,000 in 2008. These extremely low-income households represented 7 percent of all home owners and 17 percent of the City’s renter households. Both renters and owners in the extremely low income category experienced a high incidence of housing problems. 2000 CHAS data shows 69 percent of the extremely low-income renter households faced housing problems (defined as cost burden greater than 30 percent of income and/or overcrowding and/or without complete kitchen or plumbing facilities) and 40 percent were in overpayment situations. Moreover, 53 percent of extremely low-income households paid more than 50 percent of their income toward housing costs, compared to 17 percent for all households. Income Group Median Income Maximum Housing Cost (30% of Income) Extremely Low (30% of Median Income) $31,850 $620 Very Low-income Maximum (31%-50% of Median Income) $53,050 $1,150 Low-income Maximum (51%-80% of Median Income) $84,900 $1,947 Source: City of Palo Alto Consolidated Plan 2010. Affordablity calculations based on 2009 HUD Area Median Income for family of four. Chapter 2 48 Table 2-41 Households with Housing Problems Palo Alto by Income, 2000 Projected Needs To calculate the projected need for housing to accommodate extremely low-income households the City assumed 50 percent of its very low-income regional housing need is from extremely low-income households. Based on the need for 690 very low-income units, the City has a projected need for 345 units to serve extremely low-income households. Many extremely low-income households will be seeking rental housing and most likely facing an overpayment, overcrowding or substandard housing condition. Some extremely low-income households could have mental or other disabilities and special needs. To address the range of needs, the City employs as part of this Housing Element a detailed housing strategy including promoting a Household by Type, Income, & Housing Problem Total Renters Total Owners Total Household Household Income <=30% MFI 1,975 814 2,789 Household Income <= 50% MFI 2,950 1,483 4,433 % with any housing problems 72.7 67.1 71 % Cost Burden >30% 69.4 64 67.8 % Cost Burden >50% 53.3 52.1 52.9 Household Income >30 to <=50% MFI 975 669 1,644 with any housing problems 86.2 45.6 69.6 % Cost Burden >30%79.2 41.3 63.7 % Cost Burden >50% 47.6 27.2 39.3 Household Income >50 to <=80% MFI 1,065 674 1,739 % with any housing problems 71.5 33.2 56.6 % Cost Burden >30%63.9 33.2 52 % Cost Burden >50% 23.3 25.2 24 Household Income >80% MFI 6,877 12,222 19,099 % with any housing problems 23.8 18.5 20.4 % Cost Burden >30%17.6 17.2 17.3 % Cost Burden >50%1.2 4.2 3.1 Total Households 10,892 14,379 25,271 % with any housing problems 42.9 23.2 31.7 % Cost Burden >30 37 21.7 28.3 % Cost Burden >50 17 9 12.4 Source: CHAS Data 2000 Chapter 2 49 variety of housing types, such as single-room occupancy (SRO) units, senior housing and small sized units. Table 2-42 ABAG’s New Construction Need by Household Income Level in Palo Alto, 2007-2014 Table 2-43 Progress in Meeting Palo Alto’s Fair Share of the Region’s 2007-2014 Housing Need by Income Level HOUSING CHARACTERISTICS Housing Development In the year 2000, there were 26,155 residential units in Palo Alto, an increase of 967 (3.8 percent) from 1990. By 2008, there were a total of 26,960 residential units, an increase of 805 units with a slightly slower growth rate than the previous decade. Table 2-44 Total Number of Housing Units in Palo Alto, 1970-2008 Year Total Number of Units 1970 21,338 1980 23,747 1990 25,188 2000 26,155 2007 26,735 2008 26,960 Source:US Census 1970, 1980 & 2000, the 2005-2007 ACS and 2006-2008 ACS Income Level 2007-2014 New Construction Need Building Permits Issued Units Unmet Need Very Low (0-50% of AMI)690 92 598 Low (51-80% of AMI)543 2 541 Moderate (81-120% of AMI)641 104 537 Above Moderate (over 120% of AMI)986 653 333 TOTAL 2,860 851 2009 * Building Permits Issued through June 2011 Source:City of Palo Alto Income Level Number of Units % of Total Need Extremely Low Income 345 12% Very Low-income Households 345 12% Low-Income Households 543 19% Moderate-Income Households 641 22% Above Moderate-Income Households 986 34% TOTAL 2,860 100% Source:City of Palo Alto, RHNA Chapter 2 50 Table 2-43 shows that there has been a significant decrease in the rate of housing produced in the City of Palo Alto over the last three decades. During the decade from 1970-80, the City's housing stock increased by 2,409 units or approximately 240 units per year. Between 1980 and 1990, production dropped to an average of 144 new units per year and during the following decade (1990-2000), the rate slowed even more to an average of 96 units per year. Despite a slight increase in the rate of production to 101 units per year from 2000 to 2008, the downward trend can be expected to continue because of the small amount of vacant land and limited opportunities for redevelopment. Table 2-45 Annual Rate of Housing Production Since 1970 The developable area within the City of Palo Alto, which is located between Junipero Serra Boulevard and the Bayshore Freeway (US 101) is essentially "built out". Less than 0.5 percent of the developable land area is vacant. The opportunity to annex additional land to the City is limited because the City is bordered to the east and west by the cities of Mountain View, East Palo Alto, Menlo Park and Los Altos with San Francisco Bay and Stanford University to the northeast and southwest. Besides the dearth of available land, another reason for the decrease in housing production has been the two recessions, the first in the early 1990s and most recently in 2008-2010, which affected the value of real estate and made it less attractive to build housing. During the mid- and late-1990s the Silicon Valley economy boomed with the expansion of the Internet and the significant growth in high technology businesses. As the number of workers and their incomes rose, housing demand increased and so did housing production. However, production could not keep pace with demand thus driving up the cost of housing even more rapidly than the growth of the economy. Land costs increased very rapidly particularly in Palo Alto given the limited supply of available residential land which increased financing costs. These factors combined with increased materials and construction costs made it much more difficult to produce housing, especially affordable housing. After slowing down in early 2000, the local economy picked up in 2002-2003, however this had little or no effect on the already overpriced land value and construction cost in the region. Affordability remained an issue during the housing bust period of 2008-2010 because the regional decline in property values, foreclosures, and reduction of interest rates had very little effect on the Palo Alto housing market. The availability of land and stricter financing regulations will continue to be important variables in determining the amount and the rate of new housing produced in the City. Year Rate of Production*Rate of Change 1970-1980 240 units/ year NA 1980-1990 144 units/ year -40% 1990-2000 96 units/year -33% 2000-2008 101 units/ year 5% Source:US Census1970- 2000, the 2005-2007 and 2006-2008 ACS three-year estimates. * Housing units numbers were not available before 1990:Rate of production was calculated assuming a vacancy rate of 3.5% from the Household number Chapter 2 51 Vacancy Rates Vacancy rates have traditionally been used as a gauge to measure the health of a community's housing market. Vacancy trends in housing are analyzed using a “vacancy rate” which establishes the relationship between housing supply and demand. For example, if the demand for housing is greater than the available supply, then the vacancy rate is low, and the price of housing will most likely increase. Additionally, the vacancy rate indicates whether or not the City has an adequate housing supply to provide choice and mobility. HUD standards indicate that a vacancy rate of five percent is sufficient to provide choice and mobility. Low vacancy rates (typically defined as anything less than 3 percent for homeowner units and 5 percent or less for renter units) indicate a tight housing market with few vacant units and increasing demand for those vacant units which then drive up rental costs. Data from the 2000 Census indicated that 828 units were vacant in Palo Alto out of a total housing stock of 26,155 units. That reflected an overall vacancy rate of 3.17 percent. However, in looking at this data more closely only 323 of the 828 units were available for sale or rent. The remaining 505 units were vacant but were being used for seasonal, recreational, or other uses. Therefore, the real vacancy rate when evaluating units available for rent or sale was actually 1.2 percent in year 2000. Table 2-46 Housing Vacancy in Palo Alto, 2000-2008 In 2008, the vacancy rate increased to 5.31 percent. Of the 1432 vacant units, 19 percent were either for rent or for sale. Another 145 of the vacant units are used for seasonal, recreational or occasional use and 266 units were either sold or rented but unoccupied. This reduced the effective vacancy rate to 2.8 percent compared with 1.51 percent for the County as a whole. Housing Units 2008 2000 Total Dwelling Units 26,960 26,155 Total Occupied Dwelling Units 25,528 25,327 Total Vacant Dwelling Units 1,432 828 Vacancy Rate 5.31%3.17% Source: U.S. Census Bureau, 2006-2008 American Community Survey Chapter 2 52 Table 2-47 Housing Vacancy Type in Palo Alto, 2008 REAL FACTS estimated that occupancy rates for large apartment complexes (50 units or more; 1,943 units total) varied from a low of 98.3 percent (1.7 percent vacancy rate) in the middle quarter of 2000 to a high of 99.3 percent (0.7 percent vacancy rate) during the fourth quarter. However, during the first quarter of 2001, average occupancy rates decreased to 95.9 percent (4.1 percent vacancy rate) reflecting the slowdown in the economy. The rental vacancy review of March 2009, by the Planning and Community Environment Department (required by the provisions of the Palo Alto Municipal Code, Chapter 21.40), determined 1.87 percent vacancy rate for multifamily units. The vacancy rate is calculated for regulating the conversion of housing developments containing a minimum of three dwelling units from rental-type tenancy to condominium uses. The data reviewed is obtained from multiple sources like the City’s Building Division records, the City’s Utilities Department records and the Bureau of the Census data. This shows that currently Palo Alto has a total number of 7,622 multifamily rental units of which approximately 143 units are assumed to be vacant resulting in a rental vacancy rate of 1.87 percent. Housing Types The majority of housing units in Palo Alto (64 percent of the housing stock in 2008) are single-family units. Of these, 94 percent are single family detached units and the remainder single family attached units (e.g. condominium and townhouse units). Multifamily units in structures of 2-4 units represented 6 percent of the housing stock in 2008, and approximately 29 percent of the housing stock consisted of multifamily units in structures of 5 and more units. Mobile homes represented less than 0.2 percent of the total housing stock. The illustration below shows the 2008 mix of housing types in the City. 2008 Total Housing Units:26,960 Occupied 25,528 Vacant 1,432 Vacant: For rent 118 Vacant: Rented, not occupied 153 Vacant: For sale only 151 Vacant: Sold, not occupied 113 Vacant: For seasonal, recreational, or occasional use 145 For migrant workers 0 Other vacant 752 Source: 2005-2007, 2006-2008 and 2007-2009 American Community Survey Data Chapter 2 53 Figure 2-4 Housing Stock by Unit Type in Palo Alto, 2008 Source: ACS 2006-2008 Data The character of Palo Alto’s housing stock has changed little since 1990 when single-family homes constituted more than 60 percent of housing stock. Increased construction of multiple family housing in Palo Alto rose in the late 1990s. Between 1996 and 2000 the City built about 335 dwelling units of which 212 units were multiple family units. The proportion of structures with 5 or more units has remained constant since 2000. Table 2-48 Housing Stock by Type of Housing Since 2000 In 2008, approximately 61 percent of the 25,528 occupied units in the City were owner-occupied. Homeowners live in 15,485 of the City's occupied units and renter households occupy the remaining 10,043 units. From 1970 to 2000, the home ownership rate slowly increased from 54 percent to 56 percent and by 2008 the ownership rate reached 61 percent. It is interesting to note that the percentage of owner-occupied and renter-occupied units in the City's housing stock is similar to the proportion of owner and renter units in Santa Clara County 2008 Housing Stock by Unit Type Single Family 2-4 Units Other (includes mobile homes, boats, vans & RV) 5+ Units Housing Unit Type 2000 2007 2008 Change 2000 to 2008 Single Family 16,365 17,810 17,332 6% 2-4 Units 1,728 1,579 1,671 -3% 5+ Units 7,897 7,218 7,897 0% Other (includes mobile homes, boats, vans & RV) 165 128 60 -64% TOTAL 26,155 26,735 26,960 3% Source: 2000 U.S. Census, 2005-2007 and 2006-2008 American Community Survey Chapter 2 54 as a whole. The County's housing stock consisted of 40 percent renter-occupied and 60 percent owner-occupied units in 2008. The median year of construction of the renter occupied units in Palo Alto is 1965; while for the County of Santa Clara, it is 1973. This reflects that Palo Alto has older rental unit stock than the County. The owner occupied housing stock of Palo Alto is also older than the County’s, the median year of construction being 1954. Figure 2-5 Housing Tenure by Structure of Year Built Source: U.S. Census Bureau and ACS 2006-2008 Data In 2000, approximately 78.6 percent of all owner-occupied units in Palo Alto were three bedrooms or larger. In 2008, 81 percent of owner-occupied units contained three or more bedrooms. Only 18 percent of the renter occupied units have three or more bedrooms. Eleven percent are studio units, with the majority of the rental units containing 1-2 bedrooms (71%). Year 2000 Census data indicates that the average number of bedrooms in an owner-occupied unit was 3.16 while the average number of bedrooms in a renter occupied unit was 1.52. It was assumed that owner-occupied units have more bedrooms in 2008 given the increasing size of single-family detached dwellings over the last decade, while renter-occupied units in 2008 show a slight decrease in the average number of bedrooms from 1990. 0 1000 2000 3000 4000 5000 6000 7000 8000 Built 2005 or later Built 2000 to 2004 Built 1990 to 1999 Built 1980 to 1989 Built 1970 to 1979 Built 1960 to 1969 Built 1950 to 1959 Built 1940 to 1949 Built 1939 or earlier Owner occupied:Renter occupied: Chapter 2 55 Figure 2-6 Housing Stock by Tenure and Number of Bedrooms, 2008 Source: U.S. Census Bureau and ACS 2006-2008 Data Housing Age and Conditions Like many other California communities, Palo Alto experienced a huge spurt of growth in the decade after World War II. Approximately 29 percent the City's current housing stock was built in the decade between 1950-60. The 2000 Census data indicated that the median year in which a typical Palo Alto owner-occupied housing unit was constructed was 1954. The City's housing stock appears to be divided into three periods of construction or age. Roughly 56 percent of the units were constructed prior to 1959, approximately 12 percent were constructed between 1960-69 and approximately 24 percent were built between 1970-1999. Only 8 percent of the construction took place between 2000 to 2008. By looking at Census data indicators only, Palo Alto's housing stock is not substantially at risk for having severely deteriorated units. Although the majority of the City's units were built after World War II, there are limited numbers of very old housing units (50+ years) in the City without any home improvements or upgrades. Further, the 2000 Census data indicates that only 84 of the City's 26,155 total units lacked complete plumbing facilities. 0 BR 1 BR 2 BR 3 BR 4 BR 5+ BR 0% 5% 10% 15% 20% 25% 30% Owner Households Renter Households Chapter 2 56 Figure 2-7 Housing Stock of Palo Alto by Year Built, 2008 Source: U.S. Census Bureau and ACS 2006-2008 Data While a formal "windshield" survey has not been conducted in Palo Alto in recent years, there have been periodic and extensive drive-through observations of the neighborhoods in Palo Alto by both staff and consultants. Because of the high market value and income levels in many Palo Alto neighborhoods, the units generally appear to be in good condition and there appear to be very few, if any, pockets of deteriorating units. The City's 1988-91 "Housing Assistance Plan" estimated that only 3 percent of the City's owner occupied housing stock is substandard. The 3 percent figure was based on information from the City's Housing Improvement Program, which has now been discontinued, and was the most accurate information available on substandard housing. City staff observations indicate minimal change in the amount of substandard housing since 1991. City staff has also observed that in Palo Alto there does not appear to be a correlation between the age of a structure and deterioration. Further, the State Department of Housing and Community Development (HCD) reports that Santa Clara County’s housing stock is in significantly better condition than other areas of the State. Assuming that the proportion (3 percent) of owner-occupied units estimated to be substandard remains the same, only about 465 of the 15,485 owner-occupied units in Palo Alto could be considered substandard. The actual number of substandard homes is probably less, however, given the high real estate values of the City and the high level of investment property owners are likely to spend to maintain these values. The median year of construction of the renter occupied units in Palo Alto is 1965, while for the County of Santa Clara it is 1973. This reflects Palo Alto’s older rental unit stock. The owner occupied housing stock of Palo Alto is also older than the County, the median year of construction being 1954. The City's rental housing stock is "younger" than its total housing stock. 75 percent of the renter-occupied units built on or after 1990 were in structures of 5 or more units. Assuming that very-low and low-income renters might be more likely to live in substandard units because of their limited income for housing costs, a review of income status and age of housing was 8% 24% 12% 56% Built 2000 to current Built 1970 to 1999 Built 1960 to 1969 Pre 1959 Chapter 2 57 conducted using the 1990 Census data. This review indicates that the majority (60 percent) of very low- and low-income tenants in Palo Alto occupied units built after 1960. Another 28 percent (987 households total) of very low- and low-income tenants were living in units built between 1940-59 while the remaining 13 percent (462 households total) of very low- and low-income renters lived in units built prior to 1940. Therefore, the Census data indicates that most very low- and low-income tenants in Palo Alto live in "newer" units (units built after 1960) and these units are typically assumed to be in no serious threat of being substandard. There were 462 very low- and low-income tenants living in units over 50 years of age, and these units are the most likely to be substandard and in need of rehabilitation. There was also 987 very low- and low-income tenants living in units built between 1940-59 and some of these units could also be in need of repair or rehabilitation. The 1,449 total units (462+987=1,449 units) represent 5.8 percent of all housing units in the City in 1990. Assuming the same proportion (5.8 percent) of rental units that are possibly substandard for the year 2000, approximately 1,463 housing units may have needed some rehabilitation in 2000. While it does not appear that there is a serious problem with the condition of rental units, it should be noted that the City has been active in trying to maintain the condition of its existing affordable rental housing stock. Using federal funds and bond authority, several rental housing developments in Palo Alto have been rehabilitated in recent years. In 1998-99, the City assisted the Palo Alto Housing Corporation in preserving and rehabilitating the 57 unit Sheridan Apartments and, in 1999-2000, assisted the Mid-Peninsula Housing Coalition in preserving and rehabilitating the 156 unit Palo Alto Gardens. The City assisted with the acquisition and rehabilitation of the 66 unit Arastradero Park Apartments in 1995. With City assistance, the Palo Alto Housing Corporation rehabilitated the 10 unit Plum Tree Apartments in 1991 and the 26 unit Barker Hotel project in 1994. The City continues to monitor the maintenance and repair needs of this affordable rental housing stock. Housing Cost Housing costs continue to be a concern for California communities, especially in the San Francisco Bay Area. Palo Alto is a very desirable community and, consequently, the cost of housing is especially high and was rising rapidly until 2007. Census 2000 data indicated that the median value for specified owner-occupied housing for Santa Clara County was $446,400 and $811,800 for Palo Alto. The Silicon Valley Board of Realtors indicated that the price of both single-family detached dwellings and condominiums/townhouses in Palo Alto more than doubled between 1996 and 2000. Single-family detached home prices increased 105 percent from $490,000 to $1,006,600. Condominium and townhouse prices increased 107 percent from $264,000 to $546,600 (Source: Silicon Valley Board of Realtors) during this period. ACS 2006-2008 data shows median home values of Palo Alto stands above $1 million, an increase of 23 percent from year 2000. Chapter 2 58 Table 2-49 Regional Median Home Values Since 2000 As of June 2006, the median price home price in Palo Alto was $1,395,000. A condominium or townhouse had a median price of $655,000. Assuming a 20% downpayment, 6.5% interest rate and 30 year term, the monthly mortgage payment would be approximately $8500 per month. If the household would pay no more than 30 percent of their income for housing costs (principal, interest, taxes and insurance), it would mean a household would need to have an annual income of approximately $340,000 to afford the median sales price of $1,395,000 for a single family detached home. As reference, the 2006 household median income, as determined by HUD, was $103,600 for a family of four. Therefore a household would have to earn over three times the County median to purchase the median priced single-family home in Palo Alto. Using the same assumptions, the household income required to purchase the median price condominium or townhome in Palo Alto would be approximately $160,000 per year. Housing Affordability The information in the above paragraph indicates that households in Palo Alto either need a very high household income to afford median priced housing or else would need to have a substantial amount of funds for a large down payment so that the monthly mortgage costs would be reduced. Low- and moderate-income households do not have the household incomes needed to afford these units and, typically, do not have access to large amounts of funds to use for down payments. Therefore, it is very difficult for low- and moderate-income households to afford home ownership in Palo Alto. In fact, unless publicly subsidized in some manner, home ownership in Palo Alto is available only to households with above moderate incomes. The following two tables show rental and ownership affordability for Extremely Low, Very Low and Low income groups restricting spending to 30 percent of their income for housing. 2000 2007 2008 San Jose $394,000 $665,200 $678,100 72% Cupertino $649,000 $948,200 $994,100 53% Sunnyvale $495,200 $705,200 $724,900 46% MountainView $546,900 $727,600 $764,600 40% Palo Alto $811,800 $1,000,000 $1,000,000+ 23% Los Altos Hills $983,000 $1,000,000 1000000+2% City Percent Change From 2000-2008 Median Value Sources: Census 2000, 2005-2007 and 2006-2008 American Community Survey Data. Chapter 2 59 Table 2-50 Rental Housing Affordability, 2009 Table 2-51 Ownership Housing Affordability, 2009 Although there has been limited local decline in home values, it is important to note, that credit markets have also tightened in tandem with the decline in home values. Therefore, although homes have become slightly more affordable, lender requirements for a minimum down payment or credit score present a greater obstacle for buyers today. More accessible home loan products, including Federal Housing Administration (FHA) loans have traditionally allowed lower-income households to purchase a home that they could not otherwise afford. However, interviews with lenders suggest that many households are not aware of these programs. Moreover, many loan officers prefer to focus on conventional mortgages because of the added time and effort associated with processing and securing approval on a FHA loan. Income Group Median Income Maximum Housing Cost (30% of Income) Extremely Low (30% of Median Income) $31,850 $620 Very Low-income Maximum (31%-50% of Median Income) $53,050 $1,150 Low-income Maximum (51%-80% of Median Income) $84,900 $1,947 Source: City of Palo Alto Consolidated Plan 2010. Affordablity calculations based on 2009 HUD Area Median Income for family of four. Income Group Median Income Maximum Affordable Home Price Percent of Single Family Homes in North Santa Clara County within the Price Range Extremely Low (0-30% MFI)$31,850 $132,600 1.40% Very Low (31- 50% MFI)$53,050 $220,900 1.80% Low (51-80% MFI)$84,900 $353,500 5% Source: City of Palo Alto Consolidated Plan 2010. Affordablity calculations based on 2009 HUD Area Median Income for family of four. Chapter 2 60 According to the 2000 Census data, the median gross rent in Palo Alto was $1,349 while the median gross rent for Santa Clara County was $1,185. In 2008 the median gross rent for Palo Alto was $1625, a 97 percent rise in rents from 1990. Table 2-52 Median Rent and Home Value of Palo Alto Since 1990 The table below shows the current median rents by bedroom along with the Fair Market Rents established by the Santa Clara Housing Authority. Table 2-53 Median Rents by Number of Bedrooms, 2009 Source: 2009 data from local Real Estate Companies in Palo Alto, Online newspaper advertisements, Craigslist, and Housing Authority Santa Clara County In summary, home ownership in Palo Alto is expensive and available principally to households near the upper end of above moderate incomes. Without a public subsidy in some manner, the median priced home ownership units in the City require minimum household incomes of $163,000-$275,000 depending on unit type. The upper end of the households in the above moderate-income range can "afford" typical rental unit housing costs, but low- and very low-income households have much more difficulty in finding rental properties. Very low-income households, in particular, are much more challenged in finding a rental unit that is affordable and appropriately sized for their household. The recent slowing of the economy and increased vacancy rates may bring about a modest decline in rents and home prices, but not to the extent of substantially improving the affordability of housing in Palo Alto. Foreclosures As a result of the downfall in the housing market from early 2008, millions of Americans have received foreclosure notices and tens of billions in real-estate assets have been written off as losses by banks. By December 2008, the foreclosure rate in California was 3.97 percent (Source: http://www.realtytrac.com/content/press-releases/foreclosure-activity-increases-81-percent-in- 2008-4551). Compared to the rest of Santa Clara County, the rate of foreclosure in Palo Alto was far less. Because of Palo Alto’s premium real estate market, the volume of foreclosure properties Bedroom Type Median Market Rents Fair Market Rents June, 2010 Studio $1,200 $1,032 One-Bedroom $1,800 $1,196 Two-Bedroom $2,700 $1,438 Three-Bedroom $3,500 $2,068 Four-Bedroom $4,150 $2,276 Rent 1990 2000 2007 2008 1990-2008 Percent Change Median Home Value 457,800 811,800 1000000+ 1000000+118% Median Gross Rent 825 1,349 1,579 1625 97% Sources: Census 1990, 2000, 2005-2007 and 2006-2008 American Community Survey Chapter 2 61 was significantly lower than cities like San Jose and Santa Clara. Based on October 2011 Reality Trac data approximately 31 foreclosures were reported in Palo Alto in 2011 (http://www.realtytrac.com/trendcenter/ca/palo+alto-trend.html) which is about .11 percent of the total housing units in Palo Alto. Assisted Housing At-Risk of Conversion Many publicly assisted housing units throughout the state are eligible to change from low-income to market-rate housing. Termination of various government subsidy programs and/or restrictions on rental rates will expedite the conversions. These units, known as at-risk units, are a valuable source of affordable housing for families. State Housing Element law and the City’s HUD Consolidated Plan regulation require cities to prepare an inventory including all assisted multifamily rental units which are eligible to convert to non low- income housing uses due to termination of subsidy contract, mortgage prepayment, or expiring use restrictions. State Housing Element law requires this inventory cover a ten-year evaluation period following the statutory due date of the Housing Element (July 1, 2004); whereas the HUD regulation requires the inventory to cover only the five-year planning period of the Consolidated Plan. To satisfy both state and federal requirements, this at-risk housing analysis period covers from July 1, 2004 through June 30, 2014. Below is a list of Assisted Housing units that are at risk of conversion to market-rate housing from July 2004 to June 2014, based on information from the California Housing Partnership Corporation (CHPC). Palo Alto has 400 units in seven developments of very low- and low-income housing that are subject to increases in rent or conversion to market rate housing to varying degrees. Of these units, 72 are considered at severe risk of conversion, while the remainder is at low risk of conversion. These projects are assisted in part by HUD with Section 8 project-based rental assistance in which a direct subsidy is provided to the owner. Many subsidized affordable housing developments receive government funding that requires units are made affordable for a specified amount of time. Affordable developments owned by for-profit entities are more at-risk of converting to market rate in the next five years, whereas commitment and mission to preserve affordability of the nonprofits’ development significantly lowers the risk of conversion of those units. Many of the City’s affordable housing agreements are in place through 2019. However, some affordable housing developments are dependent on Section 8 vouchers to assist in the project cash flow. While difficult to predict the direction of federal funding for the Section 8 program and affordable housing funding in general, the City will continue to advocate for maintaining or increasing funding for affordable housing. Of the City’s affordable housing developments, only one development, the Terman Apartments, was found to be a high risk of reverting to market rate housing. The Terman Apartments were financed using the Section 8 221(d)(3) mortgage insurance program. The development has been at risk for some time and the City has approached the owner a number of times about the possibility of purchasing the unit. However, the owner has not been receptive to selling the development. The City will work with the owner and other non-profit affordable housing developers in preserving this project which serves moderate income households. In 2008, the City and Palo Alto Housing Corporation, Inc. (PAHC), a non-profit housing developer, approached the owner of the Terman Apartments about the possibility of selling the units to PAHC but the owner was not willing. In addition to PAHC, the City has worked with a Chapter 2 62 number of affordable housing developers in the City including Eden Housing and Bridge Housing Corporation, both established affordable housing developers in the Bay Area. Based on recent development proformas of affordable housing projects in the City, the total estimated cost of replacing 92 total units, with land acquisition and developments costs, at the Terman Apartments would be approximately $45 million. Table 2-54 Summary of Government Assisted Units “At Risk” for Conversion One of the goals of the City’s Consolidated Plan is to preserve the supply of affordable rental stock. It is also a high priority of the City to retain the existing affordable rental stock. The Terman Apartment complex is the one federally subsidized rental project that is at-risk of converting to market rate housing during the next five-year period. The current HUD Section 8 contract on the 92-unit Terman Apartment complex expired in 2010, of which 72 units are subsidized units; the property owner has continued the Section 8 subsidy on a year to year basis. The City’s top priority continues to be to preserve these affordable rental units. There are an additional 281 assisted rental units in four developments potentially at-risk for conversion. However, these units are owned and operated by nonprofit entities and are considered at low risk of conversion. Conservation of the existing affordable housing stock is critical in today's economic climate. Because of the high cost of housing and lack of vacant land to construct new affordable housing, it is extremely important to preserve and protect those affordable housing units that already exist. State Housing Element Law requires communities to conduct an inventory of affordable units that might be "at-risk" of converting to market rate units within a 10-year time frame of the Housing Element. The inventory is to include all multifamily rental units that have been funded Project Name Owner/Contact Total Number of Units Units Subject to Conversion Type of Subsidy Previous or Existing Conversion Date/Sec. 8 Status Non- Elderly units Elderly units Terman Apartments 655 Arastradero Rd. Palo Alto, CA Goldrich & Kest, 5150 Overland Ave.Culver City, CA 92 Units 92 Units 221(d)(4) & Section 8 Section 8 Opt:Year to Year Lytton Gardens I, 656 Lytton Ave. Community Housing, Inc., 656 Lytton Avenue 220 Units 140 Units 236(j)(1) Section 8 Section 8 Opt: 1996-97, 1998, 2003, (now year- to-year Section 8) Elderly Colorado Park, 1141 Colorado Ave. Palo Alto, CA Colorado Park Corp., 1141 Colorado Ave. Palo Alto, CA 60 Units 37 Units 236(j)(1), Section 8 Section 8 Opt:, 1996-97, 1998. (now year-to- year Section 8) Family Lytton Gardens II, 656 Lytton Ave., Palo Alto, CA Community Housing Inc, 656 Lytton Ave., Palo Alto, CA 100 Units 100 Units Section 202 Section 8 Section 8 Opt, 1999, (now year- to-year Section 8) Elderly Arastradero Park Apts, 574 Arastradero Road, Palo Alto, CA Palo Alto Housing Corp., 725 Alma Street, Palo Alto, CA 94301 66 Units 47 Units Section 8, Sec. 236(j)(1) Section 8 Opt:2000, (now year-to-year Section 8)Page Mill Court, 2700 Ash St., Palo Alto, CA 94306 24 Units 4 Units 221 (d)(4), Section 8 2005 TOTAL 562 Units 400 Units Adults with Disabilities Source: City of Plao A lto, 2010-2015 Consolidated Plan Summary of Government Assisted Units “At Risk” for Conversion Family & Elderly For Profit Ownership (at higher risk of conversion) Family & Elderly Non-Profit Ownership (at lower risk of conversion; possible risk of higher rents if Section 8 subsidy lost) Chapter 2 63 with federal, state or local assistance. A review of multifamily units in Palo Alto indicates that the only units that are at risk are those that have been assisted with federal funds. The only State funded project is the Barker Hotel which was assisted with State of California HOME funds and the units have affordability controls until 2033. The City has a "Below Market Rate" (BMR) program that requires 15-20 percent of units to be affordable in projects of five units or more. The units in the BMR program have resale and affordability controls for 59 years and renew each time the property title is transferred and, therefore, are not at risk of converting to market rate. Expiration of Section 8 Project Based Subsidies Section 8 rental subsidies are subsidies provided directly to the project owner and the amount of the subsidy is typically determined based on the tenant's income and the rent charged. The subsidy helps tenants "afford" their monthly rent by paying a portion of the rent for them to the property owner. HUD and the property owner enter into a contract for a specified period of time during which Section 8 rental subsidy assistance will be provided. Formerly property owners were required to renew the Section 8 assistance in periods of 5-15 years, depending on the contract. Currently, HUD only renews Section 8 assistance on a year-to-year basis, subject to Congressional funding. It is not known how long this year-to-year renewal will continue. During the next decade, three projects in Palo Alto will have their current Section 8 Project Based Subsidy contracts either expiring or up for renewal. The effects of a loss of Section 8 subsidies differ depending on many factors including the underlying mortgage assistance, the percentage of households receiving rental assistance and their income levels, and each project's annual operating costs. Following is a description of the principal types of mortgage assistance which financed the affected projects. Sec. 221(d)(4) Projects The Terman Apartments complex is the only remaining project with a Section 221(d)(4) market rate mortgage with Section 8 project based subsidy. A 221(d)(4) project uses market rate mortgages with FHA insurance. This type of mortgage has no underlying mortgage prepayment restriction which requires continued affordability. Therefore, the units in this project could be rented at market rate, and there would be no requirement that the tenants be low-income. The only other Section 221(d)(4) project in Palo Alto, the Sheridan Apartments, was recently acquired by the Palo Alto Housing Corporation with assistance from the City of Palo Alto using available CDBG funds. This project is no longer considered “at-risk” of converting to market rate units. The Terman Apartments are the only remaining subsidized rental units seriously “at- risk” of conversion. Section 8 Moderate Rehabilitation Program Projects Under this HUD program, HUD offered 5 to 10 year contracts for Section 8 assistance to owners of existing rental housing occupied by eligible very low- and low-income households if the owner performed at least a minimum amount of property rehabilitation. In many cases, the rehabilitation work was funded by loans from local housing programs using CDBG funds or other HUD funds. The effect of a loss of Section 8 assistance depends on the specific financial circumstances of each project, especially the degree to which the owner's ability to cover debt service and operating costs depends on the revenue from the Section 8 rental contract. The Palo Alto Housing Corporation (PAHC) owns and manages three Section 8 Moderate Rehabilitation projects in Palo Alto, namely, Curtner Apartments, Emerson South Apartments, and Oak Manor Townhouses. The original Housing Assistance Payments (HAP) contracts of these properties have expired, but they are renewed annually. Chapter 2 64 The Section 8 contract assistance enables PAHC to provide affordable housing to very low-income households. Without the Section 8 assistance, PAHC would need to increase the rents paid by the tenants, which would mean that occupancy would shift to somewhat higher income households over time. However, since these properties carry relatively low amounts of amortized mortgage debt, PAHC should be able to maintain them as affordable rental units for low-income households even without the Section 8 assistance. At present, HUD continues to offer owners of 5 or more units a one year extension of their Section 8 contract. PAHC controls other projects with multi-year term Section 8 HAP contracts. They are Webster Wood Apartments, Sheridan Apartments, Arastradero Park Apartments, and Colorado Park Apartments. These projects are larger than those subsidized under the Moderate Rehabilitation Program. Colorado Park and Webster Wood were developed by PAHC in the 1970s to respond to the need for affordable housing in the City of Palo Alto. In the 1990s, PAHC acquired Arastradero Park and the Sheridan Apartments to preserve and maintain them in the City’s affordable housing stock. Projects acquired and rehabilitated by PAHC have complicated financing structures in which loans, funded from tax-exempt bonds, covered a major portion of the costs. Rental income, on par with the current Section 8 contract level, is needed for PAHC to continue to meet operating costs and repay the loans. Cost Analysis The cost to conserve the units in the developments that have Project Based Section 8 Subsidies as very low-and low-income housing is as varied as the projects themselves. Some of the developments have zoning controls or deed restrictions, some have longer term contracts and some have low mortgage debt; however, as noted previously, replacement is extremely difficult given the scarcity of available land. Most of these projects have been able to extend their Section 8 contracts on a year-to-year basis. The units most at risk are those in the Terman Apartments owned by a for-profit corporation. In 1998-99, the City of Palo Alto assisted in the purchase and conservation of Palo Alto Gardens and the Sheridan Apartments. Because the other remaining units are owned by non-profits, it is highly unlikely that they would have to be replaced or purchased at market rates. Although they are in danger of losing their Project Based Section 8 rental assistance, they would likely result in a modified mortgage arrangement with HUD and/or some increase in rents, but still remain well below market rates. In addition, because of the quality and desirable location of the projects, tenants receiving Tenant Based Section 8 Subsidies are likely to continue living in the properties for some time. Potential funding sources to pay for the cost of conserving these units are limited. Similar to the Palo Alto Gardens and Sheridan projects, City staff would assist in pursuing such funding sources as bond financing, State of California housing program funds, HOME funds, CDBG funds and City funds. Other potential funding sources might include Low Income Housing Tax Credits and Affordable Housing Program Funds from the Federal Home Loan Bank. All of these funding sources are, however, limited. 2.6 Regional Housing Needs Housing Needs Allocation Process State law requires every city and county in California to show how it will accommodate its “fair share” of the housing need for the region in which it is located. Based on regional housing need Chapter 2 65 estimates established by the State, the Association of Bay Area Governments (ABAG) has formulated estimates of housing needs by different income levels, which it assigned to each city and county in the San Francisco Bay Area through a Regional Housing Needs Allocation (RHNA) process. The RHNA represents the housing need that each jurisdiction must plan for during the 2007-2014 period that is covered by the Housing Element. The allocation process used information from ABAG’s Projections 2007 as the basis for determining each jurisdiction’s fair share of the region’s housing need. The methodology includes an allocation tool that is a mathematical equation consisting of weighted factors. The allocation process considers different weighting factors such as household growth (45 percent), existing employment (22.5 percent), employment growth (22.5 percent), household growth near existing transit (5 percent), and employment growth near existing transit (5 percent) were considered in the allocation process. In addition to this data, ABAG considered the land use policies and the land use data of local governments, including the sites available for residential development and the availability of urban services. The housing need determination is primarily based on the number of households each jurisdiction is expected to plan for between 2007 and 2014. The local jurisdictions in Santa Clara County have agreed that since urbanization should take place only within the urban service areas of the cities about 75 percent of the Unincorporated County’s Sphere of Influence housing need should be allocated to the cities where these units could be better served and urban encroachments into the County would be better contained. Using available data and projections based on future employment and population trends, ABAG estimates that the total projected housing need for Santa Clara County is 60,338 new units for the 2007 to 2014 period. Palo Alto's share of that total need is 2,860 units or 4.4 percent of the County's total need. In addition to the total housing need estimate, ABAG is charged with determining the number of housing units that are needed for each of four household income levels based on County median household income. These income levels are defined as follows: Very Low-Income 0-50 percent of County median income; Low-Income 50-80 percent of County median income; Moderate-Income 80-120 percent of County median income; and, Above Moderate-Income; greater than 120 percent of County median income. The purpose of this division of housing need by income level is to more equitably distribute the type of households by income category throughout a region so that no one community is "impacted" with a particular household income group and to ensure that each jurisdiction addresses the housing needs of each economic segment in their communities. The State law recognizes that local jurisdictions are rarely involved in the actual construction of housing. The law neither requires them to produce or provide financial assistance for the units that ABAG allocates. The primary objective is for cities and counties to adopt plans that provide sites that could feasibly accommodate housing to meet its share of the regional need and to adopt and implement policies and programs that will help to make this possible. Chapter 2 66 Table 2-55 Santa Clara County Housing Needs Allocation, 2007- 2014 Table 2-56 ABAG’s New Construction Need by Household Income Level in Palo Alto, 2007-2014 Units Approved and Remaining Need Building Permit data as of December 2011 shows that 42 percent of the total ABAG/RHNA numbers have been approved or under construction. About 89 percent of the units in the above moderate income category have already been approved or entitled. Like the previous cycle, the City will have difficulty in meeting the very low, low and moderate income housing requirements stipulated by ABAG. Income Level Number of Units % of Total Need Very Low-income Households 690 24% Low-Income Households 543 19% Moderate-Income Households 641 22% Above Moderate-Income Households 986 34% TOTAL 2,860 100% Source:City of Palo Alto, RHNA Cities Very Low <50% Low <80% Moderate, <120% Above Moderate Total Campbell 199 122 158 413 892 Cupertino 341 229 243 357 1,170 Gilroy 319 217 271 808 1,615 Los Altos 98 66 79 74 317 Los Altos Hills 27 19 22 13 81 Los Gatos 154 100 122 186 562 Milpitas 689 421 441 936 2,487 Monte Sereno 13 9 11 8 41 Morgan Hill 317 249 246 500 1,312 Mountain View 571 388 488 1,152 2,599 Palo Alto 690 543 641 986 2,860 San Jose 7,751 5,322 6,198 15,450 34,721 Santa Clara 1,293 914 1,002 2,664 5,873 Saratoga 90 68 77 57 292 Sunnyvale 1,073 708 776 1,869 4,426 Unincorporated 253 192 232 413 1,090 Santa ClaraTotal 13,878 9,567 11,007 25,886 60,338 Source:San Francisco Bay Area Housing Needs Plan 2007-2014 Chapter 2 67 Table 2-57 Progress in Meeting Palo Alto’s Fair Share of the Region’s 2007-2014 Cycle Housing* Income Level Need Entitled/In Process Built/Building Permit Issued 2007-2014 Unmet Need Very Low 690 56 156 478 Low 543 30 9 504 Moderate 641 1 120 520 SUBTOTAL 1,874 87 285 1,502 Above Moderate 986 96 749 141 TOTAL 2,860 183 1,034 1,643 Source: City of Palo Alto - Entitlement and Building Permit Activity 01/01/2007 - 03/01/2013 Table 2-57a Quantified Objectives Income New Construction Rehabilitation Conservation/ Preservation Extremely Low- 45 100 Very Low- 65 175 Low- 20 75 Moderate- 10 600 92 Above Moderate- 650 2400 TOTAL 790 3350 92 As required by Section 65583 of the California Government Code, the goals, policies and actions identified in this document seek to meet quantified housing objectives. Table 2-57a summarizes these findings, which result in a total estimated construction of over 790 new housing units. The estimates for Rehabilitation and Conservation were based on City Planning and Building Department permit data. Chapter 2 68 The graph below shows a comparison between the 1999-2006 cycle and the 2007-2014 cycle achievements: Figure 2-8 Comparison of Achievements in Reaching ABAG Goals in the Past and Current Cycle by Income Level Source: City of Palo Alto, Building Permits Issued and Planning Entitled Data from 2007 to 2011 0% 20% 40% 60% 80% 100% 120% 140% 160% 180% 200% % o f A B A G G o a l s A c h i e v e d Very Low (0-50% of AMI) Low (51-80% of AMI) Moderate (81-120% of AMI) Above Moderate (over 120% of AMI) TOTAL UNITS Percentage Need Achieved As of December 2011 in 2007-2014 Cycle Percentage of Need Achieved in 1999-2006 Cycle Chapter 2 69 Table 2-58 List of Projects with Building Permit Issued and Planning Entitlement Issued by Income Categories as of December 2012 Very Low Income (0% - 50% AMI) Address Entitled/In Process Building Permit Issued 2007- 2014 901 San Antonio (Bridge/3901 Fabian) 56 1072 Tanland (addition to existing apt) 1 3445 Alma (Alma Plaza) 14 488 West Charleston (Treehouse) 35 801 Alma 50 2180 El Camino Real (JJ&F) 6 0 567-595 Maybell 50 0 TOTAL 56 156 Low Income (51% - 80% AMI) Address Entitled/In Process Building Permit Issued 2007- 2014 2051 El Camino Real 1 1072 Tanland (addition to existing apt) 2 2180 El Camino Real (JJ&F) 2 0 195 Page Mill Avenue 18 0 2811 Alma 6 567-595 Maybell 10 0 TOTAL 30 9 Moderate Income (81% - 120% AMI) Address Entitled/In Process Building Permit Issued 2007- 2014 Cottages 26 1101 E Meadow 11 4219 El Camino Real (Hyatt Rickeys) 34 3270-3290 West Bayshore (Classics) 10 901 San Antonio (TKCJL/899 Charleston) 24 1072 Tanland (addition to existing apt) 12 4329 El Camino Real (Palo Alto Bowl) 3 2080 Channing (Edgewood Plaza) 1 0 1 120 Chapter 2 70 Above Moderate Income (Above 120% AMI) Address Entitled/In Process Building Permit Issued 2007- 2014 260 Homer 2 1101 E Meadow 64 4219 El Camino Real (Hyatt Rickeys) 147 1795 El Camino Real 2 3270-3290 West Bayshore (Classics) 86 2825 - 2865 El Camino Real 2 901 San Antonio (Altaire) 103 901 San Antonio (TKCJL) 169 102 University 3 820 Ramona 1 325 Lytton 1 4249 El Camino Real (Juniper Homes) 5 455 Forest Avenue 3 4249 El Camino Real (Summerhill) 45 586 College Avenue 1 433 W Meadow 5 3445 Alma (Alma Plaza) 37 741-749 Webster -3 1128 Webster -1 420 Cambridge 4 4329 El Camino Real (Palo Alto Bowl) 23 265 Lytton Avenue 4 195 Page Mill Ave 64 0 2080 Channing (Edgewood Plaza) 9 0 2640 - 2650 Birch St 5 0 557-559 Lytton -4 718-720 La Para 1 2021 Webster 1 165 Hawthorne 1 524 Hamilton 1 4073-4111 El Camino Real 2 0 4041 El Camino Real (PA Commons) 43 797-807 Matadero (Packard/Emma Ct) 2 365 Hawthorne Ave 1 Chapter 2 71 687 Cowper St 3 0 135 Hamilton 2 0 567-595 Maybell 11 0 96 749 Source: City of Palo Alto - Entitlement and Building Permit Activity 01/01/2007 - 03/01/2013 All 251 very-low and low-income units will be/are deed restricted units. Of the 251 affordable units, 34 very low and low income rental units were created through the City’s Below Market Rate program. Those units are restricted to low income households as established by the State for Santa Clara County for a period of 59 years. The remaining 217 affordable units were created with financial assistance from the City and deed restricted to low, very low and extremely low income households. The City has loaned out over $22 million for the creation of these units. Those units carry a minimum 55-year affordability term, consistent with tax credit financing requirements. However, City documents include options to extend the affordability period. If the 251 entitled/ built low and very low income units are subtracted from the City’s need of 1,233 units, the City’s remaining need for very low and low income households is 982 housing units. State law establishes a density of 20 units per acre as the minimum density necessary to make affordable housing economically feasible in Palo Alto. The City must show that it can accommodate the remaining 982 low and very low income units on sites that have a density of 20 units per acre or higher. In the City’s Housing Inventory Sites (HIS) list, all parcels with an existing zoning density of 20 units per acre or higher have been highlighted. The total number of units provided by the highlighted parcels is 1,056. While the City does have proposed programs that will revise the Zoning Ordinance to increase densities to be consistent with Housing Element law, the City can meet its low and very low needs with existing zoning. Chapter 3 72 CHAPTER 3 HOUSING RESOURCES AND INVENTORY This chapter analyzes the resources available for development, rehabilitation, and preservation of housing in Palo Alto. This chapter of the Housing Element addresses Government Code Sections 65583 and 65583.2, requiring a parcel-specific inventory of sites that are suitable to provide housing to meet a city’s share of the need for housing for all income groups including:  Vacant residentially zoned sites;  Vacant sites with non-residential zoning that allow residential uses;  Underutilized residentially zoned sites that could be developed at a higher density or intensity; and  Non-residential zoned sites that can be redeveloped for and/or rezoned for residential use. In addition, this chapter includes an evaluation of the financial resources available to support housing activities, the administrative resources available to assist in implementing the City’s housing programs, and the opportunities for energy conservation. 3.1 LAND INVENTORY This section describes the inventory of land in Palo Alto that is suitable for residential development, including underutilized sites with the potential for redevelopment. As mentioned in earlier chapters, Palo Alto is basically a “built-out” community. Approximately 55% of Palo Alto’s total land area includes existing and designated parks, open space preserves and agricultural land conservation areas with controlled development regulations. A large portion of the City’s open space includes the Baylands Preserve, a 1,940 acre tract of undisturbed marshland, the largest remaining in the San Francisco Bay. Parks and preserves located on steep rugged unstable woodlands also comprise a significant segment of the City’s open space area Over 23% of Palo Alto’s remaining land area is designated and zoned for single family residential and contains strong existing single-family neighborhoods with distinct identities and character. This leaves less than a quarter of the City’s land area for commercial, industrial, public facilities and multifamily residential uses, and most of this remaining area is already developed. The lack of vacant land and, especially lack of vacant sites with residential zoning, has motivated an effort by the City to encourage redevelopment of parcels with commercial or industrial zoning to mixed use or multifamily residential uses. The City’s long-term policy to allow multifamily residential uses on commercially zoned parcels has resulted in the entitlement and construction of more than 1,000 residential units on sites with prior commercial uses within the current housing element cycle. However, this policy has jeopardized the economic viability of commercial areas. As a result, the City has targeted areas in the updated Housing Element that are more appropriate for multifamily housing. Strategies include limiting conversion of residential land and encouraging mixed uses (residential above retail) in commercial areas to promote residential development close to public transportation and amenities. Chapter 3 73 As detailed in Table 2-56 of Chapter 2, the Regional Housing Needs Allocation (RHNA) for Palo Alto is 2,860 units distributed among the following income groups: 690 very low income; 543 low income; 641 moderate income; and 986 above moderate income units. The RHNA represents the minimum number of housing units each community is required to plan for by identifying “adequate sites” for future housing development based on analysis of the adequacy and suitability of these sites to fulfill the City’s share of regional housing needs. The City intends to demonstrate its ability to accommodate its share of housing needs based on the following combination of approaches:  Housing units built or with building permits issued since January 2007;  Housing currently in process (discretionary review completed but building permit not yet issued);  Potential housing in existing residentially zoned sites with existing non-residential uses;  Potential housing in commercial zoning districts that could accommodate mixed use development. Zoning Appropriate to Accommodate Housing for Lower-Income Households State law establishes a density of 20 units/acre as the minimum density necessary to make affordable housing economically feasible in Palo Alto and other cities with a population under 100,000 that are located in a Metropolitan Statistical Area (MSA) with a population less than 2 million. This so-called “default” density is assigned according to the population of the community and the MSA regardless of local development conditions. In Palo Alto, parcels zoned in multifamily residential zoning districts RM-30, RM-40, Residential Transition 35 (RT35) and Residential Transition 50 (RT50) allow residential densities of 20 to 40 dwelling units per acre. Commercial zoning districts Commercial Downtown (CD), Commercial Service (CS), Community Commercial (CC) also allow residential densities of 20 to 40 dwelling units per acre in mixed use projects. The Pedestrian and Transit Oriented District (PTOD) allows densities up to 40 dwelling units per acre. These densities meet or exceed the default density standard for Palo Alto. Parcels zoned in multifamily residential zoning districts RM-15 and the Commercial Neighborhood (CN) zoning district allow residential densities of up to 15 dwelling units per acre. The City’s Housing Element update proposes revising the Zoning Ordinance to allow up to 20 dwelling units per acre on CN zoned parcels listed as Housing Inventory Sites (HIS) to meet the default density standard for Palo Alto. The following table shows allowed residential densities in specific zoning districts within the City. The City does not require rezoning additional sites to meet its lower income housing need. After subtracting the 251 lower income units approved or built during the 2007-2014 cycle from the City’s low and very low requirement of 1,233 units, the City has an unmet need of 982 low and very low income units. In order to accommodate the very low and low income needs, State law requires the City to identify sites that have a density of 20 units per acre or higher, as per the density assigned to the City per State law. In the City’s Housing Inventory Sites (HIS) list, all parcels with a density of 20 units per acre or more have been highlighted. The total number provided by the highlighted parcels is 1,056 housing units. Therefore the City can accommodate its unmet low and very low income housing need for the 2007-2014 RHNA cycle by right. Chapter 3 74 While the City does have proposed programs that will revise the Zoning Ordinance to allow up to 20 dwelling units per acre for certain zoning districts, the City can meet its low and very low needs with existing zoning. In addition, an application has been submitted to rezone the site to Planned Community (PC) to allow 60 units of extremely low to low income senior affordable rental housing and 15 market rate units by right, for a total of 75 units for 595 Maybell Avenue. There are now four units on the site, so the net yield will be 71 units. This site, with the proposed rezoning will meet the criteria for accommodating the identified unaccommodated need: the zoning will allow multiple family residential uses by right, the site is large enough to accommodate more than 16 units, and the density will be about 30 units per acre. Although the City does not plan to use this property to meet its unaccommodated need requirements, the rezoning will provide additional affordable housing to help the City meet its RHNA numbers. Table 3-1 Allowed Residential Densities per Zoning District Zoning District Maximum Allowed Residential Density (du/ac) CN 15* CC 30 CS 30 CD 30-40 RM-15 15 RM-30 30 RM-40 40 Residential Transition Zoning Districts (RT) Zoning District Allowed Residential Density (du/ac)** RT-35 25-50 RT-50 25-50 * The City’s Housing Element update proposed to revise the Zoning Ordinance to allow up to 20 dwelling units per acre on CN zoned parcels included in the Housing Inventory Sites (HIS). ** Residential densities and Floor Area Ratio (FAR) calculations in Residential Transition zoning districts varies depending on the type of project. Residential densities are based on maximum residential FAR and maximum average unit size of 1,250 square feet. Vacant and Infill Redevelopment Opportunities to Accommodate Residential Development Vacant Residential Land There are two vacant sites currently zoned for multifamily residential remaining in Palo Alto based on GIS and aerial photo analysis. The largest site is a remnant of the Sand Hill Road Extension Project which created a 2.5 acre parcel immediately adjacent to Stanford’s 1180 Welch Road Apartments. Although there are no current plans to develop the site, it is reasonable to expect that it could be used for an expansion of the 1180 Welch Road Apartments that is in the RM-40 zoning district and allows residential densities of up to 40 dwelling units per acre. If the site were developed for housing, the site should yield approximately 70 additional units. The other vacant site is approximately ¾ of an acre located on El Camino Real and currently zoned RM-15. Based on the zoning, the parcel could yield up to 11 units. Chapter 3 75 El Camino Real Sand Hill Rd, Welch and Pasteur Drive Chapter 3 76 Infill Redevelopment Opportunities to Accommodate Residential Development The City has had success in infill redevelopment of underutilized sites into higher density multifamily residential or mixed use development; the residential density factor of 20 dwelling units per acre assumed for sites identified in the Housing Inventory is actually lower than the average density of recent residential projects built or approved in the City, therefore, it is assumed that development on proposed HIS parcels may be higher than the 20 units used to calculate site yield. The following table illustrates the residential densities of multifamily residential or mixed use projects with 10 or more units built or approved since January of 2007. Table 3-2 Residential Densities of Multifamily Residential or Mixed Use Project Built or Approved SITE ADDRESS LOT SIZE (ac) NUMBER OF UNITS APPROVED/BUILT RESIDENTIAL DENSITY APPROVED/BUILT 1101 E. Meadow Dr. 4.36 75 17.19 4219 El Camino Real 13.80 181 13.11 3270 W Bayshore Rd. 6.46 96 14.87 901 San Antonio Ave 12.07 352 29.16 3445 Alma Street 4.22 51 12.09 4249 El Camino Real 4.13 45 10.90 200 San Antonio Ave. 3.46 45 13.02 488 W. Charleston Rd. 0.70 35 50.30 801 Alma Street 0.60 50 83.33 4239 El Camino Real 2.18 26 11.90 4041 El Camino Way 0.83 43 51.84 AVERAGE RESIDENTIAL DENSITY 27.97 For purposes of identifying parcels suitable for residential or mixed use redevelopment, the following criteria were used: o Improvement on sites at least 20 years old o Site of 10,000 sq. ft. or more with a yield of 5 units or more o Site with an A/V of less than 1.5, or with A/V ratios of greater than 1.5 that were determined to have an artificially low assessed land value (parcels under the same ownership for more than 10 years), with the assessed land value is far below current market land values. The improvements on these parcels are much older and are candidates for redevelopment. o Windshield survey of underdeveloped residential or commercial sites consisting of 1 or 2 story structures. Underdeveloped commercial sites were defined as Class B office space structures or older buildings with wood construction. The above criteria were chosen based on the types of sites that had been redeveloped with mixed use or residential projects within the past several years. Chapter 3 77 In Palo Alto, the market has supported infill redevelopment and intensification of commercially zoned properties to residential or mixed uses. Staff evaluated the assessed value (A/V) ratio of the HIS parcels based on the data available from the County Assessor’s Office. This ratio compares the County Assessor’s assessed value of the improvements on the parcel to the County Assessor’s value of the land. The A/V ratio of 1.5 has been used by other jurisdictions to evaluate the redevelopment potential of property. If the ratio is less than 1.0, the improvements are worth less than the land. Of the 180 parcels identified in the Housing Inventory Sites, approximately 81% have an A/V ratio of less than 1.5 with 66% having an A/V ratio of less than 1.0. Sites with greater than 1.5 A/V ratios include parcels in the Mayfield Development agreement, which requires housing development as part of the agreement. In addition, due to the Proposition 13 assessed value restrictions, the A/V ratio on some of the commercial properties may be overestimated due to those assessment restrictions. The City’s Housing Element update also includes Program (H2.2.2) that provides incentive(s) to mixed-use developments if the project is 9 units or fewer, yields at least 20 dwelling per acre and a maximum unit size of 900 square feet to further facilitate and encourage the infill redevelopment of commercial sites with a residential component. In addition, if the Housing Inventory Site is within a quarter mile of a fixed rail station, the City will explore limited exceptions to height limits to further encourage higher density housing. The City’s approach to assessing the number of units that can be potentially achieved on most of the sites is based on a realistic density of 50 to 67% percent the maximum zoning density. The table below illustrates the current allowed residential density per zone and the density factor used to determine realistic capacity for the Housing Inventory sites. Table 3-3 “Realistic Capacity” Density Factor Compared to Allowed Residential Densities per Zoning District Zoning District Maximum Allowed Residential Density (du/ac) Realistic Capacity Density (du/ac) CN 15 20* CC 30 20 CS 30 20 CD 30-40 20 RM-15 15 20** RM-30 30 20 RM-40 40 20 Residential Transition Zoning Districts (RT) Zoning District Allowed Residential Density (du/ac)*** Realistic Capacity Density (du/ac)**** RT-35 25-50 25-30 RT-50 25-50 25-30 * The updated Housing Element proposes amending the Zoning Ordinance to allow up to 20 dwelling units per acre on CN zoned parcels included in the Housing Inventory Sites (HIS). ** There is only one site identified in the HIS with an RM-15 zoning district. The site currently has a rezoning application in process requesting a zone change from RM-15 to RM-30. ***Residential Densities and Floor Area Ratio (FAR) calculations in Residential Transition zoning districts varies depending on type of development of project. Residential Densities are based on Maximum Residential FAR and Maximum Average unit size of 1,250 square feet. Exclusive Residential projects can result in higher densities than Mixed Use projects. ****Based on current development standards and rounding of figures, Realistic Capacity Density in the Residential Transition (RT) zoning districts varies depending on lot size. Realistic capacity for RT zoning districts is calculated based on development standards for mixed use projects. Chapter 3 78 Housing Inventory Sites – Mixed Use Development in Existing Commercial Zoning Districts During the preparation of this Housing Element, City staff conducted a comprehensive review of vacant and underutilized sites in the City that could accommodate residential development. As mentioned earlier in the chapter, the City’s “built out” nature, lack of vacant land, strong existing single family neighborhoods, and lack of annexation opportunities provide limited opportunities for exclusive residential development. With City Council and Planning and Transportation Commission guidance, staff focused primarily on residential and commercially zoned land that could accommodate additional residential development. These sites are typically located within one half mile radius of major transit stations, University Avenue and California Avenue Transit Stations or within a quarter mile of El Camino Real, which is served by major bus routes and is planned for future public transit intensification. In addition, the sites are generally in areas that are in proximity to or provide accessibility to urban services and jobs and are close to retail and service uses that could support their redevelopment to residential or mixed use. All but a few of the sites are occupied by one to two story, older or underutilized commercial buildings. Improvements on the identified sites are at least 20 years of age and were not significantly redeveloped since 1990. The sites have no existing residential uses and are likely to be redeveloped with higher value mixed uses with residential units in the future. Sites included in the inventory in this category have lot areas over 10,000 square feet and can potentially yield at least 5 residential units at a realistic density calculation of 20 dwelling units per acre. The City has had success in infill redevelopment in these areas on parcels with similar sizes, however, the potential for parcel consolidation could result in higher density yields. Given the lack of vacant land remaining in Palo Alto, redevelopment of such sites is an important source for future housing in the area. Many of the City’s commercially zoned parcels which allow residential uses have specific requirements, mainly that the project include a ground floor retail component. There have been many successful mixed use projects developed in the City’s commercial areas which have included ground floor retail and residential units. Following is a list of recently completed projects on smaller sites which yielded projects with residential components at densities ranging from 16 to 28 units per acre:  420 Cambridge Avenue, 4 units on 6,012 square foot parcel (28 units/acre)  2180 El Camino Real, 4 units on 22,365 square foot parcel (16 units/acre)  102 University Avenue, 3 units on 7920 square foot parcel (16 units/acre)  2051 El Camino Real, 2 units on 4800 square foot parcel (18 units/acre) The commercially zoned parcels selected in the City Housing Inventory Sites (HIS) list were based on parcels within the City’s transit corridors of El Camino Real, University Avenue and California Avenue. However, there are number of other mixed use sites throughout the City that would be equally suitable candidates for mixed use redevelopment. There have been numerous mixed use projects on similar sites that have occurred throughout the City. Based on development trends and to account for the potential for some non-residential uses (as a part of a mixed use development), the realistic capacity used in the HIS list is estimated at 66 per cent of the maximum capacity. Many of the identified sites are commercial uses along the El Camino Real and California Avenue corridors are typically low-intensity, one-story and two story buildings, surrounded by Chapter 3 79 surface parking, constructed in the late 1960’s and 1970’s with relatively little development or improvements in the past decade. These corridors have seen less development than other areas of the City, such as the University Avenue corridor. However, since many of the sites have not been improved and with the City real estate market returning to pre-2008 levels, the identified sites seem more appropriate for redevelopment opportunities. In addition, the California Avenue corridor has been designated by the City Council as a Priority Development Area, through ABAG’s FOCUS program, to provide incentives and attract greater investment in the California Avenue corridor. University Avenue Downtown Area University Avenue/ Downtown area is a thriving regional hub of commercial, residential and retail activity which includes the South of Forest Area (SOFA). The entire area is oriented around the University Avenue Multi-modal Transit Station area, the Peninsula’s busiest transit station, and should optimize the effectiveness of the multi-modal transit center and preserve nearby residential areas. The City’s vision for this area includes improving gateways to the City, improving pedestrian, bicycle, transit and auto connections, creating a major civic space at the Caltrain Station that links University Avenue/ Downtown and Stanford University, redeveloping underutilized infill parcels with a mix of uses such as retail, housing, office hotel, and medical facilities, and improving public park space. The downtown area is one of the “Growth Opportunity Areas” in the Bay Area’s “One Bay Area” Sustainable Community Strategy (SCS) land use scenarios. The Comprehensive Plan Land Use designation for the downtown area is Community Commercial and typically provides a wider variety of uses than the neighborhood shopping areas. Most of the downtown area also falls within the Transit Oriented Residential Comprehensive Plan land use designation because of its proximity to the University Avenue/Downtown multi-modal transit station. This land use designation is intended to generate residential densities that support use of public transportation, especially the use of the Caltrain commuter rail, which provides service throughout the area, including to San Francisco to the north and to San Jose to the south. The existing zoning in the downtown area is Commercial Downtown (CD) which allows a total Floor Area Ratio (FAR) of up to 3.0 for mixed use development with residential density of up to 40 dwelling units per acre which is based on the total site area, irrespective of the percent of the site devoted to commercial use. The other Housing Inventory Sites within the downtown area are multifamily residential zoned parcels now developed with commercial uses and the South of Forest (SOFA) Phase 2 area which will all be discussed later in this section. Existing Mixed Use Projects – Downtown Palo Alto Chapter 3 80 Map of Downtown Palo Alto Chapter 3 81 California Avenue Transit Neighborhood/PTOD Area California Avenue is a second “main street” in the City and is also served by a multi-modal transit station that ranks 11th overall in ridership among the 29 Caltrain stations that serve the region. It is more local-serving than University Avenue/Downtown but is the closest business district to employees and visitors to Stanford Research Park and portions of Stanford University. It is located within the oldest part of the City, with origins dating back to the 1850s when it was the main commercial street for the town of Mayfield. This connection to the past is valued by the community and is an important part of what makes the area unique. Buildings are mostly two stories tall, with surface parking located off rear alleys. According to the Santa Clara County Assessor records, many of the structures on California Avenue were built between the late 1940’s to the early 1970’s. There has not been much development in the California Avenue corridor since that time. The scale of development provides an environment that is comfortable for pedestrians. A recent streetscape project provided a more modern street design and amenities that will support the creation of a more vibrant pedestrian and bike oriented commercial and residential district. Sites included in the inventory in this category have lot areas over 10,000 square feet and can potentially yield at least 5 residential units at a realistic density calculation of 20 dwelling units per acre; the City has had success in infill redevelopment in these area with similar or even smaller sized parcels. Housing Inventory Sites within this area consist of one to two story structures with commercial uses including but not limited to retail, eating and drinking, offices and surface parking. The area is also a designated Priority Development Area (PDA) through the Association of Bay Area Governments (ABAG), a locally identified, infill development opportunity area within existing communities. Inclusion in the PDA avails the neighborhood to a number of financial resources to help encourage redevelopment within the PDA. Between the strong real estate market and the additional financial resources, it may encourage developers on the smaller lots to develop mixed uses. In addition, by the City designating the California Ave. neighborhood as a PDA, it signifies City acceptance for higher density developments for California Ave. PDA’s are one of the key strategies in the Bay Area’s “One Bay Area” Sustainable Community Strategy (SCS) a strategy being developed by a collaboration of regional agencies, including the Association of Bay Area Governments (ABAG), the Bay Area Air Quality Management District (BAAQMD), the Bay Conservation and Development Commission (BCDC) and the Metropolitan Transportation Commission (MTC). The Comprehensive Plan Land Use designations for the California Avenue area are Community Commercial, Service Commercial and Neighborhood Commercial. Service Commercial and Neighborhood Commercial land use designations both allow residential and mixed use projects. Most of the California Avenue area also falls within the Transit Oriented Residential Comprehensive Plan land use designation because of its proximity to the California Avenue transit station. This land use designation is intended to generate residential densities that support use of public transportation, especially the use of Caltrain. The existing zoning in the California Avenue area primarily includes Community Commercial (CC) and Community Service (CS) which allow a total Floor Area Ratio (FAR) for mixed use developments of up to 2.0 for CC zoned sites and 1.0 for CS zoned sites. CC and CS zoned sites both allow a residential density of up to 30 dwelling units per acre, which is calculated based upon the total site area, irrespective of the percent of the site devoted to commercial use. In addition, the California Avenue Area can Chapter 3 82 also be subject to the adopted California Avenue Pedestrian and Transit Oriented District (PTOD), which allows higher density residential dwellings on commercial, industrial and multifamily parcels within a walkable distance of the California Avenue Caltrain station. The PTOD combining district allows exclusive multifamily residential development with a total FAR of 1.0 and a residential density of up to 40 dwelling units per acre on commercially zoned parcels. A good example of a PTOD project developed on a smaller site is 420 Cambridge Ave. Four residential units were built on a 6,012 sq. ft. lot, giving a per acre yield of approximately 28 units per acre. Mixed use projects within the PTOD are allowed a total FAR of 1.25 and a residential density of up to 40 dwelling units per acre. The other Housing Inventory Sites within the California Avenue area are multifamily residential zoned parcels with commercial uses which will be discussed later in this section. Existing Mixed Use Development California Avenue Area Map of California Ave Pedestrian & Transit Oriented Development District Chapter 3 83 El Camino Real Mixed Use Transit Corridor Area El Camino Real has been historically viewed as an automobile-oriented strip with neighborhood commercial uses, and accommodates the highest volume of bus transit service in the Mid- Peninsula. Many of the parcels along the El Camino Real corridor are commercial uses are typically low-intensity, one-story and two story buildings, surrounded by surface parking, constructed in the late 1960’s and 1970’s with relatively little development or improvements in the past decade. Over time, hotel, automotive and other service commercial uses have been replaced by higher density housing along some segments of the corridor. The Palo Alto Comprehensive Plan calls for creating an environment along the corridor that is more hospitable for pedestrians and that can be identified as one or more distinct centers, rather than a commercial strip. It is envisioned to become a well-designed, compact, vital, multi-neighborhood center with diverse uses, a mix of one-, two- and three-story buildings fronting the street, and a network of pedestrian-oriented streets, creating a dynamic mixed-use corridor that serves the diverse needs of the community. The challenge for this kind of transformation is to develop a new character for both residential and commercial uses which creates an attractive environment for pedestrians, motorists and transit riders while fitting in with existing development and low density residential areas adjacent to El Camino Real. The El Camino Real Mixed-Use Transit Corridor area is another “Growth Opportunity Area” land use scenario in the Bay Area’s “One Bay Area” Sustainable Community Strategy (SCS). Similar to the land use designations for the California Avenue area, the El Camino Real Transit Corridor Comprehensive Plan land use designations are primarily Service Commercial and Neighborhood Commercial. Service Commercial and Neighborhood Commercial land use designations both allow residential and mixed use projects in appropriate locations. The existing zoning in the El Camino Real Mixed Use Transit Corridor primarily includes Community Service (CS) and Commercial Neighborhood (CN) zoning districts. As mentioned above, the CS zoning district allows a Floor Area Ratio (FAR) for mixed use developments of up to 2.0 and a residential density of up to 30 dwelling units per acre. The CN zoning district allows a FAR for mixed-use development of up to 1.0 along El Camino Real and a residential density of up to 15 dwelling units per acre, which is computed based upon the total site area, irrespective of the percent of the site devoted to commercial use. The City’s updated Housing Element Program 2.2.2 proposes to revise the Zoning Ordinance, including increasing the density of up to 20 dwelling units per acre on CN-zoned parcels included in the Housing Inventory Sites (HIS). Housing Inventory Sites within the El Camino Real Mixed-Use Transit Corridor also include lands that are part of a development agreement with Stanford University. Known as the “Mayfield Agreement” adopted in 2004, the agreement stipulates the construction of at least 250 units in two separate areas of the Stanford Research Park now occupied by Research and Development and office buildings. The sites include four parcels along El Camino Real totaling approximately 2.5 acres and three parcels totaling approximately 17 acres along Upper California Avenue. The agreement requires at least 50 to 70 of the 250 units (on the El Camino Real parcels) to be affordable to low income households. The City’s executed Mayfield Agreement requires the construction of 250 dwelling units on identified housing sites described in the Agreement. Of the 250 units to be developed, 70 units are required to be affordable rental units to very-low and low income households. The Chapter 3 84 Agreement with Stanford University requires that the University submit a building permit application for 185 units by the end of December 2013 with a specific requirement that an application for Architectural Review be submitted by December 2013 for the 70 affordable units. The agreement stipulates that the remaining units be proposed no later than December 2020. However, nothing precludes the University from submitting applications prior to that deadline. The Agreement establishes the absolute deadline, and the sites are now available for development. Therefore, at a minimum, the 70 affordable units will begin the permit approval process by 2014. Because the City of Palo Alto is primarily built out, the available sites for new development are limited. Over the past five years, there have been three projects on sites less than one acre that accommodated 128 units at densities ranging from 50 to 83 units per acre. These projects included a total of 85 units affordable to low income households. The City has a good history of mixed use residential developments. Of the 49 residential land use approvals since 2006, 19 of the approvals were approved as mixed use projects. Of the 19 mixed use projects, 11 of the projects were done on parcels of less than half an acre. Residential densities on the 11 projects ranged from 2 units per acre up to 28 units per acre. There was some affordable housing created on the smaller sites. One affordable rental unit was approved as part of a three residential unit development on a .18 acre parcel. And while actual affordable units would not be provided on these smaller mixed use lots, with the City proposing to lower its BMR Existing Mixed Use Development – El Camino Real Transit Corridor Chapter 3 85 threshold to three residential units, it anticipates capturing additional housing fees from these smaller developments. These fees would be used to finance future affordable housing developments. In order to encourage more dense housing yields, the City is proposing a number of lot consolidation programs. The advantages of lot consolidation include a potential higher yield of units. Typically, based on the City’s density calculations, the maximum density of a smaller lot always contain a “fractional” unit. By encouraging lot consolidation, these smaller lots would be able to add together the fractional units to create a whole unit. Also, with the removal of a setback requirement, it allows for greater site design flexibility, including parking, which would also yield more units. The City chose smaller parcels, generally less than .25 acres, as potential candidates for lot consolidation. As mentioned , the City has had a number of mixed use development on parcels less than .5 acres, however consolidating these smaller parcels provide a greater feasibility of a higher yield mixed use development. Although smaller parcels were chosen for lot consolidation, it does not preclude larger lots from consolidating. As shown in the City’s HIS maps, there are a number of adjacent sites of varying sizes throughout the City. Those sites also present good lot consolidation opportunities. The following table identifies Commercially Zoned sites in the University Avenue, California Avenue and El Camino Real Corridor that could accommodate up to 1,164 residential units in infill Mixed Use-Residential redevelopment with the current zoning designations, based on the above analysis. Chapter 3 86 Table 3-4 Table of Commercially Zoned Sites Notes: 1. Parcels highlighted in orange denotes zoning density greater than 20 units per acre; parcels with proposals for market rate housing are excluded. 2. *CN Parcels to be rezoned to 20 units per acre. 3. Parcels with an Assessed Value Ratio greater than 1.5 were determined to have an artificially low assessed land value from parcels under the same ownership for more than 10 years; the assessed land value is far below current market land values. APN SITE ADDRESS ZONING DISTRICT RESIDENTIAL DENSITY ALLOWED MAXIMUM YIELD LAND USE DESIGNATION LOT SIZE (ac) REALISTIC CAPACITY EXISTING USE ON SITE CONSTRAINTS/ OPPORTUNITIES ASSESSED VALUE RATIO 132-37-019 423 Page Mill Rd. CS(D) 30 du/ac 4 CN 0.15 2 Vacant SFD Vacant; Small lot; Consolidation Opportunity. An application has been submitted to merge these lots and develop an 8-unit multifamily project, the project will include 3 units affordable to low income residents through density bonus program 0.12 132-37-018 433Page Mill Rd. CS(D) 30 du/ac 4 CN 0.15 2 Vacant SFD 0.12 132-37-017 441 Page Mill Rd. CS(D) 30 du/ac 4 CN 0.15 2 Vacant SFD 0.26 132-37017 451 Page Mill Rd. CS(D) 30 du/ac 4 CN 0.15 2 Vacant SFD 0.27 132-41-085 3707 El Camino Real CN* 15 du/ac 3 CN 0.18 3 1 Story Personal Service; Retail Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.99 124-32-013 470 Cambridge Av CC (2) 30 du/ac 7 CC 0.23 5 1 Story Religious Institution: Existing Non- Residential Use 1.64 Chapter 3 87 Surface Parking 124-33-005 410 Sherman Av CC (2) 30 du/ac 7 CC 0.24 5 2 Story Office Commercial Existing Commercial Use 4.17 124-29-007 251 California Av CC (2)(R)(P) 30 du/ac 7 CC 0.26 5 1 Story retail Existing Commercial Use 1.19 124-32-035 334 California Av CC (2)(R)(P) 30 du/ac 8 CC 0.27 5 2 Story Retail; Eating Drinking; Commercial Existing Commercial Use 0.74 124-33-061 479 California Av CC (2)(R)(P) 30 du/ac 7 CC 0.24 5 1 Story commercial; Financial Service Existing Commercial Use 0.55 120-15-090 595 Bryant St CD-C (GF)(P)/ 40 du/ac 8 CC 0.22 5 1 Story Retail; Eating Drinking Small lot ; consolidation opportunity 0.75 120-03-021 581 University Av CD-C (P) 40 du/ac 10 CC 0.26 5 1 Story Financial Service Existing Commercial Use 0.73 120-03-037 578 University Av CD-C (P) 40 du/ac 8 CC 0.22 5 1 Story Office Existing Commercial Use 3.45 120-03-067 541 Cowper St CD-C (P) 40 du/ac 9 CC 0.23 5 1 Story commercial Existing Commercial Use 1.47 120-15-007 401 Waverley St CD-C (P) 40 du/ac 8 CC 0.22 5 1 Story Retail; personal Service Small lot ; consolidation opportunity 1.09 120-15-013 420 Cowper St CD-C (P) 40 du/ac 10 CC 0.25 5 2 story office Existing Commercial Use 2.12 120-26-109 542 High St CD-C (P) 40 du/ac 10 CC 0.25 5 ! Story Commerical; Retail office Existing Commercial Use 1.38 120-26-111 135 Hamilton Av CD-C (P) 40 du/ac 8 CC 0.22 5 Surface parking Parking serving adjacent commercial uses 0 124-31-059 2101 El Camino Real CN* 15 du/ac* 5 CN 0.25 5 1 Story Retail; Personal Existing Commercial Use; 0.91 Chapter 3 88 Service; Surface parking Current Maximum Residential Density is 15 du/ac 132-40-062 480 Wilton Av CN* 15 du/ac 5 CN 0.25 5 1 Story Eating Drinking; Surface parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.91 132-46-106 4112 El Camino Wy CN* 15 du/ac 5 CN 0.25 5 1 Story Eating Drinking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 2.41 137-01-116 2000 El Camino Real CN* 15 du/ac 5 CN 0.27 5 1 Story Eating Drinking; Surface parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 1.13 137-08-078 3636 El Camino Real CN* 15 du/ac 5 CN 0.25 5 1 Story Eating Drinking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.09 137-08-097 3666 El Camino Real CN* 15 du/ac 5 CN 0.25 5 1 Story Retail: Commercial; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.44 137-11-091 3972 El Camino Real CN* 15 du/ac 5 CN 0.25 5 Gas Station Underground Storage Tanks; Current Maximum Residential Density is 15 du/ac 0.27 137-11-098 3780 El Camino Real CN* 15 du/ac 5 CN 0.24 5 1 Story Retail; Commecial; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.13 Chapter 3 89 120-33-024 711 El Camino Real CS 30 du/ac 7 CS 0.24 5 1 Story Commercial; Office Existing Commercial Use 0 132-38-011 3275 Ash St CS 30 du/ac 8 CS 0.27 5 1 Story Office; Commercial; Surface Parking Existing Commercial Use 2.47 132-38-017 460 Lambert Av CS 30 du/ac 6 CS 0.22 5 Surface parking Small lot ; consolidation opportunity 0.04 132-38-018 460 Lambert Av CS 30 du/ac 6 CS 0.22 5 Surface parking Small lot ; consolidation opportunity 0.04 132-38-025 455 Portage Av CS 30 du/ac 6 CS 0.22 5 1 Story Commercial Office Small lot ; consolidation opportunity 4.26 132-38-032 3159 El Camino Real CS 30 du/ac 7 CS 0.24 5 2 Story Commercial Existing Commercial Use 1.06 132-38-047 3260 Ash St CS 30 du/ac 6 CS 0.22 5 SFD Small lot ; consolidation opportunity 5.62 137-08-079 3516 El Camino Real CS 30 du/ac 6 CS 0.23 5 1 Story Personal Service Existing Commercial Use 0.09 137-08-088 3508 El Camino Real CS 30 du/ac 7 CS 0.24 5 Automotive Service; Surface Parking Existing Commercial Use 0.16 124-28-003 2260 Park Bl CC (2) 30 du/ac 8 CC 0.29 6 Surface parking Parking serving adjacent commercial uses 0 124-29-011 2555 Park Bl CC (2) 30 du/ac 8 CC 0.29 6 2 Story Office Commercial Existing Commercial Use 2.46 124-28-033 250 California Av CC (2)(R)(P) 30 du/ac 8 CC 0.28 6 1 Story Eating Drinking Existing Commercial Use 0.57 124-32-034 300 California Av CC (2)(R)(P) 30 du/ac 8 CC 0.27 6 2 Story Eating Drinking; Commercial Existing Commercial Use 0.73 Chapter 3 90 120-15-045 353 University Av CD-C (GF)(P) 40 du/ac 12 CC 0.3 6 1 Story Commerical; Retail; Office Existing Commercial Use 2.95 120-16-020 635 Waverley St CD-C (P) 40 du/ac 12 CC 0.31 6 2 Story Office Existing Commercial Use 0.9 120-27-038 658 High St CD-C (P) 40 du/ac 12 CC 0.32 6 2 Story Commercial Surface Parking Existing Commercial Use 1.89 124-30-015 1963 El Camino Real CN* 15 du/ac 6 CN 0.28 6 Gas Station Underground Storage Tanks; Current Maximum Residential Density is 15 du/ac 0.04 132-35-045 3705 El Camino Real CN* 15 du/ac 6 CN 0.28 6 1 Story Retail Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.26 120-33-004 67 Encina Av CS 30 du/ac 8 CS 0.27 6 1 Story Commercial; Office Existing Commercial Use 1.17 132-37-055 3051 El Camino Real CS 30 du/ac 9 CS 0.3 6 1 Story Retail; Surface Parking Existing Commercial Use 0.45 132-38-058 320 Lambert Av CS 30 du/ac 8 CS 0.28 6 1 Story Office Commercial; Light Industrial Existing Commercial Use 6.46 132-38-060 280 Lambert Av CS 30 du/ac 8 CS 0.28 6 1 Story Office Commercial; Light Industrial Existing Commercial Use 0.53 132-38-061 292 Lambert Av CS 30 du/ac 9 CS 0.32 6 1 Story Office Commercial; Light Industrial Existing Commercial Use 0.93 132-39-087 455 Lambert Av CS 30 du/ac 9 CS 0.32 6 1 Story Commercial Existing Commercial Use 0.56 Chapter 3 91 142-20-055 3160 El Camino Real CS 30 du/ac 8 CS 0.29 6 2 Story Office; Surface Parking Existing Commercial Use 0.03 132-31-071 2747 Park Bl GM 6 LI 0.3 6 Vacant Lot Needs Rezoning to allow Residential Use 0.51 124-32-040 414 California Av CC (2)(R)(P) 30 du/ac 11 CC 0.37 7 2 Story Financial Services; Surface Parking Existing Commercial Use 0.49 120-15-015 469 University Av CD-C (GF)(P) 40 du/ac 13 CC 0.34 7 1 Story Commercial; Retail; Eating Drinking Existing Commercial Use 1.7 120-15-103 360 University Av CD-C (GF)(P) 40 du/ac 13 CC 0.34 7 1 Story Retail Existing Commercial Use 1 120-16-011 630 Cowper St CD-C (P) 40 du/ac 13 CC 0.34 7 1 Story Office Existing Commercial Use 0.45 120-26-002 130 Lytton Av CD-C (P) 40 du/ac 13 CC 0.34 7 2 Level Parking Structure Parking serving adjacent commercial uses 0.36 132-46-100 4115 El Camino Real CN* 15 du/ac 7 CN 0.35 7 1 Story Eating Drinking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 1.03 137-08-081 3630 El Camino Real CN* 15 du/ac 7 CN 0.37 7 2 Story Office; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.36 137-11-078 3700 El Camino Real CN* 15 du/ac 7 CN 0.36 7 1 Story Personal Service; Retail; Surface Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0 Chapter 3 92 Parking 137-11-083 3896 El Camino Real CN* 15 du/ac 7 CN 0.32 7 1 Story Retail; Eating Drinking; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.56 132-37-033 2905 El Camino Real CS 30 du/ac 9 CS 0.32 7 2 Story Commercial: Surface Parking Existing Commercial Use 0.17 132-37-052 2951 El Camino Real CS 30 du/ac 9 CS 0.32 7 1 Story Retail; Commecial Existing Commercial Use 0.62 132-37-056 3001 El Camino Real CS 30 du/ac 9 CS 0.33 7 1 Story Retail; Surface Parking Existing Commercial Use 1.08 132-38-048 268 Lambert Av CS 30 du/ac 10 CS 0.35 7 1 Story Office Commercial; Light Industrial Existing Commercial Use 0.64 132-41-088 3801 El Camino Real CS 30 du/ac 10 CS 0.35 7 1 Story Office; Surface Parking Existing Commercial Use 1.14 132-46-119 4195 El Camino Real CS 30 du/ac 10 CS 0.35 7 1 Story Automotive Services Existing Commercial Use 0.88 132-46-120 4193 El Camino Real CS 30 du/ac 10 CS 0.36 7 1 Story Medical Office; Automotive Services Existing Commercial Use 0.56 120-03-030 528 University Av CD-C (GF)(P) 40 du/ac 15 CC 0.38 8 1 Story Commercial; Retail Existing Commercial Use 1.46 124-33-066 2585 El Camino Real CN* 15 du/ac 8 CN 0.4 8 Surface parking Parking serving adjacent commercial uses 0 Chapter 3 93 132-40-059 3609 El Camino Real CN* 15 du/ac 8 CN 0.42 8 Gas Station Underground Storage Tanks; Current Maximum Residential Density is 15 du/ac 0 132-41-083 3783 El Camino Real CN* 15 du/ac 8 CN 0.42 8 1 Story Eating Drinking; Retail; Commercial: Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 1.33 137-01-070 2200 El Camino Real CN* 15 du/ac 8 CN 0.41 8 Gas Station Underground Storage Tanks; Current Maximum Residential Density is 15 du/ac 0.11 132-38-027 425 Portage Av CS 30 du/ac 12 CS 0.4 8 1 Story Commercial; Office Existing Commercial Use 0.31 132-38-045 3200 Ash St CS 30 du/ac 11 CS 0.39 8 1 Story Office; Surface Parking Existing Commercial Use 4.6 132-38-046 3250 Ash St CS 30 du/ac 11 CS 0.38 8 2 Story Office Commercial Existing Commercial Use 1.13 148-09-010 4335 El Camino Real CS 30 du/ac 12 CS 0.4 8 2 Story Commercial; Office Existing Commercial Use 1.21 120-34-014 98 Encina Av CC 30 du/ac 13 CC 0.44 9 Surface parking Parking serving adjacent commercial uses 0.01 124-30-017 1921 El Camino Real CN* 15 du/ac 9 CN 0.43 9 1 Story Eating Drinking; Surface parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.97 132-46-104 4128 El Camino Wy CN* 15 du/ac 9 CN 0.45 9 2 Story Office Existing Commercial Use; Current Maximum Residential Density 0.32 Chapter 3 94 is 15 du/ac 137-01-113 2280 El Camino Real CN* 15 du/ac 9 CN 0.43 9 1 Story Eating Drinking; Surface parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.06 137-01-125 2257 Yale St CN* 15 du/ac 9 CN 0.43 9 2 Story Office; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 1.23 132-38-026 435 Portage Av CS 30 du/ac 13 CS 0.45 9 1 Story Commercial Office Existing Commercial Use 0.34 132-39-071 429 Lambert Av CS 30 du/ac 13 CS 0.45 9 1 Story Automotive Services; Office Existing Commercial Use 0.23 167-08-036 4232 El Camino Real CS 30 du/ac 12 CS 0.43 9 1 Story Daycare School Existing Commercial Use 1.07 137-01-069 559 College Av CN* 15 du/ac 10 CN 0.47 10 2 Story Retail; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 1.81 124-33-067 2501 El Camino Real CN*; CC (2) 15/30 du/ac 10 CN 0.51 10 1 Story Eating Drinking Existing Commercial Use; Current Max Res Density is 15 du/ac on portion of lot 0.33 132-39-090 415 Lambert Av CS 30 du/ac 15 CS 0.51 10 1 Story Commercial Existing Commercial Use 3.44 132-41-096 3885 El Camino Real CS 30 du/ac 14 CS 0.47 10 1 Story Eating Drinking; Surface parking Existing Commercial Use 3.51 Chapter 3 95 167-08-030 4230 El Camino Real CS 30 du/ac 15 CS 0.52 10 1 Story Automotive Service Existing Commercial Use 0.04 167-08-035 4200 El Camino Real CS 30 du/ac 14 CS 0.48 10 1 Story Automotive Service Existing Commercial Use 0 124-29-020 150 Grant Av CC (2) 30 du/ac 17 CC 0.59 12 1 Story Commercial; Office Existing Commercial Use 0.23 132-38-062 435 Acacia Av CS 30 du/ac 18 CS 0.62 12 1 Story Office Existing Commercial Use 7.47 167-08-042 4256 El Camino Real CS 30 du/ac 17 CS 0.59 12 1 Story Eating Drinking Existing Commercial Use 0.14 132-36-077 2675 El Camino Real CN* 15 du/ac 13 CN 0.63 13 1 Story Eating Drinking; Surface parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.59 132-44-022 4115 El Camino Wy CN* 15 du/ac 13 CN 0.64 13 1 Story Commercial: Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.75 137-08-080 3606 El Camino Real CN* 15 du/ac 13 CN 0.65 13 Vacant Lot Current Maximum Residential Density is 15 du/ac 0 120-34-001 841 El Camino Real CS 30 du/ac 19 CS 0.64 13 Automotive Service Existing Commercial Use 0 167-08-037 4222 El Camino Real CS 30 du/ac 19 CS 0.63 13 1 Story Eating Drinking Existing Commercial Use 0.41 132-43-153 4085 El Camino Wy CN* 15 du/ac 14 CN 0.71 14 1 Story Retail; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.7 132-38-042 3201 El Camino Real CS 30 du/ac 20 CS 0.68 14 1 Story Retail; Surface Parking Existing Commercial Use 0.27 Chapter 3 96 132-44-100 4135 El Camino Wy CN* 15 du/ac 15 CN 0.75 15 2 Story Office; Underground Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 4.06 137-01-129 2390 El Camino Real CN* 15 du/ac 15 CN 0.76 15 2 Story Commercial Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0 132-38-065 440 Portage Av CS 30 du/ac 22 CS 0.76 15 Surface parking Existing Commercial Use 6.23 142-20-054 3150 El Camino Real CS 30 du/ac 22 CS 0.75 15 1 Story Eating Drinking; Surface parking Existing Commercial Use 0.3 132-39-088 3399 El Camino Real CS; CN* 30/15 du/ac 15 CS;CN 0.74 15 1 Story Eating Drinking; Surface parking Existing Commercial Use 0.29 142-20-013 2450 El Camino Real CS (AS1) 30 du/ac 17 CS 0.57 17 2 Story Office; Surface Parking Existing Commercial Use; Mayfield Agreement; per agreement, application for market rate units to be submitted 1.32 142-20-014 2470 El Camino Real CS (AS1) 30 du/ac 17 CS 0.57 17 2 Story Office; Surface Parking 0.96 142-20-047 2500 El Camino Real CS (AS1) 30 du/ac 19 CS 0.64 17 2 Story Office; Surface Parking 1.19 142-20-012 507 California Av CS (AS1) 30 du/ac 22 CS 0.75 19 1 Story Financial Service; Surface Parking 1 137-08-083 3400 El Camino Real CS (H); RM-15 30/15 du/ac 19 MF;CS 0.96 19 1 Story Eating Drinking Existing Commercial Use 1.74 Chapter 3 97 132-38-056 430 Lambert Av CS 30 du/ac 30 CS 1.03 21 2 Story Office Commercial Existing Commercial Use 4.49 124-28-045 154 California Av CC (2)(R)(P) 30 du/ac 34 CC 1.14 23 2 Story Retail Existing Commercial Use 0.29 148-09-014 4291 El Camino Real CS 30 du/ac 34 CS 1.16 23 1 Story Eating Drinking; Surface parking Existing Commercial Use 0.33 132-31-042 130 Sheridan Av GM 34 LI 1.13 34 Vacant Lot Needs Rezoning to allow Residential Use 0 142-20-035 3128 El Camino Real CS 30 du/ac 35 CS 1.18 24 1 Story Eating Drinking; Surface parking Existing Commercial Use 0.93 142-19-006 1501 California Av RP (AS2) 30 du/ac 117 RO 3.93 55 1 to 2 Story Professional Office; Surface Parking Existing Commercial Use; Mayfield Agreement; per agreement, application for market rate units to be submitted 16.09 142-19-007 1451 California Av RP (AS2) 30 du/ac 135 RO 4.52 55 2 Story Professional Office; Surface Parking 7.82 142-19-017 1601 California Av RP (AS2) 30 du/ac 255 RO 8.51 70 3 Story Professional Office; Surface Parking Existing Commercial Use; Mayfield Agreement; 70 affordable units proposed 11.88 Subtotal 1,806 1,177 Chapter 3 98 South of Forest Area Coordinated Area Plan - Phase 2 (SOFA 2 CAP) South of Forest Area Coordinated Area Plan – Phase 2 (SOFA 2 CAP) is a long-term plan that addresses a specific nine block area (approximately 19 acres) bounded by Forest Avenue, Addison Avenue, Alma Street and Ramona Street. The CAP recognizes SOFA 2’s location near downtown and calls for higher density housing, mixed uses and other compatible urban development in a vibrant mixed-use area within walking distance of the train station and commercial services provided in the downtown. The SOFA 2 CAP anticipates that the Residential Transition districts in SOFA 2 will become much more of a mixed use area with substantial residential development next to or combined with office and commercial uses. The area is considered an appropriate location for higher density residential development. These are 34 sites listed on the HIS within the SOFA 2 CAP. The Housing Inventory Sites are generally larger than 10,000 square feet in lot area; however, within the SOFA 2 CAP all of the sites identified in the Housing Inventory Sites are less than 10,000 square feet in lot area. The SOFA 2 CAP allows and encourages a variety of housing types on smaller lots, including apartments, studio units, single room occupancy housing and senior housing. The SOFA 2 CAP also includes creative parking policies encouraging shared parking and reduced parking that further encourage developing these sites with housing. The existing zoning in the SOFA 2 CAP area includes Residential Transition 35 (RT35) and Residential Transition (RT50) and allows for a total FAR for mixed use developments of up to 1.15 for RT35 and 1.30 for RT50. Additional FAR bonuses may be allowed in the SOFA 2 CAP for seismic and historic rehabilitation or under the City’s Transfer of Development Rights (TDR) program. RT35 and RT50 also require an average maximum unit size of 1,250 square feet for residential development which effectively results in a residential density above 20 dwellings per acre. Map of SOFA 2 Area Chapter 3 99 The following table identifies specific SOFA 2 CAP sites that could accommodate residential or mixed use redevelopment. Existing Mixed Use Project in SOFA 2 Area Chapter 3 100 Table 3-5 Table of SOFA II Housing Sites Notes: 1. Parcels highlighted in orange denotes zoning density greater than 20 units per acre; parcels with proposals for market rate housing are excluded. 2. *CN Parcels to be rezoned to 20 units per acre. 3. Parcels with an Assessed Value Ratio greater than 1.5 were determined to have an artificially low assessed land value from parcels under the same ownership for more than 10 years; the assessed land value is far below current market land values. APN SITE ADDRESS ZONING DISTRICT RESIDENTIAL DENSITY MAXIMUM YIELD LAND USE DESIGNATION LOT SIZE (ac) REALISTIC CAPACITY EXISTING USE ON SITE CONSTRAINTS/ ASSESSED ALLOWED (based on FAR) (based on avg of 35 du/ac) OPPORTUNITIES VALUE RATIO 120-27-073 718 Emerson St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 2 1 Story; Automotive Service Small lot ; consolidation opportunity 0.53 120-28-084 918 Emerson St RT-35 25-50 du/ac 3 SOFA II CAP 0.08 2 1 Story; Automotive Service Small lot; consolidation opportunity 0 120-27-072 721 Emerson St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Professional Office; Surface Parking Small lot ; consolidation opportunity 0.93 120-28-004 160 Homer Av RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 Surface Parking Small lot ; consolidation opportunity 0.05 120-28-033 839 Emerson St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Personal Service; Surface Parking Small lot ; consolidation opportunity 0.02 120-28-036 825 Emerson St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Personal Service; Surface Parking Small lot ; consolidation opportunity 0.31 Chapter 3 101 120-28-080 943 Emerson St RT-35 25-50 du/ac 3 SOFA II CAP 0.11 3 1 Story Professional Office Small lot; consolidation opportunity 1.04 120-28-081 935 Emerson St RT-35 25-50 du/ac 3 SOFA II CAP 0.11 3 1 Story Personal Service Small lot; consolidation opportunity 0.59 120-28-082 929 Emerson St RT-35 25-50 du/ac 3 SOFA II CAP 0.11 3 1 Story SFD Small lot; consolidation opportunity 0.01 120-28-085 926 Emerson St RT-35 25-50 du/ac 3 SOFA II CAP 0.11 3 2 Story Personal Service; Office Small lot; consolidation opportunity 0.34 120-28-090 931 High St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 story light manufacturin g Small lot ; consolidation opportunity 0.19 120-28-091 925 High St RT-35 25-50 du/ac 5 SOFA II CAP 0.14 3 Vacant; Auto Storage Small lot ; consolidation opportunity 0.01 120-28-093 960 High St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Automotive Service Small lot ; consolidation opportunity 0.59 120-30-048 1027 Alma St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Professional Office Small lot ; consolidation opportunity 0.79 120-30-049 1019 Alma St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Retail; Surface Parking Small lot ; consolidation opportunity 1.25 120-28-003 815 High St RT-35 25-50 du/ac 4 SOFA II CAP 0.13 4 1 Story Professional Office Small lot ; consolidation opportunity 1.55 120-28-005 160 Homer Av RT-35 25-50 du/ac 5 SOFA II CAP 0.14 4 Surface Parking Small lot ; consolidation opportunity 0.02 120-28-051 190 Channing Av RT-35 25-50 du/ac 6 SOFA II CAP 0.17 5 1 Story Professional Office Small lot ; consolidation opportunity 1.45 120-28-092 940 High St RT-35 25-50 du/ac 6 SOFA II CAP 0.18 5 1 story light manufacturin Small lot ; consolidation 0.62 Chapter 3 102 g opportunity 120-28-094 145 Addison Av RT-35 25-50 du/ac 6 SOFA II CAP 0.17 5 1 Story Professional Office Small lot ; consolidation opportunity 0.77 120-28-099 829 Emerson St RT-35 25-50 du/ac 6 SOFA II CAP 0.19 5 1 Story Personal Service; Office; Surface Parking Small lot ; consolidation opportunity 0.89 120-27-048 700 Emerson St RT-35 25-50 du/ac 8 SOFA II CAP 0.24 6 1 Story Professional Office; Surface Parking Existing Commercial Use 1.55 120-27-049 701 Emerson St RT-35 25-50 du/ac 8 SOFA II CAP 0.22 6 1 Story Personal Service; Surface Parking Existing Commercial Use 1.04 120-28-040 849 High St RT-35 25-50 du/ac 8 SOFA II CAP 0.24 6 1 Story Professional Office Existing Commercial Use 0.89 120-28-050 901 High St RT-35 25-50 du/ac 11 SOFA II CAP 0.32 6 Vacant; Auto Storage Existing Commercial Use 0 120-28-095 999 Alma St RT-35 25-50 du/ac 8 SOFA II CAP 0.24 6 1 Story Retail Existing Commercial Use 1.3 120-30-050 100 Addison Av RT-35 25-50 du/ac 8 SOFA II CAP 0.24 6 1 Story Retail; Surface Parking Existing Commercial Use 0 120-28-097 925 Alma St RT-50 25-50 du/ac 8 SOFA II CAP 0.24 6 1 Story Professional Office Existing Commercial Use 1.2 120-28-038 882 Emerson St RT-35 25-50 du/ac 8 SOFA II CAP 0.25 7 2 Story Personal Service; Medical Office; Existing Commercial Use 8.86 Chapter 3 103 Surface Parking 120-28-086 930 Emerson St RT-35 25-50 du/ac 8 SOFA II CAP 0.25 7 1 Story Automotive Service Existing Commercial Use 2.04 120-28-089 965 High St RT-35 25-50 du/ac 12 SOFA II CAP 0.35 9 1 Story Professional Office; Surface Parking Existing Commercial Use 0.47 120-27-046 700 High St RT-50 25-50 du/ac 12 SOFA II CAP 0.36 9 1 Story Office Existing Commercial Use 1.64 120-27-075 774 Emerson St RT-35 25-50 du/ac 16 SOFA II CAP 0.48 13 1 Story Retail Existing Commercial Use 1.76 120-28-037 840 Emerson St RT-35 25-50 du/ac 16 SOFA II CAP 0.48 13 Surface Parking Parking serving adjacent commercial uses 0.03 Subtotal 220 171 Chapter 3 104 Sites in Residential Zoning Districts with Existing Commercial Uses There are approximately 19 parcels in the City zoned for multifamily residential, (RM-15, RM- 30 and RM-40), that currently have legal but non-conforming commercial uses occupying the sites. These sites are generally within the University Avenue Downtown area and the California Avenue Transit Neighborhood area. Housing Inventory Sites identified in this category are typically improved with one to two story structures with commercial uses including, but not limited to, retail, office, motel/hotel and surface parking. The RM-30 zoning district allows a total FAR of 0.6 and a residential density of up to 30 dwelling units per acre while RM 40 zoning district allow a total FAR of 1.0 and a residential density of up to 40 dwelling units per acre. The RM-15 zoning district allows a total FAR of 0.5 and a residential density of 15 dwelling units per acre. Given the restrictions for improvements and alterations on non-conforming uses and structures, coupled with the City incentives for constructing housing, it is anticipated that redevelopment of the sites to residential use will be attractive to developers once the housing market rebounds. The following table identifies specific sites in multifamily residential zoning districts with existing commercial uses that could accommodate residential redevelopment. Sites in Multifamily Residential zoning districts near University Avenue Downtown Area with existing Commercial Uses. Chapter 3 105 Table 3-6 Table of Residentially Zoned Sites with Commercial Uses Notes: 1. Parcels highlighted in orange denotes zoning density greater than 20 units per acre; parcels with proposals for market rate housing are excluded. 2. *CN Parcels to be rezoned to 20 units per acre. 3. Parcels with an Assessed Value Ratio greater than 1.5 were determined to have an artificially low assessed land value from parcels under the same ownership for more than 10 years; the assessed land value is far below current market land values. APN SITE ADDRESS ZONING DISTRICT RESIDENTIAL DENSITY ALLOWED MAXIMUM YIELD LAND USE DESIGNATION   LOT SIZE (ac)   REALISTIC CAPACITY   EXISTING USE   ON SITE CONSTRAINTS/ OPPORTUNITIES ASSESSED VALUE RATIO 132-41-025 397 Curtner Ave. RM-30 30 du/ac 6 MF 0.19 4 2 story duplex Existing Residential 0.73 003-02-021 725 University Av RM-30 30 du/ac 7 MF 0.25 5 1 Story Office; Surface Parking Existing Commercial Use 0.4 003-02-022 489 Middlefield Rd RM-30 30 du/ac 7 MF 0.25 5 1 Story Office; Surface Parking Existing Commercial Use 0.12 120-04-043 704 Webster St RM-30 30 du/ac 7 MF 0.22 5 1 Story Professional Office; Surface Parking Existing Commercial Use 0.67 120-16-046 720 Cowper St RM-30 30 du/ac 7 MF 0.23 5 1 Story Office; Surface Parking Existing Commercial Use 0.49 124-27-038 2185 Park Bl RM-30 30 du/ac 7 MF 0.25 5 2 Story Office; Surface Parking Existing Commercial Use 1.21 124-27-039 2149 Park Bl RM-30 30 du/ac 7 MF 0.25 5 2 Story Office; Surface Parking Existing Commercial Use 0.74 120-03-038 610 University Av RM-40 40 du/ac 8 MF 0.22 5 2 Story Professional Office; Surface Parking Existing Commercial Use 0.22 Chapter 3 106 003-02-043 575 Middlefield Rd RM-30 30 du/ac 8 MF 0.28 6 2 Story Office; Podium Parking Existing Commercial Use 0.19 132-41-072 405 Curtner Av RM-30 30 du/ac 8 MF 0.28 6 Vacant Lot Portion of lot serves as a driveway to adjacent surface Parking 0 003-02-048 547 Middlefield Rd RM-30 30 du/ac 10 MF 0.36 7 2 Story Office; Surface Parking Existing Commercial Use 1.61 124-28-043 2211 Park Bl RM-30 30 du/ac 10 MF 0.34 7 1 Story Office; Surface Parking Existing Commercial Use 1.26 003-02-047 720 University Av RM-30 30 du/ac 12 MF 0.41 8 1 Story Office; Surface Parking Existing Commercial Use 0.37 137-01-121 531 Stanford Av RM-30 30 du/ac 12 MF 0.4 8 2 Story Hotel: Surface Parking Existing Commercial Use 4.91 120-16-041 400 Forest Av RM-40 40 du/ac 18 SOFA I CAP 0.45 9 1 Story Medical Office; Podium Parking Existing Commercial Use 1.6 120-16-042 430 Forest Av RM-40 40 du/ac 20 SOFA I CAP 0.51 10 1 Story Automotive Service Existing Commercial Use 0.91 137-37-004 4102 El Camino Real RM-30 30 du/ac 19 MF 0.64 13 1 Story Religious Institution Existing Non- Residential Use 0.02 137-24-034 4146 El Camino Real RM-15 15 du/ac 15 MF 0.77 15 Vacant Lot Current Maximum Residential Density is 15 du/ac 127-15-023 4151 Middlefield Rd RM-15 15 du/ac 18 MF 0.93 18 2 Story Office; Surface Parking Existing Commercial Use 1.46 132-42-074 3945 El Camino Real RM-30; CS 30 du/ac 26 MF;CS 0.89 18 1 to 2 Story Professional Office; Surface Parking Existing Commercial Use 1.35 132-42-073 3901 El Camino Real RM-30 30 du/ac 33 MF 1.1 22 2 Story Motel; Surface Parking Existing Commercial Use 1.39 132-38-059 340 Portage Ave RM-30 30 du/ac 374 MF 12.47 75 1 Story Commercial/Re tail Existing Commercial Use 4.68 Chapter 3 107 000-00-000 1170 Welch Rd RM-40 40 du/ac 84 RO 2.11 71 Vacant Lot Opportunity for expansion of adjacent existing multifamily residential 0 Subtotal 723 332 Total Number of Units 1,680 Parcel designated to meet the City's previously unaccommodated need from 1999-2006 Housing Element per AB2348 132-41-091 3877 El Camino Real * RM-30; CS 30 du/ac 22 MF;CS 0.75 15 1 Story Eating Drinking; Commercial; Surface Parking Existing Commercial Use 0.08 Chapter 3 108 3.2 OTHER SOURCES OF AFFORDABLE HOUSING Second Units/Cottages In 2007, the City amended its second unit ordinance and permitting process to allow second units in all single-family residential (R-1) zoned parcels that meet minimum lot size requirements. Permit approval is subject to a planning staff level review of the site and building plans to ensure compliance with lot size, maximum unit size, height, setbacks and parking requirements. In a review of online rental rates for cottages, attached and detached residential second units in Palo Alto, their rental rates are in the range of moderate income rents as determined by the Tax Credit Allocation Commission (TCAC). Therefore, the anticipated 15 second units will be listed as moderate income. Since January 2007, approximately 19 second units have been approved averaging approximate 4 second units or “cottages” a year. However, there may be numerous existing second units throughout the City that do not meet all of the zoning and building code standards. Therefore, as indicated in Chapter 4, the City is including a program in the Housing Element that will explore the feasibility of developing an amnesty program to legitimize existing illegal second units where appropriate and consistent with the character of the existing neighborhood. At this time it is premature to identify specific provisions that could be included in an amnesty program. The City expects to continue to receive applications for approximately 5 second units per year resulting in approximately 15 more units by 2014. Acquisition and Rehabilitation State law allows a jurisdiction to credit up to 25 percent of its RHNA through acquisition and rehabilitation of existing housing that will be reserved for lower-income households. Government Code Section 65583.1 (c) specifies that existing residential projects may be counted if a city commits financial assistance to substantially rehabilitate units that will be affordable for up to 55 years depending on the type of project. The criteria that projects must meet in order to receive credit include:  Units must be in an existing multifamily rental housing complex, an existing non- affordable development with four or more units, or an existing assisted affordable project that is expected to convert to market rate within five years;  Identification of a specific source of “committed assistance” pursuant to a legally enforceable agreement;  Long term affordability covenants (20 years for substantial rehabilitation, 55 years for existing non-affordable units, and 40 years for existing assisted projects at risk of conversion to market rate). The City has been active in acquisition and rehabilitation of multifamily developments. In 2006, the City provided $1.15 million in CDBG funds for acquisition of a 10 unit apartment complex on Alma Street consisting of eight studio apartments and two one bedroom apartments that can accommodate twelve low income people. More recently, in 2011, the City recently provided funding for the acquisition of six existing units on Alma Street. The units will be rehabilitated and deed restricted for low income households with the possibility of redeveloping the site at a higher density in the future. Because of the timing of the purchase, these units are not eligible Chapter 3 109 for the 2007-2014 RHNA cycle. City staff will work with HCD to credit the current units and if redeveloped, any future units to count towards the next RHNA cycle. 3.3 AVAILABLE SITES CONCLUSIONS Residential projects in various stages of development can accommodate over 41% of Palo Alto’s 2,860 RHNA with at least 921 units built or with building permits issued since January 2007. The following table shows the City’s substantial progress towards meeting its housing needs by income category. Table 3-8 Summary of Housing Unit Production from January 2007 to December 2012 Income Level RHNA Need Entitled/In Process Built/Building Permit Issued 2007-2014 Total Very Low 690 56 156 212 Low 543 30 9 39 Moderate 641 1 120 121 Above Moderate 986 96 749 845 TOTAL 2,860 183 1,034 1,217 Palo Alto proposes to accommodate the remaining RHNA of 1,668 with the City’s Housing Inventory Sites described in detail earlier in this section. The Housing Inventory Sites can potentially accommodate 1,784 housing units. The following table summarizes the City’s approach to fulfilling its Regional Housing Needs Allocation. Chapter 3 110 Table 3-9 Summary of RHNA need and Housing Inventory Sites CATEGORY Units Regional Housing Need 2,860 Housing Built, Building Permit Issued, Entitled, or in Entitlement or Building Permit Process 1,217 Housing Inventory Sites Potential housing on existing residentially zoned sites 332 Potential housing in commercial zoning districts that could accommodate mixed use development (including, Mayfield Development Agreement sites) 1,177 Potential Housing in Residential Transition (RT) zoning districts that could accommodate exclusive residential or mixed used development (SOFA sites) 171 SUBTOTAL 1,680 TOTAL 2,897 To evaluate the adequacy of these sites to address the affordability targets established by the RHNA, the Government Code establishes “default densities” at which the development of projects affordable to lower-income households is deemed feasible. As mentioned earlier in this section, the default density for Palo Alto is 20 dwelling units per acre. Using this density as a basis for determining the realistic capacity yield of sites identified in the Housing Inventory, the available sites can accommodate the remaining need of the Very-Low and Low Income as well as the Moderate and Above Moderate income categories. The following table shows how the City will accommodate the need for housing for all income levels. Chapter 3 111 Table 3-10 Total Capacity of Housing Inventory Sites at 20 DU/AC Income Level RHNA Need Entitled/In Process Built/Building Permit Issued 2007-2014 Total Remaining Need Very Low 690 56 156 212 478 Low 543 30 9 39 504 Moderate 641 1 120 121 1,502 Above Moderate 986 96 749 845 141 TOTAL 2,860 183 1,034 1,217 1,643 TOTAL CAPACITY OF HOUSING INVENTORY SITES AT 20 DU/AC* 1,680 * All sites identified in the Housing Inventory were calculated at least 20 du/ac except for the sites identified in the Mayfield Development Agreement (Total acreage of 7 parcels = 19.50 ac and requires 250 units to be built), the 15 potential additional second unit/cottages in R-1 zoning districts, and site 137-24-034 zoned RM-15 (calculated at 15 du/ac) 3.4 FINANCIAL RESOURCES Although the level of Federal and State funding for affordable housing is lower than it was in previous years, there are a number of programs the City and affordable housing developers can use to maintain or increase the housing stock for its low and very low income residents. The following summarizes the primary financial assistance programs that have been used in the City. Federal Funds The Federal government is a major provider of funding for affordable housing, primarily through the Department of Housing and Urban Development (HUD). HUD, with its multiple programs, provides funding to State, cities, counties, housing authorities and affordable housing providers and direct assistance to low and moderate income households. Community Development Block Grant Community Development Block Grant (CDBG) funding is a HUD program that is targeted to assist low and moderate income households. Known for its ability to fund a variety of activities, the City has used the CDBG funds for acquisition of affordable housing sites, rehabilitiation of existing affordable housing developments, single family rehabilitation, public infrastructure improvements and a number of other activities. However, most recently, the City has primarily used its funds for the rehabilitation activities of existing affordable housing developments. The City has been receiving CDBG funding since 1988. Chapter 3 112 Housing Choice Voucher Program Better known as the Section 8 program, the Housing Choice Voucher Program is administered by the Santa Clara County Housing Authority. This rental voucher program subsidizes the gap between the fair market rent of the unit and what a low income household can pay for rent. This allows the voucher holder to rent a market rate rent unit and not solely rely on affordable rental developments. With the voucher, the household can move to different areas in the County and still be able to use the voucher. A number of Palo Alto residents participate in this program. There is also a project based Section 8 program in which the County Housing Authority allocates a number of vouchers to a project and not to an individual household. While not directly funding the project, it guarantees a consistent stream of cash flow for the project. Two projects in Palo Alto, the Opportunity Center and Stevenson House, receive project based Section 8 vouchers for their residents. Low Income Housing Tax Credits This program is administered through the Internal Revenue Service (IRS) and a major funding source for affordable housing development. The IRS created this program with the aim of attracting investors to affordable housing developments. The IRS issues tax credits which are distributed on the state level. In California, the Tax Credit Allocation Committee in the California State Treasurer’s Office is responsible for the distribution of tax credits to affordable housing developers, The developers then sell the credits to investors who use the credits to lower their tax liability. The money received from the investors become equity in an affordable housing project. Recently built affordable housing developments, the Treehouse Apartments and Oak Court, are Palo Alto developments that were funded with tax credit financing. State Funds The State of California also has its own sources of funds in support of affordable housing. Most funds are administered through the Department of Housing and Community Development (HCD). HCD manages a number programs. Some of the State programs that have been used by Palo Alto affordable housing developments include: Multifamily Housing Program (MHP) MHP provides low-interest loans to developers of affordable housing. The funds may be used for multifamily rental and transitional housing projects involving new construction, rehabilitation, acquisition and rehabilitation or conversion of nonresidential structures. Fabian Way, an affordable housing development for seniors, and Oak Court Apartments have been developed using MHP funding. HOME HOME is the HOME Investment Partnership Program. HOME provides formula grants to states and localities that communities use, often in partnership with local nonprofit groups, to fund a wide range of activities that build, acquire, and/or rehabilitate affordable housing for rent or homeownership. The City must go through the State HCD program to qualify for HOME grants since it is not eligible to receive funds directly from HUD. Chapter 3 113 California Housing Finance Agency (CalHFA) CalHFA has suspended their Multifamily lending program however, they are responsible for administering Mental Health Services Act funding. MHSA Housing Program funds will be allocated for the development, acquisition, construction, and/or rehabilitation of permanent supportive housing. Though not a widely used funding source, as funding sources become more scarce, MSHA funds may become more popular in the future. In 2010, 801 Alma Street, a 50 unit affordable rental project for very low income households, received a MHSA grant. Local Funds City Residential Fund The City maintains a City Residential Fund to be used for affordable housing. The funding source comes from in-lieu housing fees. Typically, housing developers in Palo Alto are required to provide BMR units in the development. However, on occasion, developers are allowed to pay a fee in-lieu of providing BMR units in the development. Fees are collected in the fund to be allocated to developers with proposed affordable housing projects. The funds can be used for predevelopment, construction or permanent financing. Many affordable housing developments have received financial assistance from the City Residential Fund. City Commercial Fund The City maintains a Commercial Fund, which requires businesses when expanding their commercial space to pay a fee for affordable housing. These funds are used to finance affordable housing developments, similar to the Housing Trust Fund. The funds can also be used for predevelopment, construction and permanent financing for new construction. Local housing trusts that have provided funding assistance to Palo Alto affordable housing developments include: Housing Trust of Santa Clara County The Housing Trust of Santa Clara County (HTSCC) is a public/private trust that provides a variety of funding packages for affordable housing. Predevelopment, construction loans and permanent financing are all available through the Housing Trust. They receive a majority of their funding from corporation contributions in addition to funding from jurisdictions in the County. The City of Palo Alto has contributed $800,000 to HTSCC since its inception in 2001. The Trust Fund has funded affordable multifamily rental and special needs housing developments such as the Opportunity Center and Fabian Way Senior Apartments. They also have a first time homebuyers program and a housing grants program to prevent homelessness. Santa Clara County (Stanford Affordable Housing Trust) The Stanford Affordable Housing Fund (Stanford AHF) was established in December 2000 as a result of the approval of the Stanford University General Use Permit (GUP). The Stanford AHF contains conditions under which the University is allowed to undertake construction. The GUP requires that for each 11,763 square feet of academic development constructed, Stanford must either provide one affordable housing unit on the Stanford campus or make an appropriate cash payment in-lieu of providing the housing unit. Payments have been made since that time to a Stanford AHF maintained by the County. Two projects in Palo Alto, the Tree House and 801 Alma, have received funding from this fund. Chapter 3 114 Mortgage Credit Certificates (MCCs) Administered by Santa Clara County, MCCs provide tax credits to a first time low income homebuyer. The credits reduce income subject to federal tax thus essentially increasing their tax return amount. The money from the increased return can be applied to the mortgage payments. This essentially creates a mortgage subsidy for the homeowner. City Below Market Rate Program While this program does not provide financial assistance to develop affordable housing, it is significant in the production of affordable units. The City requires that developers make a certain percentage of their market rate units affordable to lower-income households. Since the inception of the program in 1974, 435 BMR ownership and rental units of affordable housing have been produced through this program. 3.5 OPPORTUNITIES FOR ENERGY CONSERVATION Palo Alto rates energy conservation to be a priority in the overall planning process. Conservation of energy is an important issue for all households including both owners and renters. Energy cost can be a substantial portion of monthly housing costs for some existing older housing stock in the City. The City’s interest in sustainable development, energy independence, and reduction of greenhouse gas emissions is in line with new legislation such as the Global Warming Solutions Act of 2006 (AB 32). Palo Alto employs three main strategies to promote energy conservation: integrated land use and transportation planning and development; promotion of energy conservation; and the adoption of green building standards and practices. Integrated Land Use and Transportation Planning a range of affordable housing types near jobs, services, and transit can reduce commutes, traffic congestion, and thus reduce the number of vehicle miles traveled (VMT) and vehicle hours traveled (VHT). Since Palo Alto is nearly built out, promoting infill development with higher densities along transit corridors helps to reach the goals of energy conservation and integrating land use with transportation. The City has specific goals and requirements for built environments and transportation. The following is a list of City programs to integrate land use and transportation. Chapter 3 115 Table 3-11 List of Integrated Land Use and Transportation Programs in Palo Alto Goal and Requirements (State and Assembly Bills (SB/AB), Codes, Ordinances and Mandates) Municipal and Regional Operations (including goals and programs) * Residential (including goals and programs) * Commercial (including goals and programs) * Built Environment including urban planning, comprehensive plan, construction and demolition and green building  Green Building Ordinance  Demolition and Construction Diversion requirements  Mitchell Park and all library projects  Comprehensive plan  New Construction and Retrofit Rebates  Arastradero Gateway Educational Nature Center displays and building design  Green Building Program  Demolition and Construction Diversion program  New Construction Rebate  Green Building Program  Demolition and Construction Diversion program  New Construction Rebate Transportation including SB375 and AB32, shuttles, alternative commute, bike routes, EV and all forms of transportation  SB375  AB32  Pedestrian Transit Oriented Development zones  School Commute Corridor network  City Employee alternative commute incentives  Alternative fuel vehicles for City Fleet  Biodiesel fuel program  City Bike share  EV charging stations at City Hall and the Bay Area Electric Vehicle Corridor Program  Zip Car parking spots in City parking lots  Bicycle Transportation Plan  Fire Engine Exhaust filtration spec  Regional planning and coordination  Pedestrian and Transit-Orientated Development  Safe Routes To Parks program Bay Area Air Quality Management Transportation Fund for Clean Air (TFCA) program  Palo Alto Free Community shuttles  Stanford Margarite Shuttles  CalTrain  VTA Routes  Samtrans  Way2go program  511.org  Palo Alto Bicycle Advisory Committee  CalTrain and the CalTrain Deer Creek Shuttle  VTA Routes  Samtrans  511.org Source: City of Palo Alto * Related agencies and programs listed in Italics Chapter 3 116 Energy Conservation Home energy costs have become an increasingly significant factor in housing costs as energy costs have risen, particularly in the past years with the ongoing energy crisis in California. Energy costs related to housing include not only the energy required for home heating, cooling and the operation of appliances, but the energy required for transportation to and from home. There are many opportunities for conserving energy in new and existing homes. Construction of energy efficient buildings does not lower the purchase price of housing. However, housing with energy conservation features should result in reduced monthly occupancy costs, by requiring less energy to operate and maintain. Similarly, retrofitting existing structures with energy-conserving features can result in a reduction in utility costs. In new housing construction, the City encourages design of new units sensitive to energy consumption. Energy conservation is encouraged in the unit layout such as solar orientation, location of plumbing, and choice of heating system as examples. For older homes attempting to rehabilitate, the City refers to programs that provide information referral for participants to make weatherization improvements and utilize energy and water efficient appliances and fixtures. Program participants are encouraged to use the energy conservation programs provided by the City’s Utility Department. The City has outlined goals and requirements on the following topics:  Climate Change and Adaptation including GHG inventories, sea level rise and mitigation measures.  Energy Supply and Conservation including demand management, smart grid, alternative sources  Water conservation and resource management including water quality, storm water, wastewater and bay water  Natural Environment including land use issues, stewardship programs, parks, open space, biodiversity, invasive plant species contaminated sites and green purchasing practices, air quality and toxins and  Waste and materials including management of ZeroWaste, reuse, recycling, composting and cradle-to-cradle initiatives These goals and requirements mirror Senate and Assembly Bills (SB/AB), Codes, Ordinances and Mandates and strictly follow the set of guidelines prescribed by regional and municipal programs. The following are the Environmental Sustainability Programs run by the City of Palo Alto for residential and commercial properties. Chapter 3 117 Table 3-12 List of Environmental Sustainability Programs in Palo Alto Goal and Requirements (State and Assembly Bills (SB/AB), Codes, Ordinances and Mandates) Municipal and Regional Operations (including goals and programs) * Residential (including goals and programs) * Commercial (including goals and programs) * Climate Change and Adaptation including GHG inventories, sea level rise and mitigation measures  CCAR (2010)/ The Climate Registry (2011)  AB32 – California’s Climate Plan  Western Climate Initiative  Renewable Portfolio Standards – Internal mandate 20% by 2012 and 33% by 2015; Governor’s executive order and proposed CARD Rules 33% by 2020  Palo Alto Climate Protection Plan targets  Palo Alto Climate Protection Plan and GHG Monitoring Program  Utilities Renewable energy supply goal  Bay Area Climate Change Collaborative  Joint Venture Silicon Valley – Climate Protection Task Force and Climate Coaching Program  Sustainable Silicon Valley  International Council for Local Environmental Initiatives (ICLEI)  California Municipal utilities Association (CMUA)  Community Environmental Action partnership (CEAP)  Utilities conservation related programs  Palo Alto Green – voluntary renewable energy program  Community Environmental Action partnership (CEAP)  Utilities conservation related programs  Palo Alto Green – voluntary renewable energy program Energy Supply and Conservation including demand management, smart grid, alternative sources  California Energy Code Amendments (Titles 20 & 24)  Third Party Measurement and Verification  Tiered Electricity rates to promote conservation  Utility Efficiency and Conservation Reporting (SB1037 and AB2021)  Long Term Electric Acquisition Plan (LEAP)  Gas Utility Long- Term Plan (GULP)  LED Street Lights Pilot Project  City facilities energy efficiency goals/projects  LED Traffic Signals  Photovoltaic  Home energy efficiency analysis (Acterra Green@Home and on-line audits)  Solar Water Heating program  Photovoltaic (PV) Partners program  SMART Energy rebate Program for appliances, insulation,  Free Business Efficiency Analysis by CPAU  Solar Water Heating program  Photovoltaic (PV) Partners program  Commercial Advantage Rebate Program  Right Lights Plus Direct Install Program Chapter 3 118 Goal and Requirements (State and Assembly Bills (SB/AB), Codes, Ordinances and Mandates) Municipal and Regional Operations (including goals and programs) * Residential (including goals and programs) * Commercial (including goals and programs) * Energy Supply and Conservation con’t  SB1 and AB920 – PV Net Metering and Rebates Act  AB1470 – Solar Hot Water and Efficiency Act of 2007 demonstration projects at MSC, Baylands Nature Center, Cubberley Community Center and Arastradero Gateway Nature Center furnaces, etc.  Refrigerator Replacement & Recycling Incentives  Residential Energy Assistance Program (low income)  Lighting Pilot Projects  Home Energy Reports (fall 2010)  Home Efficiency Kits  Improving Efficiency and Using Technology Workshops/Semi nars  Online Analysis Tools  New Construction and Retrofit Rebates  PACE (Property Assessed Clean Energy) Program with CalFirst  Commercial & Industrial Energy Efficiency Programs  Electric Efficiency Financing Program (summer 2010)  Commercial Kitchens Program  School District Outreach & Incentives by Utilities  Plug-in Program (distributed power generation) Water conservation and resource management including water quality, storm water, waste water and bay water  Water Efficient Landscape Ordinance  Recycled Water Ordinance  California Urban Water Conservation Council’s Best Management Practices  State Green Building Code (CALGreen)  SBx7-7 (20%x2020)  Plumbing Code  CPAU Urban water Management Plan  Water Conservation Implementation Plan (BAWSCA)  20%x2020 potable water use reduction  EPA WaterSense Partner  Alliance for Water Efficiency (AWE) partner  Demonstration gardens at  Water wise house calls  Water conservation rebate programs (landscape rebate program, ET controller rebates, high efficiency toilet rebate, & clothes washer rebate)  Storm water rebates  Save the Bay  BAWSCA Workshops  Landscape Surveys  Indoor Water Surveys  Storm water rebates  Water conservation rebate programs (landscape rebate program, ET controller rebates, high efficiency toilet & urinal installation & rebates, Chapter 3 119 Goal and Requirements (State and Assembly Bills (SB/AB), Codes, Ordinances and Mandates) Municipal and Regional Operations (including goals and programs) * Residential (including goals and programs) * Commercial (including goals and programs) * Water conservation and resource management con’t  Upcoming Gray water code  Various sanitary sewer ordinances to reduce copper, heavy metals, FOG (fats, oil, grease) and other pollutants  Tiered Water rates to promote conservation  Once-thru cooling ordinance  Ahwahnee Principles adopted by Council  Recycled water encouraged for use on construction sites for dust management Mitchell Park Library and Community Center, Downtown and Main Libraries  Rebates & fixture retrofits  Landscape irrigation system improvements  CLEAN South Bay  Complete ultraviolet light water disinfection unit  Mercury reduction  Reducing salinity of recycled water  Integrated Pest Management Program  Various pollution prevention efforts: tricolosan and pharmaceutical collection  Conversion of turf fields to artificial turf at four sites  Expansion of use of recycled water at park and median sites  Santa Clara Valley Water District (SCVWD) Workshops  Bay-Friendly Workshops and program  Water efficient landscape literature  Our Water, Our World (less toxic pest control program at local hardware and garden centers)  Pharmaceutical collection  Mercury device collection  School programs (Regional Water Quality Control Plant (RWQCP) led and County led) commercial clothes washers, water efficient technology incentives, submeters, pre- rinse spray valves)  BAWSCA, SCVWD, Bay Friendly Workshops Natural Environment including land use issues, stewardship programs, parks, open space, biodiversity, invasive plant species contaminated sites and green purchasing practices, air quality and toxins  Foothills Fire management Plan  Baylands Conservation Plan  Tree Preservation Ordinance  Wood smoke Ordinance (requirements for wood burning stoves and fireplaces)  Environmentally Preferred Purchasing  Urban Forest master Plan - including Street tree inventory, Tree species data base, Block Side Species Replacement list, Updated Tree  Open space and trails  Community gardens  Junior museum  Farmer’s markets (including Saturday’s Downtown market, Sunday’s Cal Ave market and the  Green Business Program (run by County; facilitated for PA businesses by Public Works)  Clean Bay Businesses Chapter 3 120 Goal and Requirements (State and Assembly Bills (SB/AB), Codes, Ordinances and Mandates) Municipal and Regional Operations (including goals and programs) * Residential (including goals and programs) * Commercial (including goals and programs) * Removal Process  Nature and Hiking programs  Special events and educational programs  Nature and environmental interpretive centers and Junior Museum  Open space habitat preservation  Pesticide Free Parks  Baylands conservation plan  Foothills fire management plan  Arastradero creek restoration  San Francisquito Creek Flood Control  Partnerships with Save The Bay, US Fish & Wildlife and Acterra for habitat restoration Downtown FarmShop)  Acterra  Canopy  Committee for Green Foothills  Environmental volunteers  Friends of Foothills Park  Friend of Palo Alto Parks  Midpeninsula Regional Open Space district  Peninsula Open space Trust (POST) Waste and materials including management of ZeroWaste, reuse, recycling, composting and cradle to cradle initiatives  Demolition and Construction Diversion requirements  Ordinance on Plastics, expanded polystyrene and non-recyclable food services containers  Ordinance on single use bags  AB 939  AB 32  Zero Waste Strategic and Operational Plan  City Operations recycling and composting programs  SMaRT Station  Product Stewardship/ Extended producer responsibility  Green purchasing policy  Paper reduction initiatives (CPP dept initiatives, double sided  ZeroWaste  BYOBag  Palo Alto Recycling Drop- off Center  HHW program (drop off and appointment)  City–wide Garage Sale  Curbside recycling and yard trimmings program  ZeroWaste  Composting program for food and yard waste  Business recycling program  Demolition and Construction Diversion program  Green Business Program  BYOBag  ZeroWaste Grant Program Chapter 3 121 Goal and Requirements (State and Assembly Bills (SB/AB), Codes, Ordinances and Mandates) Municipal and Regional Operations (including goals and programs) * Residential (including goals and programs) * Commercial (including goals and programs) * default, digital CMRs)  Sustainable exhibits at Junior Museum  Parks and Open Space Sustainable Operations  Reduction of waste by facility renters at community centers Source: City of Palo Alto  Related agencies and programs listed in Italics Building Design and Construction All new residential and nonresidential construction in Palo Alto must conform to the State of California’s residential building standards for energy efficiency (Title 24 of the California Administrative Code). Title 24 Standards were established in 1978 to insure that all-new construction meets a minimum level of energy efficiency standards. Standards for building energy efficiency were last updated in 2009. In order to meet and/or exceed the State energy conservation requirements, buildings can be designed and constructed to minimize energy use. Residential site design and construction techniques that can reduce the amount of energy used for space cooling would significantly reduce overall energy demand. Passive solar design keeps natural heat in during the winter and natural heat out during the summer, which reduces air conditioning and heating demands. Buildings can be oriented so that sun and wind are used to maintain a comfortable interior temperature. Landscaping features can also be used to moderate interior temperatures. In addition, technologies have been developed which can reduce energy consumption or generate renewable energy. 3.6 OTHER PROGRAMS City’s Below Market Rate Program The City requires that any new residential development of 5 units or more must provide affordable housing. The developer must provide a physical unit in the development or pay a fee in lieu of providing the physical unit. All in lieu fees are deposited in the City’s Residential Fund. Since its creation in the early 1970s, the City’s BMR program has produced 435 units of affordable ownership and rental housing. Chapter 3 122 Density Bonus The State enacted Density Bonus law in the 1970s as an incentive for developers to provide affordable housing. By providing a certain percentage of affordable housing in the development, the State law allows the developer to build a number of units beyond the existing zoning limits. In 2004, the State revised the density bonus law to provide a higher density and greater incentives to encourage the greater production of affordable housing. Concessions are also offered to developers that provide affordable housing. The concessions often provide regulatory relief from the zoning code. Although developers have not requested additional units through density bonus, developers have requested concessions in exchange for providing affordable units. If approved, applications currently going through the land use approval process would provide an additional 24 units of affordable housing. Housing Development Fee As mentioned, the City collects in lieu fees from developers when affordable units are not included in their projects, and uses those fees to finance other affordable housing developments. An advantage of the in lieu option is it allows those funds to leverage other funding sources. Many affordable housing funding sources require a local funding commitment prior to committing their funds in the project. This local commitment helps secure other funding sources. Therefore, the City’s loan may be a small percentage of the total costs; but it is able to attract many other potential lenders. Palo Alto Housing Corporation The Palo Alto Housing Corporation (PAHC) was established in 1970 with the assistance of the City. The City Council recognized that increasing housing prices were slowly forcing out fixed income households, many who were seniors. The PAHC was formed to seek ways to build affordable housing or provide rental subsidies. Since that time, PAHC has been a partner with the City in developing affordable housing. PAHC currently manages over 600 rental units and manages over 240 ownership units in the City’s BMR program. In addition, PAHC has developed their own affordable rental units, partially funded with City monies. Below Market Rate (BMR) Program Emergency Fund In 2002, the City Council established a Below Market Rate Program Emergency Fund to help prevent the loss of BMR units due to lack of adequate maintenance. The program provides emergency loans to BMR owners for mandatory homeowner association maintenance assessments of over $10,000. Since its inception, the program has provided loans to three BMR owners. As part of the Housing Element, this program is proposed to be expanded to provide financial assistance to BMR owners for maintenance of older BMR units (Program H3.1.4). Chapter 4 123 CHAPTER 4 HOUSING CONSTRAINTS The ability of any local government to provide and maintain housing to meet the needs of all economic segments of the community are affected by a variety of factors. These include matters that are outside the control of individual jurisdictions, such as real estate market conditions, construction costs, and the availability of private financing, all of which contribute to housing costs. Government policies, regulations, and programs that a local agency adopts to protect the general welfare of the community may also impede efforts to meet housing needs. This part of the Housing Element addresses both types of constraints and provides a basis for Chapter 5, which proposes a variety of programs and actions to help remove or reduce the impacts. 4.1 NON-GOVERNMENTAL CONSTRAINTS Various non-governmental factors such as the housing market, development costs, and the cost and availability of financing contribute to the cost of housing. These factors can potentially hinder the production of new affordable housing. This section analyzes these types of non- governmental constraints. Housing Market Conditions The Bay Area region was not immune to the national downturn in the real estate market. Of the nine counties that make up the Bay Area region, all counties experienced increases in foreclosures, short sales and housing price declines. However, the Bay Area was able to withstand the past few years better than many other parts of the country due to its more diversified economy and its desirable natural and cultural amenities. Although many experts believe that the downward housing market trend has finally stabilized, with the fragile economy, high number of distressed properties in the market, high unemployment and limited credit availability, the housing market recovery will be slow and sporadic. However, the Bay Area housing market, because of its economy and environment, should recover faster than other portions of the country. Even in the Bay Area, the housing market is extremely fragmented. In general, the South Bay and San Francisco areas have seen less of a decline than the East Bay. In many communities along the Peninsula, Palo Alto included, the housing market peaked in 2007, largely because of the success of its high tech industries and strong school systems. Since 2008, uncertain market conditions contributed to price decline and fluctuations in home prices. However, in the Peninsula region, because of the strength of the high-tech industries, home prices have been steadily increasing since the real estate crash. Palo Alto, like other communities in Santa Clara County, the Bay Area, California, and beyond, has experienced a drop in new housing construction in the past two years. While there was considerable housing activity during the 1980 to 1990 decade and in the early 2000’s, the rate of production of units dropped from 2007 onward. From 1999-2006, 1,713 residential units were constructed. In this current cycle, building permits were issued for 921 residential units. However, almost all received their land use approvals prior to 2007. From 2007 to 2008, only 158 residential units received land use approval. This drop in housing construction was a result Chapter 4 124 158 residential units received land use approval. This drop in housing construction was a result of a combination of factors such as shortage of financing, rise in construction costs and a poor housing market. The costs of land, hard costs (construction), and soft costs (financing, architecture, and engineering) are three major components of development costs. Construction and financing costs are, for the most part, driven by regional and, in some cases state and national conditions that are beyond the control of local jurisdictions. Land costs tend to be more reliant on local conditions and reflect the availability of developable sites as well as market demand. Land Costs Palo Alto is, for the most part, a built-out community. Developable sites are scarce and there is little vacant land suitable for development in Palo Alto--less than 0.5% of the City's developable land is vacant. Because of the lack of vacant parcels, underutilized sites or sites zoned for commercial/industrial uses have become attractive for residential re-use. However, the demand for such sites has increased their cost. Both market-rate and affordable housing developers report that acquiring sites for housing in the City is a challenge. Although the City policies encourage the integration of residential use into commercial use as mixed-use projects, the City is not supportive of sole housing proposals in non-residentially designated areas. The land cost in Palo Alto varies by location and the structure on it. Based on the information from local commercial and residential real estate brokers, the value of commercial land depends on proximity to transit and other amenities the area provides. For example, it varies from $4.5 million per acre in the California Avenue business district to $10-$15 million per acre in the commercial Downtown areas. Residential land values also vary by location. The value of multifamily residentially zoned property has more than doubled since 1996. The average land cost for multifamily residential condominium projects in 2006-2007 varied from $160 to $300 per square foot based on location. Individual single-family residential lots, if available, typically cost over $900,000 or more for a 5,000 square foot lot. Although the slowdown in the national real estate market has recently resulted in reduced construction costs, land costs in Palo Alto are still extremely high. Hard/Construction Costs A major impediment to the production of more housing is the cost of construction, which involves two factors: the cost of materials, and the cost of labor. Hard construction costs generally comprise about 45% of the total development budget. Construction costs are more stable than land costs but also influenced by market conditions. Cost of construction varies with the type of new housing and the way it is constructed. According to the Association of Bay Area Governments, wood frame construction at 20-30 units per acre is generally the most cost efficient method of residential development. However, local circumstances of land costs and market demand will impact the economic feasibility of construction types. Although the cost of building materials, which comprises a significant portion of the sales price of a home, has risen dramatically in recent years, it has not affected Palo Alto more significantly than other areas. According to the US Department of Labor, the overall cost of residential construction materials rose 22 % between 2004 and 2006, with steel costs increasing 63% and the cost of cement increasing 27%. There is some small variation in material and labor costs in different regions of the State; but, for the most part, the variation in costs are not considered Chapter 4 125 significant. Discussions with private and non-profit developers and City staff indicate that $200- $300/sq. ft. is the lower end of the scale for high-end custom new construction in Palo Alto. Multiple-family residential construction costs ranged from approximately $200-$250 or higher per square foot depending on amenities and the quality of construction materials. Even with the "economies of scale" of multifamily construction, costs are still high for those units. Because of this high rate, there is a tendency on the part of developers to build units that can be sold at the maximum the market can bear. Hence, it becomes difficult to build affordable housing with this range of construction costs. One factor that directly affects affordable housing development and not market rate housing development is prevailing wage requirements. Many affordable housing developments receive government funding and, in many instances, that funding carries the requirement that the construction employees be paid a prevailing wage as set by the government. Generally, the prevailing wage is higher than the market rate wage. Therefore, as labor costs are generally 25%-35% of the construction costs, the higher prevailing wages add to the overall construction budget. Financing/Soft Costs Soft costs, including permit fees, architectural and engineering services, and environmental reviews make up about 40%-45% of the development budget in a private development. However, in an affordable housing development, that percentage can be much higher and the effect, therefore, more significant. In order to develop housing that is affordable, especially to very low and low-income households, substantial public subsidies are routinely required because of the high cost of land and construction. Because of the deeper affordability levels, many affordable housing projects are using multiple financing sources. Since each financing source has different underwriting criteria, the administration necessary to fulfill the requirements of each financing source adds to the project soft costs causing additional time delays, leading to a longer development schedule. Financing costs are primarily dependent on national economic trends and policy decisions. The availability of financing affects a person’s ability to purchase or improve a home; the cost of borrowing money for residential development is incorporated directly into the sales price or rent. Interest rates are determined by national policies and economic conditions, and there is virtually nothing a local government can do to affect these rates. Homeowner Financing At the time this Housing Element was prepared (2011), fixed mortgage rates for single-family residential housing ranged from 4.00% to 4.75% for a 30 year fixed conforming loan as compared to 6.5% in 2006. Adjustable rate loans were slightly lower than fixed conforming loans, ranging from starting rates of 3.5% up to 4.5%. This means that financing a home has become more attractive in the last few years if the applicant has good credit and a stable income. Financing from both mortgage brokers and retail lenders (banks, savings and loans) is available in the Palo Alto area. Because of the weak housing market and more stringent lending practices, however, residential developers and homebuyers are both having difficulty obtaining financing. The availability of financing is not a significant constraint to the purchase of housing in Palo Alto, although financing for residential and mixed use development is harder to obtain. Financing costs for subsidized housing is very difficult, as the competition for the limited available funds is very severe. Chapter 4 126 Government‐insured loan programs are an option available to some households to reduce typical mortgage requirements. The Federal Housing Administration (FHA) backed insurance loan is one of the more popular government insurance loans. This loan is especially popular with lower income homebuyers that may not have the requisite down payment to qualify for a conventional loan. There are a number of homebuyer assistance programs available to lower income homebuyers on the local and federal level. With the tightening of lending requirements, lower income households have more of a challenge meeting the down payment requirements. However, there are down payment assistance programs available. The California Housing Finance Agency (CalHFA) provides a low interest, deferred loan as down payment assistance. The Housing Trust of Santa Clara County also offers closing cost and down payment assistance. The Mortgage Credit Certificate (MCC) program, administered by Santa Clara County, offers homebuyers a tax credit that they may use to reduce their taxable income. It does not help them purchase the home but with a reduced tax liability, it allows them greater disposable income to better afford the home. Under the federal Home Mortgage Disclosure Act (HMDA), lending institutions are required to disclose information on the disposition of loan applications and the income, gender, and race of loan applicants. The availability of financing for a home greatly affects a person’s ability to purchase a home or invest in repairs and improvements. Under the federal Home Mortgage Disclosure Act (HMDA), lending institutions are required to disclose information on the disposition of loan applications and the income, gender, and race of loan applicants. HMDA requires lending institutions to disclose information on the disposition of loan applications by income, gender, and race/ethnicity of applicants. Table 4-1 Disposition Table of Applications for Conventional Home Purchase Loans, 2007 The table above shows by income categories the purchases of one‐ to four‐unit properties, as well as manufactured homes. Over 74% of the loan applications were filed by households that reported their income as above moderate (earning greater than 120 percent of AMI). Over 40% of all loans were approved and accepted by the applicants, and 19% were denied. Above Chapter 4 127 moderate‐income households (120% or more of AMI) had the highest rates of approval. The City obtained this data from Home Mortgage Disclosure Act, 2007. Interest rates impact home construction, purchase, and improvement costs. Minor fluctuations in rates can make a significant difference in the annual income needed to qualify for a loan. Even though interest rates are currently at historically low levels throughout the Unites States, purchasing or refinancing is unavailable for many, because lenders have tightened their underwriting criteria to qualify for a loan. The increased number of foreclosures for households with sub‐prime loans, the recession, the credit crisis and limited access to finances are some major barriers to housing choice throughout the country. Currently, lenders are implementing stricter underwriting, reporting, and verification of information practices. Applicants must have credit score of 720 to 740 to qualify for a conventional home mortgage loan. Households facing difficulty in qualifying for a conventional mortgage can opt for a Federal Housing Administration (FHA) loan. These loans have lower interest rates, require a low down payment of 3.5 percent, and more flexible underwriting criteria. First-Time Homebuyer Programs are another option to obtain home loans. They include down payment assistance programs such as the California Homebuyers Down payment Assistance Program (CHDAP), offering a deferred-payment junior loan of up to three percent of the purchase price or appraised value. The number of default notices filed against homeowners in Santa Clara County has increased substantially since 2007. Though there is an increase in foreclosure activity throughout the Bay Area, and throughout the country, the number of foreclosures in Palo Alto is low. Between 2006 and 2008, approximately 7,700 default notices were filed in Santa Clara County of which only three were from Palo Alto. Affordable Housing Development As the Federal and State governments reduce their budgets, funding for affordable housing development has been severely cut. On the federal level, the CDBG and HOME programs have seen a 30% and 35% reduction, respectively, in the past three years. On the state level, one of the major sources of affordable housing funding, redevelopment funds, has been eliminated. Therefore, local jurisdictions are burdened with allocating a greater amount of funding to each proposed affordable housing development. The City of Palo Alto has several funding sources it can offer to assist in funding an affordable housing development. The City maintains the Commercial Housing Fund and the Residential Housing Fund. The Commercial Housing Fund, which is funded by mitigation fees assessed based on new commercial and retail square footage, was established to develop new workforce housing. The Residential Housing Fund’s purpose is to create affordable housing throughout the City. Housing developers are required to provide affordable housing in each development; however, on occasion, some developers are allowed the option to pay a fee in lieu of providing affordable housing in the development. Those fees are deposited into the Residential Housing Fund and then used to help finance other affordable housing projects. Based on discussions with affordable housing developers, as other state and federal sources are reduced or eliminated, local jurisdictions will have to carry a larger portion of the financial burden. Chapter 4 128 While federal and state funding sources have seen their allocations reduced, there still are a number of funding sources on both levels, albeit those sources are now much more competitive for the limited funding. In many instances, affordability of the units is a deciding factor in funding allocation. However, this creates a situation where additional funding sources are needed to help fill the deeper gap. In other words, the project may be more competitive as affordability increases; however, more funds are needed to subsidize the project. Environmental Constraints The environmental setting affects the feasibility and cost of residential development. There are some areas in the City that have specific environmental issues that may constrain future residential development. Environmental issues range from the suitability of land for development, the provision of adequate infrastructure and services, as well as the cost of energy. In this section, the challenging environmental issues affecting the City’s development decisions are discussed. Seismic and Geologic Hazards Several residential sites in the foothills area of the City are within a specific earthquake fault zone area. Seismic hazards include ground shaking, fault rupture, liquefaction, land sliding, ground settlement, and seismically-induced flooding. The design of new housing projects in risk-prone areas must consider relevant geologic, seismic, flood, and fire hazards. The City strictly enforces Uniform Building Code seismic safety restrictions for all types of construction. For residential sites within the earthquake fault zone area, in-depth soils reports are required as a part of their development approval process. Although the entire City is subject to moderate to severe earth movement during a seismic event, there are standard engineering solutions to address the potential seismicity. Incentives for seismic retrofits of structures in the University Avenue/ Downtown area are available. Other geologic hazards in Palo Alto that are not associated with seismic events are landslides that may result from heavy rain, erosion, removal of vegetation, or other human activities. The Public Works Department enforces strict Municipal Code regulations to combat these natural events. They require reports from engineers and geologists reviewing the geology and soils of the hazard areas. Appropriate fees are charged to cover the cost of this review. Some areas of the City have isolated cases of pollution of the soil and groundwater that may require clean up, and the close proximity of groundwater to the surface may limit excavation or require additional foundation stabilization. Limited areas of Palo Alto are subject to flooding following unusually heavy rainfall. Flooding is typically associated with overtopping of creek banks, inadequately sized bridges and culverts, and blocked storm drains. Much of the City is outside the 100-year flood plain boundary defined by the Federal Emergency Management Agency (FEMA). However, a substantial area is subject to flooding in a 100-year storm and designated as a Special Flood Hazard Area on FEMA's Flood Insurance Rate Map. According to the City of Palo Alto Public Works Department staff, approximately 25-30% of the City is within this flood hazard zone. Structures within this zone must meet certain building requirements to reduce potential flooding impacts when expanding or improving property if the improvement cost is greater than 50% of the value of the property. Chapter 4 129 The impacts of global climate change due to rise in ocean water temperature and melting of polar ice will affect future development decisions for Palo Alto since the rise in sea level will impact the low lying bay properties. According to the San Francisco Bay Conservation and Development Commission (SFBCDC) projections, mean sea level will rise between 10 and 90 cm (12 and 36 inches) by the year 2100. BCDC online maps depict a scenario for a one-meter (100 cm) rise in sea level possible for the year 2100 (http://www.bcdc.ca.gov), which exceeds projections referenced by the Intergovernmental Panel on Climate Change (IPCC) and 2006 California Climate Action Team (CCAT). Noise Probably the most pervasive source of noise in Palo Alto is motor vehicles. However, trains, aircraft, concerts, electrical substations, and mechanical equipment are also contributors, as are random sources like leaf blowers and construction equipment. Average noise levels are highest along Highway 101, El Camino Real, Alma Street and the railroad tracks, the Palo Alto Airport, and along major traffic corridors like Middlefield Road and Oregon Expressway. Sound walls or additional noise barriers may be required to reduce noise to acceptable levels for residential use along these corridors. These requirements could be viewed as constraints in that they increase the cost of new development and may prohibit owners from redeveloping or undertaking improvements. The City, however, has limited control over these requirements since they are primarily regulated by state and federal agencies. The City will continue its efforts to curb noise impacts from the above mentioned sources and will also take actions that prevent adverse levels of noise from being generated by new development. The City regulates noise impacts from loud vehicles and has a Noise Ordinance designed to address particular noise problems. It assists agencies that develop noise control legislation and promote enforcement of adopted standards. Infrastructure Constraints The City of Palo Alto is an older and well-established community with well-established infrastructure systems. The City owns and manages its utilities, including water, gas, wastewater, stormwater, and electrical. All of the identified sites on the Housing Inventory Sites list are surrounded by developed land and have the necessary infrastructure and services in place to support development. According to staff from the City Public Works and Utilities Departments, there are no significant infrastructure constraints that would affect anticipated residential development on these sites. Palo Alto receives potable water from the City and County of San Francisco’s regional water system, operated by the San Francisco Public Utilities Commission (SFPUC). The amount of water available to the SFPUC’s customers is constrained by hydrology, physical facilities, and the institutional limitations that allocate available water. The City of Palo has a long-term entitlement from the SFPUC system of 17.07 million gallons per day (MGD). The City’s supply/demand balance is discussed in detail in the City of Palo Alto’s 2010 Urban Water Management Plan (2010 UWMP). Based on the long-term water use forecast in the 2010 UWMP, there are adequate normal year supplies to serve future growth in the City, including those sites identified in the Housing Element Update. The amount of water available during a drought depends on the severity of a drought and the dry year allocation agreements between the users of the regional water system. The 2010 UWMP provides details on the City’s responses to drought reductions, including specific measures and Chapter 4 130 options to address supply limitations (Section 7 - Water Shortage Contingency Plan). Although the City will need to make adjustments to normal usage patterns, the City anticipates there will be adequate supplies to meet future demand during a drought. The City’s wastewater treatment plant has a capacity of 39 million gallons per day and has sufficient capacity to serve expected residential growth. On-going maintenance and repair of existing storm drainage, water, and wastewater improvements are identified as part of the City's Capital Improvement Plan (CIP). Needed repairs are prioritized in the CIP and projected over a multi-year period. The City’s existing stormwater infrastructure in the areas targeted for additional housing units is generally adequate to accommodate the expected storm runoff from new housing development. While there appear to be no significant infrastructure constraints on a citywide basis, there may be constraints on a site-by-site basis depending on the site's proximity to existing utility and service lines and whether there would be a need to provide additional connections or upgrades to those lines. These types of improvements would typically be the responsibility of the property owner/developer. On-site drainage improvements, in addition to any minor modifications to the municipal storm drain system triggered by the projected future development, would be the responsibility of each individual housing developer. The developers will also be responsible for incorporating stormwater source control and treatment measures into their project designs, as required by the National Pollutant Discharge Elimination System (NPDES) stormwater discharge permit issued to Bay Area municipalities by the San Francisco Bay Regional Water Quality Control Board. Small Sites Another significant constraint to new housing development is lack of available land. Palo Alto is a built-out community with very limited developable land remaining for any kind of development. About 80 percent of the Single Family lots zoned R-1 are between 5,000-10,000 square feet in size. These parcels are established R-1 neighborhoods with little chance of rezoning or developing to multifamily development in the future. As mentioned in Chapter 3, approximately 55% of Palo Alto’s total land area includes existing and designated parks, open space preserves and agricultural land conservation areas with controlled development regulations. The remaining land is, for the most part, planned for infill development with varied lot sizes. Lack of developable land and smaller parcel size is a constraint to future development for Palo Alto. The Housing Inventory Sites selection process focused on sites with lot areas over 10,000 square feet. These lots were selected because they could potentially yield at least 5 residential units at a density calculation of 20 dwelling units per acre. Some sites identified in the SOFA area are less than 10,000 square feet. With some of the smaller sites, it may be preferable that groups of parcels consolidate under one owner in order to facilitate mixed use development to provide a reasonable housing yield; however, there have been a number of mixed used developments on these smaller lots that have provided residential units. Chapter 4 131 Schools The schools in the Palo Alto Unified School District (PAUSD) consistently rank best in the state and city residents are particularly concerned with any impacts that may affect the high quality of the schools. There is community concern that additional new housing would introduce more new students into the school district and would further impact its facilities which are already near or at capacity. 4.2 GOVERNMENTAL CONSTRAINTS Local policies and regulations can impact the price and availability of housing and in particular, the provision of affordable housing. Land use controls, site improvement requirements, fees and exactions, permit processing procedures, and various other issues may constrain the maintenance, development and improvement of housing. Land Use Controls Comprehensive Plan The 2010-2020 Comprehensive Plan is Palo Alto’s chief policy document governing and guiding the long-term development of the City. The Housing Element of the Comprehensive Plan influences the production of housing along with the controls supported in the Land Use and Community Design Element. The following table describes the land use categories of the City of Palo Alto. Of the following land use categories, Single Family Residential, Multifamily Residential, Commercial and Mixed Use categories allow residential use with respective density and intensity limits for each category. Table 4-2 Existing Land Use Category Distribution of Palo Alto Land Use Categories % of Total Area** Parks / Preserve /Open Space 43.54% Single Family 21.34% Openspace/ Controlled Development 15.10% Public Facility 8.59% R&D / Limited Manufacturing 5.68% Multi Family 3.15% Commercial/Mixed Use 2.61% Vacant 0.50% ** Includes Sphere of Influence Source: City of Palo Alto Chapter 4 132 The four residential land use designations are contained in the Land Use and Community Design Element and are described below. Single-Family Residential Allows one dwelling unit on each lot as well as churches or schools (conditional uses). The typically allowed density range is 1 to 7 units per acre but the upper end of this range can be increased to 14 dwelling units per acre to accommodate second units or duplexes. Multiple-Family Residential Allows net densities ranging from 8 to 40 dwelling units per acre with more specific density limits governed by a site’s zoning district and its location. Generally, higher densities are permitted near major streets and public transit and lower densities next to single-family residential areas. Village Residential The intent of this designation is to promote housing that contributes to the harmony and pedestrian orientation of streets and neighborhoods. This designation allows a maximum density of 20 units per acre, allowing single-family housing on small lots, second units, cottage clusters, duplexes, fourplexes and small apartments. Transit-oriented Residential The intent of this designation is to allow higher density residential uses in the University Avenue/Downtown and California Avenue commercial centers within 2000 feet of a multi- modal transit station and thus support transit use. A maximum density of 50 dwelling units per acre is allowed. In addition to the residential land use designations listed above, the Comprehensive Plan allows residential development under non-residential (commercial) land use designations. A considerable portion of the City’s new housing development has been constructed in non- residential zones. New standards have been created to allow housing in these locations. These land use designations and their general development limits are described below. Neighborhood Commercial This designation typically allows smaller shopping centers with retail uses that serve nearby neighborhoods and allow housing in a mixed use configuration with housing over retail. Exclusively residential uses are generally prohibited in the Neighborhood Commercial designation, however sites designated in the Housing Element of the Comprehensive Plan may be developed pursuant to the regulations for the multifamily zone designation (RM-15, RM-30, or RM-40) identified for the site in the Housing Element. Regional/Community Commercial This designation allows larger shopping centers intended to serve markets larger than nearby local neighborhoods, but it does not allow residential or mixed use development. Sites with this designation are much larger than neighborhood shopping centers and contain large parking areas. Although residential uses are generally prohibited in the Community Commercial zone districts, such uses are allowed where a site is designated in the Housing Element of the Comprehensive Chapter 4 133 Plan. Such sites shall be developed pursuant to the regulations for the multifamily zone designation (RM-15, RM-30, or RM-40) identified for the site in the Housing Element. Service Commercial This land use designation supports citywide or regional commercial facilities for people arriving by automobile and allows mixed use development with housing and ground floor retail. Exclusively residential uses are generally prohibited in this district, however, such uses are allowed where a site is designated in the Housing Element of the Comprehensive Plan. Such sites shall be developed pursuant to the regulations for the multifamily zone designation (RM-15, RM-30, or RM-40) identified for the site in the Housing Element. Mixed Use This designation allows for combinations of Live/Work, Retail/Office, Residential/Retail and Residential/Office uses. Its purpose is to increase the types of spaces available for living and working to encourage a mix of compatible uses in certain areas, and to encourage the upgrading of certain areas with buildings designed to provide a high quality pedestrian-oriented street environment. Context-Based Design Codes The City of Palo Alto adopted form-based codes in 2006 to ensure and encourage residential development by following innovative context-based design guidelines to meet increased density needs. The code encourages creating walkable, pedestrian-oriented neighborhoods, following green building design principles and increasing density along transit corridors and in mixed-use neighborhoods. The Context-Based Design Code allows for increased density and mixed-use buildings in an appropriate and responsible way that enhances neighborhood character and walkability. Other key considerations depicted in these form-based codes include sustainability principles, tree preservation, solar orientation, historic preservation and parking design. In multi-family and mixed use zones, the development standards are presented in table format to clearly identify the setback, height, and floor area ratio requirements. In addition, the multi- family and mixed use design criteria offer a framework to guide development that is compatible with adjacent development. These guidelines provide clear direction to developers to help streamline the development review process. The guidelines are illustrated to offer examples of how parking can be integrated in to site design, appropriate locations for open space, as well as recommendations for sustainable building design. When these standards were adopted in 2007, the intent was to bring the zoning regulations into compliance with the adopted Comprehensive Plan. The form-based code has led to a better building and street design coordination, more predictable urban form, a more gradual transition between adjacent areas with different development intensities, and specification of the tapering of height, bulk, massing and lot coverage of buildings toward residential and/or commercial edges. Form based codes encourage housing development in mixed-use development for Palo Alto. Chapter 4 134 Density Bonus Provisions Density bonus is an important tool in attracting and helping developers construct more affordable housing and thus assisting the City in achieving its Regional Housing Needs Allocation (RHNA) numbers. Density bonus allows a developer to increase the density of the development above the base zoning and provide some regulatory relief in the form of concessions in exchange for providing affordable units in the development. In 2004, the State Legislature passed SB 1818, which significantly amended Government Code Section 65915, the state density bonus law. The amendment lowered the thresholds required to receive a density bonus and increased the number of concessions a developer can receive. Like all other cities and counties, Palo Alto is required to revise its current density bonus ordinance to conform with the statutes of Government Code Section 65915. Although staff is in the process of revising its ordinance, the amendments have been in effect since 2005. The City’s draft density bonus ordinance closely mirrors the SB 1818 amendments with some additional criteria. No developers have requested additional density bonus units in their developments. However, there have been developers who have requested concessions as part of their land use applications in exchange for providing affordable units. Second Units In the R-1 district and all R-1 sub districts, the minimum lot size for a second dwelling unit must be 35 percent greater than the minimum lot size otherwise established for the district. Since 2007, 19 second dwelling units have been constructed in Palo Alto averaging 4 units per year. About 22 percent of all R-1 lots meet the minimum lot size and are eligible for second dwelling units. However, the City does not have any record of how many of these lots already have an existing second unit, legal or otherwise. The City is including a program in the housing element that will explore an amnesty program to legitimize existing illegal or nonconforming second units where appropriate and consistent with maintaining the character of the existing neighborhood. The City’s parking requirements for second dwelling units requires one covered parking space for second units less than 450 square feet. The City requires one covered and one uncovered parking space for second units greater than 450 square feet mainly due to its potential for having more than one occupant with an automobile. The City allows “tandem” parking and parking in the side or rear setbacks to meet the uncovered parking requirement. Below Market Rate Housing Program Established in 1974, the City’s Below Market Rate (BMR) Housing Program has produced over 350 units of affordable housing by requiring the developer to provide a certain percentage of units as BMR in every approved project of five units or more. Currently, the program requires that for developments on sites of less than five acres, the developer must provide 15% of the total housing units as Below Market Rate (BMR) housing units. If the site is larger than 5 acres, the developer is required to provide 20% of the units as BMR housing. While the requirement has been very important in providing BMR units, it can also be a constraint. The pricing gap between a market rate unit and a BMR unit is significant. On average, a for-sale BMR unit is priced 40%-60% below its market rate counterpart. Therefore, depending on the number of Chapter 4 135 BMR units, the amount of subsidy carried by the market rate units to cover the financial gap created by the BMR units can be substantial. Given the high cost of land in the City, coupled with the large pricing gap of the BMR units, it may discourage developers moving forward with any type of housing project. In order to provide more BMR units, this Housing Element is proposing to lower the BMR requirement threshold to 3 units or more. (H.3.1.1) Given the high land costs and availability of land suitable for residential development within Santa Clara County and adjacent San Mateo County, most communities in the area have adopted inclusionary housing programs in order to provide affordable housing options. Palo Alto has had a Below Market Rate housing program since 1973. Although this could be seen as a constraint to housing development, from 2000 to 2008, Palo Alto produced an average of 100 units per year, and permits were issued for a total of 921 housing units between 2007 and 2011. The fact that most jurisdictions in the area have similar inclusionary housing programs, and that housing, including the required BMR units, continues to be produced, the City’s BMR program does not hinder housing production. In order to evaluate the program’s impact on housing production, Program H3.1.14 has been added to evaluate the provisions of the BMR program to determine if additional incentives are needed to encourage development of housing given current market conditions. Growth Control or Similar Ordinances The City of Palo Alto does not have any growth control ordinances in place. Zoning for a Variety of Housing Multifamily Rental Housing, Senior Housing, Small Size Units and Efficiency Studios and Mobile Homes and Factory-Built Housings: Policy H2.1 of this Housing Element helps to identify a variety of strategies to increase housing density and diversity near community services, including a range of unit types. It emphasizes and encourages the development of affordable housing to support the City’s fair share of the regional housing needs. Program H2.1.2 allows increased residential densities for mixed-use developments thereby encouraging more multifamily housing to be built in areas near transit and services. Currently, multifamily housing, including rental and ownership is permitted in RM-15, RM-30 and RM-40 zoning, along with mixed-use commercial zones like CS and CN. Multifamily units in structures with 2-4 units represented 6 percent of the housing stock in 2008, and 29 percent of the housing stock consisted of structures with 5 and more units. Program H2.1.5 of this Housing Element proposes to amend the Zoning Code to create zoning incentives that encourage development of smaller size housing units, including units for seniors. In addition, program H3.1.7 of this Housing Element permits Single Room Occupancy (SRO) units in commercial and high-density residential zoning districts using development standards that would encourage the construction of the maximum number of units. Sites that have access to community services and public transportation are highly desired for SRO residents. Other Chapter 4 136 R-1 R-E R-2 RMD RM-15 RM-30 RM-40 Mixed-Use Single Family P P P P P(Based on Lot Size) P(Based on Lot Size) P(Based on Lot Size) Two Family P P P P P Village Residential P P(Based on Lot Size) P(Based on Lot Size) Multiple Family P P P P (As a part of mixed use development) Residential Care P P P P P P Mobile-Homes P P P P P P Emergency Shelter Single-Room Occupancy (Considered as Multi Family Housing) P P P Transitional Housing (Considered as Residential Care Facilities/Multi Family Housing) P P P P P P Farmworker Housing Not Required Not Required Not Required Not Required Not Required Not Required Supportive Housing (Considered as Residential Care Facilities/Multi Family Housing) P P P P P P 2nd Unit (Decision based on lot size only) RESIDENTIAL USE 100 % Housing Development not allowed in this Zoning District RESIDENTIAL ZONES Source: City of Palo Alto Zoning Code P(Based on Lot Size) P=Permitted, CUP=Conditional Use. Source: City of Plao Alto Zoning Ordinance changes or additions proposed in this Housing Element to promote a variety of housing includes Program H3.1.9 that supports changes to the Zoning Code to permit innovative housing types and flexible development standards while maintaining the character of the neighborhood. Although manufactured housing and mobile homes are a permitted use in all of the City’s residential zoning districts, the City of Palo Alto currently has one existing mobile home park with approximately 60 mobile homes located within the City limits. Mobile home uses are permitted in R-E, R-2, RMD, R-1, RM-15, RM-30 and RM-40 zoning district, but are not allowed on permanent foundations in historic districts of the City. Since 2000, there has been a 64 percent drop in the number of mobile homes in the City. The 60 units in the Buena Vista Mobile Home Park make up less than 0.2 percent of the City’s housing stock. Mobile homes provide affordable housing with low yard and housing maintenance, which attracts a high number of seniors and low-income households; however, given the high cost of land in the City, it is unlikely that new mobile home development will be proposed. Program H3.1.9 of this Housing Element recognizes Buena Vista Mobile Home Park as the City’s only existing mobile home park serving low and moderate-income households and encourages its preservation. Table 4-3 Housing Types Permitted by Zoning Districts Chapter 4 137 Street Side Rear Front R-1 0.35 0.45 30 16' 20' Contextual 2 spaces; 1 covered R-2 0.35 0.45 30 16' 20' 20'1.5 spaces per unit; 1 covered RMD 0.4 0.5 35 16' 20' 20'1.5 spaces per unit; 1 covered RM-15 0.35 0.5 30 10'-16' 10'-16' 20' 1.25-2.00 spaces per unit; 1 covered RM-30 0.4 0.6 35 10'-16' 10'-16' 20' 1.25-2.00 spaces per unit; 1 covered RM-40 0.45 1 40 10'-16' 10'-16' 0-25' 1.25-2.00 spaces per unit; 1 covered Required Parking Source:City of Palo Alto Zoning Ordinance Max. Height Limit (Feet) Minimum Yard SetbackZoning District Max. Lot Coverage Floor Area Ratio (FAR) The City's Zoning Ordinance is the primary tool used to manage the development of residential units in Palo Alto. The Residential Districts described in Palo Alto’s Zoning Ordinance include the RE: Residential Estate District, R-1: Single-Family Residence District, R-2: Two Family Residence District, RMD: Two Unit Multiple-Family Residence District, RM-15: Low Density Multiple-Family Residence District, RM-30: Medium Density Multiple-Family Residence District, RM-40: High Density Multiple-Family Residence District and the Planned Community District. Permitted densities, setback requirements, minimum lot sizes and other factors vary among the residential districts. The table below lists some of the more significant standards of each of the districts. Table 4-4 Existing Residential Development Standards RE Residential Estate District The RE District is intended to create and maintain single-family living areas in more outlying areas of the City compatible with the natural terrain and the native vegetative environment. The minimum site area is one acre. Only one residential unit, plus an accessory dwelling or guest cottage, is permitted on any site. The maximum size of the main dwelling on a conforming lot is 6,000 square feet. R-1 Single Family Residence District The R-1 district is intended for single-family residential use. Typically, only one unit is allowed per R-1 lot although, under certain conditions, accessory or second dwelling units may be allowed in addition to the primary unit. Generally, the minimum lot size for the R-1 district is 6,000 square feet. However, there are certain areas of the City where the minimum lot sizes historically have been larger than 6,000 square feet and these larger lot sizes are being maintained through the Zoning Ordinance by specific R-1 zone combining districts. Chapter 4 138 Table 4-5 R-1 Districts and Minimum Site Areas The R-1 District zoning regulations also specify lot coverage maximums (typically a maximum of 35% lot coverage is allowed) and Floor Area Ratios (the ratio of the house size to the lot size). These lot coverage and FAR limits may limit the development of second dwelling units on certain lots. In addition, there are certain height restrictions that may also limit development potential. "Daylight Plane" restrictions that apply are height limitations controlling development on residential properties. In certain areas of the City where there are predominantly single-story homes, there may also be limitations on adding second stories to single-story units. R-2 and RMD Residential Districts There are two residential districts that allow two units on a site. The R-2 Two Family Residence District allows a second dwelling unit under the same ownership as the initial dwelling unit in areas designated for single-family use with regulations that preserve the essential character of single-family use. A minimum site area of 7,500 square feet is necessary for two dwelling units in this district. The RMD Two Unit Multiple-Family Residence district also allows a second dwelling unit under the same ownership as the initial dwelling unit in areas designated for multiple-family uses. The maximum density in this district is 17 units per acre. In certain instances, the City’s site development regulations can be viewed as constraints to the development of housing. Since most of the City is planned and zoned for low residential use, the City recognizes that its residential neighborhoods are distinctive and wants to preserve and enhance their special features. Since Palo Alto is a “built-out” community, most new single- family residential redevelopment will occur in existing single-family neighborhoods through infill lots or demolition/remodeling of existing structures. The regulations guiding development are intended to ensure that much of what Palo Alto cherishes in its residential areas, such as open space areas, attractive streetscapes with mature landscaping and variety in architectural styles, is preserved and protected. Multiple-Family Density Districts The Zoning Ordinance provides three categories of multiple-family residential use: low density (RM-15), medium density (RM-30) and high density (RM-40). In the RM-15 district, the permitted density is up to 15 units per acre. The RM-30 district allows up to 30 units per acre while the RM-40 allows up to 40 units per acre. All of these districts have minimum site areas, Chapter 4 139 height limitations, lot coverage and floor area ratios. In addition, all of the multiple-family zones have open space and BMR (“Below Market Rate”) requirements. PC Planned Community District The “Planned Community District” is intended to accommodate developments on a site-specific basis for residential, commercial, professional or other activities, including a combination of uses. It allows for flexibility under controlled conditions not attainable under other zone districts. The Planned Community District is particularly intended for unified, comprehensively planned developments that are of substantial public benefit. Residential and Mixed Use Zoning Combining District The Pedestrian and Transit Oriented Development (PTOD) Combining District is intended to allow higher density residential dwellings on commercial, industrial and multifamily parcels within a walkable distance of the Caltrain stations, while protecting low density residential parcels and parcels with historical resources that may also be located in or adjacent to this area. The combining district is intended to foster densities and facilitate use of public transportation. Residential Uses in Commercial Districts Prior to the Zoning Ordinance Update in 2006, all of the City’s Zoning Districts allowed for residential development. In the 1970s and 1980s, several mixed use projects were developed in the commercial zones that included significant numbers of residential units. However, during the late 1980s and 1990s, financing of mixed use projects became more difficult and the City saw a decline in mixed use proposals. Requirements for design review of mixed use projects and restrictions in uses for commercial zones resulted in constraints on the production of housing units in commercial zones. After the adoption of the new zoning ordinance in 2006, exclusive residential use is no longer allowed in commercial districts (CS, CN, CC districts); however, new development standards in the Zoning Ordinance encourage mixed use projects and have simplified the requirements and have added incentives that encourage mixed use development in the commercial zones. Site and design review of any project is required in the (D) overlay zones and (PF) Public Facility zones. Chapter 4 140 Table 4-6 Zoning Category Distribution of Palo Alto Zoning Categories Acres % of Total Area ** Public Facilities District (PF)5,106.35 32.62% Open Space District (OS)4,262.75 27.23% Single Family Residentail District (R-1)3,545.63 22.65% Research Park District (RP)713.53 4.56% Planned Community Districts (PC)326.63 2.09% Residentail Real Estate District (RE)289.59 1.85% Medium Density Multiple Family Residential District (RM-30)271.89 1.74% Research Office Limited Manufacturing District (ROLM)197.07 1.26% Low Density Multiple Family Residential District (RM-15)148.24 0.95% Community Commercial District (CC)128.42 0.82% General Manufacturing District (GM)116.55 0.74% Seervice Commercial District (CS)116.02 0.74% Agricultural District (AC (D))92.36 0.59% Two-Family Residential District (R-2)79.87 0.51% Commercial Downtown District (CD)70.17 0.45% Neighborhood Commercial District (CN)69.90 0.45% High Density Multiple Famile Residential District (RM-40)39.15 0.25% Medical Office and Medical Research District (MOR)24.42 0.16% Two Unit Multiple Family District (RMD)23.12 0.15% Residential Transition District SOFA 2 (RT-35)16.15 0.10% Attached Multi Family District SOFA 1 (AMF)6.77 0.04% Detached ouses on Small Lots SOFA 1 (DHS)6.64 0.04% Residential Transition District SOFA 2 (RT-50)3.13 0.02% Pedestrian and Transit Oriented District (PTOD)1.04 0.01% Grand Total 15,655.39 100.00% ** Does Not Include Sphere of Influence Source: City of Palo Alto Height Limits Limitations on height can constrain a developer’s ability to achieve maximum densities especially with other development controls. Height limits in the R-1, R-2, RMD, RM-15, RM-30 vary between 30 to 35 feet. In the RM-40 zoning district, the maximum height is 40 feet, which Chapter 4 141 is enough to accommodate 3 to 4 story construction. Mixed-use development standards in CS, CN, and CC zone and Downtown Commercial zones allow a maximum height of 50 feet. Theoretically, this could accommodate 4-story construction; however, the parking requirements and construction costs for four story buildings often result in the developer choosing to construct three story developments. Therefore, height can be viewed as a constraint in achieving maximum densities. Since the City of Palo Alto is close to a built out community; the types of development occurring in the last few years is mostly infill development. For infill development, zoning, FAR and height limits sometimes pose a challenge in attaining maximum allowable density. Due to market demand in the early 2000’s, the City of Palo Alto built considerable three bedrooms town home condominiums. The large size of the units (1500-1800sqft), preclude building up to maximum allowable density. Restricting unit size and reducing parking requirements could help to achieve higher densities. Parking Parking requirements vary depending on the type of dwelling, the zoning designation and in the case of multifamily units, the number of bedrooms per unit. The basic requirement for a single-family house is two spaces, at least one covered, with underground parking generally prohibited. In the case of second dwelling units, the size of the second unit determines the parking requirement. If the unit is greater than 450 square feet, two spaces of which one must be covered are required. If the unit size is less (less than 450 sq ft) only one space covered or uncovered is required. For Multiple Family Residential districts the following parking is required: 1.25 space per studio unit, 1.5 space per 1-bedroom unit and 2 spaces per 2-bedroom or larger unit. At least one space must be covered, with tandem parking allowed for units requiring 2 spaces. Guest Parking is also required for projects that exceed three units. When residential use is allowed together with or accessory to other permitted uses, residential use requirements are applicable in addition to other nonresidential requirements, except as provided by Sections 18.52.050 and 18.52.080 of the Palo Alto Municipal Code. Disabled Accessible parking is provided pursuant to the requirements of Section 18.54.030 (Accessible Parking) of the Palo Alto Municipal Code. Excessive parking standards requirements can pose a significant constraint on housing development by increasing development costs and reducing the potential land availability for project amenities or additional units and may not be reflective of actual parking demand. While the City of Palo Alto’s parking standards tend to be workable on larger projects, they are a potential constraint to the development of small infill development. The requirement that the spaces be covered can also be viewed as a constraint, as it means that garages or carports must be factored into the cost of the project. Multifamily units in mixed-use projects are subject to requirements that cumulatively add the multiple family requirements with the commercial parking requirements portion of the project to determine the total number of spaces needed. Parking reductions may be considered; however, these reductions are considered on a case-by- Chapter 4 142 case basis. Parking requirements for multifamily housing can hinder the projects ability to achieve the maximum allowable density. The Palo Alto Zoning code does allow concessions for parking for senior housing and affordable housing projects. For Senior Housing, the total number of spaces required may be reduced, commensurate with the reduced parking demand created by the housing facility, including spaces for visitors and accessory facilities, and is subject to submittal and approval of a parking analysis justifying the reduction proposed. The total number of spaces required may be reduced for affordable housing and single room occupancy (SRO) units, where the number of spaces required is commensurate with the reduced parking demand created by the housing facility, including for visitors and accessory facilities. The reduction is further considered if it is located in proximity to transit and support services. The city may require traffic demand management measures in conjunction with any approval. For housing near transit areas, the City of Palo Alto allows a maximum reduction of 20% of the total required spaces. Table 4-7 Parking Requirements for Residential Zones 4.3 DEVELOPMENT REVIEW PROCESS Fees and Exactions Chapter 4 143 Housing development is typically subject to two types of fees or exactions: Permit Processing fees for planning and zoning and Development Impact Fees or exactions imposed to defray all or a portion of the public costs related to the development project. There are four types of Development Impact fees charged by the City of Palo Alto. They are Housing Development Impact fees, Traffic Impact fees, Community Facilities Impact Fees and Parkland Dedication fees. All residential projects are exempt from Housing Development Impact fees. The City's development fee structure does not appear to be a significant impediment to residential development. Residential developments are charged fees according to the value of the project for building, planning and fire review. The fees for parks, community centers, and libraries add $13,458 to the price of a single-family dwelling unit less than 3000 square feet and $8,766 to the price of a multifamily dwelling more than 900 square feet. These fees are likely to increase the cost of a median priced single-family dwelling by about 1% and increase the cost of a median priced multifamily dwelling by about 1.3 percent. Combined with additional planning, building and other fees the City charges, Palo Alto’s fee structure adds about 2 to 3 percent to the cost of a median priced single-family dwelling and about 2 percent to the cost of a median priced multifamily dwelling. These increased costs are not significant when compared to the cost of land, labor and materials for development in Palo Alto, but they could impact affordable housing projects with limited budgets. Due to this factor, the City has exempted all 100% affordable housing projects from all development impact fees including new parks, community centers, and libraries fees. Since Palo Alto’s fee schedule is less costly for multifamily units than single-family units, this provides some incentive for the increased production of multifamily units. In addition, the fee schedule reduces the fees for multifamily units of less than 900 square feet to $4,454, approximately 50% less than the larger multifamily units. This provides an incentive for development of smaller, less expensive multifamily units. Table 4-8 Palo Alto Residential Development Impact Fees Fee Single Family Single Family over 3000 s.f. Multi-Family Multi-Family under 900 s.f. Parks 9,971$ 14,890$ 6,527$ 3,300$ Comm Ctr 2,585 3,870 1,700 858 Libraries 902 1,344 539 296 Total 13,458$ 20,104$ 8,766$ 4,454$ basis per home per home per unit per unit Fee Commercial Hotel/Motel Parks 4.234$ 1.915$ Comm Ctr 0.239$ 0.108$ Libraries 0.228$ 0.096$ Total 4.701$ 2.119$ basis per net new s.f. per net new s.f. Chapter 4 144 Table 4-9 Palo Alto Development Impact Fee Exemptions X = Exempt NOTE: When an exempt use changes to a non-exempt use, a fee is due. Exemption Housing Community Facilities Traffic: Charleston/ Arastradero Citywide Traffic Fee Traffic: San Antonio Traffic: SRP Parkland Dedication Ordinance section 16.47.030 16.58.030 16.60.040 16.59 16.46.030 16.45.050 21.50.100 Residential Exemptions Single-family home remodels or additions All residential uses exempt X X X All residential uses exempt All residential uses exempt X New home on an empty parcel Only applies if a subdivision or parcel map is required Second units Multifamily Residential Required BMR units Below Market housing beyond required units X X X 100% Affordable Housing X X X X Non-Residential Exemptions Demolition of existing building Fees may apply if replacement building has additional floor area, or in the case of the Citywide TIF, if the replacement building generates additional traffic, regardless of whether it remains the same size or not. All non- residential uses exempt Tenant improvements that do not increase building area X X X X X X Churches X Colleges and universities X Commercial recreation X Hospitals and convalescent facilities X Private clubs, lodges, and fraternal organizations X Private educational facilities X Public buildings & schools X X X X X X Retail, personal service, or automotive service 1,500 s.f. or smaller (one-time) X X X X X Non-residential use 250 s.f. or smaller X X Hazardous materials storage X X X X X X On-site cafeteria/ recreation/ childcare (employee use only) X X X X X X Thermal storage for energy conservation X X Temporary uses < 6 months X X Daycare, nursery school, preschool X X X X (Not open to general public) X (Not open to general public) Chapter 4 145 The South Bay Area Cost of Development Survey conducted by Home Builders Association of Northern California identifies Palo Alto as one of the mid-level impact/infrastructure fee charging cities for both single family and multiple family home construction. Palo Alto’s building and planning permit processing fees are comparable to similar fees charged by other jurisdictions in the Bay Area. The survey conducted by the Home Builders Association uses 2006-2007 information and compares the City of Palo Alto’s Entitlement fees with surrounding cities of Mountain View, Sunnyvale and Cupertino. Palo Alto ranks as one of the lowest entitlement fees charging cities in the south Bay Area. It should be noted, however, that the entitlement fees are designed only to cover the cost the City incurs to process these development applications and provide the support services needed by City staff. The City currently allows for waiver of existing fees for very low- and low-income housing projects. The Housing Element Programs H3.3.1 and H3.3.3 allow affordable housing projects to be exempt from infrastructure impact fees and, where appropriate, waives the imposition of development fees; however, other public service districts may charge fees that are outside of the control of the City. The most significant of these fees in Palo Alto are school impact fees. The Palo Alto Unified School District adopted a fee schedule in 2000 that specifies a fee of $2.97 per square foot for residential units. For infill and individual single-family development, the Public Works fees are minimal and estimated to be about 12 percent of the Building permit fees. For a residential subdivision, the most significant Public Works fee would be the fee for a Street Work Permit, which is 5% of the value of the street improvements. The City's Utility Department charges for gas, sewer and water hook-ups. Chapter 4 146 Table 4-10 CITY OF PALO ALTO PLANNING DIVISION APPLICATION FEE SCHEDULE EFFECTIVE AUGUST 27, 2010 Chapter 4 147 Table 4-10 Continued Chapter 4 148 Table 4-10 Continued Chapter 4 149 Table 4-11 Building Permits and Other Department Fees Nexus Requirements A Jobs–Housing Nexus Analysis for the City of Palo Alto, as outlined below, was prepared by Keyser Marston Associates in 1993 and partially updated in 1995. The Nexus study was done to meet the requirements of AB1600, as amended to Government Code Section 66001 of the California Code, in support of the City’s housing linkage fee program. The nexus analysis focused on the relationships among development, growth, employment, income and housing. The analysis yielded a causal connection between new commercial/industrial construction and the need for additional affordable housing. The analysis did not address the existing housing problems or needs, nor did it suggest that development and its relationships were the only cause of housing affordability problems and the development community should bear the full cost of addressing affordability problems. The study focused on documenting and quantifying the housing needs for the new working population in the non-residential structures. The study was updated in 2002. Based on the results of the study, on March 25, 2002, the City Council approved modifications and additions to Impact Fees collected for residential and commercial development projects. The key change in the housing fee was to increase the fee from $4.21 per square foot to $15.00 per square foot applied to nonresidential development and require that an annual cost of living adjustment be made. Chapter 4 150 Parks, Community Center, and Libraries Development Fee: The City completed surveys of the number of residential and non-residential users of parks, community center, and libraries, and generated estimates of the acres or square feet of park, community center, or library space required to accommodate the residents and employees of Palo Alto. A development fee was adopted for parks, community centers and libraries based on the number of employees or residents generated by each residential or commercial project using square feet or number of units. Housing Development Fee: The City studied the number of low-income jobs generated by different types of employers. The housing impact fee is based on the cost to the City to provide affordable housing for those employees who would choose to live in Palo Alto if housing was available. As a result of the nexus study, the fee level is set to recover approximately 20% of the cost of providing such housing. Building Codes and Enforcement The City has adopted the Uniform Building Code (UBC), published by the International Conference of Building Officials, which establishes minimum construction standards. Although a locality may impose more stringent standards, it cannot adopt any that are less restrictive than those of the UBC. Thus, the City cannot modify the basic UBC requirements. Enforcement of building code standards does not constrain the production or improvement of housing in Palo Alto but serves to maintain the condition of the City’s neighborhoods. The City's code enforcement program is an important tool in maintaining its housing stock and protecting residents from unsafe conditions. This is particularly important because approximately 29% the City's current housing stock was built in the decade between 1950-60. Local enforcement is based on the State's Uniform Housing Code that sets minimum health and safety standards for buildings. The City has amended its Building Code to include more stringent requirements for green buildings and LEED certification. The City also administers certain State and Federal mandated standards in regards to energy conservation and accessibility for disabled households. The City of Palo Alto, Department of Building Inspection, implementing the Building Code, requires all new construction and rehabilitation projects to comply with the Code’s disability access requirements. In reviewing these standards, certain requirements especially in regard to disabled accessibility may be viewed as a constraint to housing production. The City has no direct control over these types of requirements. Building Division staff investigates and enforces city codes and state statutes when applicable. Violation of a code regulation can result in a warning, citation, fine, or legal action. If a code violation involves a potential emergency, officers will respond immediately; otherwise, complaints are generally followed up within one working day by visiting the site of the alleged violation, and, if necessary, beginning the process of correcting the situation. On/Off-Site Improvement Standards Site improvements are considered a necessary component of the development process. The types of improvements may include the laying of sewer, water, and streets for use by a community. Due to the “built-out” nature of the City, most of the residential areas in Palo Alto are already Chapter 4 151 served with adequate infrastructure. New construction or infill developments may require the City to extend or add to the existing infrastructure facilities. In few instances, the City’s site development regulations can be viewed as constraints to the development of new housing. The development standards described before indicate that the maximum densities allowed by each residential zoning district can readily be achieved and can produce units of a reasonable size. Lot coverage, FAR and height standards increase as densities increase to accommodate the maximum density allowed by each district. Open space standards are concomitantly reduced to accommodate these increasing densities but still allow for adequate private and communal open space. Parking standards are governed by the number of bedrooms in the case of multifamily residential development and are directly related to the number of people of driving age expected to live in these units. Residential development standards in Palo Alto are comparable with development standards in other Bay Area communities, including communities with lower housing costs such as San Jose. Given this, it appears that Palo Alto’s residential development standards are reasonable and do not significantly add to the cost of residential units in the City when compared to the high costs associated with the purchase of land, labor and construction materials. However, these extra requirements, add substantial additional cost to the already tightly budgeted affordable housing projects. Development Review Process Processing and permit procedures can pose a considerable constraint to the production and improvement of housing. Common constraints include lengthy processing time, unclear permitting procedures, layered reviews, multiple discretionary review requirements, and costly conditions of approval. These constraints increase the final cost of housing, create uncertainty in the development of the project, and overall result in financial risk assumed by the developer. In Palo Alto there are various levels of review and processing of residential development applications, depending on the size and complexity of the development. For example, single- family use applications that require a variance or home improvement exception can be handled by the Director of Planning and Community Environment but more complicated applications, such as subdivision applications or rezoning, require review and approval by the Planning Commission and City Council and, in some instances, the City's Architectural Review Board. Residential development applications that fall under the responsibility of the Director of Planning are usually processed and a hearing held within 6-8 weeks of the application submittal date. This includes review by the Architectural Review Board, which is required for all residential projects except individually developed single-family houses and duplexes. Rezoning and minor subdivision applications typically have a longer time frame since they must be heard by both the Planning Commission and the City Council. Generally, an application will be heard by the Planning Commission 7-10 weeks after application submittal. Local ordinance requires the City Council to consider the Planning Commission recommendations within 30 days; therefore, there would be a maximum of 30 more days after the Planning Commission hearing for the City Council's action on these applications. If the application is for a major Site and Design or Planned Community rezoning, then the Architectural Review Board will conduct a hearing after the Planning Commission hearing and this could affect the time frame. As part of the Housing Element, in order to incentivize mixed use development, sites listed on the Housing Sites Inventory for mixed use development will not be subject to Site & Design Review if the project size is less than 9 units, the site is developed with a mixed use development of 20 DU/AC Chapter 4 152 and the maximum unit size is 900 sq. ft. For rezoning projects, the Planning and Transportation Commission reviews the project twice, before and after the Architectural Review Board recommendation and prior to the City Council action. This adds considerably to the processing timeline. Further, all of the time frames referenced above assume that all environmental assessment and/or studies have been completed for the development. Additional time will be required if there are any environmental issues that need to be studied or resolved as a result of the environmental assessment. With the exception of rezoning proposals, permit processing timelines in Palo Alto are comparable to other jurisdictions in the Bay Area. Architectural Review Board (ARB) approval is required for all residential projects except individually-developed single-family homes and duplexes. The ARB sets certain standards of design in order to keep the high quality of housing in Palo Alto. The ARB process may result in requiring a higher level of design, materials and construction, which can be a constraint to the development of housing; however, the level of review and the upgrade in materials has the long term benefit of lower maintenance and higher retention of property values. Moreover, the construction of thoughtful and well-designed multifamily housing has sustained community support for higher density projects and has resulted in community support for residential projects at all income levels. Furthermore, preferences on materials are sometimes waived for affordable housing projects. Architectural review is an important and necessary procedure to insure that new development is consistent and compatible with the existing surrounding developments. All new construction projects of 5000 square feet or more, and all multi-family projects with 3 or more units are required to be reviewed by the Architectural Review Board (ARB). A preliminary meeting with Planning staff is recommended to help streamline the process by identifying any potential issues up front. The design criteria found in the updated zoning code also provides clear guidelines for residential and mixed use projects. Generally, standards are related to measurable criteria such as setback, height and floor area. Once an application is submitted, it is routed to other City departments to obtain a comprehensive review of all code requirements. Once an application is deemed complete, it is scheduled for ARB review, and a recommendation is made. The municipal code findings for Architectural Review include that the design should be consistent with applicable elements of the comprehensive plan, consistent with the immediate environment, promote harmonious transitions in scale and character between different land uses, and that the design incorporates energy efficient elements. The final decision is made by the Planning and Community Environment Director, and this decision may be appealed to the City Council. The timeline for this process can range from 3 to 6 months. In order to expedite processing of applications, the Council recently approved a process revision that establishes that the Architectural Review Board has a maximum of three meetings to approve or deny an application. Because guidelines have been established for this process, there is a fair degree of certainty in the review process. In an effort to make the design review process in Palo Alto more efficient and predictable, the City has developed design guidelines for key areas of the City and preliminary review processes for major development projects. The design guidelines cover sensitive areas of the City and include the El Camino Real area, the Downtown, the Baylands, and the South of Forest Avenue Chapter 4 153 (SOFA) area. These guidelines describe the design issues and neighborhood sensitivities each development project in these areas must address and the types of designs and design elements that would be acceptable in these areas and, thus, ensure that new projects are compatible with existing neighborhoods while also creating and maintaining a desirable living and working environment. The City has established two preliminary review processes for significant development projects to assist developers in identifying critical issues to be addressed and potential design problems to be resolved prior to filing a formal application. A small fee is charged for this optional service but these processes can save time by proactively addressing issues that could delay construction of a project, which, ultimately, is the greatest contributor to increasing project development costs. The Preliminary Architectural Review process allows the City’s Architectural Review Board to review potential projects or project concepts and give useful direction during the initial or formative design steps of the project. Planning staff also reviews the project to ensure compliance with Zoning Code requirements and other pertinent design guidelines and planning policies. The preliminary process also provides other City departments with an opportunity to comment on the proposed project and identify concerns and requirements which the project must address. Preliminary Review is intended to prevent costly project redesigns and other potential delays that could significantly increase the cost of a project. The project issues covered include potential environmental problems and major policy issues in addition to the design issues covered in the Preliminary Architectural Review process. Planning staff and other City department staff also review the project for compliance with all pertinent City codes and guidelines. Both of these processes give the developer valuable information that will expedite development. Since processing delays can significantly increase the cost of housing construction, the City does, on an ad hoc basis, provide for preferential or priority processing for affordable housing projects. The City requires environmental review for most discretionary projects based on the nature of land use and the change of use the project proposes. Single Family home construction is exempt from the CEQA review process. Multifamily residential projects may require environmental review depending on the size and complexity of the project. Chapter 4 154 Under 3000s.f. Over 3000 s.f. Under 900 s.f.Over 900s.f. (ARB) Architectural Review Board (Major and Minor)N/A Major ARB Required only in Open Space Districts Major ARB Required only in Open Space Districts Major ARB Required only in Open Space Districts Major ARB Required Required Environmental Assessment Environmental Impact Assessment (EIA)N/A N/A N/A Mitigation Monitoring (MND) Depending on Size and Magnitude of the Project Depending on Size and Magnitude of the Project Required Mitigation Monitoring (EIR) Depending on Size and Magnitude of the Project Depending on Size and Magnitude of the Project Required Categorically or Statutorily Exempt N/A N/A N/A Depending on Size and Magnitude of the Project Depending on Size and Magnitude of the Project Required Historic Review Historic Review Board (Minor and Major Project) Historic Review Board (Demolition of Historic Building) Site and Design Review (Minor and Major Project) Subdivision Review Preliminary Parcel Map and Parcel Map Review Tentative Map and Final Map Review May be Applicable Depending the Year of Construction of the Building Applicable if in the "D" Overlay Zone N/A N/A New Single Family Home on Vacant Parcel Multi Family Residentials Affordable Housing Typical Approval Requirements Single Family Home Remodels or Additions N/A May be Applicable depending on the Size of the Project N/A N/A May be Applicable Depending the Year of Construction of the Building May be Applicable depending on the Year of Construction of the Building May be Applicable depending on the Year of Construction of the Building May be Applicable depending on the Size of the Project May be Applicable depending on the Size of the Project Table 4-12 Typical Processing Procedures by Project Type Chapter 4 155 Type of Approval or Permit Typical Processing Time Building Permit Review Depends on the size and complexity of the project Conditional Use Permit 3 months (approx) General Plan Amendment Not required for housing development other than a residential PC in a commercial district Site & Design Review Only required for "Site and Design D" overlay zones, 6 months (approx) Architectural/Design Review Required for Multiple Family Housing and Single Family Housing in Open Space Districts, 3-6 months (approx) Tentative and Final Maps For Development with more than 5 units, 3-6 months for Tentative Maps and 1 month for Final Map Perliminary and Parcel Maps For Development with less than 5 units, 2 months for Preliminary Map and 1 month for Parcel Map Initial Environmental Study Environmental Impact Report Based on size and complexity of the project, 3 months to years. Source: City of Palo Alto Zoning Code Under 3000s.f. Over 3000 s.f. Under 900 s.f.Over 900s.f. Conditional Use Permit (CUP) N/A N/A N/A N/A N/A N/A Residential Variance Home Improvement Exception (HIE) Individual Review - New Two Story Residence or addition to existing one story Applicable Applicable Applicable N/A N/A N/A Individual Review - Second Story expansion >150 s.f. Applicable Applicable Applicable Neighborhood Preservation Zone Exception Other Reviews Planned Community Zone Change Nonconforming Use Review Typical Approval Requirements Single Family Home Remodels or Additions New Single Family Home on Vacant Parcel Multi Family Residentials Affordable Housing May be Requested depending on Lot Configuration, Location and Affordability of the Housing Type. Grandfathered In Source: City of Palo Alto Zoning Code May be Applicable Depending on the Location and Zoning District of the Project May be Applicable Table 4-13 Typical Processing Procedures by Project Type Contd. Table 4-14 Timelines for Permit Procedures Chapter 4 156 4.4 CONSTRAINTS TO HOUSING FOR PERSONS WITH DISABILITIES This section will describe any potential or actual regulatory constraints, if any, on providing housing for the disabled in Palo Alto. The City strictly enforces the Federal Americans with Disabilities Act (ADA) and state requirements to ensure that minimum housing access requirements are met. The City also enforces disabled parking standards described in its Zoning Code for all land uses. The City is not aware of any significant constraints to the provision of affordable housing for the disabled in its Zoning Code or other regulatory provisions and has approved on an ad hoc basis, regulatory changes necessary to accommodate the needs of disabled households as required by State law. A review of the City of Palo Alto’s zoning laws and permits was conducted as a part of comprehensive study of fair housing in Santa Clara County in 2002. This study was commissioned and funded by all CDBG jurisdictions in the county, including Palo Alto, to comply with HUD's requirement for cities to conduct analyses of impediments to fair housing. The report concluded that the cities' codes were in compliance with State fair housing standards, although the authors noted they did not observe how individual permits were processed. In addition, fair housing advocates interviewed for the study generally felt that local officials acted reasonably in processing applications for the siting of group homes and other zoning issues. An analysis of regulations and processes of the City of Palo Alto shows that the City conscientiously implements and monitors Title 24 of the California Code of Regulations, which are the regulations on access and adaptability for persons with physical disabilities. These regulations, which implement State law, apply to new construction of multiple-family units in buildings having three or more units. When there is a conflict between a Title 24 requirement and a zoning ordinance requirement (for example, the location of a disabled accessible ramp and a required building setback), the City attempts to identify the conflict early in the review process and resolves it with priority given to the Title 24 requirement. The approval is administrative, and there is no fee. Although there are no mandatory disabled accessibility requirements for single-family houses, the City assists physically disabled low-income homeowners with minor accessibility modifications to their homes by funding through the Home Access Program. The City's parking requirements ensure adequate disabled accessible parking. In addition, the City has the flexibility to reduce the overall parking requirement for a use with lower-than- normal demand, for example, in special needs housing where the occupants have fewer cars. The reduction can be approved through the Planning department, which is less stringent than the variance process used in many other cities for review of applications for parking reductions. Special Needs Housing Group homes for disabled people are allowed under Palo Alto’s code requirements as "residential care homes." Residential care homes are allowed in all residential zones including R- 1, R-2, RM-15, RM-30 and RM-40. Residential care homes with less than six units are allowed by right in all the above-mentioned zones. Residential Care Homes are allowed with a Chapter 4 157 Conditional Use Permit in PF (Public Facility) and GM (General Manufacturing) districts. Consistent with other use permits, a public hearing is required as part of the approval process. Emergency and Transitional Housing An emergency shelter is a facility that houses homeless persons on a limited, short-term basis. Under the City’s existing code, emergency homeless shelters are treated as Residential Care Facilities/Multi Family Housing. This is a permitted use in R-1, R-2, RMD, RM-15, RM-30, and RM-40 zones. Effective January 1, 2008, California SB 2 requires all jurisdictions to have a zoning district that permits at least one year-round emergency shelter without a Conditional Use Permit or any other discretionary permit requirements or the City must enter into a multi- jurisdictional agreement with neighboring jurisdictions to meet its emergency shelter need. Palo Alto currently does not meet this requirement and must identify a zone where emergency shelters are permitted by-right within one year from the adoption of the housing element. The City of Palo Alto has identified the portion of the Research, Office and Limited Manufacturing-Embarcadero (ROLM)(E) zone district east of Highway 101 as having potential sites to accommodate emergency shelters. This area is a light industrial zone, which contains such uses as office use, research facilities and light manufacturing. It is also accessible by transit, and there are retail support services located nearby. The identified area can accommodate a shelter large enough to have capacity for the City’s unmet homeless need. The City has an unmet need of 107 beds. This could translate into a shelter of 107 beds, or the need could be accommodated in two or more shelters of smaller size. Depending on the size of the site required, and other amenities provided in a homeless shelter, an adequately sized facility could be accommodated in this zone. Based on the need for 107 beds, it has been determined that a one-half acre site could accommodate the need for a shelter, or two shelters could be accommodated on smaller sites. There are several sites in this area which are one half acre or more. In addition, there are opportunities for site consolidation. The ROLM(E) district is also appropriate because the square footage costs of industrial or light manufacturing property is much less than residentially or commercial zoned parcels, making the emergency shelter use in this area more cost efficient. Also, there are existing buildings in this area which are of an appropriate size to be converted to an emergency shelter. Accessibility to the downtown from this area is available through the City’s free Palo Alto shuttle, which operates in the morning through the early evening throughout the work week. Transitional housing facilities may be configured as apartments, individual shared units, or dormitory facilities. SB 2 requires that local ordinances regulate transitional facilities in the same manner as comparable apartments or group living accommodations (e.g. convents, school dormitories, etc.). Facilities may be accessory to a public or quasi-public use such as a social service agency, religious assembly or institutional use, or other facilities operated by a nonprofit organization. In all cases, however, occupancy is for a specific term that must be more than six months. In contrast to supportive housing, it is linked to onsite or offsite services, and is occupied by a target special needs population such as low-income persons with mental disabilities, AIDS, substance abuse, or chronic health conditions. Services typically include assistance designed to meet the needs of the target population in retaining housing, living and working in the community, and/or improving health, and may include case management, mental Chapter 4 158 health treatment, and life skills. The City’s current Zoning Ordinance does not identify a separate zoning district where transitional or supportive housing are permitted uses. Instead, transitional housing is treated as Residential Care Facilities/Multi Family Housing and is a permitted use in the R-1, R-2, RMD, RM-15, RM-30, and RM-40 districts. Currently, the transitional housing demand of the City has been met through the services provided by the Opportunity Center for both individual adults and family households. Reasonable Accommodations Requests The City of Palo Alto is committed to accommodating people with disabilities. In compliance with the federal Fair Housing Act, the Americans with Disabilities Act and Section 504 of the Rehabilitation Act (and implementing regulations), the requirements of the California Fair Employment and Housing Act and the Unruh Civil Rights Act, the City will make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford an otherwise qualified person with a disability equal opportunity to use and enjoy a dwelling unit, including public and common use areas. The law requires the City to incur reasonable costs to accommodate applicants and residents. An accommodation is reasonable provided it does not impose undue financial and administrative burdens or constitute a fundamental alteration of the relevant housing program. This policy governs applicant and resident requests for accommodations with respect to the Below Market Rate (“BMR”) Housing Program administered by the City of Palo Alto (City) and/or PAHC Housing Services LLC (PAHC) as its designee. The policy conforms to the requirements of the federal Fair Housing Act, the Americans with Disabilities Act, Section 504 of the Rehabilitation Act (and implementing regulations), and to the requirements of the California Fair Employment and Housing Act and the Unruh Civil Rights Act, under which it is illegal to refuse to make reasonable accommodations in rules, policies, practices, or services when such accommodations may be necessary to afford a person with a disability equal opportunity to use and enjoy a dwelling unit, as well as public and common use areas. Zoning regulations may be a constraint to development or conversion of housing to make it suitable for persons with disabilities. Physical improvements needed to accommodate a person’s disability may consist of ramps, handrails elevators, lifts, or other physical improvements. Particularly when retrofitting existing housing, it may not be possible to build these improvements within the setbacks, lot coverage and other standards required in a specific zoning district. The City is proposing to amend the zoning code to provide a procedure which would allow a request for modification to these rules, standards and practices for siting, development and use of housing-related facilities to eliminate regulatory barriers and provide a person with a disability equal opportunity to housing of their choice. Building Codes and Development Regulations The State of California has adopted statewide, mandatory codes based on the International Code Council's (ICC) codes. As part of the code, the City is required to update its Building Code every three years to be consistent with the State updates. The local jurisdiction can adopt more stringent codes than required by the State. Other than some minor variations to the code updates, the City has adopted the State updates as issued. The City’s Building Codes are reasonable, Chapter 4 159 similar to the codes of neighboring jurisdictions, and would not adversely or hinder the construction of affordable housing. Chapter 5 160 CHAPTER 5 PAST ACCOMPLISHMENTS AND NEW HOUSING GOALS, POLICIES AND PROGRAMS. 5.1 1999-2006 HOUSING PLAN ACCOMPLISHMENTS Progress in Meeting the 1999-2006 RHNA From 1999 to 2006, the period covered by the City’s previous Housing Element, Palo Alto successfully produced, or approved, 1,713 housing units affordable to various income groups. As shown in the table below these units represented 123 percent of the housing need that ABAG allocated to the City for the planning period. 1999-2006 Cycle’s Performance in Achieving RHNA Goal The 1,713 units that were approved, constructed and were already occupied or were ready for occupancy during the 1999-2006 planning period included more than twice (204 percent) the number of above moderate-income units ABAG allocated and 112 percent of the low-income need. However, the numbers allocated for very low and moderate income households were not achieved. Income Category 1999-2006 New Construction Need Actual New Construction Need Met in 1999-2006 Cycle* Percentage of Need Achieved in 1999- 2006 Cycle Very Low (0-50% of AMI)265 158 60% Low (51-80% of AMI)116 130 112% Moderate (81-120% of AMI)343 53 15% Above Moderate (over 120% of AMI)673 1,372 204% TOTAL UNITS 1,397 1,713 123% * Building Permits Issued in the cycle Source: City of Palo Alto, Chapter 5 161 Summary Evaluation of Past Accomplishments Under State Housing Element law, communities are required to assess the achievements under their adopted housing programs as part of their housing element update. These results should be quantified where possible, but may be qualitative where necessary. The City’s housing accomplishments during the 1999-2006 planning period are evaluated as part of the basis for developing appropriate policies and programs for the 2007-2014 planning period. A full account of the status in achieving the goals, policies and programs from the 1999-2006 planning period can be found in the Appendix of this section entitled 1999-2006 accomplishments matrix. As part of implementing the vision of the 1999-2006 Housing Element, the City provided funding for the following affordable housing projects that contributed to accomplishing the City’s RHNA goals:  Oak Court Apartments Affordable Housing Project – deferred land loan assistance of $6.5 million and provided $1.9 million City loan for development costs for 53 units of very low- and low-income family-oriented rental apartments.  Opportunity Center Facility Project – provided $750,000 project funding from City housing funds and $1.28 million in Community Development Block Grant (CDBG) funds for predevelopment and site acquisition for 88 units of permanent and transitional housing and a day use and service center for homeless adults and families.  In 2004, the City of Palo Alto received $1,000,000 from the State Local Housing Trust Fund Program to fund the Palo Alto Family Apartments housing project on Alma Street. The City allocated that funding in conjunction with a $1.5 million City funding match to a 50 unit project for very low income families. The project received City entitlements in 2010.  In 2006, the City used $1.15 million in CDBG funds to assist a non-profit acquire a 10 unit apartment complex for low income residents. The City also furthered its commitment to providing affordable housing through:  Updating its Below Market Rate (BMR) Program. In 2004, the City initiated a study of its BMR Program to evaluate how the program can be more effective in helping the City achieve affordable housing objectives and increase production of affordable owner and rental units. As a result of that study, the City Council approved BMR Program changes in 2008 that improved the current BMR program by increasing the efficiency of program administration and strengthened the BMR requirement to increase overall affordable housing production.  Adopting a BMR ordinance. In 2008, the City codified in the zoning code its Below Market Rate Program previously found in the Housing Element to more effectively govern and define its inclusionary housing program. Chapter 5 162 Response to AB 1233 Of the City parcels that were proposed to be rezoned in Program H-14, the City rezoned all but one parcel as specified in the City’s 1999-2006 Housing Element. The total estimated yield of the one unzoned parcel is 15 units. Therefore, the City’s unmet need is 15 units. In the Draft Housing Element in Appendix 5.3, (1999-2006 Accomplishments Matrix), the City originally reported for Program H14, that it had three unzoned parcels, rather than one. The yield of the two additional parcels originally reported to be unzoned for housing was estimated to be 20 units. Based on further research, the City has determined that the two previously reported unzoned parcels were in fact rezoned. The City will update Appendix 5.3 to reflect this. The explanation of the zoning history of the two parcels is set forth below. At the time of Housing Element adoption in 2002, the City was in the process of adopting the South of Forest Avenue Coordinated Area Plan, Phase 2 (SOFA2) in which two of the parcels are located. The parcels were rezoned from Commercial Downtown-C (community) or CD-S (service), which allowed for mixed use development, to the SOFA 2 land use designation of Residential Transition-50 (RT-50) when SOFA 2 was adopted in December 2003. The RT-50 zone also allows for mixed-use residential developments. The difference between CD and RT- 50 zoning is that CD density is measured by units per acre while RT-50 determines residential density by Floor Area Ratio (FAR). In addition, if it is a proposed residential rental development, the RT-50 zone provides a higher FAR to achieve a more dense development. However, because the City did not rezone the one parcel within the planning period, the City must meet the site suitability requirements of Government Code Section 65583.2 [AB2348]. To fulfill the requirements of AB 2348, the City has selected 3877 El Camino Real as the designated site to accommodate the 15 “carry over” units. This .75 acre site is a mix of Service Commercial (CS) and RM-30 zoning. Approximately 30% of the site (.22 acres), the area fronting El Camino Real, is covered by the CS zone district. CS zoning allows for mixed use development with a maximum density of 30 units. Using the City’s realistic capacity of 20 units per acre, the CS portion could have a capacity of 4 units. The remaining .53 acres of the parcel is zoned RM-30, which at 20 units per acre, could provide 11 residential units. The site is adjacent to a .28 acre, vacant RM-30 parcel (405 Curtner Avenue) that is currently being used as a parking lot. 405 Curtner Avenue is also on the City HIS list which could provide for the potential of a lot merger to achieve a greater yield of housing. Below is a table showing the AB 2348 requirements with an explanation of how the site at 3877 El Camino Real meets each requirement: AB 2348 Requirement 3877 El Camino Real 1. Must meet the 100 percent shortfall The City’s shortfall is 15 units. This site accommodates the entire shortfall of 15 units. 2. The zoning allows owner-occupied and rental multifamily residential uses “by right” Both the RM-30 and CS zoning allows for residential uses by right. The codes do not differentiate by tenure. 3. The site provides development that permits at least 16 units per site based on minimum density Based on the realistic capacity estimate of 20 units per acre, the site can accommodate 15 units. However, as described in page 75 of the draft Housing Element, the realistic capacity is much more conservative than the densities Chapter 5 163 achieved in built or approved developments. The average density of those developments is almost 28 units per acre. Therefore, this site could easily accommodate an additional unit to meet the 16 unit per site requirement. 4. Suburban and metropolitan jurisdictions must provide sites that allow at least 20 dwelling units per acre. Both the RM-30 and CS zoning have a maximum zoning density of 30 units per acre. However, a realistic capacity of 20 units per acre is used to estimate the potential yield for this site. 5. At least 50 percent of the low and very low-income need be accommodated on sites designated exclusively residential uses Seventy percent of the site is zoned RM-30 thus providing more than half of the unaccommodated need in exclusive residential zoning with a density of greater than 20 units per acre. 5.2 HOUSING GOALS, POLICIES AND PROGRAMS This section establishes the Vision, Goals, Policies, and Programs for the 2007-2014 planning period. It includes programs from the prior planning period (see Appendix) that have been revised as appropriate to improve the success of the program during this planning period. Vision Our housing and neighborhoods shall enhance the livable human environment for all residents, be accessible to civic and community services and sustain our natural resources. Chapter 5 151 5.2 HOUSING GOALS POLICIES AND PROGRAMS EXISTING NEIGHBORHOODS H1 GOAL ENSURE THE PRESERVATION OF THE UNIQUE CHARACTER OF THE CITY’S RESIDENTIAL NEIGHBORHOODS H1.1 POLICY Promote the rehabilitation of deteriorating or substandard residential properties using sustainable and energy conserving approaches. H1.1.1 PROGRAM Continue the citywide property maintenance, inspection and enforcement program. Five-Year Objective: Continue to provide services which promote rehabilitation of substandard housing. Funding Source: City Funds Responsible Agency: Planning & Community Environment, Code Enforcement Time Frame: Ongoing H1.1.2 PROGRAM Explore creating an amnesty program to legitimize existing illegal second units where appropriate and consistent with maintaining the character and quality of life of existing neighborhoods. The granting of amnesty should be contingent on compliance with minimum building, housing, and other applicable code standards and on maintaining the affordability of the second unit to very low, low or moderate-income households. Five-Year Objective: Amend the zoning code to create a second unit amnesty program to extend the life of existing affordable units. Funding Source: General Fund Responsible Agency: Planning & Community Environment Time Frame: Conduct a study within one year of adoption of Housing Element to determine how many illegal second units exist and what incentives are needed to encourage legitimizing illegal second units. H1.1.3 PROGRAM Provide incentives to developers such as reduced fees and flexible development standards to encourage the preservation of existing rental cottages and duplexes currently located in the R-1 and R-2 residential areas. Five-Year Objective: Preserve 10 rental cottages and duplexes. Funding Source: City Housing Fund Responsible Agency: Planning and Community Environment Time Frame: Explore incentives within one year of Housing Element adoption H1.2 POLICY Support efforts to preserve multifamily housing units in existing neighborhoods. Chapter 5 152 H1.2.1 PROGRAM When there is a loss of rental housing due to subdivision or condominium approvals, the project shall require 25 percent BMR units. Five-Year Objective: Provide 10 additional affordable housing units on sites where rental housing will be lost. Funding Source: NA Responsible Agency: Planning and Community Environment Time Frame: Ongoing H1.3 POLICY Encourage community involvement in the maintenance and enhancement of public and private properties and adjacent rights-of-way in residential neighborhoods. H1.3.1 PROGRAM Create community volunteer days and park cleanups, plantings, or similar events that promote neighborhood enhancement and conduct City- sponsored cleanup campaigns for public and private properties. Five-Year Objective: Coordinate with the City’s waste and disposal hauler to conduct a cleanup campaign once a year to promote neighborhood clean-up. Funding Source: City Housing Funds Responsible Agency: Public Works Department Time Frame: Ongoing H1.4 POLICY Assure that new developments provide appropriate transitions from higher density development to single family and low density residential districts in order to preserve neighborhood character. STRATEGIES FOR NEW HOUSING H2 GOAL SUPPORT THE CONSTRUCTION OF HOUSING NEAR SCHOOLS, TRANSIT, PARKS, SHOPPING, EMPLOYMENT AND CULTURAL INSTITUTIONS H2.1 POLICY Identify and implement a variety of strategies to increase housing density and diversity, including mixed use development, near community services, including a range of unit types. Emphasize and encourage the development of affordable housing to support the City’s fair share of the regional housing needs. H2.1.1 PROGRAM Consider amending the zoning code to allow high density residential in mixed use projects in commercial areas within half a mile of fixed rail stations and to allow limited exceptions to the 50-foot height limit for Housing Inventory Sites within a quarter mile of fixed rail stations to encourage higher density residential development. Five-Year Objective: Provide opportunities for a diverse range of housing types near fixed rail stations. Chapter 5 153 Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Consider zoning code amendments within one year of Housing Element adoption H2.1.2 PROGRAM Allow increased residential densities and mixed use development only where adequate urban services and amenities, including, traffic capacity, are available. Five-Year Objective: Make sure that adequate services are available when considering increased residential densities. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H2.1.3 PROGRAM Amend the zoning code to increase the minimum density of the RM-15 Zoning District to at least eight dwelling units per acre consistent with the multi-family land use designation under the Comprehensive Plan. Five-Year Objective: To provide opportunities for up to10 additional dwelling units on properties zoned RM-15. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H2.1.4 PROGRAM Amend the Zoning Code to create zoning incentives that encourage the development of smaller, more affordable housing units, including units for seniors, such as reduced parking requirements for units less than 900 square feet and other flexible development standards. Five-Year Objective: Provide opportunities for 75 smaller, more affordable housing units. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H2.1.5 PROGRAM Use sustainable neighborhood development criteria to enhance connectivity, walkability and access to amenities and to support housing diversity. Five-Year Objective: Increase connectivity and walkability in new development. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H2.1.6 PROGRAM Encourage density bonuses and/or concessions including allowing greater concessions for 100% affordable housing developments consistent with the Residential Density Bonus Ordinance. Five-Year Objective: Provide opportunities for 100% affordable housing developments. Chapter 5 154 Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H2.1.7 PROGRAM Amend the zoning code to develop a small residential unit overlay district to allow higher densities in areas designated Pedestrian Transit Oriented Development (PTOD). Five-Year Objective: Provide opportunities for smaller residential units. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one-year of Housing Element adoption H2.1.9 PROGRAM Explore developing a Transfer of Development Rights (TDR) program to encourage higher density housing in appropriate locations. Five-Year Objective: Create opportunities for higher density housing. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Consider program within two years of Housing Element adoption H2.1.10 PROGRAM Amend the Zoning Code to create zoning incentives that encourage the consolidation of smaller lots identified as Housing Inventory Sites, such as development review streamlining, reduction in required parking for smaller units, setback modifications, or graduated density when consolidated lots are over one-half acre. Five-Year Objective: Provide opportunities for lot consolidation to increase availability of suitable sites for affordable housing. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H2.1.11 PROGRAM Promote redevelopment of underutilized sites and lot consolidation by providing information about potential housing sites on the City’s website, including the Housing Sites Inventory and information about financial resources available through City housing programs. Five-Year Objective: Provide information to developers about potential housing sites and opportunities for lot consolidation. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Post information on website within one year of Housing Element adoption H2.2 POLICY Continue to support the redevelopment of suitable lands for mixed uses containing housing to encourage compact, infill development, optimize the use of existing urban services and support transit use. Chapter 5 155 H2.2.1 PROGRAM Adopt an ordinance for density bonus concessions to promote more flexible concessions and incentives to projects that propose smaller units at a higher density, to encourage development of suitable housing sites currently planned and zoned for non-residential use with mixed use projects to contribute to the City’s fair share of the region’s housing needs. Five-Year Objective: Increase opportunities for higher density development by providing density bonus incentives. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Density Bonus Ordinance is being considered by the Planning Commission in January 2013; Council to consider adoption in early 2013 H2.2.2 PROGRAM Implement an incentive program within a year of Housing Element adoption for small properties identified as a Housing Inventory Site to encourage housing production on those sites. The incentive eliminates Site and Design Review if the project meets the following criteria:  The project has 9 residential units or fewer  A residential density of 20 dwelling units per acre or higher  Maximum unit size of 900 sq. ft. Five-Year Objective: Streamline processing for identified Housing Inventory Sites. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Adopt program within one year of Housing Element adoption H2.2.3 PROGRAM Work with Stanford University to identify sites suitable for housing that may be located in the Stanford Research Park and compatible with surrounding uses. Five-Year Objective: Identify sites suitable for housing to accommodate up additional housing units. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Identify sites within two years of Housing Element adoption 2.2.4 PROGRAM Use coordinated area plans and other tools to develop regulations that support the development of housing above and among commercial uses. Five-Year Objective: Explore additional opportunities to encourage housing in commercial areas. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing 2.2.5 PROGRAM Revise the Zoning Ordinance to increase the density of up to 20 units per acre on CN-zoned parcels included in the Housing Inventory Sites. Chapter 5 156 Five-Year Objective: Provide opportunities for affordable units on CN zoned Housing Inventory Sites. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Amend zoning code within one year of Housing Element adoption. 2.2.6 PROGRAM Revise the Zoning Ordinance to allow for residential uses with the density of up to 20 units per acre on GM parcels included in the Housing Inventory Sites. Five-Year Objective: Provide opportunities for affordable units on GM zoned Housing Inventory Sites. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Amend zoning code within one year of Housing Element adoption. 2.2.7 PROGRAM Amend the Zoning Code to create zoning incentives that encourage development on and consolidation of smaller lots, such as development review streamlining, reduction in required parking for smaller units, setback modifications, or graduated density when consolidated lots are over one-half acre. Five-Year Objective: Provide opportunities for lot consolidation to increase availability of suitable sites for affordable housing. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Within one year of adoption of Housing Element H2.2.8 PROGRAM Rezone property at 595 Maybell Avenue from the RM-15 and R-2 zone districts to the PC zone district to allow for development of 60 units of extremely low to low income senior affordable rental housing units and 15 market rate units. Five-Year Objective: Provide an opportunity for development of 60 units affordable to extremely low and low income senior residents and 15 market rate units. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H2.2.9 PROGRAM To maintain adequate sites are available throughout the planning period to accommodate the City’s RHNA, on a project basis, pursuant to Government Code Section 65863, the City will monitor available residential capacity and evaluate development applications on Housing Inventory Sites in mixed use zoning districts. Should an approval of development result in a reduction of capacity below the residential capacity needed to accommodate the remaining need for lower-income households, the City will identify and zone sufficient sites to Chapter 5 157 accommodate the shortfall. Five-Year Objective: Maintain Residential Capacity of sites suitable for lower income households. Responsible Agency: Planning & Community Environment Time Frame: Ongoing AFFORDABLE HOUSING H3 GOAL MEET UNDERSERVED HOUSING NEEDS AND PROVIDE COMMUNITY RESOURCES TO SUPPORT OUR NEIGHBORHOODS H3.1 POLICY Encourage, foster and preserve diverse housing opportunities for very-low, low, and moderate income households. H3.1.1 PROGRAM Amend the City’s BMR ordinance to lower the BMR requirement threshold from projects of five or more units to three or more units and to modify the BMR rental section to be consistent with recent court rulings related to inclusionary rental housing. Five-Year Objective: Provide opportunities for 4 additional BMR units. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Amend BMR Ordinance within one year of Housing Element adoption. H3.1.2 PROGRAM Implement the City’s “Below Market Rate” (BMR) Program ordinance to reflect the City’s policy of requiring: a) At least 15 percent of all housing units in projects must be provided at below market rates to very low-, low-, and moderate-income households. Projects on sites of five acres or larger must set aside 20 percent of all units as BMR units. Projects that cause the loss of existing rental housing may need to provide a 25 percent component as detailed in Program H 1.2.1. BMR units must be comparable in quality, size and mix to the other units in the development. b) Initial sales price for at least two-thirds of the BMR units must be affordable to a household making 80 to 100 percent of the Santa Clara County median income. The initial sales prices of the remaining BMR units may be set at higher levels affordable to households earning between 100 to 120 percent of the County’s median income. For the projects with a 25 percent BMR component, four-fifths of the BMR units must be affordable to households in the 80 to 100 percent of median range, and one-fifth may be in the higher price range of between 100 to 120 percent of the County’s median income. In all cases, the sales price should be sufficient to cover the estimated cost to the developer of constructing the BMR unit, including financing, but excluding land, marketing, off-site improvements, and profit. Chapter 5 158 c) If the City determines that on-site BMR units are not feasible, off-site units acceptable to the City, or vacant land determined to be suitable for affordable housing, construction, may be provided instead. Off- site units should normally be new units, but the City may accept rehabilitated existing units when significant improvement in the City’s housing stock is demonstrated. d) If the City determines that no other alternative is feasible, a cash payment to the City’ Residential Housing Fund, in lieu of providing BMR units or land, may be accepted. The in-lieu payment for projects subject to the basic 15 percent BMR requirement shall be 7.5 percent of the greater of the actual sales price or fair market value of each unit. For projects subject to the 20 percent requirement, the rate is 10 percent; for projects with a 25 percent requirement, (as described in Program 1.2.1 regarding the loss of rental housing) the rate is 12.5 percent. The fee on for-sale projects will be paid upon the sale of each market unit in the project. e) When the BMR requirement results in a fractional unit, an in-lieu payment to the City’s Residential Housing Fund may be made for the fractional unit instead of providing an actual BMR unit. The in-lieu fee percentage rate shall be the same as that otherwise required for the project (7.5 percent, 10 percent, or 12.5 percent). The fee on for-sale projects will be paid upon the sale of each market unit in the project. Larger projects of 30 or more units must provide a whole BMR unit for any fractional unit of one-half (0.50) or larger; an in-lieu fee may be paid, or equivalent alternatives provided, when the fractional unit is less than one-half. f) Within fifteen days of entering into a BMR agreement with the City for a project, the developer may request a determination that the BMR requirement, taken together with any inclusionary housing incentives, as applied the project, would legally constitute a taking of property without just compensation under the Constitution of the United States or of the State of California. The burden of proof shall be upon the developer, who shall provide such information as is reasonably requested by the City, and the initial determination shall be made by the Director of Planning and Community Environment. The procedures for the determination shall generally be those described in Chapter 18.90 of the Palo Alto Municipal Code, including the right of appeal to the City council under Chapter 18.93, or such other procedures as may be adopted in a future BMR ordinance. Notice of the hearing shall be give by publication but need not be sent to nearby property owners. If the City determines that the application of the BMR requirement as applied to the project would constitute a taking of property without just compensation, then the BMR agreement for the project shall be modified, reduced or waived to the extent necessary to prevent such a taking. Chapter 5 159 g) Consider allowing smaller BMR units than the market rate units if the developer provides more than the required BMR amount in the R-1 Zoning district for new single family residential subdivisions subject to compliance with appropriate development standards. h) Revise BMR policy language to clarify the City’s BMR program priorities in producing affordable housing units including exploring the option of requiring land dedication as the default option on sites of three or more acres. i) Evaluate revising the method of calculating the number of required BMR units by basing the number of BMR units required on the maximum density allowable on the site instead of the total number of proposed units in the development. j) Conduct a nexus study to identify the impacts of market rate housing and the need for affordable housing and develop BMR rental policies based on the results of the study. Five-Year Objective: Provide 10 affordable units through implementation of the City’s BMR program. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing – implementation of existing program H3.1.3 PROGRAM Continue implementation of a Below Market Rate (BMR) Program Emergency Fund to prevent the loss of BMR units and to provide emergency loans for BMR unit owners to maintain and rehabilitate their units. Five-Year Objective: Use the BMR Program Emergency Fund to prevent the loss of up to 2 affordable units. Funding Source: BMR Emergency Fund Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.1.4 PROGRAM Consider expansion of the BMR Program Emergency Fund to provide financial assistance to help BMR homeowners maintain and rehabilitate older BMR units. Five-Year Objective: Assist in maintenance and rehabilitation of 4 older BMR units. Funding Source: BMR Emergency Funds Responsible Agency: Planning & Community Environment Time Frame: Expand Program within two years of Housing Element adoption H3.1.5 PROGRAM Preserve affordable housing stock by monitoring compliance, providing tenant education, and seeking other sources of funds for affordable Chapter 5 160 housing developments at risk of market rate conversions. The City will continue to renew existing funding sources supporting rehabilitation and maintenance activities. Five-Year Objective: Prevent conversion of affordable housing to market rate and renew funding sources for rehabilitation and maintenance of housing stock. Funding Source City, CDBG funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.1.6 PROGRAM Encourage the use of flexible development standards including floor area ratio limits, creative architectural solutions and natural resource conservation, in the design of projects with a substantial BMR component. Five-Year Objective: Increase opportunities for BMR development through use of flexible development standards. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.1.7 PROGRAM Amend the Zoning Code to allow Single Room Occupancy (SRO) units in commercial and high density residential zoning districts subject to development standards that would encourage the construction of the maximum number of units consistent with the goals of preserving the character of adjacent neighborhoods. Sites that have access to community services and public transportation for SRO residents are highly desired. Five-Year Objective: Provide affordable efficiency units on appropriate sites. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Amend the Zoning Code within one year of Housing Element adoption H3.1.8 PROGRAM Require developers of employment-generating commercial and industrial developments to contribute to the supply of low- and moderate-income housing through the provision of commercial in- lieu fees as prescribed in a nexus impact fee study. Five-Year Objective: Generate in-lieu fees to contribute toward the creation of low and moderate income housing. Funding Source: City Housing Fund Responsible Agency: Planning & Community Environment Time Frame: Continue to update the commercial in-lieu fee on an annual basis. H3.1.9 PROGRAM Ensure that the Zoning Code permits innovative housing types, such as co- housing, and provides flexible development standards that will allow such housing to be built provided the character of the neighborhoods in which they are proposed to be located is maintained. Chapter 5 161 Five-Year Objective: Review the Zoning Code and determine appropriate amendments to allow innovative housing types with flexible development standards. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Consider changes to the Zoning Code within two years of Housing Element adoption H3.1.10 PROGRAM Adopt a revised density bonus ordinance that allows up to a maximum zoning increase of 35 percent in density and grants up to three concessions or incentives. The density bonus ordinance will meet State standards for the provision of housing units for very low- and lower-income renters, seniors and moderate-income condominium buyers in compliance with Government Code Section 65915, et seq. Five-Year Objective: To provide opportunities for increased density as outlined in State law. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Density Bonus Ordinance is being considered by the Planning Commission in January 2013; Council to consider adoption in early 2013 H3.1.11 PROGRAM Recognize the Buena Vista Mobile Home Park as providing low- and moderate income housing opportunities. Any redevelopment of the site must be consistent with the City’s Mobile Home Park Conversion Ordinance adopted to preserve the existing units. To the extent feasible, the City will seek appropriate local, state and federal funding to assist in the preservation and maintenance of the existing units in the Buena Vista Mobile Home Park. Five-Year Objective: Preserve the 120 mobile home units in the Buena Vista Mobile Home Park as a low and moderate income housing resource. Funding Source: City, State and Federal Funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.1.12 PROGRAM Continue enforcing the Condominium Conversion Ordinance. Five-Year Objective: Maintain the City’s rental housing stock. Funding Source: N/A Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.1.13 PROGRAM Annually monitor the City’s progress in the construction or conversion of housing for all income levels including the effectiveness of housing production in mixed use developments. Five-Year Objective: Provide information on the effectiveness of City programs. Funding Source: City funds Responsible Agency: Planning & Community Environment Chapter 5 162 Time Frame: Provide annual reports H3.1.14 PROGRAM Evaluate the provisions of the Below Market Rate (BMR) Program to determine if additional incentives are needed to encourage development of housing given current market conditions. Five-Year Objective: Engage in discussions with the development community and determine if additional incentives are needed to improve the BMR Program. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Evaluate the Program within one year of Housing Element adoption H3.1.15 PROGRAM When using its Housing Development funds for residential projects, the City shall give a strong preference to those developments which serve extremely low-income (ELI) households. Five-Year Objective: Provide funding opportunities for development of housing for Extremely Low Income (ELI) households. Funding Source: City Housing Development funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.1.16 PROGRAM Amend the Zoning Code to provide additional incentives to developers who provide extremely-low income (ELI) housing units, above and beyond what is required by the Below Market Rate (BMR) program, such as reduced parking requirements for smaller units, reduced landscaping requirements and reduced fees. Five-Year Objective: Provide incentives for development of housing for Extremely Low Income (ELI) households. Funding Source: City Housing funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H3.1.17 PROGRAM Any affordable development deemed a high risk at market rate conversion, within two years of the expiration of the affordability requirements, the City will contact the owner and explore the possibility of extending the affordability of the development. Five-Year Objective: To protect those affordable developments deemed a high risk to converting to market rate. Funding Source: City Housing funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H3.2 POLICY Reduce the cost of housing by continuing to promote energy efficiency, resource management, and conservation for new and existing housing. Chapter 5 163 H3.2.1 PROGRAM Continue to assist very low-income households in reducing their utility bills through the Utilities Residential Rate Assistance Program (RAP). Five-Year Objective: Provide assistance to with utility bills to 10 low income households. Funding Source: City Funds Responsible Agency: Palo Alto Utilities Department Time Frame: Ongoing H3.2.2 PROGRAM Use existing agency programs such as Senior Home Repair to provide rehabilitation assistance to very low- and low-income households. Five-Year Objective: Provide rehabilitation assistance to 10 very low and low-income households. Funding Source: CDBG & General Fund Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.3 POLICY Support the reduction of governmental and regulatory constraints and advocate for the production of affordable housing. H3.3.1 PROGRAM Where appropriate and feasible, require all City departments to expedite processes and allow waivers of development fees as a means of promoting the development of affordable housing. Five-Year Objective: Continue to reduce processing time and costs for affordable housing projects. Funding Source: City funds Responsible Agency: All City Departments Time Frame: Ongoing, continue implementation upon adoption of Housing Element H3.3.3 PROGRAM Continue to exempt permanently affordable housing units from any infrastructure impact fees that may be adopted by the City. Five-Year Objective: Reduce costs for affordable housing projects. Funding Source: City Funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.3.4 PROGRAM Promote legislative changes and funding for programs that subsidize the acquisition, rehabilitation, and operation of rental housing by housing assistance organizations, nonprofit developers, and for-profit developers. Five-Year Objective: Continue as an active member of the Non-Profit Housing Association of Northern California to promote legislative changes and funding for programs relating to housing. Funding Source: City Funds Responsible Agency: Planning & Community Environment, City Manager Time Frame: Ongoing Chapter 5 164 H3.3.5 PROGRAM Support the development and preservation of group homes and supported living facilities for persons with special housing needs by assisting local agencies and nonprofit organizations in the construction or rehabilitation of new facilities for this population. Five-Year Objective: Review existing development regulations and amend the Zoning Code to reduce regulatory obstacles to this type of housing. Funding Source: City & CDBG Funds Responsible Agency: Planning & Community Environment Time Frame: Amend Zoning Code within one year of Housing Element adoption. H3.3.6 PROGRAM Continue to participate in the Santa Clara County Homeless Collaborative as well as work with adjacent jurisdictions to develop additional shelter opportunities, and Five-Year Objective: Continue City staff participation as members of the Collaborative’s CDBG and Home Program Coordinators Group. Funding Source: City, CDBG & HOME funds Responsible Agency: Planning & Community Environment, City Council Time Frame: Ongoing H3.3.7 PROGRAM Continue to participate with and support agencies addressing homelessness. Five-Year Objective: Continue City staff participation in prioritizing funding for County-wide programs. Funding Source: City, CDBG & HOME funds Responsible Agency: Planning & Community Environment, City Council Time Frame: Ongoing H3.3.8 PROGRAM Amend the Zoning Code to allow transitional and supportive housing by right in all multifamily zone districts which allow residential uses only subject to those restrictions that apply to other residential uses of the same type in the same zone. Five-Year Objective: Provide appropriately zoned sites for transitional and supportive housing. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H3.4 POLICY Pursue funding for the acquisition, construction or rehabilitation of housing that is affordable to very low, low, and moderate-income households. H3.4.1 PROGRAM Maintain a high priority for the acquisition of new housing sites near public transit and services, the acquisition and rehabilitation of existing housing, and the provision for housing-related services for affordable housing. Seek funding from all appropriate state and federal programs whenever they are available to support the development or rehabilitation Chapter 5 165 of housing for very low, low, or moderate-income households Five-Year Objective: Allocate CDBG funding to acquire and rehabilitate housing for very low, low, or moderate income households. Funding Source: CDBG, State Local Housing Trust Fund Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.4.2 PROGRAM Support and expand local funding sources including the City’s Housing Development Fund, Housing Trust of Santa Clara County, CDBG Program, County of Santa Clara’s Mortgage Credit Certificate Program (MCC) or similar program. Continue to explore other mechanisms to generate revenues to increase the supply of low- and moderate-income housing. Five-Year Objective: Increase the supply of affordable housing stock. Funding Source: City Housing Development Fund, Housing Trust of Santa Clara County, CDBG, Santa Clara County MCC Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.4.3 PROGRAM Periodically review the housing nexus formula as required under Chapter 16.47 of the Municipal Code to fully reflect the impact of new jobs on housing demand and cost. Five-Year Objective: Continue to evaluate the housing nexus formula and adjust the required impact fees to account for the housing demand from new development. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Ongoing H3.4.4 PROGRAM The City will work with affordable housing developers to pursue opportunities to acquire, rehabilitate and convert existing multi-family developments to long term affordable housing units to contribute to the City’s fair share of the region’s housing needs. Five-Year Objective: Identify potential sites for acquisition and conversion and provide this information to developers. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Identify sites within one year of Housing Element adoption. H3.5 POLICY Support the provision of emergency shelter, transitional housing and ancillary services to address homelessness. H3.5.1 PROGRAM Enter into discussions with local churches participating in the City’s year round Hotel de Zink emergency shelter program to establish a permanent Chapter 5 166 emergency shelter in each church within a year of Housing Element adoption. Five-Year Objective: To determine interest from local churches in establishing permanent emergency shelters. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Enter into discussions within two years of Housing Element adoption H3.5.2 PROGRAM Amend the Zoning Code to allow emergency shelters by right with appropriate performance standards to accommodate the City’s unmet need for unhoused residents within an overlay of the ROLM zone district located east of Highway 101. Five-Year Objective: Provide appropriately zoned sites for emergency shelters. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H3.6 POLICY Support the creation of workforce housing for City and school district employees if feasible. H3.6.1 PROGRAM Conduct a nexus study to evaluate the creation of workforce housing for City and school district employees. Five-Year Objective: Create the opportunity for up to 5 units of workforce housing. Funding Source: City of Palo Alto Commercial Housing Fund Responsible Agency: Planning & Community Environment Time Frame: Conduct study within two years of Housing Element adoption. HOUSING DISCRIMINATION H4 GOAL PROMOTE AN ENVIRONMENT FREE OF DISCRIMINATION AND THE BARRIERS THAT PREVENT CHOICE IN HOUSING. H4.1 POLICY Support programs and agencies that seek to eliminate housing discrimination. H4.1.1 PROGRAM Work with appropriate state and federal agencies to ensure that fair housing laws are enforced. Five-Year Objective: Continue to coordinate with state and federal agencies to support programs to eliminate housing discrimination. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H4.1.2 PROGRAM Continue to support groups that provide fair housing services, such as Chapter 5 167 Mid-Peninsula Citizens for Fair Housing. Five-Year Objective: Continue to provide financial support through CDBG funding for fair housing services such as Mid-Peninsula Citizens for Fair Housing and Project Sentinel. Funding Source: CDBG funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H4.1.3 PROGRAM Continue the efforts of the Human Relations Commission to combat discrimination in rental housing, including mediation of problems between landlords and tenants. Five-Year Objective: Continue to provide mediation services for rental housing discrimination cases. Funding Source: City funds Responsible Agency: Human Relations Commission Time Frame: Ongoing H4.1.4 PROGRAM Continue implementation of the City’s ordinances and state law prohibiting discrimination in renting or leasing housing based on age, parenthood, pregnancy or the potential or actual presence of a minor child. Develop written procedures describing how Palo Alto will process and treat reasonable accommodation requests for projects proposing housing for special needs households. Five-Year Objective: Implement existing ordinances regarding discrimination and develop reasonable accommodation procedures. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Implementation – Ongoing; Establish reasonable accommodation procedure within one year of Housing Element adoption H4.1.5 PROGRAM Continue the City’s role in coordinating the actions of various support groups that are seeking to eliminate housing discrimination and in providing funding and other support for these groups to disseminate fair housing information in Palo Alto, including information on referrals to pertinent investigative or enforcement agencies in the case of fair housing complaints. Five-Year Objective: Continue to provide funding and other support for these groups to disseminate fair housing information in Palo Alto. Funding Source: City Funds, Human Services Resource Allocation Process (HSRAP) Responsible Agency: Office of Human Services Time Frame: Ongoing H4.1.6 PROGRAM Amend the Zoning Code to provide individuals with disabilities reasonable accommodation in rules, policies, practices and procedures that may be necessary to ensure reasonable access to housing. The Chapter 5 168 purpose of this program is to provide a process for individuals with disabilities to make requests for reasonable accommodation in regard to relief from the various land use, zoning, or building laws, rules, policies, practices and/or procedures of the City. Five-Year Objective: Allow for reasonable accommodation for persons with disabilities in interpreting land use regulations. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Amend the Zoning Code within one year of Housing Element adoption H4.1.7 PROGRAM Continue to implement the “Action Plan” of the City of Palo Alto’s Community Development Block Grant (CDBG) Consolidated Plan or its successor documents. Five-Year Objective: Provide for increased use and support of tenant/landlord educational mediation opportunities as called for in the CDBG Action Plan. Funding Source: CDBG funds, General Fund Responsible Agency: Planning & Community Environment Time Frame: Ongoing H4.2 POLICY Support housing that incorporates facilities and services to meet the health care, transit, and social service needs of households with special needs, including seniors and persons with disabilities. H4.2.1 PROGRAM Ensure that the Zoning Code facilitates the construction of housing that provides services for special needs households and provides flexible development standards for special service housing that will allow such housing to be built with access to transit and community services while preserving the character of the neighborhoods in which they are proposed to be located. Five-Year Objective: Evaluate the Zoning Code and develop flexible development standards for special service housing. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Evaluate the Zoning Code within one year of Housing Element adoption H4.2.2 PROGRAM Work with the San Andreas Regional Center to implement an outreach program that informs families in Palo Alto about housing and services available for persons with developmental disabilities. The program could include the development of an informational brochure, including information on services on the City’s website, and providing housing- related training for individuals/families through workshops. Five-year objective: Provide information regarding housing to families of persons with developmental disabilities. Chapter 5 169 Funding Source: General Fund Responsibility: Planning and Community Environment Time frame: Develop outreach program within two years of adoption of the Housing Element. SUSTAINABILITY IN HOUSING H5 GOAL REDUCE THE ENVIRONMENTAL IMPACT OF NEW AND EXISTING HOUSING. H5.1 POLICY Reduce long term energy cost and improve the efficiency and environmental performance of new and existing homes. H5.1.1 PROGRAM Periodically report to the City on the status and progress of implementing the City’s Green Building Ordinance, intended to improve indoor air quality and assess the environmental performance and efficiency of homes in the following areas: - Greenhouse gas emissions - Energy use - Water use (indoor and outdoor) - Material efficiency - Stormwater runoff - Alternative transportation - Site preservation Five-Year Objective: Prepare reports evaluating the progress of implementing the City’s Green Building Ordinance. Funding Source: City funds, Development fees Responsible Agency: Planning & Community Environment, Building Division Time Frame: Ongoing H5.1.2 PROGRAM Continue providing support to staff and public (including architects, owners, developers and contractors) through training and technical assistance in the areas listed under Program H5.1.1. Five-Year Objective: Provide educational information regarding the City’s Green Building Ordinance. Funding Source: City funds, Development fees Responsible Agency: Planning & Community Environment, Building Division Time Frame: Ongoing H5.1.3 PROGRAM Participate in regional planning efforts to ensure that the Regional Housing Needs Allocation (RHNA) targets areas that support sustainability by reducing congestion and greenhouse gas emissions. Five-Year Objective: Provide a regional framework for sustainability in creating new housing opportunities. Funding Source: City Funds Responsible Agency: Planning & Community Environment Chapter 5 170 Time Frame: Ongoing H5.1.4 PROGRAM Review Federal, State, and regional programs encouraging the improvement of environmental performance and efficiency in construction of buildings and incorporate appropriate programs into Palo Alto’s policies, programs and outreach efforts. Five-Year Objective: Continue to update regulations for environmental sustainability. Funding Source: City funds Responsible Agency: Planning & Community Environment, Public Works & Utilities Time Frame: Ongoing H5.1.5 PROGRAM Enhance and support a proactive public outreach program to encourage Palo Alto residents to conserve resources and to share ideas about conservation. Five-Year Objective: Provide up to date information for residents regarding conservation through educational brochures available at City Hall and posted on the City’s website. Funding Source: City funds Responsible Agency: Planning & Community Environment, Public Works & Utilities Time Frame: Ongoing H5.1.6 PROGRAM Provide financial subsidies, recognition, or other incentives to new and existing home owners or developers to achieve performance or efficiency levels beyond minimum requirements. Five-Year Objective: Establish a program to recognize home owners and developers who achieve incorporate sustainable features beyond what is required by the Green Building Ordinance. Funding Source: City funds Responsible Agency: Planning & Community Environment, Building Division Time Frame: Establish program within two years of Housing Element adoption Chapter 5 171 APPENDIX 5.3 1999-2006 ACCOMPLISHMENTS MATRIX HOUSING OPPORTUNITIES Goal H-1: A Supply of Affordable and Market Rate Housing That Meets Palo Alto’s Share of Regional Housing Needs. POLICY H-1: Meet community and neighborhood needs as the supply of housing is increased. Ensure the preservation of the unique character of the City’s existing neighborhoods. POLICY H-2: Identify and implement a variety of strategies to increase housing density and diversity in appropriate locations. Emphasize and encourage the development of affordable and attainable housing. Program Accomplishments PROGRAM H-1: Increase housing density immediately surrounding commercial areas and particularly near transit stations by either increasing allowed densities or encouraging development at the higher end of the existing density range for sites within 2,000 feet of an existing or planned transit station or along two major transit corridors, El Camino Real and San Antonio Road, wherever appropriate. Progress: The City has allowed increased housing density immediately surrounding commercial areas and particularly near transit stations by either increasing allowed densities or encouraging development at the higher end of the existing density range for sites within 2,000 feet of existing or planned transit corridors, El Camino Real and San Antonio Road. Effectiveness: This program has had some success. For example, the City approved the development of a 60-unit affordable housing project on a .7 acre site near Caltrain Station resulting in 20 units more than the 40 units allowed by the existing land use designation. Appropriateness: This program has been modified to encourage higher density housing in mixed use projects near transit stations. PROGRAM H-2: Encourage development densities at the higher end of allowed density ranges in multiple family zones by using methods such as preferential or priority Progress: The City provides opportunities for higher density housing development; however, preferential or priority processing and application fee reductions are not being provided. Chapter 5 172 processing and application fee reductions for projects that propose development at the higher end of a site’s allowed density range and that provide affordable housing in excess of mandatory BMR program requirements. Consider increasing minimum density requirements in multiple family zones as well as in all Comprehensive Plan land use designations that permit housing. Effectiveness: In order for the program to be effective, minimum density requirements must be implemented. Appropriateness: The program has been modified to encourage higher density residential development in mixed use projects near transit. Minimum density requirements were evaluated and rejected by Council. PROGRAM H-3: Encourage the conversion of non-residential lands to residential use to both increase the supply of housing, particularly affordable housing, and decrease the potential for the creation of new jobs that exacerbate the need for new housing. Land use and development applications that propose the conversion of non- residential land to residential or mixed use development will be given preferential or priority processing to encourage such conversion. Progress: Conversions of non-residential land to residential use were initially encouraged to both increase the supply of housing, particularly affordable housing and decrease the potential for the creation of new jobs that exacerbate the need for new housing. However, due to concerns relating to the potential loss of commercial establishments and economic development, the City Council modified this direction and instead has supported only commercial/residential mixed use development on non- residential lands. No preferential or priority processing is given on land use and development applications that proposed the conversion of non-residential land to mixed use development. Effectiveness: Given Palo Alto’s economic need for retention of non- residential land uses, the program was modified to encourage mixed-use development. Appropriateness: This program has been modified to promote mixed-used development to increase housing opportunities in appropriate locations. PROGRAM H-4: Allow increased residential densities and mixed use development only where adequate urban services and amenities can be including traffic capacity. Progress: The City has allowed increased residential and mixed use development where adequate urban services and amenities can be provided. A number of development projects along El Camino and near downtown were the beneficiary of this program. Effectiveness: This program is effective at increasing housing density and diversity in appropriate locations. Chapter 5 173 Appropriateness: The concept of allowing increased density and mixed use development in appropriate locations is retained in the updated Housing Element. PROGRAM H-5: Consider the following modifications during the Zoning Ordinance Update currently underway and incorporate those modifications in the revised Zoning Ordinance that are conducive to increasing the production of affordable housing by the year 2004. Density Limits and Residential Uses A. Specify the range of housing densities appropriate for each commercial and industrial Comprehensive Plan land use designation and zoning district that permits housing. For proposed projects located within 2,000 feet of an existing or planned rail transit station not adjacent to a single family neighborhood with a substantial proportion of a proposed project’s units affordable to very low-, low-, or moderate- income households, development may be allowed at a higher density than that normally allowed under these land use designations and zoning districts. Development at the high end of the density range should only be permitted where it is demonstrated that the project will make significant use of existing transit facilities or other alternative modes of transportation, thereby avoiding significantly degrading existing traffic levels of service on nearby intersections. Progress: The City modified the Zoning Ordinance to specify the range of housing densities appropriate for commercial zones. In the new PTOD zoning overlay area, projects are allowed at a higher density than normally allowed if they are located within 2,000 feet of an existing or planned rail transit station, not adjacent to a single family neighborhood, with a substantial proportion of a proposed project’s units affordable to very low, low-, or moderate- income households. Effectiveness: The new Zoning Code changes reflect the City’s need to retain non-residential land for non-residential uses and allow housing in appropriate areas. Mixed use development in commercial zones is encouraged. Appropriateness: This program has been substantially changed to encourage higher density housing in mixed-use projects along transit corridors and rail transit stations. B. Consider allowing higher densities on sites that are not precisely within 2,000 feet of a rail transit station but that may Progress: This program has partially been implemented with the adoption of the pedestrian Transit Oriented Development (PTOD) land use and zoning district. Chapter 5 174 be suitable for transit oriented development due to exceptional access to other transit opportunities or alternative modes of transportation. Development of these sites should be compatible with surrounding densities and intensities of development and should be designed to preserve neighborhood character. Development of these sites at the high end of the density range should only be permitted where it is demonstrated that the project will make significant use of existing transit facilities or other alternative modes of transportation and will not significantly degrade existing traffic levels of service on nearby intersections. Effectiveness: The City Council has indicated support for the concepts in this program. Emphasis should be made on creating mixed use development in proximity to transit stations. Appropriateness: This program is appropriate for continuation in the Housing Element update. C. Allow the construction of affordable housing on surplus sites designated Major Institution/Special Facilities under the Comprehensive Plan or zoned for Public Facilities, excepting those areas that are used for open space or playgrounds. Development of these sites should be compatible with surrounding densities and intensities of development and should be designed to preserve neighborhood character. Consideration should also be given to encouraging the conversion of portions of buildings or sites (e.g., religious institutions) to allow ancillary residential uses, such as caretaker quarters, by modifying pertinent sections of the Zoning Ordinance and Building Code. Progress: This program has not been implemented. Effectiveness: Since there have not been any changes to the Zoning Ordinance to allow construction of housing on sites identified for public use, the City is unable to measure its effectiveness. Appropriateness: Staff reviewed the policy and determined protection of Major Institution/Special Facilities sites is a City priority. Therefore this program will not be included in the Housing Element update. D. Allow a high or very high residential density under the Mixed Use land use designation for those sites within 2,000 feet of an existing or planned rail transit station unless adjacent to Progress: In 2007, the City modified its Zoning Ordinance to include the creation of Pedestrian and Transit Oriented development (PTOD) Combining District, which allows a high or very high residential density under the Mixed Use land use designation for those sites within 2,000 feet of an Chapter 5 175 single family neighborhoods. In areas adjacent to single family neighborhoods, require lower densities as a buffer. Development at the high end of the density range should only be permitted where it is demonstrated that the project will make significant use of existing transit facilities or other alternative modes of transportation and will not significantly degrade existing traffic levels of service on nearby intersections. existing or planned rail transit station unless adjacent to single family neighborhoods. Effectiveness: The City has recently approved the first application in the PTOD area. It does appear that this program will be effective for providing high density housing in mixed-use development in appropriate locations especially when market conditions improve. Appropriateness: The City will continue to consider further changes to the Zoning Code to implement a modified version of this program as it is deemed appropriate in increasing housing density and diversity in appropriate locations E. Restrict the size of main units under the DHS Zoning District and ensure that second units are adequate to accommodate a second household. Progress: The DHS district is only found in the South of Forest Area (SOFA) Coordinated Area Plan, which has no vacant parcels at this time; no change has been made to restrict the size of the units under the DHS Zoning District and to ensure that second units are adequate to accommodate a second household. Effectiveness: This program does not appear relevant because the DHS zoning district is limited in applicability to SOFA and sites with this zoning are fully developed. Appropriateness: This program is eliminated since the DHS zoning district is built out and only applicable in the SOFA area. F. Address the loss of housing due to the combination of single family residential lots. Consider modifying the R-1 Zoning District to create a maximum lot size to prevent the loss of housing or housing opportunities. Progress: In 2005, the City modified its R-1 Zoning District code to create a maximum lot size to prevent the loss of housing or housing opportunities. Effectiveness: The modification has been effective in preventing the loss of housing or housing opportunities. Appropriateness: The task has been completed; therefore, it will not be carried forward in the Housing Element update. G. Permit higher densities under the R-1 Zoning District to accommodate smaller lots for courtyard homes or other similar types of housing. Progress: During its update of the Zoning Ordinance the City explored the idea of permitting higher densities under the R-1 Zoning District to accommodate smaller lots for courtyard homes or other similar types of housing, however; due to other priorities, this program was not implemented. Chapter 5 176 Effectiveness: Since there has not been a change to the Zoning Ordinance, the City was unable to measure the effectiveness of this program. Appropriateness: The program continues to be relevant for inclusion in the Housing Element since the City Council has supported the concept of village residential development on small lots in the R-1 district. H. Increase the minimum density of the RM-15 Zoning District to at least eight dwelling units per acre consistent with the multi- family land use designation under the Comprehensive Plan. Progress: No change has been made to increase the minimum density of the RM-15 Zoning District to at least eight dwelling units per acre consistent with the multi-family land use designation under the Comprehensive Plan. Effectiveness: Since there have not been any changes relating to this particular section of the Zoning Ordinance, the City was unable to measure the effectiveness of this program; however, the concept should provide more housing if implemented. Appropriateness: This program is appropriate for continuation in the Housing Element update. New Development Standards and Zoning Districts I. For projects that are 100% affordable, allow for increased flexibility in the application of development standards, such as parking and height, to better implement the housing programs contained in this chapter and to encourage the production of affordable housing. Progress: The 2007 Zoning Ordinance Update allows for increased flexibility in the application of development standards, such as parking and height for projects that are 100% affordable to encourage the production of affordable housing. Effectiveness: These changes have been effective in encouraging the production of affordable housing. Appropriateness: The task has been completed; therefore it will not be carried forward in the Housing Element update. The City will continue to monitor the effectiveness of the program. J. Floor area ratio limits should be made flexible for the purpose of creating affordable housing. Maximum unit sizes should also be considered to encourage the production of more affordable housing. The use of a “form” code to achieve these objectives should be considered during the Zoning Ordinance Update. Progress: The 2007 Zoning Ordinance Update allowed more flexibility in floor area ratio limits for the purpose of creating affordable housing. The Zoning Ordinance Update also incorporated the use of a “form” code for mixed use and multi-family projects. Effectiveness: The modification made to the floor area ratio limits has been effective in increasing density by providing Chapter 5 177 developers greater flexibility of floor area ratio limits. Appropriateness: This program has been partially completed; it will continue to be included in the Housing Element update to further encourage development of affordable housing. K. Create new zoning districts to implement the Transit-Oriented Residential and Village Residential land use designations and establish development standards that allow the maximum amount of housing, particularly for affordable housing projects, permitted under the allowed density range while preserving the character of adjacent neighborhoods. Progress: The 2007 Zoning Ordinance Update included the creation of a new zoning district, the Pedestrian and Transit Oriented Development (PTOD) and modified its multiple family residential zoning to allow Village Residential uses. The Update also established development standards that allow increased housing density, particularly for affordable housing projects. Effectiveness: The program’s effectiveness has not yet been measured since the City has not developed a project within the newly-created California Avenue PTOD zoning district. Appropriateness: This program has been completed; therefore, it will not be included in the Housing Element update. The City will continue to monitor the effectiveness of the program. L. Create development standards for permitted mixed residential/non-residential uses that would permit a number of dwelling units, including a minimum number of affordable housing units, to be built with each project. Mixed uses with an office component should be discouraged. The definition of mixed use development and the standards to be utilized in such developments will be addressed during the Zoning Ordinance Update. Progress: The 2007 Zoning Ordinance Updated created development standards for permitted mixed residential/non-residential uses, but did not include a standard for the minimum number of affordable housing units to be built with each project. The Zoning Ordinance Update also addressed the definition of mixed use development and the standards to be utilized in such developments. Effectiveness: The new development standards for mixed use development increases housing development at higher densities and in appropriate locations. Appropriateness: Parts of this program have been completed. However, due to State law prohibiting affordable housing programs to require affordable rental units, determining the required minimum number of affordable housing units for mixed use projects is inappropriate for the Housing Element update. This concept will be addressed by providing incentives for mixed use development for property developed at higher densities and listed on the Housing Inventory. PROGRAM H-6: As part of the Zoning Ordinance Update process, create zoning Progress: This program has not been implemented during the planning period. Chapter 5 178 incentives that encourage the development of diverse housing types, such as smaller, more affordable units and two- and three-bedroom units suitable for families with children. Consider using a “form” code to achieve these objectives. Effectiveness: The program has the potential to provide more affordable housing units if implemented. Appropriateness: This program continues to be appropriate for the Housing Element update. PROGRAM H-7: As part of the Zoning Ordinance Update process, modify the provisions, such as parking requirements, minimum lot size, and coverage and floor area ratio limits, that govern the development of second dwelling units in single family areas to encourage the production of such units. Consider using a “form” code to achieve these objectives. Progress: In 2003 the Zoning Code was changed to allow the development of second dwelling units in single-family areas as required by State law. These changes included development standards relating to parking requirements, minimum lot size, and coverage and floor area ratio limits. Effectiveness: The City has yet to determine the effectiveness of this program since there have been very few applications for second dwelling units. Appropriateness: This program has been completed; therefore it will not be included in the Housing Element update. The City will continue to monitor the effectiveness of this program. PROGRAM H-8: As part of the Zoning Ordinance Update process, modify the Zoning Code to allow second dwelling units that are incorporated entirely within the existing main dwelling, or that require only a small addition (200 square feet or less) and limited exterior modifications, to be approved through a ministerial permit (i.e., no design review or public hearing) on sites that meet the minimum development standards, including the parking requirement. Progress: In 2003, the Zoning Ordinance was amended to allow attached second units or small detached second units through a ministerial process as required by State law. Effectiveness: This program has had limited success. Although the Zoning Code has been modified to allow attached second units or small detached second units through ministerial process, the City has not seen significant increase in planning applications related to these changes in the Zoning Code. Appropriateness: This program has been completed; therefore, it will not be included in the Housing Element update. The City will continue to monitor the effectiveness of this program. PROGRAM H-9: Explore feasibility of establishing an amnesty program to legitimize existing illegal second units where appropriate and consistent with maintaining the character and quality of life of existing neighborhoods. The grant of amnesty should be contingent on compliance with minimum building, housing and other applicable code standards and on maintaining the affordability of the second unit to very low-, low- or Progress: This program was not implemented during the planning period. Effectiveness: The City is unable to measure the program’s effectiveness since it has yet to be implemented at this time. Appropriateness: This program is appropriate for continuation in the Housing Element update. Chapter 5 179 moderate-income households. PROGRAM H-10: As part of the Zoning Ordinance Update process, create a Planned Development zone that allows the construction of smaller lot single family units and other innovative housing types without the requirement for a public benefit finding provided that the project significantly increases the number of affordable housing units on the site over what would otherwise be allowed by existing zoning. Progress: The 2007 Zoning Ordinance Update included provisions creating a Planned Development zone that allows the construction of smaller lot single family units and other innovative housing types without the requirement for a public benefit finding provided that the project significantly increases the number of affordable housing units on the site over what would otherwise be allowed by existing zoning. Effectiveness: The City has received and approved a several applications for the construction of smaller lot single-family units in a Planned Development zone district. There have not been additional affordable units provided; therefore the public benefits have been required. Appropriateness: The program to modify the zoning code has been implemented; therefore, it will not be included in the Housing Element update. The City will continue to monitor the effectiveness of this program. PROGRAM H-11: As part of the Zoning Ordinance Update process, amend zoning regulations to permit residential lots of less than 6,000 square feet where smaller lots would be compatible with the surrounding neighborhood. Progress: As part of the 2007 Zoning Ordinance Update, the City amended its zoning regulations to permit residential lots of less than 6,000 square feet using the Village Residential standards where smaller lots would be compatible with the surrounding neighborhood. Effectiveness: Although the Zoning Code has been modified to permit residential lots of less than 6,000 square feet where smaller lots would be compatible with the surrounding neighborhood, the City has not seen planning applications related to these changes in the Zoning Code. Appropriateness: The program to modify the zoning code has been implemented; therefore, it will not be included in the Housing Element update. The City will continue to monitor the effectiveness of this program. PROGRAM H-12: As part of the Zoning Ordinance Update process, amend the Zoning Code to reduce parking requirements for higher density development in appropriate areas thus reducing development costs and producing housing that is more affordable. The potential consequences of reducing Progress: As part of the 2007 Zoning Ordinance Update, the Zoning Code was amended to allow reductions in parking requirements for projects located within the Pedestrian/Transit Oriented area or elsewhere in immediate proximity to public transportation facilities. Effectiveness: A number of projects near transit facilities benefited from Chapter 5 180 parking will be evaluated for particular types of projects during the Zoning Ordinance Update, but parking reductions should primarily be considered for Transit-Oriented development or developments that can demonstrate that its need for parking is less than the required parking standard called for by the Zoning the zoning amendment. Appropriateness: This program has been completed, and will not be included in the Housing Element update; however, the City will continue to monitor the effectiveness of this program. POLICY H-3: Continue to support the re-designation of suitable vacant or underutilized lands for housing or mixed uses containing housing. PROGRAM H-13: Implement the Housing Opportunities Study that identifies vacant and underutilized sites and sites with existing non-residential uses that are suitable for future housing or mixed use development focusing particularly on sites near an existing or planned transit station, along major transportation corridors with bus service, and in areas with adequate urban services and supporting retail and service uses. Progress: During the planning period, the City implemented the Housing Opportunities Study. More than 900 units were either approved or developed from the study sites. Effectiveness: The City was successful in implementing the Housing Opportunities Study, which resulted in facilitating an increase in housing stock. Appropriateness: Given the City’s significant RHNA allocation for the 2007-2014 planning period, sites from the Housing Opportunities Study appropriate for higher density housing are proposed for listing on the Housing Inventory. A. Suitable housing sites currently planned and zoned for non- residential use should be designated for residential or mixed use in sufficient quantities to accommodate the City’s fair share of the region’s housing needs. Progress: Suitable housing sites were designated for residential or mixed-used development in sufficient quantity resulting in the City’s ability to accommodate is fair share of the region’s housing needs. Effectiveness: This program has been effective in accommodating and meeting the total number of the City’s fair share of the region’s housing needs Appropriateness: The City has identified adequate sites to meet its RHNA. These sites are listed on the Housing Inventory Sites as part of the Housing Element update. B. Convert sites near transit and other major transportation facilities to higher density residential and mixed use to reinforce the City’s policies Progress: Wherever appropriate, the City has allowed the conversion of sites near transit and other major transportation facilities to higher density residential and mixed use to reinforce the City’s policies. Chapter 5 181 supporting transit use, create a pedestrian friendly environment, and reduce reliance on the automobile as well as increase the supply of housing, consistent with the City’s policies of encouraging compact, infill development and optimizing the use of existing urban services. Effectiveness: This program has been effective as part of implementing a variety of strategies to increase housing density and diversity in appropriate locations; however, the City Council has determined that conversion of non-residential land to residential is unhealthy for the City’s economy. The Council has, however, encouraged mixed use development (housing over commercial) in areas near transit. Appropriateness: The program has been modified to reflect current Council policy and is continued in the Housing Element update. C. Work with Stanford University to identify sites suitable for housing that may be located in the Stanford Research Park. Progress: As Stanford plans to expand, the City continues to work with Stanford to identify sites suitable for housing that may be located in the Stanford Research Park. In 2005, the City of Palo Alto and Stanford entered into development agreement that granted to Stanford vested right to build 250 dwelling units in the Stanford Research Park. Effectiveness: This program is effective in helping to provide the jobs/housing imbalance in the City. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-14: Rezone, where necessary, those sites identified on the Housing Sites Inventory, using appropriate residential or mixed use zoning districts, prior to 2004. Progress: All but 3 sites on the Housing Inventory were rezoned for residential or mixed use development Effectiveness: The rezoning of the sites increased the potential supply of housing and conformed to State requirements. Appropriateness: The program will continue in the Housing Element update for new sites listed on the updated Housing Inventory. As required by State law, sites that were proposed for rezoning in the previous housing element but were not rezoned during the planning period will be rezoned. Additional sites needed to accommodate the City’s fair share of the regional housing need that do not currently allow housing at an appropriate density will also be rezoned during the 2007-2014 planning period. PROGRAM H-15: Conduct a special study of the El Camino Real transportation corridor to examine in detail the potential for Progress: The City conducted a study of El Camino Real to assess the potential for locating high-density housing along the corridor as a part of the analysis for the 2007-2014 Chapter 5 182 developing higher density housing, especially affordable housing, on specific residential or non-residential sites consistent with the City’s traffic level of service policies, the City’s ability to provide urban services and amenities and the preservation of the character and quality of life of adjacent neighborhoods. Housing Element Update. Effectiveness: The study identified appropriate locations throughout the El Camino Real corridor for higher density, mixed use development. Appropriateness: This program has been completed and is not continued as part of the Housing Element update. POLICY H-4: Encourage mixed use projects as a means of increasing the housing supply while promoting diversity and neighborhood vitality. PROGRAM H-16: As part of the Zoning Ordinance Update process, evaluate and improve existing incentives that encourage mixed use (with a residential component) and residential development on commercially zoned land and establish development standards that will encourage development of the maximum amount of housing permitted under the allowed density range, particularly for projects that provide affordable housing. Progress: The 2007 Zoning Ordinance Update included changes to the provisions of incentives that encourage mixed use (with a residential component) and residential development on commercially zoned land. In the Pedestrian and Transit Oriented Development (PTOD) District, incentives include, but are not limited to reductions in parking requirements and increases in density, Floor Area Ratio (FAR), and height for the construction of additional below market rate (BMR) housing units. The City also revised its commercial zones to allow fully residential projects in these zones for sites listed in the City’s Housing Inventory. Effectiveness: This program has been somewhat effective in attracting developers to building more housing. However, the City’s current regulations do not facilitate mixed use development. Appropriateness: This program has been modified to provide incentives for mixed use development when the property is developed at higher density and is listed on the Housing Inventory; the program will be included in the Housing Element update. PROGRAM H-17: Use coordinated area plans and other tools to develop regulations that support the development of housing above and among commercial uses. Progress: The City Council adopted the South of Forest Area (SOFA) Coordinated Area Plan as a planning tool to address a specific nine block area of the City comprising approximately 19 acres. The area provides increased housing opportunities convenient to shops, services, and transit. Effectiveness: The City has taken actions to support the development Chapter 5 183 of housing above and among commercial uses for this area. Other sites in the City have been identified as appropriate for Coordinated Area Plans. Appropriateness: The program is considered appropriate for inclusion in the Housing Element Update. The City will continue to monitor the number of units created through implementation of coordinated area plans. PROGRAM H-18: Encourage the development of housing on or over parking lots by adopting incentives that will lead to housing production while maintaining the required parking. Progress: The reuse of parking lots has not been evaluated. Effectiveness: Since the program has not been implemented, the City is unable to measure its effectiveness. Appropriateness: Staff reviewed the policy and determined it was not appropriate for the Housing Element update. Therefore this program will not be included in the Housing Element update. PROGRAM H-19: (REVISED) Eliminate the requirement for Site and Design review by the Planning Commission and City Council for mixed use projects shortly after development standards have been established for mixed use projects during the Zoning Ordinance Update expected to be completed in 2004. Progress: The City Council decided that Planning Commission and City Council review was appropriate for large scale mixed use projects but small scale mixed use projects can be processed without the two reviews. Effectiveness: This program has increased applications for small scale mixed use projects Appropriateness: This program has been completed and will not be included in the Housing Element Update. However, as an incentive for developing parcels in the Housing Inventory Sites, Site and Design review has been eliminated as part of the Housing Element update for those projects that meet the Housing Inventory Sites minimum density standards and are comprised of smaller units. POLICY H-5: Discourage the conversion of lands designated as residential to non-residential uses and the use of multiple family residential lands by non-residential uses, such as schools and churches, unless there is no net loss of housing potential on a community-wide basis. PROGRAM H-20: As part of the Zoning Ordinance Update process, change the Zoning Code to disallow uses other than residential uses Progress: This program has not been implemented. Chapter 5 184 in a multiple-family residential zone unless the project can demonstrate an overriding benefit to the public or the project results in no net planned or existing housing loss. Planning Commission and City Council approval would be required in such instances. Effectiveness: Since there have not been any changes to the Zoning Ordinance relating to this particular element, the City is unable to measure its effectiveness. Appropriateness: This program is appropriate for continuation in the Housing Element update. POLICY H-6: Support the reduction of governmental and regulatory constraints to the production of affordable housing. PROGRAM H-21: Where appropriate and feasible, allow waivers of development fees as a means of promoting the development of housing affordable to very low-, low-, and moderate-income households. Evaluate the feasibility of waiving fees for projects that proposed affordable housing units in excess of minimum City BMR Program standards either in terms of the number of the affordable units or the household income levels that the project is targeted to serve. Progress: The City has not implemented a program that allows waivers of development, application and similar fees for affordable housing projects for very low-, low, and moderate income households. Effectiveness: Since this program has not been implemented, the City is unable to measure its effectiveness. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-22: Exempt permanently affordable housing units from any infrastructure impact fees that may be adopted by the City. Progress: The City exempts permanently affordable housing units from any infrastructure impact fees that may be adopted by the City, including impact fees for community facilities, traffic and parkland dedication. Effectiveness: The exemption has assisted a number of affordable housing projects developed by nonprofit affordable housing developers. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-23: Require all City departments to expedite all processes, including applications, related to the construction of affordable housing above minimum BMR requirements. Progress: While no requirement for expedited processing has been instituted formally, the City recognizes the importance of constructing affordable housing above minimum BMR requirements; therefore departments strive to provide greater attention to applications related to the construction of affordable housing. Effectiveness: The program has been effective in reducing processing time for affordable housing projects and, Chapter 5 185 as a result reducing overall project cost. Appropriateness: This program is appropriate for continuation in the Housing Element update. POLICY H-7: Monitor, on a regular basis, the City’s progress in increasing the supply of housing and monitor the preservation of BMR rental units for very low- and low- income residents. PROGRAM H-24: Establish an annual monitoring program to review the progress made in the construction of housing for all income levels, the rezoning of suitable housing sites, and the implementation of policies to encourage the production of affordable housing. Progress: In 2003, the City established an annual monitoring and reporting program to review the progress made in the construction of housing for all income levels, the rezoning of suitable housing sites, and the implementation of policies to encourage the production of affordable housing. Effectiveness: The annual monitoring and reporting program allows the City to better track the progress of residential developments. Appropriateness: The program is an important tool for City officials and City staff to assess the development growth in the City and is continued in the Housing Element update. HOUSING CONSERVATION Goal H-2: Conservation and Maintenance of Palo Alto’s Existing Housing Stock and Residential Neighborhoods. POLICY H-8: Promote the rehabilitation of deteriorating or substandard residential properties. PROGRAM H-25: Continue the citywide property maintenance, inspection, and enforcement program. Progress: The City implements a citywide property maintenance, inspection and enforcement program through its Code Enforcement Unit. Effectiveness: The City has been effective in ensuring citywide property maintenance and responding to complaints as needed. Chapter 5 186 Appropriateness: Code Enforcement is an important component in promoting safe and decent living conditions and this program remains appropriate for inclusion in the Housing Element update. PROGRAM H-26: Enact development regulations that encourage retention and rehabilitation of historic residential buildings, older multifamily rental buildings and smaller single family residences. Progress: In 2005, through the Zoning Ordinance Update, the City enacted development regulations that encourage retention and rehabilitation of historic residential buildings, older multifamily rental buildings and smaller single family residences. The new regulations provide exemption to gross floor area requirements for historic homes and allow additional square footage and certain other exceptions for home improvements to single family residences. In addition, the Home Improvement Exception (HIE) provides incentives that encourage retention and rehabilitation of historic residential buildings. Effectiveness: The modification has been effective in promoting the rehabilitation of historic residential properties. Appropriateness: This program has been completed and will not be continued in the Housing Element update. Policy H-9: Maintain the number of multi-family housing units, including BMR rental and ownership units, in Palo Alto at no less than the number of multi-family rental and BMR units available as of December 2001 and continue to support efforts to increase the supply of these units. PROGRAM H-27: Continue implementation of the Condominium Conversion Ordinance. Progress: The City continues to implement its Condominium Conversion Ordinance. Effectiveness: This program has effectively maintained and preserved the number of available multi-family rental housing units. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-28: Implement a Below Market Rate (BMR) Program Emergency Fund to prevent the loss of BMR units and to provide emergency loans for BMR unit owners for substantial mandatory assessments. Progress: In September 2002, the City Council established a BMR program emergency fund as an ongoing permanent program to prevent the loss of BMR units and provide emergency loans for BMR unit owners for substantial mandatory assessments. The Council Chapter 5 187 approved loan program criteria and loan terms and seed money for the programs. Effectiveness: The program has been effective in assisting extremely low income BMR owners who were unable to obtain conventional financing for substantial mandatory assessments. Since the inception of the program, the City has approved three (3) loans for approximately $72,000. Appropriateness: As more BMR units become older, BMR owners could be faced with substantial maintenance costs. Therefore, it will be appropriate to continue and expand the program to prevent the loss of BMR units and it is included in the Housing Element update. PROGRAM H-29: Where a proposed subdivision or condominium would cause a loss of rental housing, grant approval only if at least two of the following three circumstances exist: • The project will produce at least a 100 percent increase in the number of units currently on the site and will comply with the City’s Below Market Rate (BMR) program (described in Program H-34 or 35); and/or • The number of rental units to be provided on the site is at least equal to the number of existing rental units; and/or • No less than 25 percent of the units will comply with the City’s BMR program. Progress: The City halted the implementation of the program due to its legality; the City Attorney has concluded that the program is unenforceable based on recent court decisions. Effectiveness: The program as stated cannot continue to be implemented. Appropriateness: The City has included component parts that are considered legal as part of the Housing Element Update. Policy H-10: Preserve the existing legal, non-conforming rental cottages and duplexes currently located in the R-1 and R-2 residential areas of Palo Alto, which represent a significant portion of the City’s affordable housing supply. PROGRAM H-30: Require developers of new residential projects in the R-1 and R-2 Zoning Districts to preserve and incorporate, where feasible, existing rental cottages or duplexes within the project. Explore the feasibility of requiring the developer to replace any units being demolished as a result of new construction. Progress: This program has not been implemented. Effectiveness: Since there have not been any changes to the Zoning Ordinance relating to this particular program, the City is unable to measure its effectiveness. It is also questionable whether the program can be effectively implemented as proposed. Chapter 5 188 Appropriateness: This program has been revised to identify incentives for preservation of these types of units and is continued in the Housing Element. POLICY H-11: Encourage community involvement in the maintenance and enhancement of public and private properties and adjacent rights-of-way in residential neighborhoods. PROGRAM H-31: Create community volunteer days and park cleanups, plantings, or similar events that promote neighborhood enhancement. Progress: The City teams up with local organizations and social and service clubs, such as Rotary and Kiwanis to hold park cleanups and plantings events to promote neighborhood enhancement. Effectiveness: The program has been effective in increasing community participation in the maintenance and enhancement of public and private properties and adjacent rights-of-way in residential neighborhoods. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-32: Conduct City-sponsored cleanup campaigns for public and private properties. Progress: The City’s Public Works Department sponsors the City’s Clean-up Day, a service for Palo Alto residents to dispose of extra debris and unwanted household items that may be filling garages, attics or backyards. The Clean-up Day is designed to meet the residents’ needs and schedule. Palo Alto residents living in single family homes and housing complexes of four units or less can schedule one Clean-up Day each year. Effectiveness: The program has been effective in encouraging community involvement in the maintenance and enhancement of public and private properties and adjacent rights-of-way in residential neighborhoods. Appropriateness: This program is appropriate for continuation in the Housing Element update. Chapter 5 189 HOUSING DIVERSITY Goal H-3: Housing Opportunities for a Diverse Population, Including Very low-, Low- and Moderate-Income Residents, and Persons with Special Needs. POLICY H-12: Encourage, foster and preserve diverse housing opportunities for very low-, low- and moderate-income households. PROGRAM H-33: Take all actions necessary to preserve the 92-unit Terman Apartments as part of Palo Alto’s affordable housing stock and to continue the renewal of the existing HUD Section 8 rental assistance contract that provides rental subsidies for up to 72 units in the project. Progress: Terman Apartments is owned by a for-profit investor. Efforts were made to partner with nonprofit organizations to acquire and preserve the 92-unit apartments as part of Palo Alto’s affordable housing stock. However, the owner still has no intention of selling and is continuing to renew the project-based Section 8 contract annually. The City had intended to use its State Local Housing Trust Fund grant to assist a local non-profit acquire this project if the owner decided to sell or decided to terminate the Sec. 8 contracts. City staff, a local housing non-profit and the California Housing Partnership Corp investigated whether any actions of the owner had triggered a right-to-purchase under State law, whether the owner would enter into a voluntary sale & what level of subsidy funding would be needed to accomplish a non-profit purchase. The result of this study was that an acquisition would require extremely high subsidies due to the high Sec. 8 contract rents, that the owners had no interest in selling and that the owners are renewing the Sec. 8 contracts on an annual basis. Effectiveness: Due to the owner’s unwillingness to sell the property, efforts were not effective in acquiring the property. Appropriateness: The City will continue to take actions available to preserve the Terman Apartments. The Housing Element includes a program to support the renewal of Section 8 contracts. PROGRAM H-34: Provide preferential or priority processing for those residential or mixed use projects that propose more affordable housing than the minimum required under the City’s BMR Program and for 100% affordable housing projects. Progress: Preferential or priority processing for those residential or mixed use projects that propose more affordable housing than the minimum required under the City’s BMR Program and for 100% affordable housing projects has been informally instituted. The City recognizes the importance of constructing affordable housing above minimum BMR requirements; therefore, the City strives to provide greater attention Chapter 5 190 to applications related to the construction of affordable housing. Effectiveness: The program effectiveness varies depending on the number of additional affordable housing units to be constructed above the minimum BMR requirements. Appropriateness: This program is appropriate for continuation in the Housing Element update. POLICY H-13: Provide for increased use and support of tenant/landlord educational and mediation opportunities. PROGRAM H-35: Implement the “Action Plan” of the City of Palo Alto’s Consolidated Plan or its successor documents. Progress: The City continues to implement its Annual Action Plan and to use CDBG funds to provide for increased use and support of tenant/landlord educational mediation opportunities. Effectiveness: The City of Palo Alto’s Human Service Resource Allocation Process (HSRAP) funded with the General Fund allows the City to provide funding to Project Sentinel, a nonprofit organization, for support of tenant/landlord educational mediation opportunities. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-36: Implement the City’s “Below Market Rate” (BMR) Program by requiring that at least 15 percent of all housing units in projects of five units or more, be provided at below market rates to very low-, low-, and moderate-income households. Projects on sites of five acres or larger must set aside 20 percent of all units as BMR units. Progress: The City continues to implement this program that requires at least 15 percent of all housing units in projects of five units or more, be provided at below market rates to very low-, low-, and moderate-income households. Projects on sites of five acres or larger must set aside 20 percent of all units as BMR units. Effectiveness: Through this program, 123 BMR units have been created during the planning period, of which 105 are rental units. Appropriateness: The City will continue to implement this program as a part of the Housing Element Update to increase its affordable housing stock. The program has been modified to lower the threshold for the BMR Chapter 5 191 requirement to three units. PROGRAM H-37: Adopt an ordinance codifying and implementing the City’s “Below Market Rate” (BMR) Program. Progress: In March 2008, the City Council adopted an ordinance codifying and implementing the City’s “Below Market Rate” (BMR) Program. Effectiveness: Adoption of a BMR ordinance has been effective in increasing awareness of the BMR requirements. Appropriateness: The program has been completed and will not be continued in the Housing Element update. PROGRAM H-38: Adopt a revised density bonus program ordinance that allows the construction of up to three additional market rate units for each BMR unit above that normally required, up to a maximum zoning increase of 50 percent in density. Allow an equivalent increase in square footage (Floor Area Ratio) for projects under this program. The revised density bonus program will meet State standards for the provision of housing units for very low- and lower-income renters, seniors and moderate-income condominium buyers in compliance with Government Code Section 65915, et seq. Progress: This program has not been implemented. Effectiveness: Since there have not been any changes to the Zoning Ordinance to implement this program, the City is unable to measure its effectiveness. Appropriateness: This program is appropriate for the Housing Element update. PROGRAM H-39: Encourage the use of flexible development standards and creative architectural solutions in the design of projects with a substantial BMR component. The intent of this program is to allow individual projects to develop individual solutions to create an attractive living environment both for the project and adjacent development and to address specific project needs, such as the provision of open space. Progress: Although greater flexibility in development standards have not been modified, the City’s Architectural Review Board and Planning and Transportation Commission continue to encourage creative architectural solutions in the design of projects with substantial BMR component. Effectiveness: This limited implementation of the program has been effective in fostering and preserving diverse housing opportunities and creating attractive living environment both for the project and adjacent development addressing specific project needs, such as the provision of open space. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-40: Consider allowing the development of duplexes in the R-1 Zoning District as the Progress: This program was not implemented during the planning period. Chapter 5 192 required BMR units for a new single family residential subdivision subject to appropriate development standards. Development standards will be prepared, evaluated, and implemented during the Zoning Ordinance Update. Effectiveness: Since the program was not implemented, the City is unable to measure the program’s effectiveness at this time. Appropriateness: The program is continued in the Housing Element update. PROGRAM H-41: Recognize the Buena Vista Mobile Home Park as providing low- and moderate- income housing opportunities. Any redevelopment of the site must be consistent with the City’s Mobile Home Park Conversion Ordinance adopted to preserve the existing units. To the extent feasible, the City will seek appropriate local, state and federal funding to assist in the preservation and maintenance of the existing units in the Buena Vista Mobile Home Park. Progress: Buena Vista Mobile Home Park continues to exist and provide low- and moderate-income housing opportunities. There has not been any plan to redevelop the park. Effectiveness: This program effectively preserves the existence of the only mobile home park in the City. Appropriateness: This program is appropriate for continuation in the Housing Element update. POLICY H-14: Support agencies and organizations that provides shelter, housing, and related services to very low-, low-, and moderate-income households. PROGRAM H-42: Promote legislative changes and funding for programs that facilitate and subsidize the acquisition, rehabilitation, and operation of existing rental housing by housing assistance organizations, nonprofit developers, and for-profit developers. Progress: The City of Palo Alto is an active member of the Non- Profit Housing Association of Northern California, an advocacy non-profit organization focusing on housing, and continues to collaborate with the group to promote legislative changes and funding for programs relating to housing. In addition, the City utilizes federal legislative consultants to work with the City’s federal representatives and federal departments to ensure the City receives appropriations. Since 2001, the consultants have assisted with acquiring over $4 million in appropriations. Effectiveness: This program has been effective in supporting the City, other agencies and organizations that provide housing, and related services to very low-, low-, and moderate-income households. Appropriateness: This program is appropriate for continuation in the Housing Element update. Chapter 5 193 PROGRAM H- 43: Use existing agency programs such as Senior Home Repair to provide rehabilitation assistance to very low- and low-income households. Progress: The City provides grants to agencies for programs that provide rehabilitation assistance to very low- and low income households using Community Development Block Grant (CDBG) funds and/or General Fund monies such as the Avenidas Handyman Services and Senior Home Repair Effectiveness: Over 2,000 minor home repair jobs were completed during the planning period. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-44: Support the development and preservation of group homes and supported living facilities for persons with special housing needs by:  Assisting local agencies and nonprofit organizations in the construction or rehabilitation of new facilities for this population.  Reviewing existing development regulations and identifying and reducing regulatory obstacles to this type of housing during the timeframe of this Housing Element. Progress: The City supports development and preservation of group homes as part of its CDBG Consolidated Plan. The zoning code however, has not been modified to facilitate the development of these facilities. This program has not been fully implemented. Effectiveness: The CDBG program provides potential funding for group home development. Appropriateness: This program is appropriate for continuation in the Housing Element update. POLICY H-15: Pursue funding for the construction or rehabilitation of housing that is affordable to very low-, low-, and moderate-income households. Support financing techniques such as land banking, federal and state tax credits, mortgage revenue bonds, and mortgage credit certificates to subsidize the cost of housing. Chapter 5 194 PROGRAM H-45: Maintain a high priority for the acquisition of new housing sites, acquisition and rehabilitation of existing housing, and housing-related services in the allocation of Community Development Block Grant (CDBG) funds or similar programs. Progress: The City of Palo Alto gives housing a high priority by allocating over 60% of its Community Development Block Grant (CDBG) funds for the acquisition and rehabilitation of existing, and housing-related services each year. Effectiveness: CDBG provides funding for the construction or rehabilitation of housing that is affordable to very low-, low-, and moderate-income households. Appropriateness: This program remains appropriate for inclusion in the Housing Element update. PROGRAM H-46: Support and expand the City’s Housing Development Fund or successor program. Progress: The City of Palo Alto supports and expands its Housing Development Funds, which are primarily composed of the following sources of fundings: federal Community Development Block Grant (CDBG) funds; local impact fees on new commercial space; Below Market Rate (BMR) in-lieu fees on residential units; and other grant funds from state and federal programs. Effectiveness: The use of the Housing Development Fund has increased the supply of affordable housing stock by 152 units during the planning period. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-47: Consider requiring 30% of all revenues generated by the Redevelopment Agency to be used for the provision of affordable housing. Progress: On July 9, 2001, the City Council approved an ordinance to establish a redevelopment agency for the City of Palo Alto. The City did not establish a Redevelopment Project Area since no area in Palo Alto was able to meet the “blight findings” requirements. Therefore, no redevelopment funds were generated. The City Redevelopment Agency was abolished in 2011. Effectiveness: The effectiveness of this program was never determined. Appropriateness: This program will not be included in the Housing Element Update. PROGRAM H-48: Continue to seek funding from all Progress: In 2003, the City was granted $1,000,000 from the Chapter 5 195 appropriate state and federal programs whenever they are available to support the development or rehabilitation of housing for very low-, low-, or moderate-income households. State’s Housing and Community Development Department through the Local Housing Trust Fund Program that has been targeted for a 60-unit very low income affordable housing project in the City. In addition, the City continues to support and work with nonprofit developers to seek additional funding from various state and federal programs, leveraging the City’s financial contribution. Effectiveness: This program has provided significant funding for developing affordable housing units in the City. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-49: Continue to support the County of Santa Clara’s Mortgage Credit Certificate (MCC) Program to create and support homeownership opportunities for lower- and moderate-income households in Palo Alto. Progress: The City of Palo Alto continues to participate in the County of Santa Clara’s Mortgage Credit Certificate (MCC) Program. The program provides financial assistance to first-time homebuyers for the purchase of single-family homes, townhomes, and condominiums. Effectiveness: The MCC program has helped 23 households purchase their homes during this planning period. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-50: Continue to require developers of employment-generating commercial and industrial developments to contribute to the supply of low- and moderate-income housing. Progress: Chapter 16.47 of the City’s Municipal Code requires developers of commercial projects to contribute to programs that increase the City’s low- and moderate- income housing stock by the required payment of a housing impact fee on the net increase in commercial square footage. The payments are deposited in the City’s affordable Housing Trust Fund and used for loans to affordable housing developers to enable the construction of new very low and low-income rental housing. Effectiveness: This program has been effective in increasing the supply of affordable housing. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-51: Periodically review the housing nexus formula as required under Chapter 16.47 Progress: The City periodically reviews the housing nexus formula as required by Chapter 16.47 of the Municipal Chapter 5 196 of the Municipal Code to better reflect the impact of new jobs on housing demand and cost. Code. On March 25, 2002, the City Council approved modifications and additions to Impact Fees collected for residential and commercial development projects based on a nexus study and required that an annual cost of living adjustment be made. Effectiveness: Periodic reviews of the Nexus formula allow the City to better gauge the impact of new jobs on housing demand and cost and to make necessary adjustments to the required impact fees as needed. Appropriateness: This program is appropriate for continuation in the Housing Element update. POLICY H-16: Encourage the preservation, rehabilitation, and construction of Single Room Occupancy (SRO) hotels and SRO housing. PROGRAM H-52: Permit Single Room Occupancy (SRO) units in industrial, commercial, and high density residential zoning districts using development standards that would encourage the construction of the maximum number of units consistent with the goals of preserving the character of adjacent neighborhoods. Progress: Whenever appropriate and feasible, the City has permitted Single Room Occupancy (SRO) housing units in appropriate zoning district(s). For example in 2006, the City permitted the construction of the Opportunity Center, an 89-unit affordable housing project with 70 SRO units in a commercial district. This is one of the sites identified in the previous Housing Element’s Housing Inventory list. Effectiveness: This program has been effective in encouraging the preservation, rehabilitation, and construction of Single Room Occupancy (SRO) hotels and SRO housing. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-53: Examine the Zoning Code during the current Zoning Ordinance Update (2002- 2004) to ensure that the Code facilitates shared housing or other innovative housing types and provides flexible development standards for these types of housing that will allow such housing to be built while preserving the character of the neighborhoods in which they are proposed to be located. Progress: The City did not examine this program during the update of the Zoning Ordinance. Therefore, changes were not made to the Code to implement this program. Effectiveness: The City is unable to measure the effectiveness of this program since it was not implemented. Appropriateness: This program is appropriate for continuation in the Housing Element update. Chapter 5 197 POLICY H-17: Support opportunities for Shared Housing and other innovative housing forms to promote diversity and meet the needs of different household types and income levels. POLICY H-18: Support housing that incorporates facilities and services to meet the health care, transit, or social service needs of households with special needs, including seniors and persons with disabilities. PROGRAM H-54: As part of the Zoning Ordinance Update process, develop zoning modifications, which would allow higher densities and create other incentives for projects proposing 100% affordable senior rental housing. Progress: The 2007 Zoning Update included zoning modifications which would allow higher housing densities in the Pedestrian Transit Oriented Development (PTOD), and create incentives for projects proposing 100% affordable senior housing rental housing such as a reduction in parking requirement up to 50%, Floor Area Ratio (FAR) increases and height increases. Effectiveness: This program resulted in increased density allowance for projects proposing 100% affordable senior rental housing. Appropriateness: The program has been implemented. As a result it will not be included in Housing Element update. The City will continue to monitor the impact of the ordinance on increasing the supply of affordable senior rental housing. PROGRAM H-55: Examine the Zoning Code during the current Zoning Ordinance Update (2002- 2004) to ensure that the Code facilitates the construction of housing that provides services for special needs households and provides flexible development standards for special service housing that will allow such housing to be built while preserving the character of the neighborhoods in which they are proposed to be located. Progress: Changes have not been made to the Code to implement this program. Effectiveness: The City is unable to measure the effectiveness of this program since it was not implemented. Appropriateness: This program is appropriate for continuation in the Housing Element update. POLICY H-19: Support family housing that addresses resident needs for childcare, youth services, recreation opportunities and access to transit. Chapter 5 198 PROGRAM H-56: Provide preferential or priority processing for those residential or mixed-use projects that incorporate child care facilities, provide recreational opportunities above normal open space requirements, or that provide enhanced access to public transit. Progress: The City does not have a formal process to provide preferential or priority processing for those residential or mixed-use projects that incorporate child care facilities, provide recreational opportunities above normal open space requirements, or provide enhanced access to public transit. Effectiveness: On a case by case basis, projects with special and unique features receive additional attention and guidance during the application process. Appropriateness: This program remains appropriate for continuation in the Housing Element update. POLICY H-20: Support legislation, regulatory changes, federal funding, and local efforts for the permanent preservation of HUD-assisted very low- and low-income units at risk of conversion to market rate housing or loss of federal rental assistance. POLICY H-21: Support the provision of emergency shelter, transitional housing and ancillary services to address homelessness. PROGRAM H-57: As part of the Zoning Ordinance Update process, modify the Zoning Code to allow homeless shelters in the CS, CD and industrial zoning districts with a Conditional Use Permit. Progress: No modification has been made to the Zoning Code to allow homeless shelters in the CS, CD and industrial zoning districts with a Conditional Use Permit. Effectiveness: The City is unable to measure the effectiveness of this program at this time since it was not implemented. Appropriateness: Identification of an appropriate zoning district and modifications to the zoning code to allow homeless shelters continues to be a program necessary for inclusion in the Housing Element. Since the City has an unmet need for the provision of adequate emergency shelter for its unhoused residents, this program will be amended to identify that the zoning ordinance must be amended to identify where shelters are allowed by right. PROGRAM H-58: Create emergency homeless shelter and transitional housing location and development criteria during the timeframe Progress: The program implementation has not occurred. Chapter 5 199 of this Housing Element to aid the developers of this type of housing in understanding the standards the City will use to review these types of housing projects and to expedite the processing of Conditional Use Permits and other permits required for these types of housing. Location and development criteria for emergency homeless shelters should be based on the size and operating characteristics of the facility. Transitional housing location and development criteria should use standards comparable to traditional housing of similar size and density since transitional housing has impacts similar to traditional housing although non-traditional assistance services are provided. Effectiveness: Since this program has not been implemented, it cannot be assessed for effectiveness. Appropriateness: A modified version of this program is included in the Housing Element update. POLICY H-22: Provide leadership in addressing homelessness as a regional issue. POLICY H-23: Work closely with appropriate agencies in the region to develop and implement policies and programs relating to homelessness. PROGRAM H-59: Continue to participate in the Santa Clara County Homeless Collaborative as well as work with adjacent jurisdictions to develop additional shelter opportunities. Progress: The City of Palo Alto continues to participate in the Santa Clara County Housing and Homeless Collaborative that addresses issues of homelessness on a regional basis. The Collaborative prioritizes county applications for McKinney funding, and establishes the County’s Continuum of Care program. City staff serves as a member of the CDBG and HOME Program coordinators group of entitlement jurisdictions from throughout Santa Clara County that addresses multi-jurisdictional funding and other issues of common interest. Effectiveness: Since homelessness is a regional issue, the City’s participation in various countywide collaborative efforts has resulted in better utilization and leveraging of the City’s resources to address homelessness. Appropriateness: This program is appropriate for continuation in the Housing Element update. The City of Palo Alto will continue to participate in regional efforts to address homelessness. Chapter 5 200 PROGRAM H-60: Continue to participate with and support agencies addressing homelessness. Progress: The City of Palo Alto continues to participate in the Santa Clara County Housing and Homeless Collaborative that addresses issues of homelessness on a regional basis. The Collaborative prioritizes county applications for McKinney funding, and establishes the County’s Continuum of Care program. City staff serves as a member of the CDBG and HOME Program coordinators group of entitlement jurisdictions from throughout Santa Clara County that address multi-jurisdictional funding, and other issues of common interest. Effectiveness: Since homelessness has become of a regional issue, participating in various countywide collaborative efforts has provided the City the ability to be part of the wider efforts to address homelessness. Appropriateness: This program is appropriate for continuation in the Housing Element update. The City of Palo Alto will continue to participate in regional efforts to address homelessness. FAIR HOUSING Goal H-4: An End to Housing Discrimination on the Basis of Race, Religion, National Origin, Age, Sex, Sexual Orientation, Marital Status, Physical Handicap, or Other Barriers that Prevent Choice in Housing. POLICY H-24: Support programs and agencies that seek to eliminate housing discrimination. PROGRAM H-61: Work with appropriate state and federal agencies to ensure that fair housing laws are enforced. Progress: The City works with appropriate state and federal agencies to ensure that fair housing laws are enforced. Effectiveness: This program has been effective in eliminating housing discrimination. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-62: Continue to support groups that provide fair housing services, such as Mid- Peninsula Citizens for Fair Housing. Progress: The City of Palo Alto continues to support groups that provide fair housing services. During the planning period, the City of Palo has provided over $200,000 in Chapter 5 201 CDBG funds to groups that provide fair housing services such as Mid-Peninsula Citizens for Fair Housing and Project Sentinel. Effectiveness: This program has been effective in promoting fair housing and reducing discrimination. The City plans to continue supporting groups that provide fair housing services. Appropriateness: This program will be continued in the Housing Element update. PROGRAM H-63: Continue the efforts of the Human Relations Commission to combat discrimination in rental housing, including mediation of problems between landlords and tenants. Progress: The City’s Human Relations Commission is charged with the discretion to act with respect to any human relations matter when the Commission finds that any person or group does not benefit fully from public or private opportunities or resources in the community or is unfairly or differently treated due to factors of concern to the Commission. The City’s Human Relations Commission continues to hold public meetings and forums to combat discrimination in rental housing, including mediation of problems between landlords and tenants. Effectiveness: The Human Relations Commission’s efforts are effective in preventing and eliminating housing discrimination. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-64: Continue implementation of the City’s Ordinances prohibiting discrimination in renting or leasing housing based on age, parenthood, pregnancy or the potential or actual presence of a minor child. Progress: The City continues to implement the City’s ordinances prohibiting discrimination in renting or leasing housing based on age, parenthood, pregnancy or the potential or actual presence of a minor child. Effectiveness: In addition to federal and state laws against housing discrimination, the City’s ordinances have been effective in combating housing discrimination. Appropriateness: This program remains appropriate for inclusion in the Housing Element update. PROGRAM H-65: As part of the current (2002-2004) Zoning Code Update process, examine all Zoning Code and other pertinent development Progress: This program was not addressed as part of the Zoning Code update process. Chapter 5 202 regulations affected by the passage of Senate Bill SB520, which is designed to eliminate housing discrimination based on familial status or disability, and modify those provisions that would hamper the implementation of SB520. Develop written procedures describing how Palo Alto will process and treat reasonable accommodation requests for projects proposing housing for special needs households. Effectiveness: The City is unable to measure the effectiveness of this program since it was not implemented. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-66: Continue the City’s role in coordinating the actions of various support groups that are seeking to eliminate housing discrimination and in providing funding and other support for these groups to disseminate fair housing information in Palo Alto, including information on referrals to pertinent investigative or enforcement agencies in the case of fair housing complaints. Progress: The City’s Office of Human Services (OHS) continues to sponsor housing information and referral coordination meetings for service providers seeking to eliminate housing discrimination. Through the Human Service Resource Allocation Process (HSRAP), the City of Palo continues to provide funding and other support for these groups to disseminate fair housing information in Palo Alto. Effectiveness: The program is effective in addressing and eliminating housing discrimination and in affirmatively furthering fair housing. Appropriateness: This program is appropriate for continuation in the Housing Element update. PROGRAM H-67: Continue to interpret and apply the City’s land use regulations in a manner that does not deny to person with disability the access to housing and public accommodations that they are guaranteed under state and federal law. Progress: The City continues to interpret and apply the City’s land use regulations to ensure that person with disabilities have access to housing and public accommodations as guaranteed under state and federal laws. The City of Palo Alto does not discriminate against individuals with disabilities. Effectiveness: This program ensures access to housing and public accommodations for people with disabilities. Appropriateness: This program is appropriate for continuation in the Housing Element update. Chapter 5 203 ENERGY CONSERVATION AND COST REDUCTION Goal H-5: Reduced Housing Expenses for Energy POLICY H-25: Reduce the cost of housing by continuing to promote energy efficiency, resource management, and conservation for new and existing housing. PROGRAM H-68: Continue providing staff support and technical assistance in energy conservation and demand management to architects, developers, and utility customers. Progress: The City’s Development Review Committee (DRC), comprised of staffs from various departments including Utilities Department, Public Works Department, and Department of Planning and Community Environment, continues to provide support and technical assistance in energy conservation and demand management to architects, developers, and utility customers. Effectiveness: Through staff support and technical assistance, architects, developers, and utility customers are able to enhance their understanding of energy conservation and demand management measures and incorporate them into their projects, resulting in potential reduction in housing costs. Appropriateness: The program remains appropriate for inclusion in the Housing Element update. PROGRAM H-69: Review State programs encouraging energy efficiency and incorporate appropriate programs in Palo Alto’s energy conservation programs and outreach efforts. Progress: The City continues to review State programs encouraging energy efficiency and to incorporate appropriate programs in Palo Alto’s energy conservation programs and outreach efforts. The City’s Public Work Department, Utilities Department and Department of Planning and Community Environment work together in promoting energy efficiency, resource management and conservation for new and existing housing. Effectiveness: This program has been effective in reducing housing costs as a result of energy efficiency, resource management and conservation. Appropriateness: This program is appropriate for continuation in the Housing Element update. Program H-70: Continue to develop a proactive public Progress: The City continues to develop a proactive public Chapter 5 204 outreach program to encourage Palo Alto residents to conserve energy and to share ideas regarding energy conservation. outreach program to encourage residents to conserve energy and to share ideas regarding energy conservation working in collaboration with the City’s Planning and Community Environment, Public Works and Utilities Departments. The City’s website and Development Center serve as resources for valuable information relating to energy conservation. Effectiveness: Brochures and materials relating to energy conservation are available at City Hall, recreational facilities, libraries and other public locations throughout the community to provide valuable information promoting energy conservation. Appropriateness: This program remains appropriate for inclusion in the Housing Element update. PROGRAM H-71: Encourage developers and builders to construct sustainable residential buildings that increase energy efficiency by at least 15% above the energy standards of Title 24. Progress: The City continues to encourage builders to construct sustainable residential buildings that increase energy efficiency by at least 15% above the energy standards of Title 24. Effectiveness: This program has been effective in reducing housing costs as a result of energy efficiency, resource management and conservation. Residents of new housing developments have benefited from reduced housing costs. Appropriateness: This program is appropriate for continuation in the Housing Element update. POLICY H-26: Reduce the cost of housing using the Utilities Residential Rate Assistance Program (RAP). PROGRAM H-72: Continue to assist very low-income households in reducing their utility bills through the RAP. Progress: The City’s Utilities Department continues to offer utilities discounts to provide financial relief to low- income households. Qualified households receive a twenty percent (20%) discount in their utilities including, gas, water, electricity and storm drainage. Effectiveness: The program is effective in providing relief, reducing housing costs, particularly for low-income households. Over 900 households are currently enrolled in the program and receiving a utilities Chapter 5 205 discount. Appropriateness: This program is appropriate for continuation in the Housing Element update. EXHIBITS g a s d J u n i p e r o S e r r a B o u l e v a r d ag e Mill Road Arastradero Road E l C a m i n o R e a l S an Antonio Avenue Charles ton Road O r e g o n E x p r e s Midd lefield Road University Aven Al ma S tree t F o o t h i l l E x p r e s s w a yHillview Fabian Sand Hill Road Embarcadero Road Wi MoanaCourt Wallis Ct Donald Drive Encina Grande Drive Cereza Drive Los Robles Avenue Villa Vera Verdosa Drive Campana Drive Solana Drive Georgia Ave Ynigo Way Driscoll Ct ngArthur'Maybell Way Maybell Avenue Frandon Ct Florales Drive Georgia Avenue Amaranta Avenue Amaranta Ct MirandaGreen Foothill Expressway Ki sCourt Terman Drive Baker Avenue Vista Avenue Wisteria Ln Pena Ct Coulombe Drive Cherry Oaks Pl Pomona Avenue Arastradero Road Abel Avenue Clemo Avenue Villa Real El Camino Way Curtner Avenue Ventura Avenue Maclane Emerson Street Ventura Ct Park Boulevard Magnolia Dr South El Camino Real Cypress Lane GlenbrookD Fairmede Avenue Arastradero RoadIrven Court Los Palos Cir LosPalosPl Maybell Avenue Alta Mesa Ave Kelly Way Los Palos Avenue Suzanne Drive Suzanne Drive rive El Camino Real Suzanne Ct Lorabelle Ct McKellar Lane El Camino Way James Road Maclane Second Street Wilkie Way Camino CtWest Meadow Drive Thain Way Barclay Ct Victoria Place Interdale Way West Charleston Road Tennessee LaneWilkie Way Carolina Lane Tennessee Lane Park Boulevard Wilkie Ct Davenport Way Alma Street Roosev Monroe Drive Wilkie Way Whitclem Pl Whitclem Drive Duluth Circle Edlee Avenue Dinah's Court Cesano Court Monroe DriveMiller Avenue Whitclem Wy Whitclem Ct Ferne Avenue Ben Lomond Drive Fairfield Court Ferne Avenue Ponce Drive HemlockCourt Ferne Court Alma Street Monroe Drive San Antonio Avenue NitaAvenue Ruthelma Avenue Darlington Ct Charleston Road LundyLane Newberry Ct Park Boulevard George Hood Ln Alma Street eltCircle LinderoDrive Wright Place Starr KingCircle Shasta Drive Mackay DriveDiablo Court Scripps Avenue Scripps Court Nelson Drive Tioga Court Creekside Drive Greenmeadow Way Ben Lomond Drive Parkside Drive Dixon Place Ely Place Dake Avenue Ferne Avenue San Antonio Court (Private) ChristopherCourt CalcaterraPlace Ely Place Ely Place Adobe PlaceNelson Court ByronStreetKeats CourtMiddlefield Road Duncan Place Carlson Court Duncan Place Mumford Place Charleston Road San Antonio Avenue East Meadow Drive Emerson Street Court BryantStreet RooseveltCircle RamonaStreet CarlsonCircleRedwoodCircle South Leghorn Street Montrose AvenueMaplewood Charleston Ct Charleston Road Seminole Way Sutherland Drive Nelson Drive El Capitan Place Fabian Street Loma Verde Avenue Bryson Avenue Midtown Court Cowper Street Gary Court Waverley Street South Court Bryant Street Ramona Street Alma Street Coastland Drive Colorado Avenue Byron Street Middlefield Road Gaspar Court Moreno Avenue Coastland Drive El Carmelo Avenue Rosewood D Campesino Avenue Dymond Ct Martinsen Ct Ramona Street Bryant Street Towle Way Towle Place Wellsbury Ct AvalonCourt FlowersLane Mackall Way Loma Verde Avenue KiplingStreet Cowper Street South Court Waverley Street El Verano Avenue Wellsbury Way La Middlefield Road St Claire Drive Alger Drive Ashton Avenue St Michael Drive St Michael Drive Maureen Avenue Cowper Court Rambow Drive East Meadow Drive Ashton Court Murdoch Drive CowperStreet Murdoch Ct St Michael Court MayCourt Mayview Avenue Middlefield Road Ensign Way Bibbits DriveGailen Ct Gailen Avenue Grove Avenue San Antonio Avenue Commercial Street Industrial Avenue Bibbits Drive Charleston Road Fabian Way T East Meadow Drive Grove Avenue Christine Drive Corina Way Ross RoadCorina Way Louis Road Nathan Way Transport Street Ortega CourtEast Meadow Drive yneCourt alisman Loma Verde Avenue Allen Court Ros s C o u r t Loma Verde Pl Am e s Av e nue Rich a r d s o n C o u r t Holly Oak Drive Ame s Av e nue CorkOakWay Middlefield Road Ames Ct Ames A v e n ue Ross Road Rorke Way RorkeWay Ston e L a n e Toyon Place Torr e y a C o u r t Lupine Avenue Thornwood Drive DriftwoodDrive Talisman Drive Arbutus Avenue Ross Road Louis Road Aspen W ay Evergreen Drive Janice Way East Meadow Circle GreerRoad rive Ellsworth Place San Carlos Court Wintergreen Way SutterAvenue Sutter Avenue Clara Drive Price Court Stern Avenue Colorado Avenue Randers Ct Ross Road Sycamore Drive Sevyson Ct Stelling Drive Ross Road David Avenue MurrayWay Stelling Drive Stelling Ct ManchesterCourt rRoad Stockton Place Vernon Terrace Louis Road Janice Way T Loma V CliftonCourt ElbridgeWay Clara Drive BautistaCourtStockton Place Madd Piers Ct Louis Road Moraga Ct Old Page Mill Road Deer Creek Road Coyote Hill Road Hillview Avenue Porter Drive Hillview Avenue Hanover Street Foothill Expressway Arastradero Road Miranda Avenue Stanford Avenue Amherst Street Columbia Street Bowdoin Street Dartmouth Street Hanover Street College Avenue California Avenue Hanover Street Ramos Way (Private) Page Mill Road Hansen Way Hanover Street Old Adobe Road Old Trace Court Arastradero Road Miranda Avenue MockingbirdLane OldTraceRoad Manuela Way Robb Road Manuela Court Mesa Avenue Oak Hill Avenue Manuela Avenue Miranda Avenue Laguna Ct Barron Avenue Josina Avenue Kendall Avenue Tippawingo St Julie Ct Matadero Avenue Ilima Way Ilima Court Laguna Oaks Pl Carlitos Ct La Calle Laguna Avenue ElCerrit Paradise Way Roble Ridge (Private) LaMataWay Chimalus Drive Matadero Avenue oRoad Paul AvenueKendall AvenueWhitsell Avenue Barron Avenue Los Robles Avenue Laguna Way ShaunaLane La Para Avenue San Jude Avenue El Centro Street Timlott La Jennifer Way Magnolia Dr North La Donna Avenue LosRobles Avenue Rinc Manzana Lane onCircle MesaCourt Crosby Pl Georgia Avenue Hubbartt Drive Willmar Drive Donald Drive Arastradero Road Foothill Expressway Miranda Avenue La Para AvenueSan Jude Avenue Magnolia Drive Military Way Arbol Drive Orme Street Fernando Avenue Matadero Avenue Lambert Avenue Hansen Way El Camino Real Margarita Avenue Matadero Avenue Wilton Avenue Oxford Avenue Harvard Street California Avenue Wellesley Street Princeton Street Oberlin Street Cornell Street Cambridge Avenue College Avenue Williams Street Yale Street Staunton Court Oxford AvenueEl Camino Real Churchill Avenue Park Boulevard Park Avenue Escobita Avenue Churchill Avenue Sequoia Avenue Mariposa Avenue Castilleja Avenue Miramonte Avenue Madrono Avenue Portola Avenue Manzanita Avenue Coleridge Avenue Leland Avenue Stanford Avenue Birch Street Ash Street Lowell Avenue Alma StreetTennyson Avenue Grant Avenue Sheridan Avenue Jacaranda Lane El Camino Real Sherman Avenue Ash Street Page Mill Road Mimosa Lane Chestnut Avenue Portage Avenue Pepper Avenue Olive Avenue Acacia Avenue Emerson Street Park Boulevard Orinda StreetBirch Street Ash Street Page Mill Road Ash Street Park Boulevard College Avenue Cambridge Avenue New Mayfield LaneBirch Street California Avenue Park Boulevard Nogal Lane Rinconada Avenue Santa Rita Avenue Park Boulevard Seale Avenue Washington Avenue Santa Rita Avenue Waverley Stree Bryant Street High Street Emerson Street Colorado Avenue Street Emerson Street Ramona Street Bryant Street South Court El Dorado Avenue Alma Street Alma Street HighStreet t Emerson Waverley Oaks Washington Avenue Bryant Street South Court Waverley Street Emerson Street Nevada Avenue North California Avenue Santa Rita Avenue Ramona Street High Street North California Avenue Oregon Expressway Marion Avenue Ramona Street Colorado Avenue Waverley Street Kipling Street South Court Cowper Street Anton Court Nevada Avenue Tasso StreetTasso Street Oregon Avenue Marion Pl Webster Street Middlefield Road Ross Road Warren Way El Cajon Way Garland Drive Louis Road Morton Street Marshall Drive Fieldin Moreno Avenue MarshallDrive Dennis Drive Agnes Way Orego Elsinore Dr El Cajon Way Nort gDrive Colorado Avenue Sycamore Drive Amar Bruce Drive CoMore Celia Drive Sandra PlaceColoradL Sand Hill Road Quarry Road Welch Road Arboretum Road Quarry Road Sand Hill Road Homer Avenue Lane 8 West Medical Foundation Way Lane 7 West Lane 7 East Embarcadero Road Encina Avenue El Camino Real Urban Lane Wells Avenue Forest Avenue High Street Emerson Street Channing Avenue Alma StreetAlma Street PaloAltoA El Camino Real venue Mitchell Lane Hawthorne Avenue Everett Avenue Lytton Avenue Lane 15 E High Street Alma Street Bryant Street Lane 6 E Lane 11 W Lane 21 High Street Gilman Street Hamilton Avenue University Avenue Bryant Court Lane 30 Florence Street Kipling Street Tasso Street Cowper Street Ruthven Avenue Hawthorne Avenue Lane 33 PaloAltoAvenue Everett Avenue Poe Street Waverley Street Tasso Street Cowper Street Palo Alto Avenue Webster Street Everett Court Lytton Avenue Byron Street Fulton Street Middlefield Road Churchill Avenue Lowell Avenue Seale Avenue Tennyson Avenue Melville Avenue Cowper Street Tasso Street Webster Street Byron Street North California Avenue Coleridge Avenue Waverley Street Bryant Street Emerson Street Kellogg Avenue Kingsley Avenue Portal Place Ross Road Oregon Avenue Garland Drive Lane A West Lane B West Lane B East Lane D West Lane 59 East Whitman Court Kellogg Avenue Embarcadero Road Kingsley Avenue Lincoln Avenue Addison Avenue Lincoln Avenue Forest Avenue Downing Lane Homer Avenue Lane D East Lane 39 Lane 56 Hamilton Avenue Webster Street Waverley Street Kipling Street Bryant Street Ramona Street Addison Avenue Scott Street Byron Street Palo Hale Street Seneca Street Lytton Avenue Guinda StreetPaloAltoAvenue Fulton Street Middlefield Road Forest Avenue Webster Street Kellogg Avenue Middlefield Road Byron Street Webster Street Cowper Street Tasso Street Cowper Street Addison Avenue Lincoln Avenue Boyce Avenue Forest Avenue Hamilton Avenue Homer Avenue Guinda Street Middlefield Road Channing Avenue AltoAvenueChaucer Street Chaucer Street University Avenue Channing Avenue Addison Avenue Lincoln Avenue Regent Pl Guinda Street Lincoln Avenue Fulton Street Melville Avenue Byron Street Kingsley Avenue Melville Avenue Hamilton Avenue Hamilton Court Forest Avenue Forest Ct Marlowe Street Maple Stre Pa Somerset Pl Pitman Avenue Fife Avenue Forest AvenueDana Avenue Lincoln AvenueUniversity Avenue Coleridge Avenue Lowell Avenue Fulton Street Cowper Street Tennyson Avenue Seale Avenue Northampton Drive West Greenwich Pl Middlefield Road Newell Road Guinda Street East Greenwich Pl Southampton Drive Webster Street Kirby Pl Kent Place Tevis Pl Martin Avenue Center Drive Harriet Street Wilson Street Cedar Street Harker AvenueGreenwood Avenue Hutchinson Avenue Channing Avenue Hopkins Avenue Embarcadero Road Pitm Arcadia Place Newell Pl Sharon Ct Erstwild Court Walter Hays Drive Walnut Drive Newell Road Parkinson AvenuePine Street Mark Twain Street Louis Road Barbara Drive Embarcadero Road Walter Hays Drive Lois LaneJordan Pl Lois Lane Heat Bret Harte Street Stanley Way Walter Ramona Street Addison Avenue Channing Avenue Waverley Street Tennyson Avenue Seale Avenue Middlefield Road Byron Street Webster Street Marion Avenue Welch Road Sedro Lane Peral Lane McGregor Way Monroe Drive Silva Avenue Silva Court Miller Court Briarwood Way Driscoll Place Paulsen Ln Community Lane Lane 15 E Court Madeline Ct Arroyo Ct David Ct Green Ct Oregon Expressway Sheridan Avenue Page Mill Road Page Mill Road Foothill Expressway Miranda Avenue Foothill Expressway Miranda AvenueFoothill Expressway Cerrito Way Emerson Street Miranda Avenue Lane 20 W Lane 20 E Oregon E University Avenue Jacob's Ct CalTrain ROW CalTrain ROW CalTrain ROW CalTrain ROW Emerson Street Waverley Street Kipling Street Clark Way Durand Way Sandhill RoadSwain Way Clark Way Mosher Way Charles Marx Way Orchard Lane Vineyard Lane Oak Road Sand Hill Road Sand Hill Road Sand Hill Road Hillview Avenue Arastradero Road Lane 66 Bryant Street Ramona Street Blake Wilbur Drive West Charleston Road Palo Road Shopping Center Way Shopping Center Way Shopping Center Way London Plane Way Plum Lane Sweet Olive Way Pear Lane Lane 66 La Selva Drive Grove Ct Miranda Court Stanford Avenue Lane 12 W Lane 5 E Lasuen Street Serra Mall Escondido Road Olmsted Road Pistache Place Santa Ynez Street Lane B Lane C El Dorado Avenue Oak Creek Drive Clara Drive Bellview Dr Everett Avenue Homer Avenue La Calle Matadero Ave Los Robles Avenue Timlott Ct Vista Villa PaloAltoAvenue Lane La Donna Avenue Cass Way Kenneth Drive Fabi Page Mill Road Middlefield RoadChristine Drive Louis Road Charleston Road Chimalus Drive Hanover Street Community Lane Greenwood Avenue Harker Avenue Parkinson Avenue AvenueMaplewood Pl Mackay Drive Santa Teresa Lane Byron Street Varian Way Quail Dr Quail Paloma Dr Heron W Plover Ln Sandpiper Ln Curlew Ln Mallard LnEgret Ln Deodar StAlder Ln Spruce Ln Rickey's Ln Juniper Way Rickey's Wy Rickey's Wy Rickey's Wy Juniper Lane Emerson Street Cashel St Noble StHettinger Ln Pratt Ln Emma Court Galvez Mall Federation Way Abrams Court Allardice Way Alta Road Alvarado Ct Alvarado Row Angell Court Arguello Way Arguello Way Avery Mall Ayrshire Farm Lane Barnes Court Bonair Siding Bowdoin Street Cabrillo Avenue Cabrillo Avenue Campus Drive Campus Drive Campus Drive Campus Drive Campus Drive Campus Drive Campus Drive Campus Drive Campus Drive Campus Drive Campus Drive Campus Drive Campus Drive Campus Drive Capistrano Way Casanueva Place Cathcart Way Cedro Way Cedro Way Churchill Mall Comstock Circle Aboretum Road Aboretum Road Blackwelder Court Campus Drive Cathcart Way Constanzo Street Cooksey Lane Coronado Avenue Cottrell Way Cottrell Way Cowell Ln Crothers Way Dolores Street Dolores Street Dudley Lane Duena Street Electioneer Road Escondido Mall Escondido Mall Escondido Road Escondido Road Escondido Road Esplanada Way Estudillo Road Fremont Road Frenchmans Road Frenchmans Road Galvez Mall Alvarado Row Galvez Street Galvez Street Galvez Street Gerona Road Gerona RoadEl Escarpado Gerona Road Hoskins Court Hulme Court Jenkins Court Junipero Serra Boulevard Junipero Serra Boulevard Junipero Serra Boulevard Junipero Serra Boulevard Knight Way Lagunita Drive Lane L Lane W Lasuen Mall Lasuen Mall Lasuen Mall Lasuen Street Lathrop Drive Lathrop Drive Lathrop Place Lathrop Drive Links Road Links Road Lomita Drive Lomita Drive Lomita Drive Lomita Drive Lomita Drive Lomita Court Lomita Mall Los Arboles Avenue Masters Mall Mayfield Avenue Mayfield Avenue Mayfield Avenue Mayfield Avenue Mayfield Avenue Mayfield Avenue McFarland Court Mears Court Mears Court Memorial Way Mirada AvenueMirada Avenue Museum Way N Service Road N Tolman Ln Nelson Mall Nelson Road North-South Axis Oberlin St Comstock Circle Escondido Mall Olmsted Road Olmsted Road Olmsted Road Olmsted Road Olmsted Road Palm Drive Palm Drive Pampas Lane Panama Mall Panama Mall Panama Street Panama Street Pearce Mitchell Pl Peter Coutts Circle Peter Coutts Road Peter Coutts Road Pine Hill Court Pine Hill Road Quarry Extension Quarry Road Quillen Ct Raimundo Way Raimundo Way Raimundo Way Roble Drive Rosse Lane Roth Way Roth Way Roth Way Running Farm Lane Ryan Court S Service Road S Tolman Ln Salvatierra Street Salvatierra St Salvatierra Walk Samuel Morris Wy San Francisco Terrace San Francisco Court San Juan St San Juan St San Rafael Pl Santa Fe Avenue Santa Maria Avenue Santa Teresa Street Santa Teresa Street Santa Ynez Street Searsville Road Sequoia Wy Serra Mall Serra Street Serra Street Serra Street Sonoma Terrace Stanford Avenue Stanford Avenue Stock Farm Road Thoburn Court Tolman Drive Valdez Place Valparaiso Street Vernier Place Via Ortega Via PalouVia Pueblo Mall Welch Road Wellesley St Wilbur Way Wing Place Yale St Alma Street Alma Street Alma Street Alma Street Alma Street Hawthorne Avenue Lytton Avenue Nathan Abbott Way Sam McDonald Road Sam McDonald Mall Vista Lane Bowdoin Lane Arguello Way Governors Avenue Governors Avenue Governors Avenue S Governors LanePasteur Drive Lagunita Drive Alma Village Lane Alma Village Circle R e s e Reservoir Road Reservoir Road Ryan LaneBowling Lane Fiesta Court Marlowe Court O'Connor Lane This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend DRAFT HIS on Existing Commercial Zones DRAFT HIS on Existing Residential Transition Zones (SOFA2) DRAFT HIS on Existing Residential Zones Site designated to meet AB2348 requirement Small Lot; Consolidation Opportunity City Jurisdictional Limits abc Quarter Mile Radius from El Camino Real Half Mile Radius from Caltrain Station Caltrain Stations 0'1843' DR A F T Ho u s i n g I n v e n t o r y S i t e s ( H I S ) Ar e a M a p v04 1 3 CITY OF PALO ALTOINCORPORATED CALI FORNIA P a l o A l t oT h e C i t y o f APRIL 1 6 1894 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2013 City of Palo Alto rrivera, 2013-04-03 10:27:25 (\\cc-maps\gis$\gis\admin\Personal\rrivera.mdb) Univer d Hill Road Quarry Road Welch Road Arboretum Road Quarry Road Sand Hill Road Homer Avenue Lane 8 West Medical Foundation Way Lane 7 West Lane 7 East Embarcadero Road Encina Avenue El Camino Real Urban Lane Wells Avenue Forest Avenue High Street Emerson Street Ch a n n i n g A v e n u e Alma StreetAlma Street PaloAltoA El Camino Real venue Mitchell Lane Hawthorne Avenue Everett Avenue Lytton Avenue Lane 15 E High Street Alma Street Bryant Street Lane 6 E Lane 11 W Lane 21 High Street Gilman Street Hamilton Avenue University Avenue Bryant Court Lane 30 Florence Street Kipling Street Tasso Street Cowper Street Ruthven Avenue Hawthorne Avenue Lane 33 PaloAltoAvenue Everett Avenue Poe Street Waverley Street Tasso Street Cowper Street Palo Alto Avenue Webster Street Everett Court Lytton Avenue Byron Street Fulton Street Middlefield Road Kingsley Avenue Lane A West Lane B West Lane B East Lane D West Lane 59 East Whitman Court Kingsley Avenue Lincoln Avenue Addison Avenue Lincoln Avenue Forest Avenue Downing Lane Homer Avenue Lane D East Lane 39 Lane 56 Hamilton Avenue Webster Street Waverley Street Kipling Street Bryant Street Ramona Street Addison Avenue Scott Street Byron Street Lytton Avenu Fulton Street Middlefield Road Forest Aven Webster Street Middlefield Road Webster Street Cowper StreetCowper Street Addison Avenue Lincoln Avenue Home r Avenu Middlefield Road Channing Avenue Lincoln Aven Fulton Street Byron Street Kingsley Avenue Ramona Street Addison Aven Channing Aven Waverley Street Welch Road Paulsen Ln Lane 15 E Emerson Street Lane 20 W Lane 20 E University Avenue CalTrain ROW Emerson Street Waverley Street Kipling Street Clark Way Durand Way Sandhill Road Swain Way Clark Way Mosher Way Charles Marx Way Orchard Lane Vineyard Lane Sand Hill Road Sand Hill Road Sand Hill Road Bryant Street Ramona Street Blake Wilbur Drive Palo Road Shopping Center Way Shopping Center Way Shopping Center Way London Plane Way Plum Lane Sweet Olive Way Pear Lane Lane 12 W Lane 5 E Lasuen Street Serra Mall Pistache Place Everett Avenue Homer Avenue Palo Alto Avenue Byron Street Varian Way Emerson Street Arguello Way Campus Drive Campus Drive Campus Drive Campus Dr i ve Campus Drive Campus Drive Aboretum Road Aboretum Road Crothers Way ena StreetEscondido Mall Escondido Mall Galvez Mall Galvez Street Galvez Street Galvez Street Lasuen Mall Lasuen Mall suen Mall Lasuen Street Lomita Drive Lomita Drive Lomita Mall Memorial Way Museum Way N Service Road Nelson Road North-South Axis Es Palm Drive Palm Drive Panama Mall P Quarry Extension Quarry Road Roth Way Roth Way Roth Way Serra Mall Serra Street Via Ortega Via PalouVia Pueblo Mall Welch Road Alma Street Hawthorne Avenue Lytton Avenue Sam McDonald Road Sam McDonald Mall Governors LanePasteur Drive This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend DRAFT HIS on Existing Commercial Zones DRAFT HIS on Existing Residential Transition Zones (SOFA2) DRAFT HIS on Existing Residential Zones Small Lot; Consolidation Opportunity City Jurisdictional Limits abc Quarter Mile Radius from El Camino Real Half Mile Radius from Caltrain Station Caltrain Stations 0'700' DRAFTHousing Inventory sites (HIS)University Ave/DowntownArea Mapv0313 CITY OF PALO ALTOINCORPORATED CALI FORNIA P a l o A l t oT h e C i t y o f APRIL 1 6 1894 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2013 City of Palo Alto RRivera, 2013-03-11 17:44:43HOS 2007 2014 downtown 0313 (\\cc-maps\gis$\gis\admin\Personal\RRivera.mdb) 124-28-049 137-16-031 137-15-066 137-15-065 137-15-064 137-15-063 137-15-045 137-15-067 137-15-035 137-15-023 137-15-034 137-15-033 137-09-029 137-09-032 137-09-062 137-09-061 137-09-033 137-09-034 137-09-060 137-09-035 137-09-059 137-09-036 137-09-058 137-09-057 137-09-056 137-10-007 137-10-006 137-10-005 137-09-030 137-09-031 137-09-028 137-15-053 137-15-054 137-15-055 137-15-056 137-15-057 137-15-058 137-15-052 137-15-075 137-15-051 137-15-040 137-15-050 137-15-041 137-15-049 137-15-042 137-15-069 137-15-070137-15-072 137-10-002 137-15-068 137-15-073 137-15-074 137-15-044 137-15-047 137-15-046 137-15-059 137-15-060 137-15-061 137-15-062 137-10-120 137-10-121 137-10-003 137-10-022 137-10-010 137-10-009 137-10-008 137-10-125 137-10-011 137-10-013 137-09-017 137-09-016 137-10-019 137-10-020 137-10-021 137-09-018 137-09-019 137-09-020 137-09-021 137-09-022 137-09-024 137-09-023 137-09-069 137-09-071 137-09-068 137-09-063 137-09-064 137-09-053 137-09-054 137-09-055137-09-039 137-09-038 137-09-037 137-09-073 137-09-074 137-09-027 137-10-015 137-10-016 137-09-044 137-09-043 137-09-042 137-09-065 137-09-041 137-09-040 137-09-048 137-09-049 137-09-050 137-10-014 137-10-128 137-10-122 137-10-051 137-10-052 137-10-054 137-10-130 137-09-004 137-10-114 137-10-126 137-10-048 137-10 137-10-129 142-20-098 137-09-015 137-09-014 137-09-013 137-09-012 137-09-011 137-09-067 137-09-066 137-09-001137-09-002 137-09-009 137-09-008 137-09-007 137-09-006 137-10-053 137-08-085 137-08-053 137-08-054 137-09-003 137-08-095137-08-096 137-09-072 137-09-005 137-10-018 137-08-014 137-08-013 137-08-064 137-08-010 137-08-052 137-08-089 137-08-077 132-38-035 132-38-066 132-38-032 132-38-042 132-38-025 132-38-026 132-38-047 132-38-017 132-38-018 132-38-022 132-38-019132-38-020132-38-021 132-39-090 132-39-059 132-39-074 132-39-005 132-39-071 137-08-058 137-08-059 137-08-060 137-08-055 137-08-062 142-20-055 142-20-054 142-20-046 137-08-057 137-08-086 137-08-061 132-39-017 132-39-018 132-38-056 142-20-035 142-20-079 132-39-087 142-20-037 132-39-080 137-08-084 137-08-006 132-40-019 132-40-056 132-40-060 132-40-063 132-39-078132-39-077132-39-079 137-08-007 137-08-080 137-08-079 137-08-016 137-08-092 137-08-091 132-39-055 137-08-083 132-40-061 137-08-072 137-08-088 132-33-038 132-33-037 132-33-056132-33-039 132-33-051 132-33-052 132-33-031 132-33-034 132-39-083 132-39-049 132-39-048 132-39-047 132-39-043 132-39-042 132-39-041 132-39-040 132-39-039 132-39-038 132-39-037 132-39-035 132-39-036 132-39-050 132-39-051 132-39-052 132-39-053 132-39-034 132-39-033 132-39-031 132-39-024 132-39-025 132-39-026 132-39-081132-39-082 132-39-084 132-39-030 132-33-055 132-33-057 132-33-032 132-39-054 132-39-065 132-33-033 132-39-075 132-39-032 132-40-046 132-40-047 132-40-048 132-40-049 132-40-005 132-40-006 132-40-007 132-40-008 132-40-009 132-40-010 132-40-011 132-40-012 132-40-023 132-40-058 132-40-04 132-40 132-40-022 132-40-021 132-40-020 132-40-050 132-40-051 132-40-052 132-40-028 132-40-001 132-40-002 132-40-003 132-40-004 132-40-024 132-40-025 132-40-026 132-34-032 132-34-036 132-34-035 132-34-034 132-34-033132-34-010 132-34-009 132-34-008 132-34-007 132-34-006 132-34-005 132-34-004 132-34-016 132-34-015 132-34-014 132-34-013 132-34-012 132-34-011 132-39-046 132-39-044 132-39-045 132-40-027 132-40-055 132-40-053 132-40-054 132-34-047132-34-048132-34-049132-34-050132-34-051 132-34-023 132-34-024 132-34-031 132-34-030 132-34-029 132-34-028 132-34-027 132-34-026 132-34-025 132-34-022132-34-021 132-34-040 132-34-039 132-34-038 132-34-037 13 132-35-008 132-35-007 132-35-006 132-35-005 132-35-004 132-35-003 132-35-002 132-35-001 132-35-009 132-35-010 132-37-024 132-37-023 132-37-022 132-37-049 132-37-048 132-37-046 132-37-045 132-37-044 132-37-053 132-37-042 132-38-064 132-38-065 132-38-062 132-38-027 132-38-045 132-38-046 132-32-047 132-32-026 132-32-027 132-32-037 132-32-025 132-32-024 132-32-043 132-37-055 132-37-057132-37-054 132-37-047 132-38-059 132-38-055 132-38-011 132-33-050 132-33-028 132-33-030 132-33-041 132-33-029 132-34-017 132-34-018 132-34-019 132-38-040 132-33-042 132-38-058 132-38-041 132-38-013 132-38-057 132-38-048 132-38-043 132-38-060 132-38-061 132-26-073132-26-074 132-33-008 132-33-007 132-33-006 132-33-005 132-33-004 132-33-003 132-33-002 132-33-001 132-33-024 132-33-023 132-33-022 132-33-021 132-33-020 132-33-019 132-33-018 132-33-017 132-33-059 132-33-026 132-33-027 132-33-044 132-33-045 132-33-046 132-33-047 132-33-048 132-33-049 132-34-064132-26-064132-26-065132-26-072132-26-075 132-26-052 132-33-043 132-25-028 132-25-027 132-25-024 132-25-053 132-25-023 132-25-022 132-25-021132-25-020 132-26-028 132-26-071 132-37-064 132-32-054 132-32-034 132-32-033 132-32-032 132-32-031 132-32-035 132-32-029 132-32-030 132-32-028 132-32-036 132-31-078 132-32-042 132-32-053 132-26-076 132-26-079 132-26-078 132-26-026 132-26-027 132-26-025 132-26-024 132-26-023 132-26-022 132-26-021 132-26-019 132-26-018 132-26-060 132-26-068 132-26-063 132-26-070132-26-010132-26-009132-26-008132-26-007132-26-006132-26-005132-26-004132-26-003132-26-002 132-26-001 132-26-029 132-19-050 132-19-049 132-19-048 132-19-047 132-19-046 132-19-045 132-19-044 132-19-043 132-19-042 132-19-031132-19-030132-19-029 132-26-062 132-18-057 132-18-058 132-58-001132-58-002132-58-003 132-34-020 132-34-001 132-34-002 132-34-003 132-34-062 132-34-061 132-34-059132-34-060 132-34-058 132-34-057 132-34-055132-34-056 132-34-054 132-34-053 132-34-052132-34-063 132-48-006132-48-007132-48-008 132-19-068 132-19-015132-19-016 132-19-032 132-19-033 132-19-034 132-19-035 132-19-064 132-19-065 132-19-066 132-19-041 132-26-061 132-26-013 132-48-009 132-47-030132-47-029 132-48-023 132-48-021132-48-022 132-48-010 132-48-011 132-48-012 132-48-036 132-48-037 132-48-001132-48-002132-48-003132-48-004132-48-005 132-19-014 132-19-067 132-19-059 132-19-056 132-19-058 132-19-057 132-19-060 132-19-061 132-19-063 132-48-015132-48-041 132-48-040 132-48-033 132-48-038 132-48-039 132-27-103 132-27-102 132-27-101 132-27-100 132-27-099 132-27-098 132-27-095132-27-097 132-27-055132-27-052 132-27-053 132-27-054132-27-051132-27-049 132-27-050 132-27-048 132-27-045132-27-046132-27-047 132-27-108 132-48-014 132-27-007132-27-004 132-27-042 132-21-081 132-21-080 132-27-044 132-27-005 132-27-006 132-27-043 132-21-079 132-47-055132-47-056 132-47-054 132-47-053 132-47-052 132-47-051 132-47-050 132-47-032132-47-031 132-48-034 132-48-030132-48-029 132-48-031 132-48-032132-48-028132-48-027132-48-026132-48-024 132-48-025 132-48-018132-48-019132-48-020 132-19-054132-19-053 132-19-055 132-21-082 132-47-019 132-47-018 132-47-012 132-47-058132-47-017132-47-020132-47-021 132-47-049 132-47-048 132-47-047 132-47-046 132-47-043132-47-045 132-47-044 132-47-042132-47-041132-47-039132-47-038132-47-037132-47-036 132-47-036 132-47-035132-47-034132-47-033 132-21-045132-21-043 132-21-042 132-21-041 132-21-040 132-21-039 132-21-001 132-47-011 132-47-040 132-21-046132-21-044 132-21-002 132-21-003 132-21-004 132-15-071 132-47-014132-47-013 132-47-015 132-15-073 132-15-072 132-15-075 132-15-074 132-15-038 132-15-076 132-15-00 132-15-037 132-15-077 132-15-002 132-15-035132-15-036 124-08-084 124-08-042 124-08-075 124-08-076 124-08-046 124-08-047 124-08-072 124-08-053 124-08-074 124-08-055 124-08-041 124-08-040 124-08-038 124-08-037 124-08-056 124-08-057 124-08-058 124-08-059 124-08-060 124-08-073 124-08-035 124-08-034 124-08-033 124-08-032 124-08-031 124-06-015124-06-070 124-09-001 124-09-002 124-09-045 124-09-004 124-09-027 124-09-028 124-09-029 124-09-044 124-09-042 124-09-038 124-09-037 124-09-036 124-09-035 124-09-033 124-09-031 124-09-030 124-09-034 124-09-025 124-13-001 124-08-039 124-08-036 124-02-072 124-02-071 124-08-069 124-08-030 124-08-029124-08-028 124-08-070 124-08-026 124-08-025 124-08-062 124-08-061 124-02-073124-02-074 124-02-031 124-02-032 124-06-018 124-06-017 124-09-006 124-06-013 124-06-012 124-06-011 124-06-010 124-06-009 124-06-008 124-06-007 124-06-067 124-06-066 124-09-005 124-09-007 124-09-007124-09-007 124-09-026 124-09-011 124-09-018 132-02-081 132-02-080 124-14-001 124-14-002 124-14-003 124-14-004 124-14-005 124-14-006 124-14-007 124-14-016 124-14-015 124-14-014124-14-017124-14-018124-14-019124-14-020124-14-021124-14-022 124-14-027 124-14-028 124-14-029 124-14-010 124-14-011124-14-009124-14-008 124-11-068 124-11-072 124-11-071 124-11-070 124-11-069 124-11-052 124-11-083 124-11-051 124-11-050 124-11-049 124-11-048 124-11-047 124-11-035 124-11-034 124-11-033 124-11-038124-11-037 124-11-032 124-11-031 124-11-030 124-11-029 124-11-028 124-11-027 124-11-026 124-11-025 124-11-024124-11-044124-11-043124-11-042 124-11-039 124-11-040124-11-036124-10-014 124-10-015 124-10-016 124-10-017 124-10-013 132-12-049 124-11-041 124-10-053 124-10-054 124-10-058 124-10-051 132-12-051 124-14-050 124-14-024 124-04-029124-04-030124-04-031124-06-005 124-06-004 124-10-001 124-10-002 124-10-003 124-10-004 124-10-043 124-10-044 124-10-045 124-10-009 124-10-006124-10-005 124-10-042 124-10-010 124-10-041 124-10-011 124-10-012124-10-038124-10-039124-10-040 124-10-037 124-09-012 124-11-073 124-11-067124-11-074 124-11-075 124-11-066 124-11-065 124-11-064 124-11-076 124-04-020 124-04-018124-04-019 124-10-008 124-10-007 124-11-077 124-11-079124-11-080124-11-001 124-11-023124-11-045 132-12-002 132-12-003 132-12-004 132-12-005 132-12-024 132-07-033 132-07-031 132-07-027132-07-028 132-07-026 132-07-025 132-07-046 132-07-056 132-07-021 132-07-058 132-07-018132-07-017 132-07-020132-07-019 132-07-048 132-07-054 132-02-087 132-07-055 132-07-057 132-08-024 132-08-025 132-08-031 132-08-030 132-08-029 132-08-109 132-08-110 132-08-002 132-08-003132-08-001 132-08-026 132-08-093 132-08-111 132-08-103 132-07-059132-07-061 132-08-112 132-07-052 132-07-032 124-11-022 124-11-021124-11-081 124-11-019 124-11-018 124-11-017124-11-057124-11-056124-11-053 124-11-055124-11-054 124-11-016124-11-058124-11-059124-11-060124-11-061 132-07-016132-07-060 132-07-012132-07-013132-07-014 132-07-010 132-07-009 132-07-011 132-07-001 132-02-086 132-02-085 132-02-084 132-02-083 132-02-082 132-02-091132-02-092 132-08-004 132-08-007 132-08-104 132-08-008 124-11-062124-11-063124-11-078 132-17-071 132-17-084 132-17-082 132-17-072 132-25-054 132-17-058 132-17-053 132-31-071 132-31-042 132-25-044 132-25-043 132-25-042 132-25-041 132-25-004132-25-052 132-25-001 132-25-002 132-25-050 132-25-049 132-25-047 132-25-048 132-17-080 132-17-059132-17-060 132-17-073 132-17-074 132-17-075 132-17-076 132-17-069 132-17-070 132-25-040 132-25-039 132-25-038132-25-037132-25-036 132-25-035 132-25-034 132-25-033 132-25-011132-25-010132-25-009132-25-008132-25-007132-25-006132-25-005 132-18-073132-18-074132-18-075 132-18-041132-18-040 132-18-077 132-18-091 132-18-092 132-18-093 132-18-094 132-18-095 132-18-076 132-17-079 124-14-066124-14-065124-14-064124-14-063124-14-062124-14-061 124-14-039 124-14-034 124-14-042 124-14-041 124-14-040 124-14-033124-14-032124-14-031 124-14-043 124-14-030 124-14-044124-14-045 124-20-017 124-20-018 124-14-067124-14-068124-14-069124-14-070 124-14-038 124-14-035 124-14-036 124-14-037 132-17-061 132-17-049 132-17-050 132-17-051 132-17-052 132-17-045 132-17-027 132-17-044 132-17-043 132-17-042 132-17-028 132-17-048 124-14-012124-14-013 132-17-029 132-17-030 132-17-031 132-17-032 132-17-041 132-17-033 132-17-039132-17-040 132-17-078 132-17-077 132-17-015 132-17-014132-17-016132-17-019 132-17-007 132-17-008 132-17-018 132-17-006132-17-004 132-17-005 132-17-021132-17-022132-17-023 132-17-003132-17-002 132-17-024 132-17-020 132-17-017 132-17-009 132-17-034 132-12-048 132-12-052 132-12-028 132-12-047 132-12-046 132-12-045 132-12-029 132-12-044 132-12-023 132-12-001 132-18-021132-18-022132-18-023132-18-024 132-18-049 132-18-050 132-18-051 132-18-052 132-18-053 132-18-054 132-18-055 132-18-056 132-18-059132-18-060132-18-061132-18-062132-18-063132-18-064132-18-065132-18-066132-18-067132-18-068132-18-069 132-25-012 132-25-055 132-25-056 132-25-014 132-25-015 132-25-016 132-25-017 132-25-018 132-25-019 132-25-029132-25-030132-25-031132-25-032 132-19-051 132-19-052 132-19-026132-19-025 132-19-027 132-13-039 132-13-040 132-13-041 132-13-052132-13-053 132-13-051132-13-054132-13-055132-13-056132-13-059 132-13-058 132-13-057 132-18-090 132-18-084 132-18-005 132-18-006 132-18-007 132-18-086 132-18-08 6 132-18-035132-18-036132-18-037132-18-038132-18-039 132-18-034 132-18-087 132-18-010 132-18-032 132-18-088 132-18-083 132-18-028132-18-029132-18-031 132-18-027 132-18-026 132-18-015132-18-014 132-18-016 132-18-017 132-18-019132-18-018 132-18-025 132-18-042 132-18-043 132-18-044 132-18-045 132-18-046 132-18-047 132-18-048 132-18-070132-18-071132-18-072 132-19-003132-19-002132-19-001 132-19-022132-19-023132-19-024 132-19-028 132-19-028 132-18-020 132-19-004 132-19-005 132-19-020 132-19-019 132-19-018 132-19-017 132-19-069132-19-010132-19-009132-19-008132-19-007132-19-006 132-19-021 132-14-024 132-14-046 132-14-045 132-14-044 132-14-028132-14-027 132-14-029 132-14-043 132-14-042 132-14-041 132-14-030 132-14-031 132-14-032 132-14-038132-14-039132-14-040132-13-050 132-13-049 132-13-048 132-13-047132-13-046132-13-045132-13-044132-13-043132-13-042 132-13-022 132-13-018132-13-019132-13-021 132-13-020 132-13-016 132-13-017 132-14-026132-14-025 132-14-001 132-14-002 132-14-003 132-14-023 132-14-022 132-14-019132-14-020132-14-021 132-17-011 132-17-013 132-18-085 132-18-089 132-13-076 132-13-077 132-12-034 132-12-041 132-12-040 132-12-036 132-12-037 132-12-038 132-12-039 132-12-035 132-12-042 132-12-033 132-12-043 132-17-012132-17-010 132-13-037 132-13-038 132-13-067 132-13-068 132-13-071 132-13-060132-13-061 132-13-034132-13-033132-13-032 132-13-072 132-13-073 132-13-006 132-13-007 132-13-027132-13-028132-13-029 132-13-030 132-13-069 132-13-070132-12-016 132-12-013 132-12-014 132-12-015 132-13-036132-13-035 132-13-031 132-12-030 132-12-031 132-12-032 132-12-012 132-12-019 132-12-010 132-12-018 132-12-009132-12-008 132-12-020132-12-021 132-12-006 132-12-022 132-12-007 132-12-017 132-12-011 132-08-019 132-08-018 132-08-094 132-08-023 132-08-014 132-08-106 132-08-015 132-08-021 132-08-022 132-08-020 132-13-026 132-13-025 132-13-024 132-13-013132-13-012 132-13-014132-13-011132-13-010132-13-008 132-13-023 132-13-015 132-08-065132-08-066132-08-067132-08-068132-08-069132-08-070132-08-071132-08-072132-08-073132-08-074132-08-075 132-08-057 132-08-058 132-08-059 132-08-060 132-08-061 132-08-062 132-08-063 132-08-064 132-09-045 132-08-044 132-13-009 132-08-076132-08-082132-08-083132-08-102 132-08-101 132-08-088 132-08-091 132-08-092 132-08-095 132-08-079 132-08-056 132-08-036132-08-097 132-08-098132-08-034132-08-108132-08-114132-08-113 132-08-045132-08-046132-08-047132-08-048132-08-049132-08-089132-08-090 132-02-073132-02-074132-02-075 132-08-009 132-08-105 132-08-010 132-08-011 132-08-013 132-14-033 132-14-034 132-14-037 132-14-035 132-14-062 132-14-055 132-14-056 132-14-057 132-14-058132-14-059132-14-060 132-14-017132-14-018 132-14-016 132-14-015 132-14-014 132-14-013 132-14-061 132-14-047132-14-010132-14-009132-14-008132-14-007 132-14-054 132-14-053 132-14-064 132-14-049 132-14-063 132-14-065 132-14-067 132-47-028 132-47-027 132-47-026 132-47-003132-47-002132-47-001 132-47-025 132-47-024 132-47-023 132-47-022 132-47-005132-47-004 132-09-047 132-09-035 132-20-174 132-20-181 132-20-172132-20-175 132-20-173 132-20-171 132-20-170 132-14-006132-14-005132-14-004 132-09-002 132-09-003132-09-001 132-09-022 132-09-023 132-09-021 132-09-020 132-09-019 132-09-018 132-09-031132-09-030132-09-025 132-09-026 132-09-027 132-09-028 132-09-029132-09-024 132-09-046 132-09-044 132-09-043 132-09-042 132-09-041 132-09-038 132-09-037132-09-039132-09-040 132-55- 132-55-009 132-55-007 132-55-006 132-55-005 132-55-004 132-55-003 132-55-002 132-08-042 132-08-041 132-08-039 132-08-040132-08-038132-08-037 132-08-043 132-55-008 132-20-127 132-20-126 132-20-128 132-09-004 132-09-005 132-09-007 132-09-009 132-09-010 132-09-011 132-09-012132-09-013132-09-014132-09-015132-09-016132-09-017 132-09-008 132-09-034132-09-033132-09-032 132-09-036 132-55-001 132-09-006 132-47-010132-47-009132-47-008132-47-007132-47-006 132-20-182 132-20-145 132-20-144 132-20-143132-20-142 132-20-134 132-20-184 132-20-140 132-20-139 132-20-178 132-20-147 132-20-148 132-20-149 132-20-150 132-20-151 132-20-152 132-20-153 132-20-154 132-20-146 132-56-062 132-20-161 132-20-165132-20-166132-20-167 132-20-163 132-20-164 132-20-162 132-20-141 132-20-135 132-20-129 132-20-180 132-15-095 132-15-137 13 132-15-138 132-20-160 132-20-159 132-20-156132-20-155 132-10-045 132-10-00 132-57-044132-57-045132-57-046 132-20-158 132-20-157 132-57-047132-57-048132-56-060132-56-061 132-20-133 132-20-183 132-20-132 132-20-131 132-56-067132-56-068 132-56-065 132-56-071 132-56-070 132-20-125 132-56-072 137-04-001 137-04-002 137-04-003 137-04-004 137-04-005 137-02-023 137-02-086 142-20-008 142-20-009 142-20-010 137-02-019 137-02-020 137-02-091 137-02-024 137-02-016 137-02-029 137-02-030 137-02-031 137-01-108 137-01-097137-01-098137-01-099 137-01-105 137-01-107 137-01-096137-01-095137-01-094137-01-093 137-01-091 137-01-109 137-35-001137-35-002 137-01-141137-01-140 142-20-057 124-33-039 124-33-066 142-20-011 142-20-012 142-20-048 142-20-047 142-20-013 137-01-110 137-01-145 137-01-088 137-01-089 137-01-130 132-36-068 132-36-077 137-01-129 137-01-087 124-32-045 124-32-048124-32-049 124-32-019 137-01-074 137-01-075137-01-125 137-01-113 137-01-070 137-01-069 137-01-143137-01-142 137-01-104 137-01-102 137-01-103 137-01-034 137-01-035 124-32-012 137-01-086 137-01-146137-01-147 124-32-046 124-32-047 137-01-078 137-34-001137-34-002137-34-003137-34-004137-34-005 124-33-056 124-33-047 124-33-046 124-33-065 124-33-043 124-33-035 124-33-036124-33-042 124-33-037 124-33-067 124-33-026 124-33-005 124-33-007 124-33-008 124-33-006 124-33-019 124-33-018 124-33-017 124-33-016 124-33-015 124-32-043 124-32-044 124-33-025 124-33-024 124-33-012 124-33-013 124-33-014 132-50-012 132-50-011 132-50-010 132-50-009 132-50-008 132-50-007 132-50-006132-50-005 132-50-004 132-50-003 132-50-002 132-50-001132-51-001 132-51-013132-51-014 132-51-015 132-51-016 132-51-017 132-51-018 132-51-019132-51-020 132-51-021 132-51-022 132-51-023 132-51-024 132-51-012132-51-011 132-51-010 132-51-009 132-51-008 132-51-007132-51-006132-51-005 132-51-004 132-51-003 132-51-002 124-33-061 124-33-062 132-37-019 132-37-018 132-37-017 132-37-016 132-37-004 132-37-003 132-37-005 132-37-006 132-37-007 132-37-008 132-37-015 132-37-067 132-37-009 132-37-041 132-37-040 132-37-039 132-37-038 132-37-034 132-37-029 132-37-028 132-37-027 132-37-026 132-37-037 132-37-036 132-37-035 132-37-025 132-37-030132-37-052132-37-033132-36-087 132-36-084132-36-031 132-37-056 142-20-080 132-37-063 132-37-062 132-37-061132-37-060 132-37-059 132-37-058 132-36-081 132-36-092 132-36-024 124-33-064 132-54-015 132-54-016 132-54-017132-54-018 132-54-019 132-54-020 132-54-021 132-54-022 132-54-023 132-54-024 132-54-025 132-54-026132-54-027 132-54-028132-54-029 132-54-030 132-54-031132-54-032132-54-033 132-54-014 132-54-013132-54-012132-54-011 132-54-010 132-54-009 132-54-008132-54-007 132-54-006132-54-005 132-54-001 132-54-002 132-54-003132-54-004 132-54-034 132-54-035 132-54-036 132-54-037 132-54-038 132-54-039 132-54-040132-54-041 132-54-042 132-54-043 132-54-044 132-54-045132-54-046132-54-047 132-54-048 132-54-049 132-54-050 132-54-051 132-54-052 132-54-053 132-54-054132-54-055 132-36-075 132-36-094 132-36-093 132-36-074 132-36-015 132-36-069 132-36-070 132-36-020 132-36-025 124-17-071 124-17-072 124-17-073 124-17-074 124-17-075 124-17-076 124-17-077 124-17-078 124-17-041 124-17-040 124-18-001 124-18-003 124-18-004 124-18-006 124-18-008 124-18-010 124-18-036 124-18-037 124-18-040 124-18-041 124-18-007 124-18-005 124-18-042 124-18-043 124-18-044 124-18-047 124-18-046 124-18-045 124-18-048 124-18-009 124-18-032 124-18-053 124-18-052 124-18-051 124-18-050 124-18-049 124-18-100 124-18-055 124-23-063 124-23-062 124-23-061 124-23-060 124-23-059 124-25-024 124-26-007124-26-006 124-26-004 124-26-005 124-27-001 124-27-050 124-23-058 124-18-039124-18-038 124-18-002 124-18-035 124-18-011 124-18-012 124-23-050 124-26-025 124-18-101124-34-001 124-34-002 124-34-003 124-34-004 124-17-044 124-17-088 124-17-089 124-17-084 124-17-064 124-17-067 124-17-068 124-17-069 124-17-070 124-17-066 124-17-045 124-17-065 124-17-043 124-17-042 124-17-063124-17-049 124-17-050 124-17-051 124-17-052 124-17-053 124-17-058 124-17-059 124-17-060 124-17-083 124-17-062 124-17-057 124-17-056124-17-054 124-17-055 124-18-033 124-18-034124-18-013 124-18-014 124-18-104124-18-105 124-18-016 124-08-077 124-08-078 124-17-082 124-17-085 124-17-048 124-19-098 124-19-063 124-19-062 124-19-061 124-19-099 124-19-089 124-19-064 124-19-003 124-19-001 124-19-002 124-19-055 124-19-054 124-19-053 124-19-052 124-19-049 124-19-048 124-19-047 124-19-046 124-19-042 124-19-044 124-19-043124-19-041 124-19-045 124-19-116 124-19-005 124-19-006 124-19-007 124-19-111 124-19-040 124-18-096 124-18-098 124-18-097 124-18-099 124-18-087 124-18-054 124-19-008 124-19-112 124-19-009 124-19-038124-19-010 124-19-031 124-19-034 124-19-033 124-19-032 124-19-030 124-19-035124-19-036 124-19-037 124-19-011 124-19-029 124-19-028 124-18-091 124-18-092 124-18-093 124-18-094 124-18-095 124-18-086 124-18-090 124-18-089 124-19-090 124-19-073 124-19-074 124-19-075 124-19-076 124-19-077 124-19-078 124-19-079 124-19-080 124-19-081 124-19-082 124-19-083 124-19-084124-19-085 124-19-087 124-19-088 124-19-066 124-19-065 124-19-067 124-19-068 124-19-115 124-19-071 124-19-072 124-19-086 124-14-087 124-14-054 124-14-055 124-14-056 124-14-023 124-14-053 124-14-052 124-14-051 124-14-025 124-14-049 124-14-048 124-14-047 124-14-026 124-14-046 124-10-022 124-10-021 124-10-018 124-20-008 124-19-091 124-20-034 124-20-042 124-18-056 124-18-057 124-18-059 124-18-058 124-18-085 124-18-088 124-18-077 124-18-066 124-18-065 124-18-064 124-18-110 124-18-062 124-18-061 124-18-060 124-18-084 124-18-083 124-18-082 124-18-078 124-18-080124-18-081 124-18-079 124-18-031 124-18-027 124-18-028 124-18-029 124-18-030 124-13-027124-13-052 124-19-012 124-19-013 124-19-014 124-19-015 124-19-016 124-19-114 124-19-017 124-19-113 124-19-020124-19-019 124-18-076 124-18-075 124-18-074 124-18-073 124-18-072 124-18-071124-18-069 124-18-070 124-13-043 124-08-051 124-08-050 124-08-049 124-08-048 124-18-025 124-18-024124-18-021124-18-020 124-18-018 124-18-017 124-18-107124-18-106 124-13-029 124-13-031 124-13-033 124-13-034 124-13-036 124-13-035 124-13-038 124-13-039 124-13-040 124-13-049 124-13-054124-13-055 124-13-044 124-13-045 124-13-006124-13-004 124-13-005 124-13-046 124-13-047 124-13-003 124-13-002 124-09-032 124-18-068 124-18-067 124-18-023124-18-022 124-13-030 124-13-007 124-13-010 124-13-032 124-13-008 124-13-048 124-13-050 124-13-051 124-19-027 124-19-026 124-19-025 124-19-024 124-19-023 124-19-022 124-09-014 124-10-046 124-10-047 124-10-028 124-10-030 124-10-056 124-10-027 124-10-057 124-10-060 124-10-025 124-10-024 124-10-059 124-10-036 124-10-035 124-13-053 124-13-015 124-13-025 124-13-024 124-13-059 124-13-026 124-13-019124-13-018 124-13-020 124-13-021 124-13-058 124-13-017124-13-016 124-09-022 124-09-021 124-09-023 124-09-024 124-06-006 124-09-020 124-09-019 124-09-013 124-09-010124-09-009124-09-008 124-09-043 124-10-048 124-10-049 124-13-011 124-13-012 124-13-013 124-13-009 124-09-017 124-10-050 124-31-058 124-31-060 124-31-059 124-31-055 124-31-054 124-31-063 124-31-062 124-31-061 124-31-064 124-31-065 124-31-066 124-31-053 124-31-012 124-31-026 124-31-027 124-31-013 124-31-014 124-31-015 124-31-016 124-31-017 124-31-018 137-01-131137-01-029 137-01-135 124-31-029 124-31-019124-31-021 124-31-020 124-31-022124-31-023124-31-024124-31-025 124-32-010 124-32-011 124-32-022 124-32-021 124-32-016124-32-072 124-31-050 124-31-051 124-31-052 124-31-070 124-31-069 124-31-068 124-31-067 124-31-049 124-31-080 124-31-079124-31-071 124-31-047 124-31-046 124-32-007124-32-027 124-32-026 124-32-028 124-32-029 124-32-030 124-32-031 124-32-050 124-32-025 124-32-071 124-32-009 124-32-020 124-32-013 124-32-060124-32-061124-32-062 124-32-063 124-32-065124-32-064 124-32-068124-32-067124-32-066 124-31-030 124-30-001 124-30-002 124-30-003 124-30-004 124-30-005 124-30-006 124-30-007 124-30-008 124-30-009 124-30-027 124-30-028 124-30-029 124-30-030 124-31-031 124-31-032 124-31-033 124-31-009 124-31-010 124-31-011 124-31-008 124-31-007 124-31-006 124-31-038 124-31-037 124-31-036 124-31-035 124-31-034 124-31-001 124-26-010 124-26-009 124-26-008 124-26-011 124-26-012 124-26-013 124-26-014 124-26-015 124-26-016 124-26-024 124-26-023 124-26-022 124-26-021 124-26-020 124-26-019 124-26-017 124-31-028 124-31-005 124-31-004 124-31-003 124-31-002 124-31-076 124-31-039 124-31-040 124-31-075 124-31-043 124-31-044 124-31-045 124-31-072 124-31-083 124-26-018 124-27-002 124-27-003 124-27-005 124-27-018 124-27-017 124-27-016 124-27-015 124-27-014 124-27-013 124-27-012 124-27-011 124-27-010 124-27-009 124-27-008 124-27-007 124-27-006 124-27-031 124-27-032 124-27-049 124-33-059 124-33-055 124-33-027 124-33-001 124-33-028 124-33-029 124-33-030 124-33-023124-33-022 124-33-021 124-33-020 124-32-051 124-32-035 124-32-036 124-32-037 124-32-038 124-32-039 124-32-052 124-32-053 124-32-054 124-32-055 124-32-040 124-32-041 124-32-042 124-36-036 124-36-037 124-36-038 124-36-039 124-36-040 124-36-017 124-36-018124-36-019 124-36-020124-36-021 124-36-022 124-29-008 124-29-017 132-36-073 132-31-072 132-31-081 132-31-065 132-31-074 124-36-035124-36-034 124-36-033 124-36-032 124-36-031124-36-030 124-36-029124-36-028 124-36-027124-36-026 124-36-025124-36-024 124-36-023 124-36-016 124-36-015 124-36-014124-36-013 124-36-012124-36-001 124-36-002 124-36-003124-36-004 124-36-005 124-36-011 124-36-010124-36-009 124-36-008 124-36-007 124-36-006 124-37-014 124-37-015124-37-036 124-37-059 124-37-016 124-37-013 124-37-035124-37-034124-37-033 124-37-056124-37-057124-37-058 124-37-060124-37-061 124-37-017124-37-018124-37-019124-37-020 124-37-037124-37-038124-37-039124-37-040124-37-041 124-37-055124-37-054124-37-053124-37-052124-37-051 124-37-062 124-37-063124-37-064124-37-065 124-37-012124-37-011124-37-010124-37-009124-37-008124-37-007124-37-006124-37-005124-37-032124-37-031 124-37-030124-37-029 124-37-066124-37-067 124-37-068124-37-069 124-37-050124-37-049124-37-048124-37-047 124-37-042 124-37-043 124-37-044124-37-045124-37-046 124-37-028 124-37-027124-37-026124-37-025 124-37-004 124-37-024 124-37-003124-37-002 124-37-021124-37-022124-37-023 124-37-084124-37-085124-37-083124-37-082124-37-081124-37-080 124-37-070124-37-071124-37-072 124-37-073124-37-074 124-37-075124-37-076124-37-077 124-37-078 124-29-016 124-37-086124-37-079 124-28-009 124-28-010 124-28-011 124-27-027 124-27-028 124-27-029 124-32-056 124-32-033 124-32-034 124-32-005 124-32-004 124-32-003 124-32-002 124-32-001 124-32-032 124-32-006 124-31-042124-31-041 124-28-036 124-28-051 124-28-012 124-28-013 124-28-014 124-28-015 124-28-016 124-28-017 124-28-008 124-28-050 124-28-021 124-28-022 124-28-020 124-28-018 124-28-019 124-28-030 124-28-032 124-28-034124-28-035 124-28-029 124-28-028 124-28-053 124-29-004124-29-005 124-29-007 124-28-003 124-29-022 124-29-021 124-29-002124-29-001 124-28-004 124-28-045 124-28-052 124-28-033 124-28-031 124-28-027 124-27-022124-27-021 124-27-038124-27-039124-27-040124-27-041124-27-042124-27-043124-27-044124-27-045124-27-046124-27-047124-27-048 124-27-023 124-27-024 124-27-025 124-27-026 124-27-030 124-27-037 124-27-036 124-27-035 124-27-034 124-27-033 124-27-004 124-28-001 124-28-024 124-28-023 124-28-002124-27-020124-27-019 124-19-102 124-19-109 124-19-108124-19-110 124-19-056 124-19-059 124-19-058 124-19-057 124-19-107 124-19-106 124-19-105 124-19-104 124-19-103 124-19-101124-19-100 124-19-060 124-19-097 124-19-051 124-19-050 124-28-043 124-29-013 124-29-012 124-29-011 124-29-020 132-31-005 124-20-040 124-29-023 124-29-025 132-31-079 124-20-035124-20-006 124-20-009 124-20-041 124-20-003 124-20-004 124-20-002 124-20-037 124-20-036 124-20-005 124-19-096 124-19-095 124-19-094 124-19-093 124-19-092 124-20-007 124-20-001 124-20-020 124-20-021 124-20-023 124-20-022 124-20-016124-20-015124-20-014 124-20-024 124-20-013 124-20-028 124-20-027 124-20-026 124-20-025124-20-032 124-20-031124-20-033 124-20-030 124-20-029 124-20-011 124-20-012 124-20-019 124-14-085124-14-086 124-14-058 124-14-075 124-14-057 124-14-082 124-14-059 124-14-060 124-14-074 124-14-073 124-14-072 124-14-071 124-14-078 124-14-079 124-14-076 124-14-081 124-14-084124-14-083 124-14-080 124-14-077 137-07-085 137-07-051 137-07-052 137-07-053 137-07-054 137-07-055 137-07-056 137-07-057 137-07-058 137-07-065 137-07-064 137-07-066 137-07-063137-07-062137-07-061137-07-060137-07-059 137-07-069137-07-068137-07-067 137-07-003137-07-002 137-07-021 137-07-022137-07-023 137-07-024 137-07-026 137-07-001 137-07-029 137-07-028 137-07-088 137-07-087137-07-086 137-07-033 137-07-030 137-07-025 137-06-062 137-06-063 137-07-082 137-07-084 137-07-037 137-07-036 137-07-035 137-07-034 137-07-040 137-07-039 137-07-038 137-06-105 137-06-106137-06-104 137-06-108 137-06-107 137-05-074 137-07-047 137-07-048 137-07-049 137-06-053 137-06-055 137-06-054 137-06-056137-06-058 137-06-057 137-07-078137-07-079 137-07-081137-07-080137-07-077 137-06-051 137-06-052137-06-071 137-06-072 137-06-097137-06-098137-06-095137-06-096137-06-094 137-06-085137-06-069137-06-068137-06-067137-06-066 137-06-075 137-06-076 137-06-074 137-06-073 137-06-028 137-06-043 137-06-042 137-06-040 137-06-039 137-06-038 137-06-037 137-06-029 137-06-088137-06-087 137-06-111 137-06-110137-06-109 137-06-093 137-07-075 137-07-076 137-07-072137-07-071 137-07-073 137-07-015 137-07-014 137-07-013 137-07-012 137-07-011 137-07-010137-07-009137-07-008137-07-007137-07-006137-07-005 137-07-074 137-07-018 137-07-017 137-07-016 137-05-066 142-19-017 142-19-005 137-07-004 137-05-073 137-05-076 137-05-075 137-05-072 137-05-071 137-05-070 137-05-069 137-05-068 137-05-067 137-05-065 137-05-064 137-05-083 137-05-082 137-05-081137-05-080137-05-079137-05-078 137-05-037 137-05-038 137-05-036 137-05-039 137-05-040137-05-041 137-05-042 137-05-028 137-05-095137-05-094 137-05-092 137-05-093 137-05-034 137-05-033137-05-035 137-05-032 137-05-031 137-05-030 137-05-029 137-05-025 142-19-009 142-19-018 142-19-007 142-19-006 137-05-043 137-05-045 137-05-089 137-05-088 137-05-046 137-05-047 137-06-079 137-06-078 137-06-032 137-06-077 137-06-030 137-06-031 137-06-036 137-06-035 137-06-034 137-06-023 137-06-025137-06-026137-06-027 137-05-048137-05-049 137-05-097 137-05-051 137-05-053 137-05-052 137-05-054 137-05-055 137-06-103 137-06-102 137-06-049 137-06-050 137-06-022 137-06-048 137-06-099 137-06-100 137-06-101 137-06-047 137-06-092 137-06-091 137-06-081137-06-080137-06-082 137-06-001 137-06-021 137-06-020 137-06-083 137-06-019 137-06-084 137-06-090 137-06-012 137-03-075 137-05-009 137-05-090137-05-091 137-05-017137-05-016 137-05-001 137-05-087 137-05-018 137-05-019 137-05-021137-05-020 137-05-002137-05-003137-05-005137-05-006137-05-007137-05-008137-05-010 137-05-015 137-05-027 137-05-026 137-05-024 137-05-063 137-05-023 137-05-062137-05-061137-05-059 137-05-060137-05-058137-05-057137-05-056 137-04-065 137-03-041 137-03-040 137-03-037137-03-038 137-03-056137-03-055 137-03-039 137-05-011 137-05-012 137-05-013 137-05-014 137-04-058 137-04-055137-04-056137-04-083137-04-084 137-04-064 137-06-011 137-06-010 137-06-008 137-06-007 137-06-006 137-06-005 137-06-004 137-06-089 137-06-015137-06-014137-06-013 137-03-045 137-03-080137-03-079137-03-078137-03-077 137-03-067137-03-068137-03-069137-03-070137-03-071137-03-072 137-03-073 137-03-087 137-03-088 137-06-009 137-33-001 137-33-002 137-33-003 137-33-004 137-33-005 137-04-059 137-04-060 137-03-054 137-03-057 137-03-033 137-03-034 137-03-035 137-03-036137-03-096137-03-044 137-03-082137-03-081 137-03-084137-03-083 137-03-085 137-03-086 137-03-091137-03-090 137-03-061 137-03-062 137-03-063 137-03-064 137-03-065137-03-066 137-03-047 137-03-046 137-03-053 137-03-052137-03-051 137-03-048 137-03-049 137-03-050 137-03-013 137-03-014 137-03-015 137-03-089 137-03-007137-03-008 137-03-018 137-03-019 137-03-020 137-03-021 137-03-022 137-03-023 137-02-088 137-03-012 137-03-009 137-03-011 137-03-010 137-04-063137-04-062137-04-073137-04-072 137-04-030137-04-031137-04-079137-04-080137-04-033137-04-034137-04-035 137-04-070 137-04-037 137-04-036 137-04-044137-04-043137-04-082137-04-081137-04-040137-04-039 137-04-018 137-04-088137-04-011137-04-012 137-04-013 137-04-014 137-04-015 137-03-093 137-03-059137-03-058 137-03-031 137-03-032 137-04-016 137-04-017 137-03-024 137-03-028 137-03-030137-03-029 137-03-025 137-03-027137-03-026 137-03-006 137-03-005 137-03-004 137-03-001 137-03-002 137-03-092 137-02-001 137-02-081 137-02-082 137-02-083137-02-040137-02-041137-02-042 137-02-002 137-02-003 137-02-004 137-02-005 137-02-039 137-02-038 137-02-037 137-02-036 137-02-035 137-02-034 137-02-033 137-02-090 137-02-089 137-02-028137-02-027137-02-026 137-02-006 137-02-025 137-04-087 137-04-074 137-04-007 137-04-006 137-04-025137-04-024137-04-023137-04-022137-04-021137-04-020137-04-019 137-04-045 137-04-046 137-04-027 137-04-026 137-04-047 137-02-073137-02-075 137-02-077 137-02-078 137-02-079 137-02-080 137-02-043 137-02-045 137-02-044 137-02-052 137-02-072 137-02-071 137-02-070 137-02-069 137-02-068 137-02-067 137-02-074 137-02-076 137-02-066137-02-065137-02-093137-02-092 137-02-063 137-02-054 137-02-055 137-02-053 137-02-008 137-02-060 137-02-059 137-02-058 137-02-057 137-02-056 137-02-061 137-02-062 137-01-128 137-01-012 137-01-013 137-01-061137-01-060 137-01-058 137-01-057 137-01-056 137-01-052137-01-053 137-01-123 137-01-059 137-30-005137-30-004 137-30-003 137-30-002137-30-001 137-01-116 124-30-017 137-01-121 137-01-006 137-01-007 137-01-126 137-01-014 137-01-015 137-01-016 137-01-065137-01-064137-01-063137-01-062 137-01-051 137-01-050 137-01-049 137-30-006 137-01-138137-01-137 137-01-136 137-02-007 137-02-013 137-02-012 137-02-011 137-02-010 137-02-009 137-01-100 137-01-031 137-01-042 137-01-039 137-01-043 137-01-044 137-01-048 137-01-047 137-01-046 137-01-045 137-01-134137-01-133 137-01-139 137-36-001 137-36-002 137-36-003137-36-004 137-36-005137-36-006 137-36-007137-36-008 137-01-036 137-02-015137-02-014 137-01-101 137-01-030 137-01-037 137-01-038 137-01-004 137-01-003 137-01-002 124-30-012 124-30-014 124-30-016 124-30-015 137-01-112137-01-024137-01-132 124-35-003124-35-002124-35-001 124-25-045 124-25-044 124-23-006 124-23-007 124-23-008 17 124-23-018 124-23-019 124-23-021124-23-071124-23-073 124-23-020 124-25-007 124-25-060 124-25-059 124-25-052 124-25-054 124-25-055 124-25-057 124-25-058 124-25-043 124-25-042 124-25-041 124-25-040 124-25-009 124-25-011 124-25-012 124-25-013 124-25-014 124-25-015 124-25-039 124-25-038 124-25-037 124-25-036 124-30-040 124-30-045 124-30-047124-25-053 124-25-056 124-25-008 124-25-010 124-30-039 124-30-041 124-30-043 124-30-042 124-30-038 124-30-037124-30-051 124-30-050 124-30-049 124-30-048 124-30-052 124-30-053 124-30-054 124-30-055 124-30-056 124-30-057 124-30-036 124-30-035 124-30-034 124-30-033 124-30-058 124-30-031 124-30-032 124-30-026 124-30-025 124-30-011 124-30-019 124-30-018 124-30-020 124-30-010 124-30-024 124-30-023 124-30-022 124-30-021 124-25-027124-25-021 124-25-018 124-25-019 124-25-020 124-25-026 124-25-025 124-25-017 124-25-016 124-25-028 124-25-029 124-25-030 124-25-031 124-25-032 124-25-033 124-25-034 124-25-035 124-23-032 124-23-035 124-26-003 124-26-002 124-26-001 124-23-034 124-25-022 124-23-033 124-25-023 124-17-039 124-23-0364-23-037 124-23-029 124-23-030 124-23-031124-23-028 124-23-046124-23-045124-23-044124-23-043124-23-0421 124-23-055 124-23-054 124-23-053 124-23-052 124-23-051 124-23-047 124-23-048 -068 124-23-067 124-23-066 124-23-065 124-23-064 124-23-049 142-20-094 142-20-056 142-20-002 142-20-001 142-20-050 142-20-067 142-19-011 142-19-014 142-19-019 142-19-020 142-19-012 142-20-095 137-16-004 137-16-034 142-19-010 142-19-008 142-20-071 137-04-029 137-04-069 137-04-078 137-04-085 137-04-086 137-04-049 137-04-050137-04-052 137-04-051 137-04-068137-04-076 137-04-028 137-05-086 137-05-085 137-05-084 142-20-007 142-20-021 142-20-072 142-20-023 142-20-024 142-20-078 142-20-040 142-20-073 142-20-086 142-20-087 137-16-029 137-16-030 137-16-028 137-16-032 142-20-084 142-20-081 142-20-097 142-20-096 142-18-042 142-18-029 142-18-030 142-18-041 142-18-027 142-18-026 142-18-040 142-17-016 142-17-020 142-18-038 142-18-037 142-18-036 142-18-023 142-18-013 142-18-016 142-18-046 142-18-039 142-17-017 137-16-017 137-16-026 137-16-025 137-16-022 137-16-023 137-16-009 137-16-016 137-16 137-16-005 137-16-008 142-18-007 124-37-088124-37-089124-37-090124-37-091124-37-092124-37-093 124-37-094 124-37-095 124-37-096 124-37-097 124-37-098 124-37-099124-37-100 124-37-101124-37-102 124-37-103124-37-104 124-37-105124-37-106 124-37-107124-37-108 124-37-109124-37-110124-37-111124-37-112124-37-113124-37-114124-37-115 124-37-116 124-37-117 124-37-118 124-37-119 124-37-120 124-37-121 124-37-122124-37-123 124-37-124 124-37-125 124-37-126124-37-127124-37-128124-37-129124-37-130124-37-131124-37-132 124-37-133124-37-134 124-37-135124-37-136124-37-137 124-37-138124-37-139124-37-140 124-37-141124-37-142124-37-143124-37-144124-37-145124-37-146 124-37-147 124-37-148 124-37-149 124-37-150 124-37-151 124-37-152 124-37-153 124-37-154 124-37-155 124-37-156 124-37-157 124-37-158 124-37-159 124-37-160 124-37-161 124-18-111 132-39-089 124-30-059 124-30-060 124-30-061 137-04-093 137-04-092 137-04-095137-04-094 142-20-014 142-20-089 142-20-099 142-20-090 142-20-09 1 142-20-092 142-20-093 142-18-048 137-08-098 137-08-100 132-47-057 124-32-069 124-29-027124-29-026 124-22-046 124-28-054 124-28-055 132-31-080 132-36-096 132-36-097 132-36-098 132-36-099 132-36-100 132-36-101 132-36-102 132-36-103132-36-104 132-36-105 132-36-106 132-36-107 132-36-108 132-36-109 132-36-110 132-36-111 132-36-112 132-36-113 132-36-114 132-36-115 132-36-116 132-36-117 132-36-118 132-36-119 132-36-120 132-36-121 132-36-122 132-36-123 132-36-124 132-36-125 132-36-126 132-36-127 132-36-128132-36-129 132-36-130 137-07-089 124-31-082 124-31-081 124-32-070 124-09-046 124-31-084 132-39-069 132-33-058 137-15-076 137-05-096 132-38-063 132-17-083 124-30-062124-30-063 124-30-064124-30-065 137-01-148 137-01-149 142-21-002 142-21-003 000-00-000 137-38-001 137-38-004 124-08-083 124-19-117 142-27-007 142-27-001 142-27-002 147-27-003 142-27-004 147-27-005 147-27-006 147-27-008 147-27-009 147-27-010 147-27-012147-27-011 147-27-013 147-27-014 147-27-016147-27-015 142-27-017 142-27-018 142-27-019 142-27-020 142-27-021 142-27-022 142-27-023 142-27- 024 142-27-025 142-27-026 142-27-028 142-27-027 142-27-030 142-27-029 142-27-031 142-27-032 142-27-033 142-27-034 142-27-035 142-27-036 142-27-037 142-27-038 142-27-039 124-38-003 124-38-005 124-38-002 124-38-004124-38-001 137-16-033 142-09-010 142-09-010 142-09-010 142-09-009 142-09-009 142-04-006 142-04-025 142-04-025 142-04-002 142-04-003 142-04-024 142-21-037 132-37-068132-37-069132-37-070 132-37-071 E l O r e g A l ma St re e t Loma Verde Avenue Cowper Street Gary Court Waverley Street South Court Bryant Street Ramona Street Alma Street El Carmelo Avenue Dymond Ct Martinsen Ct Kipl C Porter Drive Hillview Avenue Hanover StreetStanford Avenue Amherst Street Columbia Street Bowdoin Street Dartmouth Street Hanover Street College Avenue California Avenue Hanover Street Ramos Way (Private) Page Mill Road Hansen Way Hanover Street Tippawingo St Julie Ct Matadero Avenue LaM Chimalus Drive Matadero Avenue Whitsell Av Fernando Avenue Matadero Avenue Lambert Avenue Hansen Way El Camino Real Margarita Avenue Matadero Avenue Oxford Avenue Harvard Street California Avenue Wellesley Street Princeton Street Oberlin Street Cornell Street Cambridge Avenue College Avenue Williams Street Yale Street Staunton Court Oxford Avenue El Camino Real Park Boulevard Park AvenueSequoia Avenue Mariposa Avenue stilleja Avenue Leland Avenue Stanford Avenue Birch Street Ash Street Lowell Avenue Alma Street Tennyson Avenue Grant Avenue Sheridan Avenue Jacaranda Lane El Camino Real Sherman Avenue Ash Street Page Mill Road Mimosa Lane Chestnut Avenue Portage Avenue Pepper Avenue Olive Avenue Acacia Avenue Emerson Street Park Bo Orind Birch Street Ash Street Page Mill Road Ash Street Park Boulevard College Avenue Cambridge Avenue New Mayfield LaneBirch Street California Avenue Park Boulevard Nogal Lane Rinconada Avenue Santa Rita Avenue Park Boulevard Seale Avenue Washington Avenue Santa Rita Avenue Waverley Stree Bryant Street High Street Emerson Street Colorado Avenue Street Emerson Street Ramona Street Bryant Street South Court El Dorado Avenue Alma Street Alma Street High Street t Emerson Wa v e r l e y O a k s Washin Bryant Street South Court Waverley Street Emerson Street Nevada Avenue North California Avenue Sa Ramona Street High Street North California Avenue Orego n Expressway Ramona Street Colorado Avenue Waverley Street Kipling Street South Court Cowper Street Anton Court Nevada Avenue Seale Avenue Tennyson Avenue Cowper Street Ten Se Sedro Lane Peral Lane Oregon Expressway Sheridan Avenue Page Mill Road CalTrain ROW La Lane 66 Stanford Avenue Olms ted Road El Dorado Avenue Matadero Ave Page Mill Road Chimalus Drive Hanover Street Emma C Abrams Court Way Alvarado Ct Alvarado Row Angell Court yrshire Farm Lane Barnes Court Bowdoin Street Cathcart Way Cedro Way Comstock Circle ackwelder Court Cathcart WayCoronado Avenue Dudl ey L a ne Road Escondido Road Escondido Road Esplanada Way Frenchmans Road ns Court Hulme Court Cour t Lathrop Dr i ve Lat hrop Dr i ve Mayfield Avenue Mayfield Avenue Court Mears Court Mears Court N Tolman Ln Oberlin St Comstock Circle Olmsted Road Olmsted Road Olmsted Road Peter Coutts Circle Peter Coutts Road Peter Coutts Road Pine Hill Court Pine Hi ll Road Raimundo Way Wa y Rosse Lane Running Farm Lane Ryan Court Salvatierra St San Francisco Terrace San Francisco Court San Rafael Pl Santa Fe Avenue Sonoma Ter race Stanford Avenue Court Tolman Drive Wellesley St Yale St treet Alma Street This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend DRAFT HIS on Existing Commercial Zones DRAFT HIS on Existing Residential Transition Zones (SOFA2) DRAFT HIS on Existing Residential Zones Small Lot; Consolidation Opportunity City Jurisdictional Limits abc Quarter Mile Radius from El Camino Real Half Mile Radius from Caltrain Station Caltrain Stations 0'700' DRAFTHousing Inventory Sites (HIS)California AvenueArea Mapv0413 CITY OF PALO ALTOINCORPORATED CALI FORNIA P a l o A l t oT h e C i t y o f APRIL 1 6 1894 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2013 City of Palo Alto rrivera, 2013-04-03 10:36:25 (\\cc-maps\gis$\gis\admin\Personal\rrivera.mdb) 167-10-033 167-10-034 167-10-035 167-10-026 167-10-025 167-10-024 167-10-023 167-10-022167-10-021 167-10-094 167-10-099 167-10-016 167-10-011167-10-012167-10-013167-10-015 167-10-014167-10-017 167-10-018167-10-019167-10-020 167-10-036 167-10-037 167-10-038 167-10-039 167-10-040 167-10-041 167-10-042 167-10-043 167-10-044 167-10-045 167-10-075 167-10-076 167-10-077 167-10-074 167-10-073 167-10-078 167-10-079 167-10-080 167-10-081 167-10-082 167-10-083 167-10-084 167-10-059 167-10-060 167-10-061167-10-062 167-10-063 167-10-064 167-10-065 167-10-066 167-10-067 167-10-068167-10-069 167-10-070 167-10-071 167-10-072 167-10-103 167-10-104 167-10-046 167-10-047 167-10-049 167-10-050 167-10-051 137-18-015 137-18-012 137-18-013 137-18-014 137-18-052 137-18-055 137-18-078137-18-079 137-18-080 137-18-076 137-18-077 137-18-058137-18-059 137-18-060 137-18-063 137-18-065 137-18-064 137-18-062 137-18-056137-18-054137-18-053 137-18-069 137-18-068 137-18-066 137-18-061 137-19-023 137-19-024 137-19-018 137-19-019 137-19-020 137-19-022137-18-057 137-19-021 137-17-026137-17-009 137-17-022 137-18-067 137-19-017 137-18-096 137-18-024 137-18-023 137-18-022 137-18-021 137-18-020 137-18-019 137-18-018 137-18-017 137-18-016 137-18-075 137-18-071 137-18-074 137-18-073 137-18-072 137-18-090 137-18-093 137-18-095 137-18-002 137-18-003 137-18-004 137-18-007 137-18-005 137-18-008 137-18-009 137-18-010 137-18-011 137-18-100 137-18-070 137-18-101 137-18-037 137-17-005 137-17-011 137-18-099 137-18-098 137-18-097 137-17-006 137-17-025 137-17-018 137-18-026 137-18-006 137-19-065 137-19-064 137-19-075 137-19-052 137-19-053 137-19-054 137-19-015 137-19-002 137-19-003 137-19-014 137-19-004 137-19-080 137-19-010 137-19-081 137-19-013 137-19-005 137-19-007 137-19-008 137-19-009 137-19-035 137-19-030 137-19-031 137-19-033 137-19-034 137-19-032 137-19-026 137-19-025 137-18-044 137-18-045 137-19-066 137-20-004137-20-003137-20-002137-20-001 137-19-027 137-19-051 137-19-006 137-19-039 137-19-048 137-19-047 137-19-049 137-19-050 137-19-076 137-19-077 137-18-051 137-18-082 137-18-083 137-18-050 137-18-042 137-18-085 137-18-086 137-18-049 137-18-048 137-18-047 137-18-046 137-14-039 137-20-022 137-20-021 137-20-026 137-20-024 137-20-023 137-20-025 137-20-020137-14-016 137-14-015 137-14-014 137-14-017 137-14-018 137-14-011 137-14-010 137-14-012 137-14-009 137-14-008 137-20-046 137-14-038 137-14-037 137-17-007 137-14-167 137-14-166 137-17-015 137-17-002 137-14-173 137-17-016 137-17-017 137-17-027 137-17-019 137-18-025 137-18-001 137-14-069 137-14-055 137-14-054 137-14-053 137-14-068 137-14-067 137-14-056 137-17-013 137-17-014 137-17-001 137-16-015 137-17-012 137-14-078 137-15-020 137-15-019 137-15-017 137-15-016 137-15-015 137-15-014 137-15-013 137-15-009 137-15-002 137-15-003 137-15-004 137-15-006 137-15-007 137-15-008 137-15-012 137-15-011 137-15-010 137-14-081 137-14-079 137-14-080 137-14-077 137-14-076 137-14-075137-14-074 137-14-073 137-14-179 137-14-071 137-14-070 137-14-066 137-14-065 137-14-064 137-14-063 137-14-062 137-14-061 137-14-057 137-14-098 137-14-099 137-14-100 137-14-101137-14-085 137-14-082 137-14-083 137-14-084 137-14-086 137-14-088 137-15-018 137-14-058 137-14-036 137-14-040 137-14-041 137-14-042 137-14-043 137-14-044 137-14-045 137-14-035 137-14-034 137-14-033 137-14-032 137-14-031 137-14-030 137-14-046 137-14-143 137-14-152 137-14-153 137-14-172 137-14-156 137-14-157137-14-020 137-14-007 137-14-021 137-14-006 137-14-022 137-14-127 137-14-128 137-14-151137-14-150 137-14-168 137-14-004 137-14-169 137-14-003 137-14-025 137-14-060 137-14-059 137-14-165 137-14-164 137-14-162 137-14-163 137-14-109 137-14-108 137-14-107 137-14-106 137-14-105 137-14-104 137-14-103 137-14-102 137-14-129 137-14-155 137-14-142 137-14-136 137-14-176 137-14-141137-14-132 137-14-140137-14-133 137-14-134 137-14-177137-14-135 137-13-074 137-14-048 137-14-026 137-14-027137-14-160 137-14-161 137-14-112 137-13-073 137-14-170 137-13-072 137-13-070 137-14-171 137-13-071 137-14-154 137-14-139 137-19-055 137-19-056 137-19-059137-19-060 137-19-062 137-19-061 137-20-010 137-20-009 137-20-006 137-20-007 137-20-008 137-20-005 137-20-011 137-20-012 137-20-013137-20-014137-20-015137-20-016 137-20-017137-20-018137-20-019 137-20-027 137-20-028 137-20-029 137-20-030 137-20-031 137-20-035137-20-034137-20-033 137-20-039137-20-040 137-20-038 137-20-061 137-27-056 137-27-057 137-27-058 137-27-059 137-27-060 137-27-065 137-27-064 137-27-063 137-27-062 137-27-061 137-27-067 137-27-066 137-27-046 137-27-038137-27-039137-27-040 137-27-044 137-27-042 137-27-041 137-27-043 137-26-013 137-26-012 137-26-011137-26-010 137-26-038 137-26-113 137-26-115137-26-116 137-26-032 137-20-032 137-20-036 137-19-057 137-19-046 137-20-057 137-19-058 137-19-045 137-21-034 137-21-033 137-21-004 137-21-003 137-21-002 137-21-001 137-20-045 137-20-042 137-20-043 137-20-044 137-20-047 137-20-050 137-20-062 137-20-049 137-20-048 137-14-124 137-14-123 137-14-122 137-14-146 137-14-145 137-14-144 137-14-028 137-13-088 137-13-114 137-13-113 137-13-090 137-13-091 137-13-092 137-13-093 137-13-068 137-13-069 137-13-115 137-13-116 137-13-112 137-13-111 137-13-155 137-21-064 137-21-062 137-21-063 137-21-065 137-21-066 137-21-067 137-21-068 137-21-069 137-21-070 137-21-083 137-21-084 137-21-085 137-21-086 137-21-087 137-21-088 137-21-041 137-21-042 137-21-054 137-21-061 137-21-035 137-21-036 137-21-059 137-21-060 137-21-058 137-21-040 137-21-039 137-21-038 137-21-037 137-21-057 137-21-056 137-21-055 137-21-046 137-21-045 137-21-044 137-21-043 137-21-053 137-21-052 137-21-051 137-21-050 137-21-023 137-21-022 137-21-010 137-21-011 137-21-009 137-21-027 137-21-007 137-21-028 137-21-008 137-21-024 137-21-025 137-21-026 137-21-006 137-21-029 137-21-032 137-21-031 137-21-030137-21-005 137-20-041 137-22-001 137-22-002 137-20-052 137-20-053 137-20-054 137-20-055 137-20-056 137-13-109 137-21-048137-21-047 137-13-154 137-27-075 137-27-082 137-27-074 137-27-073 137-28-037 137-27-114 137-27-071 137-28-036 137-28-001 137-28-028137-28-029 137-28-030 137-28-031 137-28-032 137-28-033 137-28-034 137-28-035 137-28-049 137-28-048 137-28-047 137-28-046 137-28-045 137-28-044 137-28-043 137-28-042 137-28-041 137-28-040 137-28-039 137-28-038 142-17-032 137-27-070 137-27-069 137-27-068 137-27-076 137-27-077 137-19-037137-19-036 137-19-044 137-19-072 137-19-069 137-19-043 137-19-071 137-19-029 137-19-028 137-29-001 137-28-027 137-28-026 137-28-025 137-28-024 137-28-023 137-28-022 137-28-021 137-28-020 137-28-014 137-28-013 137-28-012 137-28-011 137-28-010 137-28-009 137-28-008 137-28-007 137-28-004 137-28-003 137-27-094 137-27-093 137-27-092 137-27-107 137-27-106 137-27-105 137-27-104 137-27-091 137-27-111 137-27-110 137-27-109 137-27-108 137-27-090 137-29-002 137-29-003 137-29-004 137-29-005 137-29-006 137-29-007 137-29-008 137-29-009 137-29-010 137-29-028 137-29-047 137-29-046 137-29-045 137-29-044 137-29-043 137-29-042 137-29-036 137-29-037 137-29-035 137-29-030 137-29-029 137-29-041 137-29-040 137-29-039 137-29-038 137-28-050 137-28-002 137-27-133 137-27-087 137-27-084 137-27-132 137-27-126 137-27-027 137-27-026 137-27-025 137-27-112 137-27-113 137-27-083 137-27-089 137-27-081 137-27-078 137-27-049 137-27-050137-27-051 137-27-055 137-27-054 137-27-085 137-27-086 137-27-115 137-27-079 137-27-080 137-27-103 137-27-102 137-27-101 137-27-100 137-27-099 137-27-097 137-27-096 137-27-095 137-27-098 137-27-021 137-27-022 137-27-020 137-27-019 137-28-015 137-28-016 137-28-017 137-28-018 137-28-019 167-05-021 167-05-022 167-05-025 167-05-026 167-04-014 167-04-013 167-05-020 137-27-053 137-27-052 137-27-047 137-27-117 137-27-037 137-27-024 137-27-023 137-27-130 137-27-016137-27-015 137-27-014 137-27-013 137-27-127 137-27-033 137-27-034 137-27-120 137-27-036 137-27-121 137-26-045 137-26-096 137-26-044 137-26-111 137-26-110 137-26-082 137-26-083 137-26-040 137-26-039 137-26-035 137-26-034 137-27-032 137-27-116 137-27-031 137-27-012 137-27-011 137-27-045 137-27-088 137-27-017 137-27-010 137-26-043 137-27-009 167-05-024 167-05-023 167-05-031 167-05-028 167-05-003 167-05-030 167-05-007 167-05-008 167-05-009 167-05-010 167-05-006 167-05-011 167-05-012 167-05-013 167-05-014 167-05-015 167-05-016 167-05-018 167-05-017 167-06-008 167-06-007 167-06-006 167-06-005 167-06-004 167-06-003 167-06-002 167-06-001 167-06-049 167-06-038 167-06-039 167-06-040 167-06-044 167-06-045 167-06-048 167-06-047 167-06-046 167-06-062 167-06-052 167-06-053 167-06-054 167-06-055 167-06-057 167-06-056 167-05-005 167-06-059 167-06-058 137-27-131 137-27-004 137-27-008 137-27-007 137-27-006 137-27-005 137-26-069 137-26-066 137-26-068 137-26-065 137-26-063 137-26-062 137-26-061 137-26-059 137-26-060 137-26-064 137-26-049 137-26-050 137-26-051 137-26-052 137-26-053 137-26-048 137-26-046 137-26-090 137-26-103 137-26-106 137-26-107 137-26-108 137-26-109 137-26-104 167-06-026 167-06-027 167-06-012 167-06-013 167-06-060 167-06-061 167-06-009 167-06-010 167-06-011 167-06-016 137-27-118 137-27-003 137-27-119 137-26-097137-26-102 137-26-091 137-26-105 167-06-041 167-06-042 167-06-043 167-06-037 167-06-028 167-06-029 167-06-030 167-06-031 167-06-025 167-06-024 167-06-035167-06-034167-06-033 167-06-032 167-07-029 167-07-030 167-07-031 167-07-008 167-07-007 167-07-006 167-07-005 167-07-004 167-07-003 167-07-002 167-07-001 167-06-036 167-06-020 167-06-019 167-06-018 167-06-017 167-06-022 167-06-023 167-06-021 167-07-064 167-07-065 167-07-066 167-07-067 167-07-068 167-07-069 167-07-039 167-07-038 167-07-040167-07-041167-07-042167-07-043167-07-044167-07-045167-07-046167-07-047167-07-061 167-07-015 167-07-016 167-07-018 167-07-019 167-07-020 167-07-021 167-07-022 167-07-023 167-07-024 167-07-025 167-07-026 167-07-027 167-07-028 167-07-017 167-07-032 167-07-033 167-07-034 167-07-035 167-07-092 167-07-085167-07-084 167-07-087 167-07-086 167-07-073167-07-074167-07-075 167-07-093 167-07-094 167-07-095 167-07-097 167-07-096 167-07-098 167-07-099 167-07-072 167-07-014 167-07-012 167-07-011 167-07-010 167-07-009 167-08-001 167-07-013 137-26-018 137-26-020 137-26-019 137-26-017 137-26-016 137-26-015 137-26-014 137-26-022 137-26-023 137-26-024 137-26-028 137-26-027 137-26-026 137-26-025 137-26-029 137-26-030 137-26-001137-26-002 137-26-003 137-26-004 137-26-008 137-26-007 137-26-006 137-26-005 137-26-009 137-26-036 137-25-088 137-25-063 137-25-065 137-25-066 137-25-067 137-26-033 137-26-031 137-26-080 137-26-021 137-25-068 137-21-071 137-21-072 137-21-080 137-21-081 137-21-082 137-22-005 137-22-004 137-22-003 137-25-062 137-22-049 137-21-073 137-21-078 137-21-079 137-22-048 137-22-047 137-22-046 137-22-061137-22-060137-22-059 137-22-058137-22-057 137-22-051 137-22-050 137-22-030 137-22-018 137-22-017 137-22-016 137-22-015 137-22-014 137-22-013 137-22-012 137-22-011 137-22-010 137-22-009 137-22-008 137-22-007 137-22-006 137-25-064 137-25-072 137-25-073 137-25-074 137-25-075 137-25-076 137-25-077 137-25-046 137-25-048 137-25-047 137-25-049 137-25-050 137-25-056 137-25-061 137-25-060 137-25-059 137-25-058 137-25-057 137-25-055 137-25-053 137-25-052 137-25-051 137-25-054 137-21-074 137-21-077 137-21-075 137-21-076 167-07-063 167-07-048 167-07-060 167-07-049 167-07-050 167-07-051 167-07-059 167-07-058 167-07-091 167-07-057 167-07-056 167-07-055 167-07-054 167-07-089 167-07-082167-07-081167-07-080 167-07-079 167-07-083167-07-078 167-07-076167-07-077 167-08-030 167-08-036 167-08-032 167-08-031 167-08-038 167-08-007 167-08-006 167-08-005 167-08-004 167-08-003 167-08-002 137-25-106 137-25-109 167-07-062 137-22-022 137-22-021 137-22-020 137-22-019 137-25-085 137-25-086 137-25-087 137-25-084 137-25-069 137-25-078 137-25-079 137-25-080 137-25-081 137-25-082 137-25-083 137-25-044 137-25-043 137-25-042 137-25-041 137-25-040 137-25-039 137-25-038 137-25-125 137-25-124 137-25-123137-25-122 137-25-120 137-25-119 137-25-118 137-25-117 137-25-090 137-25-045 137-25-029 137-25-030 137-25-031 137-25-108 137-25-070 137-25-071 137-25-110 137-25-112 137-25-098 137-25-099 137-25-018 137-25-017 137-25-100 137-25-096 137-25-095 137-25-094137-25-008 137-25-007 137-25-006 137-25-005 137-25-034 137-25-033 137-25-032 137-25-010 137-25-011 137-25-012 137-25-013 137-25-014 137-25-015 137-25-016 137-25-114 137-25-113 167-08-011 167-08-028 167-08-035 167-08-039 167-08-040 167-08-037 167-08-010 137-25-093 137-25-127 137-25-126 137-24-015 137-24-029 137-24-019 137-24-022 137-24-035137-24-036137-24-037 137-24-038 137-24-039 137-24-040 137-24-041 137-24-042 132-46-068 132-46-069 132-46-070 132-46-072 132-46-065 132-46-066 132-46-022 132-46-021132-46-020 148-01-001 132-62-051 132-46-119 132-46-120 132-61-001 132-61-002 132-61-003 132-61-004 132-61-005 132-61-006 132-61-007 132-61-008 137-14-118 137-16-031 137-14-091 137-14-093 137-14-090 137-15-022 137-15-025 137-15-029 137-15-028 137-15-027 137-15-026 137-15-021 137-14-094 137-14-095 137-14-096 137-14-097 137-14-087 137-14-089 137-15-001 137-15-005 137-14-175137-14-174 137-15-066 137-15-065 137-15-064 137-15-063 137-15-045 137-15-067 137-13-132 137-13-131 137-15-035 137-13-118 137-13-117 137-13-020 137-13-019 137-15-023 137-15-024 137-15-034 137-15-033 137-15-032 137-15-031 137-15-030 137-13-022 137-13-023 137-13-024 137-13-026 137-10-036 137-10-033 137-10-034 137-10-035 137-13-025 137-13-078 137-13-075 137-13-017 137-13-016 137-13-015 137-13-014 137-13-013 137-13-012 137-13-011 137-13-010 137-13-032 137-13-029 137-13-030 137-13-031 137-13-028 137-13-027 137-13-076 137-13-077 137-13-137 137-13-138 137-09-029 137-09-032 137-09-062 137-09-061 137-09-033 137-09-034 137-09-060 137-09-035 137-09-059 137-09-036 137-09-058 137-09-057 137-09-056 137-10-029 137-10-007 137-10-006 137-10-005 137-09-030 137-09-031 137-09-028 137-15-053 137-15-054 137-15-055 137-15-056 137-15-057 137-15-058 137-15-052 137-15-075 137-15-051 137-15-040 137-15-050 137-15-041 137-15-049 137-15-042 137-15-069 137-15-070137-15-072 137-10-002 137-15-068 137-15-073 137-15-074 137-15-044 137-15-047 137-15-046 137-15-059 137-15-060 137-15-061 137-15-062 137-10-120 137-10-121 137-10-003 137-10-073 137-10-072 137-10-037 137-10-038 137-10-039 137-10-040 137-10-032137-10-031137-10-030 137-10-028 137-10-027 137-10-026 137-10-025 137-10-024 137-10-023 137-10-022 137-10-010 137-10-009 137-10-008 137-10-125 137-10-011 137-10-013 137-09-017 137-09-016 137-10-019 137-10-020 137-10-021 137-09-018 137-09-019 137-09-020 137-09-021 137-09-022 137-09-024 137-09-023 137-09-069 137-09-071 137-09-068 137-09-063 137-09-064 137-09-053 137-09-054 137-09-055137-09-039 137-09-038 137-09-037 137-09-073 137-09-074 137-09-027 137-10-015 137-10-016 137-09-044 137-09-043 137-09-042 137-09-065 137-09-041 137-09-040 137-09-048 137-09-049 137-09-050 137-10-014 137-10-128 137-13-038 137-13-037 137-10-041 137-10-042 137-10-067 137-10-068 137-10-069 137-10-070 137-10-071 137-10-081 137-10-080 137-10-079 137-10-078 137-10-077 137-10-076 137-10-075 137-10-074 137-10-093 137-10-092 137-10-091 137-10-090 137-10-089 137-10-088 137-10-087 137-13-130 137-12-022 137-13-129 137-13-128 137-13-001 137-13-042 137-13-143 137-13-142 137-13-040 137-13-039 137-13-151137-13-150 137-13-141 137-13-140 137-13-033 137-13-034 137-13-035137-13-036 137-13-007 137-13-008 137-13-009 137-10-086 137-10-085 137-10-059 137-10-122 137-10-058 137-10-051 137-10-052 137-10-054 137-10-130 137-10-113 137-09-004 137-10-062 137-10-114 137-10-126 137-10-048 137-10-047 137-10-045 137-10-046 137-10-063 137-10-064 137-10-065 137-10-044 137-10-043 137-10-066 137-10-094 137-10-129 137-10-127 137-10-123 137-10-124 137-08-101 137-08-049137-08-050 137-12-024 137-12-025 137-10-083 137-10-082 137-12-029 137-12-028 137-12-027 137-12-026 137-12-023 137-12-032 137-08-074 137-08-044 137-08-045 137-08-073 137-10-100 137-10-099 137-10-098 137-10-097 137-10-096 137-10-133 137-10-112 137-10-110 137-10-108 137-10-107 137-10-134 137-10-101 137-10-102 137-10-103 137-10-104 137-10-105 137-10-084 137-08-076 137-10-109 137-13-006 137-13-080 137-13-079 137-13-052 137-13-053 137-13-054 137-13-055 137-13-056 137-13-082 137-13-084 137-13-083 137-13-051 137-13-050 137-13-049 137-13-086 137-13-085 137-13-048 137-13-047 137-13-157 137-13-063 137-13-147 137-13-149137-13-148 137-13-065 137-13-044 137-13-045 137-13-046 137-13-081 137-13-066 137-13-067 137-21-012 137-21-013 137-21-014 137-21-021 137-21-020 137-21-019 137-21-018137-21-017 137-21-016 137-21-015 137-22-053 137-22-073 137-22-074 137-22-075 137-13-095 137-13-096 137-13-106 137-13-105 137-13-097 137-13-098 137-13-061 137-13-060 137-13-059 137-12-010 137-12-074 137-12-073 137-12-008 137-12-006 137-12-068 137-12-003 137-12-004 137-12-002 137-13-058 137-13-144137-13-135 137-13-133 137-13-099 137-13-103137-13-102 137-12-001 137-13-094 137-13-153 137-13-152 137-13-107 137-12-069 137-13-057 137-12-036 137-12-037 137-12-038 137-12-039 137-12-040 137-12-033 137-12-035137-12-034 137-11-025 137-11-024 137-11-023 137-11-022 137-11-021 137-11-026 137-13-005 137-12-021 137-12-020 137-12-019 137-12-018 137-12-017 137-12-016 137-12-015 137-12-014 137-12-011137-12-012 137-12-013 137-13-003 137-13-004 137-13-087 137-12-030 137-12-031 137-11-030 137-11-031 137-11-020 137-11-029 137-11-027 137-08-042 137-08-043 137-11-049 137-11-048 137-11-014137-11-008137-11-007 137-11-009 137-11-010 137-11-011 137-11-012 137-11-013 137-11-005 137-11-004 137-11-003 137-11-002 137-11-001 137-11-032 137-11-033 137-11-034 137-11-006 137-11-028 137-11-084137-11-087137-11-083137-11-082137-11-081137-11-077 137-11-095137-11-094 137-11-089137-11-075 137-11-016 137-11-042 137-11-039 137-11-044137-11-046 137-11-045137-11-047 137-11-019 137-12-061 137-12-062 137-12-063 137-12-064 137-12-065 137-12-066 137-12-067 137-11-040 137-12-076 137-12-055 137-12-056 137-12-057 137-12-058 137-12-059 137-12-060 137-12-041 137-12-051 137-12-050 137-12-049 137-12-048 137-12-047 137-12-052 137-12-075 137-11-043 137-11-097 137-11-096 137-12-044 137-11-038 137-11-099 137-11-100 137-12-071 137-12-042 137-12-043 137-12-072142-20-098 137-09-015 137-09-014 137-09-013 137-09-012 137-09-011 137-09-067 137-09-066 137-09-001137-09-002 137-09-009 137-09-008 137-09-007 137-09-006 137-10-053 137-08-085 137-08-053 137-08-054 137-09-003 137-08-095137-08-096 137-09-072 137-09-005 137-10-018 137-08-014 137-08-013 137-08-064 137-08-010 137-08-052 137-08-089 137-08-029 137-08-077 137-08-070 137-08-069 137-08-081 137-08-090 132-38-035 132-38-066 132-38-032 132-38-042 132-38-025 132-38-026 132-38-047 132-38-017 132-38-018 132-38-022 132-38-019132-38-020132-38-021 132-39-090 132-39-059 132-39-074 132-39-005 132-39-071 137-08-058 137-08-059 137-08-060 137-08-055 137-08-062 142-20-055 142-20-054 142-20-046 137-08-057 137-08-086 137-08-061 132-39-017 132-39-018 132-38-056 142-20-035 142-20-079 132-39-087 142-20-037 132-39-080 137-08-084 137-08-006 132-40-019 132-40-056 132-40-060 132-40-063 132-39-078132-39-077132-39-079 137-08-007 137-08-080 137-08-079 137-08-016 137-08-092 137-08-091 132-39-055 137-08-083 132-40-061 137-08-072 137-08-088 132-33-038 132-33-037 132-33-056132-33-039 132-33-051 132-33-052 132-33-031 132-33-034 132-39-083 132-39-049 132-39-048 132-39-047 132-39-043 132-39-042 132-39-041 132-39-040 132-39-039 132-39-038 132-39-037 132-39-035 132-39-036 132-39-050 132-39-051 132-39-052 132-39-053 132-39-034 132-39-033 132-39-031 132-39-024 132-39-025 132-39-026 132-39-081132-39-082 132-39-084 132-39-030 132-33-055 132-33-057 132-33-032 132-39-054 132-39-065 132-33-033 132-39-075 132-39-032 137-08-078 137-08-031 137-08-030 137-08-033 137-08-032 137-11-078 137-11-051137-11-052137-11-053 137-08-041 137-08-040 137-08-039 137-08-038 137-08-037 137-08-097 132-41-089 132-41-072 132-41-027 132-41-091132-41-025 132-41-096 132-41-048 132-41-028 132-35-045 132-41-020 132-41-083 137-11-074 137-11-098137-11-079137-11-093 137-11-050 132-41-088 132-41-085 132-41-084 137-11-015 137-11-041 132-40-046 132-40-047 132-40-048 132-40-049 132-40-005 132-40-006 132-40-007 132-40-008 132-40-009 132-40-010 132-40-011 132-40-012 132-40-023 132-40-058 132-40-045 132-40-044 132-40-038 132-40-039 132-40-022 132-40-021 132-40-020 132-40-062 132-40-059 132-40-037 132-40-036 132-40-035 132-40-050 132-40-051 132-40-052 132-40-028 132-40-001 132-40-002 132-40-003 132-40-004 132-40-024 132-40-025 132-40-026 132-34-032 132-34-036 132-34-035 132-34-034 132-34-033132-34-010 132-34-009 132-34-008 132-34-007 132-34-006 132-34-005 132-34-004 132-34-016 132-34-015 132-34-014 132-34-013 132-34-012 132-34-011 132-39-046 132-39-044 132-39-045 132-40-027 132-40-029 132-40-055 132-35-019 132-41-019 132-35-026 132-35-025 132-35-024 132-41-016 132-41-017 132-41-029 132-41-018 132-41-078 132-41-011 132-41-010 132-41-009 132-41-070 132-35-027 132-35-028 132-35-029 132-35-030 132-35-031 132-35-032 132-35-033 132-35-048 132-35-049 132-35-035 132-35-036 132-35-037 132-40-034 132-40-033 132-40-032 132-40-031 132-40-030 132-40-053 132-40-054 132-34-047132-34-048132-34-049132-34-050132-34-051 132-34-023 132-34-024 132-34-031 132-34-030 132-34-029 132-34-028 132-34-027 132-34-026 132-34-025 132-34-022132-34-021 132-34-040 132-34-039 132-34-038 132-34-037 132-34-046 132-34-045 132-34-044 132-34-043 132-34-042 132-34-041 132-35-008 132-35-012 132-35-013 132-35-014 132-35-015 132-35-016 132-35-017 132-35-007 132-35-006 132-35-005 132-35-004 132-35-003 132-35-002 132-35-018 132-35-020 132-35-001 132-35-009 132-35-043 132-35-038 132-35-039 132-35-040 132-35-041 132-35-042 132-35-010 132-35-011 132-41-007 137-22-056137-22-055137-22-054 137-22-052 137-22-037 137-22-072 137-22-071 137-22-069 137-22-070 137-21-049 137-22-023 137-22-045 137-22-032 137-22-031 137-32-011 137-32-010 137-32-009 137-32-008 137-32-007 137-32-006 137-32-005 137-32-004 137-32-003 137-32-002 137-32-001 137-32-022 137-32-021 137-32-020 137-32-019 137-32-018 137-32-017 137-32-016 137-32-015 137-32-014 137-32-013 137-32-012 137-32-033137-32-032137-32-031 137-32-030 137-32-029 137-32-028137-32-027 137-32-026137-32-025137-32-024 137-32-023 137-32-065 137-32-064 137-32-063 137-32-062 137-32-061 137-32-060 137-32-059 137-32-058 137-32-057 137-32-055 137-32-054 137-32-053 137-32-052 137-32-051 137-32-050 137-32-049 137-32-048 137-32-047137-32-046 137-32-045137-32-044 137-32-043137-32-042 137-32-041137-32-040 137-32-039 137-32-038137-32-037 137-32-036 137-32-035137-32-034 137-32-056 137-31-004 137-31-005 137-31-017137-31-016 137-31-015 137-31-014 137-31-006137-31-007 137-31-009 137-31-010137-31-011 137-31-018 137-31-019 137-22-033137-22-034137-22-035 137-22-036 137-22-044137-22-043137-22-042 137-22-041137-22-040137-22-039137-22-038 137-22-062 137-22-064137-22-065137-22-067 137-22-066 137-22-063 137-22-028137-22-029 137-31-026 137-31-025 137-31-013 137-31-012 137-31-001137-31-002 137-31-008 137-31-024 137-31-023137-31-022137-31-021 137-31-020 137-22-027 137-22-026 137-22-025 137-22-024 137-23-066 137-23-067 137-23-065 137-23-064 137-23-063 137-23-056 137-23-057 137-23-058 137-23-059 137-23-060 137-23-061 137-23-062 137-23-049 137-23-050 137-23-051 137-23-052 137-23-053137-23-055 137-23-054 137-23-048 137-22-068 137-22-078 137-22-077 137-22-076 132-42-069 137-11-091 137-23-073 137-11-071 137-11-080137-11-085 137-23-047 137-23-042137-23-043137-23-044137-23-045137-23-046 132-42-074 132-42-067 132-42-070132-42-068 137-23-068 137-23-072 137-23-039 137-23-035137-23-036137-23-037137-23-038 137-23-071137-23-069 137-23-070137-23-040 137-23-041 132-43-164 132-43-163 132-43-162 132-43-161 132-43-160 132-43-159 132-43-158 132-43-157 132-43-156 132-43-120 132-43-149 132-43-139 132-43-141 132-46-107 132-43-134 137-23-022 137-23-025 132-43-154 132-43-052 132-43-051 132-43-165 132-43-166 132-43-167 132-43-168 132-43-169 132-43-170 132-43-171 132-43-172 132-43-173 132-43-174 132-46-109 137-24-034 132-46-102 132-46-063 132-46-025 132-46-024 132-46-015 132-46-018 132-46-016132-46-011 132-46-013 132-46-014 132-46-077 132-46-019 132-46-010 132-46-009 132-46-006 132-46-007 132-46-008 132-46-005 132-46-004 132-46-079 132-46-078 132-46-026 132-45-049 132-60-027132-60-026132-60-025132-60-024132-60-023132-60-022 132-60-021132-60-020132-60-019132-60-018 132-60-017132-60-016132-60-015132-60-014132-60-013132-60-012132-60-011132-60-010 132-60-009132-60-008132-60-007132-60-006132-60-005132-60-004132-60-003132-60-002132-60-001 132-60-028132-60-029 132-60-030132-60-031 132-60-032 132-60-033 132-60-034 132-60-035 132-60-036132-60-037 132-60-038132-60-039132-60-040132-60-041132-60-042132-60-043 132-60-044132-60-045132-60-046132-60-047132-60-048 132-60-049132-60-050132-60-051132-60-052 132-60-053132-60-054 132-62-001132-62-002132-62-003132-62-004132-62-005 132-62-006132-62-007 132-62-009 132-62-010 132-62-020 132-62-050 132-62-049 132-62-048 132-62-047 132-62-046132-62-045 132-62-044 132-62-043 132-62-042 132-62-041 132-62-040 132-62-039 132-62-038132-62-037132-62-036 132-62-035 132-62-034 132-62-033 132-62-032 132-62-031 132-62-030 132-62-029 132-62-028 132-62-027 132-62-026 132-62-025 132-62-024132-62-023132-62-022132-62-021 132-62-019 132-62-018132-62-017132-62-016132-62-015 132-62-008 132-62-014 132-62-013 132-62-012 132-62-011 132-46-115 132-46-116 132-46-100 132-44-100 132-46-105 132-46-090 132-46-103 132-44-010 132-44-012 132-44-022132-43-153 132-46-104 132-46-106 132-44-090 132-53-011 132-53-010 132-53-009 132-53-008 132-53-007 132-53-006132-53-005132-53-004132-53-003132-53-002132-53-001 132-43-062 132-43-121 132-43-175 132-43-176 132-43-146 132-43-103 132-43-102 132-43-114 132-43-101 132-43-100 132-43-061 132-43-105 132-43-104132-43-106 132-43-143 132-43-111132-43-110132-43-116132-43-109132-43-108132-43-115 132-43-118 132-43-112 132-43-117 132-43-060 132-43-054 132-43-055 132-43-056 132-43-057 132-43-058 132-43-059 132-43-050 132-43-041 132-43-039132-43-040 132-43-063 132-43-064 132-43-065 132-43-066 132-43-142 132-44-096 132-44-099 132-44-061 132-44-060 132-44-059 132-44-093 132-46-082 132-46-081 132-46-080 132-44-109132-44-108 132-44-081 132-44-083 132-44-082132-44-088 132-46-012 132-46-003 132-46-002132-46-001 132-44-084 132-44-076 132-44-077 132-44-078 132-44-079 132-44-075 132-44-080 132-45-029 132-45-028 132-45-027 132-45-026 132-45-045 132-45-044 132-45-046132-45-047132-45-048132-45-025 132-45-022 132-45-021 132-45-020 132-45-019 132-45-018 132-45-017 132-45-016 132-45-023132-45-024 132-44-073 132-44-072 132-44-071 132-44-070 132-44-069 132-44-086132-44-066 132-44-065 132-44-064 132-44-087 132-44-043 132-44-044 132-44-047 132-44-048 132-44-046 132-44-045 132-44-049 132-44-057 132-44-058 132-44-052 132-44-053 132-44-054 132-44-056 132-44-055 132-44-029132-44-030132-44-031132-44-041 132-44-032132-44-033132-44-034132-44-035132-44-036132-44-037132-44-038132-44-039132-44-040 132-29-061 132-29-062 132-29-064132-29-063 132-43-038 132-43-032 132-43-033 132-43-037 132-43-036 132-43-035 132-43-034 132-44-068132-44-074 132-44-085 132-43-125 132-44-050 132-44-051 132-44-067 132-42-011132-42-010132-42-009 132-42-006 132-42-073 132-42-072 132-42-082 132-41-042 132-41-043 132-41-067 132-41-058 132-41-060 132-41-061 132-41-059 132-41-086 132-41-031 132-41-030 132-41-047 132-52-016132-52-015 132-52-014132-52-013 132-52-012132-52-011 132-52-010132-52-009 132-52-001132-52-002132-52-003132-52-004132-52-005132-52-006132-52-007132-52-008 132-41-069 132-59-002132-59-001 132-59-005132-59-003132-59-004 132-27-062 132-27-110132-27-111132-27-092 132-27-107 132-27-104 132-27-112 132-27-114 132-41-005 132-41-073 132-41-092132-41-093132-41-003132-41-002 132-41-036 132-41-076132-41-001 132-41-032 132-41-074 132-41-064 132-41-068 132-41-090 132-42-032 132-42-020 132-42-018132-42-019 132-42-017 132-42-016 132-42-015 132-42-013132-42-012 132-43-022 132-43-021 132-43-020 132-43-019 132-43-018 132-43-048 132-43-049 132-43-047 132-42-058 132-43-016132-42-080 132-42-051 132-42-052 132-42-081 132-43-017 132-42-077 132-43-123 132-43-124 132-43-042132-43-043 132-43-031132-43-030 132-43-001 132-29-056 132-29-057 132-29-058 132-29-027 132-29-025 132-29-030 132-29-024 132-29-023 132-29-022 132-29-021 132-29-059 132-29-055 132-29-052 132-29-053 132-29-054 132-29-026 132-28-078 132-28-028132-28-025 132-28-026 132-28-027 132-43-024 132-43-023 132-43-044132-43-045 132-43-029132-43-028132-43-027132-43-026132-43-025 132-43-130 132-43-128 132-43-012 132-43-002132-43-003132-43-004132-43-005132-43-006132-43-007132-43-008132-43-009132-43-010132-43-011 132-42-021 132-42-079 132-42-040 132-42-039 132-42-038132-42-049132-42-048132-42-050132-42-057132-42-065 132-42-031132-42-030 132-42-029132-42-028 132-42-025 132-42-024 132-42-027132-42-026 132-28-080 132-41-077 132-42-054 132-28-037 132-28-046132-28-045 132-28-055 132-28-054 132-28-053 132-28-001 132-28-002 132-28-057132-28-058 132-22-124132-22-127 132-27-063 132-27-069132-27-068 132-27-026 132-27-070132-27-064 132-27-065 132-27-066 132-27-067 132-27-081 132-27-072 132-27-028132-27-031 132-27-029132-27-030 132-27-024132-27-021 132-27-022 132-28-038132-28-077 132-28-044 132-28-004 132-28-056 132-27-113132-27-077 132-27-106132-27-080 132-28-049132-28-047 132-28-040 132-28-048 132-27-105 132-28-050 132-28-039 132-27-071 132-28-043 132-43-131 132-22-086 132-22-087 132-22-088 132-22-089 132-22-090 132-22-091 132-22-092 132-22-093 132-22-098132-22-099132-22-100132-22-101132-22-102132-22-103132-22-104132-22-105132-22-106132-22-107132-22-108 132-28-076 132-28-075 132-28-024132-28-023132-28-022 132-28-067132-28-066 132-28-068 132-28-017132-28-018132-28-019132-28-020 132-28-014132-28-013132-28-012132-28-011132-28-010 132-28-016 132-28-015 132-28-021 132-29-051 132-29-050 132-22-096 132-23-069 132-23-068 132-28-062132-28-061132-28-072 132-22-072 132-22-073 132-22-114 132-22-113 132-22-112 132-22-109132-22-110132-22-111 132-22-079132-22-078132-22-077132-22-076132-22-074 132-22-117 132-22-115132-22-116132-22-118132-22-119132-22-121 132-22-120132-22-122132-22-123 132-22-071132-22-070132-22-069132-22-068132-22-067 132-28-065132-28-064132-28-063 132-28-005 132-28-006 132-28-007 132-28-052 132-22-085132-22-084132-22-083132-22-082132-22-081132-22-080 132-37-024 132-37-023 132-37-022 132-37-049 132-37-048 132-37-046 132-37-045 132-37-044 132-37-053 132-37-042 132-38-064 132-38-065 132-38-062 132-38-027 132-38-045 132-38-046 132-32-047 132-32-026 132-32-027 132-32-037 132-32-025 132-32-024 132-32-043 132-37-055 132-37-057132-37-054 132-37-047 132-38-059 132-38-055 132-38-011 132-33-050 132-33-028 132-33-030 132-33-041 132-33-029 132-34-017 132-34-018 132-34-019 132-38-040 132-33-042 132-38-058 132-38-041 132-38-013 132-38-057 132-38-048 132-38-043 132-38-060 132-38-061 132-26-073132-26-074 132-33-008 132-33-007 132-33-006 132-33-005 132-33-004 132-33-003 132-33-002 132-33-001 132-33-024 132-33-023 132-33-022 132-33-021 132-33-020 132-33-019 132-33-018 132-33-017 132-33-059 132-33-026 132-33-027 132-33-044 132-33-045 132-33-046 132-33-047 132-33-048 132-33-049 132-34-064132-26-064132-26-065132-26-072132-26-075132-26-052 132-33-043 132-25-028 132-25-027 132-25-024 132-25-053 132-25-023 132-25-022 132-25-021132-25-020 132-26-028 132-26-071 132-32-034 132-32-033 132-32-032 132-32-031 132-32-035 132-32-029 132-32-030 132-32-028 132-32-036 132-32-042 132-32-053 132-26-076 132-26-079 132-26-078 132-26-026 132-26-027 132-26-025 132-26-024 132-26-023 132-26-022 132-26-021 132-26-019 132-26-018 132-26-060 132-26-068 132-26-063 132-26-070132-26-010132-26-009132-26-008132-26-007132-26-006132-26-005132-26-004132-26-003132-26-002 132-26-001 132-26-029 132-19-050 132-19-049 132-19-048 132-19-047 132-19-046 132-19-045 132-19-044 132-19-043 132-19-042 132-19-031132-19-030132-19-029 132-26-062 132-18-057 132-18-058 132-58-001132-58-002 132-58-003 132-34-020 132-34-001 132-34-002 132-34-003 132-34-062 132-34-061 132-34-059132-34-060 132-34-058 132-34-057 132-34-055132-34-056 132-34-054 132-34-053 132-34-052132-34-063 132-48-006132-48-007132-48-008 132-19-068 132-19-015132-19-016 132-19-032 132-19-033 132-19-034 132-19-035 132-19-064 132-19-065 132-19-066 132-19-041 132-26-061 132-26-013 132-48-009 132-48-023 132-48-021132-48-022 132-48-010 132-48-011 132-48-012 132-48-036 132-48-037 132-48-001132-48-002132-48-003132-48-004132-48-005 132-19-014 132-19-067 132-19-059 132-19-056 132-19-058 132-19-057 132-19-060 132-19-061 132-19-063 132-48-015132-48-041 132-48-040 132-48-033 132-48-038 132-48-039 132-27-103 132-27-102 132-27-101 132-27-100 132-27-099 132-27-098 132-27-095132-27-097 132-27-096 132-27-094 132-27-055132-27-052 132-27-053 132-27-054132-27-051132-27-049 132-27-050 132-27-048 132-27-045132-27-046132-27-047 132-27-108 132-48-014 132-27-093 132-27-056 132-27-057 132-27-058 132-27-060 132-27-034 132-27-015 132-27-033132-27-035 132-27-014132-27-013 132-27-036 132-27-011132-27-010 132-27-039 132-27-038 132-27-037 132-27-012132-27-009 132-27-040 132-27-008132-27-007132-27-004 132-27-032 132-27-061 132-27-041132-27-042 132-21-081 132-21-080 132-21-078 132-21-077 132-21-076 132-21-075 132-27-044 132-27-005 132-27-006 132-27-043 132-21-047 132-21-048 132-27-059 132-21-079 132-21-050132-21-049 132-48-034 132-48-030132-48-029 132-48-031 132-48-032132-48-028132-48-027132-48-026132-48-024 132-48-025 132-48-018132-48-019132-48-020 132-19-054132-19-053 132-19-055 132-21-082 132-21-045132-21-043 132-21-046132-21-044 132-27-017 132-27-018 132-27-019 132-27-020132-27-016 132-21-059 132-21-060 132-21-061 132-21-062 132-21-063132-21-064132-21-065132-21-066132-21-067132-21-068132-21-069 132-22-064 132-22-065 132-22-066 132-28-003 132-27-025132-27-027 132-27-023 132-21-072132-21-073132-21-074 132-21-051 132-21-052 132-21-057 132-21-058132-21-056132-21-055132-21-054132-21-053 132-21-071 132-21-070 132-22-075 132-25-038 132-25-037 132-25-036 132-25-035 132-25-034 132-25-033 132-25-011132-25-010132-25-009 132-18-021132-18-022132-18-023132-18-024 132-18-049 132-18-050 132-18-051 132-18-052 132-18-053 132-18-054 132-18-055 132-18-056 132-18-059132-18-060132-18-061132-18-062132-18-063132-18-064132-18-065132-18-066132-18-067132-18-068132-18-069 132-25-012 132-25-055 132-25-056 132-25-014 132-25-015 132-25-016 132-25-017 132-25-018 132-25-019 132-25-029132-25-030132-25-031132-25-032 132-19-051 132-19-052 132-19-026132-19-025 132-19-027 132-18-007 132-18-086 132-18-086 132-18-035 132-18-034 132-18-087 132-18-010 132-18-032 132-18-088 132-18-083 132-18-028132-18-029132-18-031 132-18-027 132-18-026 132-18-015132-18-014 132-18-016 132-18-017 132-18-019132-18-018 132-18-025 132-18-044 132-18-045 132-18-046 132-18-047 132-18-048 132-18-070132-18-071132-18-072 132-19-003132-19-002132-19-001 132-19-022132-19-023132-19-024 132-19-028 132-19-028 132-18-020 132-19-004 132-19-005 132-19-020 132-19-019 132-19-018 132-19-017 132-19-069132-19-010132-19-009132-19-008132-19-007132-19-006 132-19-021 142-20-057 132-37-004 132-37-003 132-37-005 132-37-006 132-37-007 132-37-008 132-37-009 132-37-041 132-37-040 132-37-039 132-37-038 132-37-034 132-37-029 132-37-028 132-37-027 132-37-026132-37-037 132-37-036 132-37-035 132-37-025 132-37-030132-37-052132-37-033 132-37-056 142-20-080 6362 132-37-061132-37-060 132-37-059 132-37-058 148-10-022 148-10-021 148-10-020148-10-019148-10-018 148-09-019 148-09-020 148-09-021 148-09-022 148-09-023 148-09-012 148-09-010 148-09-013 148-09-011 148-08-042 148-08-041148-08-040 148-08-039 148-08-038 148-08-037 148-08-036 148-08-035 148-08-034 148-08-033 148-08-032 148-08-031148-08-030148-08-029148-08-028 148-08-027148-08-026 148-08-025 148-08-024 148-08-023 148-08-022148-08-021 148-08-020 148-08-019 148-08-018 148-08-017 148-08-016148-08-015148-08-014 148-08-013148-08-012 148-08-011 148-08-010 148-08-009 148-08-008148-08-007148-08-006 148-08-005 148-08-004 148-08-003148-08-002148-08-001 148-01-016 148-01-006 167-08-042 167-08-043 148-05-001 148-05-014 148-05-031 148-05-032 148-05-033 148-05-034 148-05-035 148-05-036 148-05-024 148-05-030 148-09-016 148-05-037 148-05-025 148-05-015 148-05-016 148-05-017 148-05-018 148-05-019 148-05-002 148-05-003 148-05-004 148-05-005 148-05-007 148-05-006 148-05-028 148-05-027 148-05-026 148-09-014 148-10-015 148-05-039 148-05-038 148-10-017148-10-016 148-09-017 148-09-018 148-06-035 148-06-020 148-06-021 148-06-023 148-06-019 148-02-057 148-01-015 148-01-010 148-01-011 148-01-012 148-01-014 148-01-013 148-05-009 148-05-023 148-05-020 148-05-021 148-05-022 148-05-008 148-05-010 148-05-011 148-05-013 148-05-012 148-05-029 148-06-039 148-06-038 148-06-037 148-06-040 148-06-036 148-06-024 148-12-023 148-12-024 148-12-026 148-12-025 148-12-027 148-10-001148-10-002148-10-003148-10-004148-10-005148-10-006 148-10-026 148-10-024 148-10-025148-05-041 148-05-040 148-10-008 148-10-009 148-10-010 148-10-011 148-10-012 148-10-013148-10-014 148-12-022 148-12-021 148-10-023 148-10-007 148-12-029 148-06-002 148-06-004 148-06-003 148-06-005 148-06-008 148-06-007 148-06-006 148-06-009 148-06-010 148-06-011 148-06-012 148-06-013 148-06-014 148-06-015 148-12-015 148-12-014 148-12-012 148-12-013 148-12-017 148-12-016148-12-018 148-12-020 148-12-019 148-12-005 148-12-004 148-12-003 148-06-016 148-06-017 148-06-018 148-06-001 148-12-028 148-02-099 148-02-098 148-02-001 148-02-100 148-02-101 148-02-071 148-02-092 148-02-096 132-45-083 132-45-082 132-45-081 132-45-084 132-45-080 132-45-079 132-45-078 132-45-077 132-45-076 132-45-055 132-45-054 132-45-053 132-45-052 132-45-051 132-45-050 132-46-023 132-46-064 148-01-037 148-01-005 148-02-097 132-46-067 132-46-017 148-02-095 132-45-059 132-45-058 132-45-057 132-45-056 132-45-038 132-45-039 132-45-040 132-45-041 132-45-037132-45-036132-45-035 132-45-033 132-45-032 132-45-031 132-45-030 132-45-043 132-45-042 148-02-062 148-02-063 148-02-066 148-02-061 148-02-060 148-02-059 148-06-025148-06-032 148-06-031 148-06-030 148-06-029 148-01-009 148-02-102 148-02-067 148-06-041 148-06-033 148-06-034 148-06-022 148-02-069 148-02-068 148-02-056 148-02-051 148-02-050 148-02-049148-02-038 148-02-040 148-02-039 148-02-048 148-02-047 148-02-046 148-02-029 148-02-030 148-02-087 148-02-085 148-02-084 148-02-025 148-02-026 148-02-027 148-02-028 148-02-055 148-02-054 148-02-053 148-02-052148-02-035 148-02-036 148-02-031 148-02-033 148-02-034 148-02-064 148-02-065 148-02-072 148-02-073 148-02-074 148-02-075 148-02-076 148-02-077 148-02-083 148-02-082 148-02-081 148-02-079 148-02-078 148-02-070 148-02-086 148-02-037 148-02-032 148-02-080 148-06-027 148-06-026 148-06-028 148-12-011 148-12-009 148-12-008 148-12-007 148-12-006 148-12-010 147-26-045 148-03-021 148-03-020 148-02-088148-02-089 148-02-091 148-02-090 148-02-094 148-02-093 148-02-002 148-02-003 148-02-004 148-02-005 148-02-006 148-02-007 148-02-008 148-02-009 148-02-024 148-02-023 148-02-021 148-02-022148-02-020 148-02-019148-02-018148-02-017148-02-016148-02-015148-02-014148-02-013 148-03-049 148-03-050 148-03-051 148-03-062 148-02-044 148-03-022 148-03-012148-03-011 148-03-023 148-03-024 148-03-025 148-03-026 148-03-027 148-03-028 148-03-029 148-03-030 148-03-031 148-03-032 148-03-052 148-03-053 148-03-059 148-03-058 148-03-057 148-03-056 148-03-055 148-02-045 148-02-041 148-02-042 148-02-043 132-45-087 132-45-088 132-45-086 132-45-074 132-45-075 148-02-012148-02-011148-02-010 148-03-060 148-03-003148-03-002148-03-001148-03-061 148-03-036 148-03-035 148-03-034 148-03-033 148-03-040 148-03-041 148-03-042 148-03-037 148-03-038 148-03-039 148-03-043 148-03-044 148-03-045 148-03-046 148-03-047 148-03-048 147-30-042 132-45-005 132-45-004 132-45-003 132-45-002 132-45-072 148-03-010148-03-009148-03-008148-03-007148-03-006148-03-005148-03-004 148-03-054 147-25-008 147-30-026 147-30-034 147-30-033 147-30-040 147-30-031 147-30-046 147-30-047 147-30-029 147-30-030147-30-043 147-31-023 147-31-055 147-31-056 147-26-007 147-26-006147-26-005147-26-004 147-26-008 147-26-023 147-26-022 147-26-010 147-26-011 147-26-012 147-26-021 147-26-024 147-26-025 147-26-026 147-26-027 147-26-028 147-26-009 147-26-003 147-27-006 147-27-023 148-03-013 148-03-014 148-03-015 148-03-016 148-03-017 148-03-018 148-03-019 147-56-025 147-56-012147-56-013147-56-014147-56-015147-56-016147-56-017 147-56-022 147-56-002147-56-003147-56-004147-56-005 147-56-009 147-56-010147-56-011 147-59-001 147-59-002 147-59-003 147-59-004 147-59-005 147-59-006 147-59-007 147-59-008 147-59-009 147-59-010147-59-011147-59-012147-59-013147-59-014 147-31-026 147-31-021 147-31-022 147-25-042 147-30-016 147-30-020 147-30-019 147-30-018 147-30-053 147-30-014 147-30-013 147-30-039 147-30-032 147-30-038 147-30-037147-30-036147-30-035 147-31-025 147-31-013 147-31-015 147-31-019 147-31-020 147-31-016 147-31-014 147-31-018 147-25-024 147-25-012 147-30-017 147-25-041 147-31-017 147-31-053 147-31-060 147-31-063 147-31-029 147-31-028 147-31-027 147-31-032 147-31-031 147-31-061 147-31-059 147-31-064 147-31-062 147-31-058 147-31-057 147-31-052 147-31-051 147-31-050 147-31-049 147-31-054 147-26-013 147-26-014147-31-030147-31-012 132-29-071 132-29-084 132-29-083 132-29-082 132-29-085 132-29-070 132-29-067 132-29-068 132-29-069 132-29-086 132-29-087 132-29-066 132-29-065 132-29-072 132-29-015 132-29-017 132-29-018 132-29-019 132-29-073 132-29-088 132-30-003 132-30-005 132-30-006 132-30-007 132-30-002 132-30-001 132-30-004 132-45-034 132-45-015 132-45-014132-45-013 132-45-006132-45-007132-45-008132-45-009132-45-010132-45-011132-44-028 132-44-027 132-45-012132-44-026 132-29-016 132-44-014 132-44-104 132-29-060 132-29-014 132-29-034 132-29-036 132-29-035 132-29-037 132-29-013 132-29-038 132-29-033 132-29-020 132-29-031 132-29-049 132-29-048 132-29-046 132-29-047 132-29-029 132-29-011 132-29-010 132-29-009 132-29-040 132-29-012 132-29-032 132-29-039 132-29-080 132-29-079 132-29-074 132-29-075 132-29-076 132-29-081 132-29-078 132-29-077 132-30-029 132-30-028 132-30-027 132-30-026 132-30-025 132-30-018 132-30-019 132-30-020132-30-021 132-30-022 132-30-023 132-30-037 132-30-038 132-30-034 132-30-008 132-30-009 132-30-011 132-30-010 132-30-014 132-30-013 132-30-036 132-30-017 132-30-012 132-30-035 132-23-052 132-23-053 132-23-054 132-23-049 132-23-051 132-23-050 132-24-012 132-24-013 132-24-014 132-24-015 132-24-016 132-30-024 132-29-028 132-29-001 132-23-067 132-23-035 132-23-034132-22-094 132-22-095 132-22-097 132-29-045 132-29-044 132-29-042 132-29-008 132-29-002 132-29-003 132-29-004 132-29-005 132-29-006 132-29-007 132-29-041 132-23-066 132-23-065 132-23-062 132-23-063 132-23-064 1 132-23 132-23-055 132-23-056132-23-057 13 132-29-043 132-23-037 132-23-036 147-25-021 147-25-011147-25-010 147-25-004 147-25-003 147-25-002 147-25-007 147-25-005 147-25-006 147-30-023 147-30-024 147-30-021147-30-022 147-30-025 147-30-005 147-30-049 147-30-050 147-30-045147-30-044 132-30-041 132-30-040 132-30-039 132-30-016 132-30-015 132-30-033 147-25-020147-25-019147-25-018 147-25-017 147-25-016 147-25-015 147-25-014 147-25-031147-25-032 147-25-001 147-25-009 147-30-051 147-25-023 147-25-022 147-25-030 147-25-029 147-25-028 147-25-027 147-25-026 147-25-025 147-31-011 147-31-010 132-30-030 132-30-031 132-30-032 132-30-042 132-30-044 132-30-045 132-30-046 132-30-043 132-30-047 132-30-048 132-30-049 132-24-037 132-24-040 132-24-039132-24-038 132-24-041 132-24-007 132-24-008 132-24-009 132-24-010132-24-011 132-24-005 147-19-001 147-19-010 132-24-006 132-24-036 132-24-035 147-27-029 147-27-001 147-27-011 147-27-010 147-27-009 147-27-025 147-27-026 147-27-027 147-27-028 147-27-002 147-27-003 147-27-004 147-26-017 147-26-020 147-26-019 147-26-018147-26-015 147-26-016 147-28-016 147-27-012 142-20-050 142-20-067 142-20-095 137-16-004 137-16-034 142-20-071 142-20-072 142-20-023 142-20-024 142-20-078 142-20-040 142-20-073 142-20-086 142-20-087 137-16-029 137-16-030 137-16-028 137-16-032 142-20-084 142-20-081 142-20-097 142-20-096 147-32-028 147-32-023 147-32-024 147-32-029 147-32-050 147-32-048 147-32-049 147-60-017 147-32-015 147-32-013 147-76-016147-76-015147-76-014 147-76-013 147-76-012 147-76-011 147-76-010 147-76-009 147-76-001 147-76-002 147-76-003 147-76-004 147-76-005 147-76-006 147-76-007 147-76-008 147-32-057 147-32-058 147-32-059 147-32-060 147-32-035147-32-034 147-32-027 147-32-026 147-32-025 147-60-016 147-60-013 147-60-012 147-60-015 147-60-014 147-32-043 147-32-044 147-32-047 147-27-016 147-27-015 147-27-014 147-27-013 147-27-008 147-27-007 147-27-017 147-27-018147-27-019147-27-020147-27-021147-27-022 147-27-024 147-26-033 147-26-039 147-26-038 147-26-037 147-26-036 147-26-035 147-26-034 147-26-032147-26-031147-26-030147-26-029 147-32-045 147-27-005 147-32-046 147-28-014 147-28-007 147-28-015 147-28-005 147-32-040 147-32-039 147-32-038 147-32-037 147-32-036 147-32-033147-32-032147-32-031 147-32-030 147-28-006 147-32-041 147-32-042 147-26-041 147-26-040 147-28-008 147-28-017 147-28 147-28-022 167-04-011 167-04-012 167-04-015 167-04-002 167-04-001 137-17-004 142-17-016 137-17-003142-17-017 137-16-017 137-16-021 137-16-026 137-16-025 137-16-022 137-16-023 137-16-009 137-16-016 137-16-018 137-16-013 137-16-012 137-16-005 137-16-008 137-16-020 132-39-089 132-59-006132-59-008132-59-009132-59-007 137-37-003 137-37-001 137-37-004 137-37-022137-37-021137-37-020137-37-018137-37-017 137-37-019 137-37-023 137-37-024 137-37-025137-37-026 137-37-007137-37-006137-37-005 137-37-027 137-37-028 137-37-030137-37-029 137-37-016 137-37-015137-37-014137-37-013137-37-012137-37-011 137-37-010 137-37-009137-37-008 142-20-092 142-20-093 142-18-048 148-02-058 148-09-015 167-09-018 167-09-017 167-09-014 167-09-015 167-09-016 167-09-005 167-09-006 167-09-007 167-09-008 167-09-01 3 167-09-012 167-09-011 167-09-010 167-09-009 167-09-019 137-27-136 137-27-135 137-27-134 137-19-078 137-19-079 137-14-013 167-04-010 137-08-098 137-08-100 137-37-031 137-37-032 137-37-033 137-37-034137-37-035137-37-036137-37-037 137-37-038137-37-039137-37-040137-37-041137-37-042 137-25-128 137-25-129 137-25-130 137-25-131 137-24-045 137-24-046 137-24-044 148-07-042 148-01-007 132-43-096 132-41-094 132-41-095 132-42-083 132-42-084 132-44-110 132-44-111 148-03-063 148-03-064 147-56-026 147-56-024 147-56-028147-56-027 167-09-003 167-55-020167-55-059 167-55-021167-55-060167-55-098 167-55-022167-55-061167-55-099 167-55-023167-55-062167-55-100 167-55-026 167-55-065 167-55-103 167-55-027167-55-066167-55-104 167-55-024167-55-063167-55-101 167-55-025167-55-064167-55-102 167-55-050 167-55-089 167-55-012167-55-051 167-55-090 167-55-013167-55-052 167-55-091 167-55-114 167-55-014 167-55-053 167-55-092 167-55-115 167-55-015167-55-054167-55-093167-55-116 167-55-017167-55-056167-55-095 167-55-018167-55-057167-55-096 167-55-019167-55-058167-55-097 167-55-016167-55-055167-55-094167-55-117 167-55-029167-55-068167-55-106 167-55-028167-55-067167-55-105 167-55-038167-55-077 167-55-113 167-55-037167-55-076167-55-112 167-55-069 167-55-036167-55-075167-55-111167-55-031167-55-070 167-55-032167-55-071167-55-107167-55-033167-55-072167-55-108167-55-034167-55-073 167-55-109167-55-035167-55-074167-55-110 137-11-102 137-11-101 000-00-000 167-55-011 167-55-030 167-04-008 167-05-029 167-55-079 167-55-041167-55-080 167-55-001167-55-039 167-55-078 167-55-002167-55-040 167-55-003167-55-042167-55-081 167-55-004167-55-043167-55-082167-55-005167-55-044167-55-083 167-55-006167-55-045167-55-084 167-55-007167-55-046167-55-085 167-55-008167-55-047167-55-086 167-55-009167-55-048167-55-087 167-55-010 167-55-049167-55-088 137-25-133 000-00-000 132-60-059132-60-060132-60-061 132-60-068 137-18-081 137-26-112 137-25-132 147-47-999 132-39-069 132-33-058 137-15-076 148-01-028 148-01-019 148-01-020148-01-021148-01-022148-01-023148-01-024148-01-025148-01-026148-01-027 148-01-018 132-38-063 148-01-030 148-01-031 148-01-032 148-42-136148-42-135148-42-134148-42-133 148-42-132 148-42-142 148-42-141 148-42-140 148-42-139148-42-138 148-42-137 148-42-148148-42-147148-42-146148-42-145148-42-144148-42-143 148-42-150 148-42-149 148-42-151148-42-152148-42-153148-42-154 148-42-001 148-42-002 148-42-003 148-42-004 148-42-006 148-42-012 148-42-011 148-42-010 148-42-009 148-42-008 148-42-007 148-42-013 148-42-014 148-42-015 148-42-016 148-42-017 148-42-018 148-42-024 148-42-036 148-42-022 148-42-021 148-42-035148-42-037 148-42-020 148-42-038 148-42-039 148-42-040 148-42-019 148-42-044148-42-043148-42-042148-42-041 148-42-045148-42-046148-42-047148-42-048148-42-049148-42-050148-42-051148-42-052148-42-053 148-42-054148-42-055148-42-056 148-42-057 148-42-058148-42-059148-42-060 148-42-023 148-42-070148-42-071148-42-072148-42-073148-42-074148-42-075148-42-076 148-42-077148-42-078148-42-079 148-42-080148-42-081148-42-082148-42-083 148-42-090148-42-091148-42-092148-42-093148-42-094148-42-095148-42-096 148-42-097148-42-098148-42-099 148-42-100 148-42-101148-42-102148-42-103148-42-104 148-42-025 148-42-026148-42-027148-42-028148-42-029 148-42-030 148-42-031148-42-032148-42-033148-42-034 148-42-061 148-42-062 148-42-063 148-42-064 148-42-065 148-42-066 148-42-084 148-42-085 148-42-086148-42-087 148-42-088 148-42-089 148-42-067148-42-068148-42-069 148-42-118 148-42-119 148-42-117 148-42-116 148-42-115 148-42-114 148-42-113 148-42-126 148-42-125 148-42-123 148-42-122 148-42-121148-42-120 148-42-124 148-42-112 148-42-111 148-42-110 148-42-109 148-42-108 148-42-107 148-42-106 148-42-105 148-42-130 148-42-129 148-42-128 148-42-127 148-42-156 148-42-172 148-42-157 148-42-171148-42-170148-42-169 148-42-168148-42-167148-42-166148-42-165148-42-164 148-42-158 148-42-159148-42-160148-42-161148-42-162148-42-163 148-42-005 148-12-030 132-60-066132-60-067 132-60-069 132-60-065132-60-064132-60-063132-60-062 132-60-055132-60-056 132-60-057132-60-058 148-01-034 148-01-035 132-63-001 132-63-002 132-63-003 132-63-004 132-63-005 132-63-007 132-63-006 137-38-001 137-38-002 137-38-003 137-38-004 148-10-037 148-43-001 148-43-002 148-43-003 148-43-004 148-43-005 148-43-006 148-43-007 148-43-008 148-43-009 148-43-010 148-43-011 148-43-012 148-43-013 148-43-014 148-43-015 148-43-016 148-43-017 148-43-018148-43-019 148-43-020 148-43-021 148-43-022 148-43-023 148-43-024 148-43-025 148-43-026 148-43-027 148-43-028 148-43-029 148-43-030 148-43-031148-43-032 148-43-033 148-43-034 148-43-042 148-43-035 148-43-043 148-43-036 148-43-037148-43-038 148-43-039 148-43-040 148-43-041 148-43-044 148-43-045 132-28-081 132-28-082 132-28-083 132-28-084 132-28-085 132-28-086 132-28-087 132-28-088 132-28-089 132-28-090 132-28-091132-28-092132-28-093 132-28-094 132-28-095 132-28-096 132-28-097 132-28-098 132-28-099132-28-100 132-28-101 132-28-102 132-28-103132-28-104 132-28-105 132-28-106 132-28-107 132-28-108 132-28-109 132-28-110132-28-111 132-28-112 132-28-113 132-28-114 132-28-115 132-28-116 132-28-117132-28-118 132-28-119 132-28-120 132-28-123 132-28-122 132-64-001 132-64-002 132-64-006 132-64-005 132-64-004 132-64-003 148-01-036 137-13-156 000-00-000 137-31-003 137-16-033 137-14-178 132-28-124 132-28-125 167-10-029 167-10-100 167-10-028 167-10-027 167-10-030 167-10-088167-10-087 167-10-031 167-10-032 167-10-054167-10-052 167-10-053 167-10-048 167-10-056 167-10-057 167-10-092 167-10-055 167-10-055 167-14-006 167-14-009 167-14-069 167-14-068 167-14-005 167-14-004 167-14-001 167-14-002 167-14-003 167-14-010 167-14-070 167-14-013 167-14-075 167-14-064 167-14-074 167-14-076 167-14-073 167-14-072 167-14-018 167-14-071 167-14-022 167-14-023 167-14-024 167-14-027 167-14-017 167-14-036 167-14-066 167-14-034 167-14-033 167-14-032 167-14-031 167-14-030 167-14--028 167-14-029 167-14-037 167-14-038 167-14-039 167-14-040 167-14-041 167-14-042 167-14-043 167-14-044 167-14-045 167-14-047 167-14-046 167-14-048 167-14-049 167-14-050 167-14-052 167-14-051 167-14-054 167-14-055 167-14-056 167-14-058 167-14-061 167-14-060 167-14-059 167-14-062 167-14-057 167-14-053 167-18-071 167-19-001 167-19-002 167-19-004 167-19-003 167-18-072 167-18-061 167-180-60 167-18-070 167-18-069 167-18-068 167-19-006 167-19-005 167-19-007 167-19-008 167-18-062 167-19-015 167-19-014 167-19-012 167-19-013 167-19-011 167-19-010 167-19-022 167-19-020 167-19-021 167-19-024 167-19-023 167-11-046 167-11-053 167-11-054 167-11-057167-11-013 167-11-010 167-11-009167-11-008167-11-007167-11-043 167-11-042 167-11-052 167-11-051 167-11-050 167-11-049167-11-047 167-11-027 167-11-025 167-11-028 167-11-026 167-13-045 167-13-037 167-13-036 167-13-036 167-13-042 167-13-040 167-13-041 167-13-039 167-13-038 167-13-032 167-13-031 167-13-029167-13-028 167-13-027 167-13-026 167-13-025 167-13-048 167-13-049167-13-050 167-13-051 167-13-021 167-13-022 167-13-024 167-13-033 167-13-030 167-13-023 167-13-016 167-13-014 167-13-012 167-13-010 167-13-015 167-13-013 167-13-011 167-15-040 167-15-006 167-15-008 167-15-009 167-15-007 167-15-041 167-15-003 167-15-032 167-15-001 167-15-034 167-15-004 167-15-033 167-18-059 167-18-058 E l C a m i n o R e a l Ch a r e et Wallis Ct Donald Drive Encina Grande Drive Cereza Drive Los Robles Avenue Villa Vera Verdosa Drive Campana Drive Solana Drive Georgia Ave Ynigo Way Driscoll Ct ngArthu r 'Maybell Way Ma ybell Avenue Frandon Ct Florales Drive Georgia Avenue Amaranta Avenue Amaranta Ct Ki sCourt Terman Drive Baker Avenue Vista Avenue Wisteria Ln Pena Ct Coulombe Drive Cherry Oaks Pl Pomona Avenue Arastradero Road Abel Avenue Clemo Avenue Villa Real El Camino Way Curtner Avenue Ventura Avenue Maclane Emerson Street Ventura Ct Park Boulevard Magnolia Dr South El Camino Real Cypress Lane GlenbrookD Fairmede Avenue Arastradero RoadIrven Court Los Palos Cir LosPalosPl Maybell Avenue Alta Mesa Ave Kelly Way Los Palos Avenue Suzanne Drive Suzanne Drive rive El Camino Real Suzanne Ct Lorabelle Ct McKellar Lane El Camino Way James Road Maclane Second Street Wilkie Way Camino CtWest Meadow Drive Thain Way Barclay Ct Victoria Place Interdale Way West Charleston Road Tennessee LaneWilkie Way Carolina Lane Tennessee Lane Park Boulevard Wilkie Ct Davenport Way Alma Street Roosev Monroe Drive Wilkie Way Whitclem Pl Whitclem Drive Duluth Circle Edlee Avenue Dinah's Court Cesano Court Monroe DriveMiller Avenue Whitclem Wy Whitclem Ct Ferne Avenue Ben Lomond Drive HemlockFerne Court Alma Street Monroe Drive Ruthelma Avenue Darlington Ct Charleston Ro ad LundyLane Newberry Ct Park Boulevard George Hood Ln Alma Street elt Circle LinderoDrive Wright Place Star r King Circle Scripps Avenue Scripps Court Creekside Drive Greenmeadow Way Ben Lomond Drive Parkside Drive Dixon Place Ely Place Ely Place Mumford Place East Meadow Drive Emerson Street Roosevelt Circle RamonaStreet Ramona Street Alma Street El C Cam Ramona Street Bryant StreetEl V os Way (Private) Page Mill Road Hansen Way Hanover Street Laguna Ct Barron Avenue Josina Avenue Kendall Avenue Tippawingo St Julie Ct Matadero Avenue Ilima Way Ilima Court Laguna Oaks Pl Carlitos Ct La Calle Laguna Avenue ElCerrit Paradise Way Roble Ridge (Private) LaMataWay Chimalus Drive Matadero Avenue o Road Paul AvenueKendall AvenueWhitsell Avenue Barron Avenue Los Robles Avenue Laguna Way ShaunaLane La Para Avenue San Jude Avenue El Centro Street Timlott La Jennifer Way Magnolia Dr North La Donna Avenue LosRobles Avenue Rinc Manzana Lane onCircle by Pl Georgia Avenue Hubbartt Drive Willmar Drive Donald Drive La Para Avenue San Jude Avenue Magnolia Drive Military Way Arbol Drive Orme Street Fernando Avenue Matadero Avenue Lambert Avenue Hansen Way El Camino Real Margarita Avenue Matadero Avenue Wilton Avenue Chestnut Avenue Portage Avenue Pepper Avenue Olive Avenue Acacia Avenue Emerson Street Park Boulevard Orinda Street Birch Street Ash Street Ash Street Park Boulevard Emerson Street Ramona Street Alma Street McGregor Way Monroe Drive Silva Avenue Silv a C o u r t Miller C ourt Briarwood Way Driscoll Place Madeline Ct Page Mill Road Cerrito Way Jac o b ' s C t CalTrain ROW CalTrain ROW Lane 66 West Charleston Ro ad Lane 66 La Selva Drive El D o r a d o A v e n u e La Calle Matadero Ave Los Robles Avenue Timlott Ct Vista Villa Lane La Donna Avenue Cass Way Page Chimalus Drive Hanover Street Ma c k a Deodar StAlder Ln Spruce Ln Rickey's Ln Juniper Way Rickey's Wy Rickey's Wy Rickey's Wy Juniper Lane Cashel St Noble StHettinger Ln Pratt Ln Emma Court Alma Street Alma Village Lane Alma Village Circle Ryan LaneBowling Lane Fiesta Court Marlo we Co u rt This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend DRAFT HIS on Existing Commercial Zones DRAFT HIS on Existing Residential Transition Zones (SOFA2) DRAFT HIS on Existing Residential Zones Small Lot; Consolidation Opportunity City Jurisdictional Limits abc Quarter Mile Radius from El Camino Real Half Mile Radius from Caltrain Station Caltrain Stations 0'700' DR A F T Ho u s i n g I n v e n t o r y S i t e s ( H I S ) El C a m i n o R e a l Ar e a M a p v0 4 1 3 CITY OF PALO ALTOINCORPORATED CALI FORNIA P a l o A l t oT h e C i t y o f APRIL 1 6 1894 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2013 City of Palo Alto rrivera, 2013-04-03 10:42:19HOS 2007 2014 ECR 0313 (\\cc-maps\gis$\gis\admin\Personal\rrivera.mdb) 1996-2006 Housing Element NO CHANGE REVISED MERGED REMOVED 2007-14 Housing Element See H2.1 Policy H-1:X See Goal H-1 Policy H-2:X See H2.1 Program H-1 X See H2.1.1 Program H-2 X See H2.1.2 and H3.3.1 Program H-3 X See H2.2.1 Program H-4 X See H2.1.2 Program H-5 X See H2.1.1 Program H-5-A X See H2.1.1 Program H-5-B X X See H.2.1.1 and H2.1.8 Program H-5-C X See H3.3.2 Program H-5-D X See H.2.1.1 and H2.1.8 Program H-5-E X Deleted Program H-5-F X Completed Program H-5-G X See H2.1.2 Program H-5-H X See H2.1.3 Program H-5-I X Completed Program H-5-J X See H3.1.6 Program H-5-K X Completed (SEE 2.1.3 AND 2.1.9) Program H-5-L X Deleted Program H-6 X See H2.1.5 Program H-7 X Completed Program H-8 X Completed Program H-9 X H1.1.2 Program H-10 X Completed Program H-11 X Completed Program H-12 X Completed Policy H-3:X See Policy H2.2 Program H-13 X See H.2.2.1 Program H-13-A X See H.2.2.2 Program H-13-B X See H.2.2.2 Program H-13-C X See H.2.2.3 Program H-14 X See H.21.4 Program H-15 X Deleted Policy H-4:X See Policy H2.1 and Program H2.2.1 Program H-16 X See H2.1.11 Program H-17 X See H2.2.4 Program H-18 X See H2.1.4 Program H-19 X Completed Policy H-5:X See H2.3 Program H-20 X SeeH2.3.1 Policy H-6:X See H3.3 Program H-21 X See H3.3.1 Program H-22 X See H3.3.3 Program H-23 X See H3.3.1 Policy H-7:X See H3.1.14 Program H-24 X See H3.1.14 See H1 HOUSING ELEMENT UPDATE GOALS, POLICIES AND PROGRAMS DISPOSITION GOAL H-1: A Supply of Affordable and Market Rate Housing That Meets Palo Alto’s Share of Regional Housing Needs GOAL H-2: Conservation and Maintenance of Palo Alto’s Existing Housing Stock and Residential Neighborhoods. Page 1 of 3 1996-2006 Housing Element NO CHANGE REVISED MERGED REMOVED 2007-14 Housing Element Policy H-8: X See H1.1 Program H-25 X See H1.1.1 Program H-26 X Completed Policy H-9: X See H1.2 Program H-27 X See H.3.1.13 Program H-28 X See H3.1.3 Program H-29 X See H1.2.1 Policy H-10: X See H1.1.3 Program H-30 X See H1.1.3 Policy H-11: X See Policy H1.3 Program H-31 X See H1.3.1 Program H-32 X See H1.3.1 See H3 Policy H-12: X See H3.1 Program H-33 X See H3.1.5 Program H-34 X See H3.3.1 Policy H-13: X See H4.1.3 Program H-35 X See H4.1.7 Program H-36 X See H3.1.2 Program H-37 X Completed Program H-38 X See H3.1.10 Program H-39 X See H3.1.6 Program H-40 X See H3.1.2.g Program H-41 X See H3.1.11 Policy H-14: See Policy H3.1 and Program 3.3.7 Program H-42 X See H3.3.4 Program H-43 X See H3.2.2 Program H-44 X See H3.3.5 Policy H-15: X See H3.1 and Program H3.4.2 Program H-45 X See H3.4.1and H3.4.2 Program H-46 X See H3.4.2 Program H-47 X Deleted Program H-48 X See H3.4.1 Program H-49 X See H3.4.2 Program H-50 X See H3.1.8 Program H-51 X See H3.4.3 Policy H-16: X See H3.1.7 Program H-52 X See H3.1.7 Program H-53 X See H3.1.9 Policy H-17: X See H3.1.9 Policy H-18: X See H4.2 Program H-54 X See H2.1.5 Program H-55 X See H4.2.1 Policy H-19: X See H2.1.2 Program H-56 X See H2.1.2 Policy H-20: X Deleted Policy H-21: X See H3.5 Program H-57 X See H3.5.1 Program H-58 X See H3.5.1 Policy H-22: X Deleted Policy H-23: X See H3.3.7 Program H-59 X See H3.3.6 Program H-60 X See H3.3.7 GOAL H-3: Housing Opportunities for a Diverse Population, Including Very low-, Low- and Moderate-Income Residents, and Persons with Special Needs. Page 2 of 3 1996-2006 Housing Element NO CHANGE REVISED MERGED REMOVED 2007-14 Housing Element See H4 Policy H-24: X See H4.1 Program H-61 X See H4.1.1 Program H-62 X See H4.1.2 Program H-63 X See H4.1.3 Program H-64 X See H4.1.4 Program H-65 X See H4.1.4 Program H-66 X See H4.1.5 Program H-67 X See H4.1.6 See Goal H5 and Policy H3.2 Policy H-25:X See Policy H5.1 Program H-68 X See H5.1.2 Program H-69 X See H5.1.4 Program H-70 X See H5.1.5 Program H-71 X See H5.1.6 Policy H-26: X See H3.2.1 Program H-72 X See H3.2.1 GOAL H-5: Reduced Housing Expenses for Energy GOAL H-4: An End to Housing Discrimination on the Basis of Race, Religion, National Origin, Age, Sex, Sexual Orientation, Marital Status, Physical Handicap, or Other Barriers that Prevent Choice in Housing. Page 3 of 3 S:\PLAN\PLADIV\Advance Planning\Housing Element2007_2014\HE TAG\TAG Names Only Updated 2-2-10.doc Housing Element Technical Advisory Group (TAG) Updated on February 2, 2010 Stakeholder / Expertise / Organization Name of Representative Planning & Transportation (PTC) Commissioner Susan Fineberg Human Relations (HRC) Commissioner PAUSD Board Member Melissa Baten Caswell Palo Alto Parents (PTA Members / Parents) Vacant* Palo Alto Parents (PTA Members / Parents) Vacant* PAN (Palo Alto residential neighborhood associations) North Palo Alto Representative Tom Jordan PAN (Palo Alto residential neighborhood associations) South Palo Alto Representative Sherrie Furman PAN (Palo Alto residential neighborhood associations) Barron Park & West Palo Alto Representative Doug Moran Local Business representative Deborah Pappas Local Real Estate representative Adam Montgomery League of Women Voters Housing Team Janet Owens Palo Alto Housing Corporation (PAHC) Board member Jean McCown Alliance for a Livable Palo Alto representative Steve Raney Mixed Use Housing Developer (with experience in Palo Alto) Tony Carrasco Affordable Housing Expert and City resident Vacant Housing Advocate and City resident Carol Lamont Housing Expert (Senior, Family, Affordable, Mixed Income) Fran Wagstaff * Holly Ward resigned on: _________________ PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 EXISTING NEIGHBORHOODS H1 GOAL ENSURE THE PRESERVATION OF THE UNIQUE CHARACTER OF THE CITY’S RESIDENTIAL NEIGHBORHOODS H1.1 POLICY Promote the rehabilitation of deteriorating or substandard residential properties using sustainable and energy conserving approaches. H1.1.1 PROGRAM Continue the citywide property maintenance, inspection and enforcement program. Five-Year Objective: Continue to provide services which promote rehabilitation of substandard housing. Funding Source: City Funds Responsible Agency: Planning & Community Environment, Code Enforcement Time Frame: Ongoing H1.1.2 PROGRAM Explore creating an amnesty program to legitimize existing illegal second units where appropriate and consistent with maintaining the character and quality of life of existing neighborhoods. The granting of amnesty should be contingent on compliance with minimum building, housing, and other applicable code standards and on maintaining the affordability of the second unit to very low, low or moderate-income households. Five-Year Objective: Amend the zoning code to create a second unit amnesty program to extend the life of existing affordable units. Funding Source: General Fund Responsible Agency: Planning & Community Environment Time Frame: Conduct a study within one year of adoption of Housing Element to determine how many illegal second units exist and what incentives are needed to encourage legitimizing illegal second units. H1.1.3 PROGRAM Provide incentives to developers such as reduced fees and flexible development standards to encourage the preservation of existing rental cottages and duplexes currently located in the R-1 and R-2 residential areas. Five-Year Objective: Preserve 10 rental cottages and duplexes. Funding Source: City Housing Fund Responsible Agency: Planning and Community Environment Time Frame: Explore incentives within one year of Housing Element adoption H1.2 POLICY Support efforts to preserve multifamily housing units in existing neighborhoods. H1.2.1 PROGRAM When there is a loss of rental housing due to subdivision or condominium approvals, the project shall require 25 percent BMR units. Five-Year Objective: Provide 10 additional affordable housing units on sites where rental housing will be lost. Funding Source: NA Responsible Agency: Planning and Community Environment Time Frame: Ongoing PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 2 of 2 H1.3 POLICY Encourage community involvement in the maintenance and enhancement of public and private properties and adjacent rights-of-way in residential neighborhoods. H1.3.1 PROGRAM Create community volunteer days and park cleanups, plantings, or similar events that promote neighborhood enhancement and conduct City-sponsored cleanup campaigns for public and private properties. Five-Year Objective: Coordinate with the City’s waste and disposal hauler to conduct a cleanup campaign once a year to promote neighborhood clean-up. Funding Source: City Housing Funds Responsible Agency: Public Works Department Time Frame: Ongoing H1.4 POLICY Assure that new developments provide appropriate transitions from higher density development to single family and low density residential districts in order to preserve neighborhood character. STRATEGIES FOR NEW HOUSING H2 GOAL SUPPORT THE CONSTRUCTION OF HOUSING NEAR SCHOOLS, TRANSIT, PARKS, SHOPPING, EMPLOYMENT AND CULTURAL INSTITUTIONS H2.1 POLICY Identify and implement a variety of strategies to increase housing density and diversity, including mixed use development, near community services, including a range of unit types. Emphasize and encourage the development of affordable housing to support the City’s fair share of the regional housing needs. H2.1.1 PROGRAM Consider amending the zoning code to allow high density residential in mixed use projects in commercial areas within half a mile of fixed rail stations and to allow limited exceptions to the 50-foot height limit for Housing Inventory Sites within a quarter mile of fixed rail stations to encourage higher density residential development. Five-Year Objective: Provide opportunities for a diverse range of housing types near fixed rail stations. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Consider zoning code amendments within one year of Housing Element adoption H2.1.2 PROGRAM Allow increased residential densities and mixed use development only where adequate urban services and amenities, including, traffic capacity, are available. Five-Year Objective: Make sure that adequate services are available when considering increased residential densities. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 3 of 3 H2.1.3 PROGRAM Amend the zoning code to increase the minimum density of the RM-15 Zoning District to at least eight dwelling units per acre consistent with the multi-family land use designation under the Comprehensive Plan. Five-Year Objective: To provide opportunities for up to10 additional dwelling units on properties zoned RM- 15. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H2.1.4 PROGRAM Amend the Zoning Code to create zoning incentives that encourage the development of smaller, more affordable housing units, including units for seniors, such as reduced parking requirements for units less than 900 square feet and other flexible development standards. Five-Year Objective: Provide opportunities for 75 smaller, more affordable housing units. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H2.1.5 PROGRAM Use sustainable neighborhood development criteria to enhance connectivity, walkability and access to amenities and to support housing diversity. Five-Year Objective: Increase connectivity and walkability in new development. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H2.1.6 PROGRAM Encourage density bonuses and/or concessions including allowing greater concessions for 100% affordable housing developments consistent with the Residential Density Bonus Ordinance. Five-Year Objective: Provide opportunities for 100% affordable housing developments. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H2.1.7 PROGRAM Amend the zoning code to develop a small residential unit overlay district to allow higher densities in areas designated Pedestrian Transit Oriented Development (PTOD). Five-Year Objective: Provide opportunities for smaller residential units. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one-year of Housing Element adoption PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 4 of 4 H2.1.9 PROGRAM Explore developing a Transfer of Development Rights (TDR) program to encourage higher density housing in appropriate locations. Five-Year Objective: Create opportunities for higher density housing. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Consider program within two years of Housing Element adoption H2.1.10 PROGRAM Amend the Zoning Code to create zoning incentives that encourage the consolidation of smaller lots identified as Housing Inventory Sites, such as development review streamlining, reduction in required parking for smaller units, setback modifications, or graduated density when consolidated lots are over one-half acre. Five-Year Objective: Provide opportunities for lot consolidation to increase availability of suitable sites for affordable housing. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H2.1.11 PROGRAM Promote redevelopment of underutilized sites and lot consolidation by providing information about potential housing sites on the City’s website, including the Housing Sites Inventory and information about financial resources available through City housing programs. Five-Year Objective: Provide information to developers about potential housing sites and opportunities for lot consolidation. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Post information on website within one year of Housing Element adoption H2.2 POLICY Continue to support the redevelopment of suitable lands for mixed uses containing housing to encourage compact, infill development, optimize the use of existing urban services and support transit use. H2.2.1 PROGRAM Adopt an ordinance for density bonus concessions to promote more flexible concessions and incentives to projects that propose smaller units at a higher density, to encourage development of suitable housing sites currently planned and zoned for non-residential use with mixed use projects to contribute to the City’s fair share of the region’s housing needs. Five-Year Objective: Increase opportunities for higher density development by providing density bonus incentives. Funding Source: City funds Responsible Agency: Planning & Community Environment PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 5 of 5 Time Frame: Density Bonus Ordinance is being considered by the Planning Commission in January 2013; Council to consider adoption in early 2013 H2.2.2 PROGRAM Implement an incentive program within a year of Housing Element adoption for small properties identified as a Housing Inventory Site to encourage housing production on those sites. The incentive eliminates Site and Design Review if the project meets the following criteria: • The project has 9 residential units or fewer • A residential density of 20 dwelling units per acre or higher • Maximum unit size of 900 sq. ft. Five-Year Objective: Streamline processing for identified Housing Inventory Sites. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Adopt program within one year of Housing Element adoption H2.2.3 PROGRAM Work with Stanford University to identify sites suitable for housing that may be located in the Stanford Research Park and compatible with surrounding uses. Five-Year Objective: Identify sites suitable for housing to accommodate up additional housing units. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Identify sites within two years of Housing Element adoption 2.2.4 PROGRAM Use coordinated area plans and other tools to develop regulations that support the development of housing above and among commercial uses. Five-Year Objective: Explore additional opportunities to encourage housing in commercial areas. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing 2.2.5 PROGRAM Revise the Zoning Ordinance to increase the density of up to 20 units per acre on CN- zoned parcels included in the Housing Inventory Sites. Five-Year Objective: Provide opportunities for affordable units on CN zoned Housing Inventory Sites. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Amend zoning code within one year of Housing Element adoption. 2.2.6 PROGRAM Revise the Zoning Ordinance to allow for residential uses with the density of up to 20 units per acre on GM parcels included in the Housing Inventory Sites. Five-Year Objective: Provide opportunities for affordable units on GM zoned Housing Inventory Sites. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Amend zoning code within one year of Housing Element adoption. PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 6 of 6 2.2.7 PROGRAM Amend the Zoning Code to create zoning incentives that encourage development on and consolidation of smaller lots, such as development review streamlining, reduction in required parking for smaller units, setback modifications, or graduated density when consolidated lots are over one-half acre. Five-Year Objective: Provide opportunities for lot consolidation to increase availability of suitable sites for affordable housing. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Within one year of adoption of Housing Element H2.2.8 PROGRAM Rezone property at 595 Maybell Avenue from the RM-15 and R-2 zone districts to the PC zone district to allow for development of 60 units of extremely low to low income senior affordable rental housing units and 15 market rate units. Five-Year Objective: Provide an opportunity for development of 60 units affordable to extremely low and low income senior residents and 15 market rate units. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H2.2.9 PROGRAM To maintain adequate sites are available throughout the planning period to accommodate the City’s RHNA, on a project basis, pursuant to Government Code Section 65863, the City will monitor available residential capacity and evaluate development applications on Housing Inventory Sites in mixed use zoning districts. Should an approval of development result in a reduction of capacity below the residential capacity needed to accommodate the remaining need for lower-income households, the City will identify and zone sufficient sites to accommodate the shortfall. Five-Year Objective: Maintain Residential Capacity of sites suitable for lower income households. Responsible Agency: Planning & Community Environment Time Frame: Ongoing AFFORDABLE HOUSING H3 GOAL MEET UNDERSERVED HOUSING NEEDS AND PROVIDE COMMUNITY RESOURCES TO SUPPORT OUR NEIGHBORHOODS H3.1 POLICY Encourage, foster and preserve diverse housing opportunities for very-low, low, and moderate income households. H3.1.1 PROGRAM Amend the City’s BMR ordinance to lower the BMR requirement threshold from projects of five or more units to three or more units and to modify the BMR rental section to be consistent with recent court rulings related to inclusionary rental housing. PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 7 of 7 Five-Year Objective: Provide opportunities for 4 additional BMR units. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Amend BMR Ordinance within one year of Housing Element adoption. H3.1.2 PROGRAM Implement the City’s “Below Market Rate” (BMR) Program ordinance to reflect the City’s policy of requiring: a) At least 15 percent of all housing units in projects must be provided at below market rates to very low-, low-, and moderate-income households. Projects on sites of five acres or larger must set aside 20 percent of all units as BMR units. Projects that cause the loss of existing rental housing may need to provide a 25 percent component as detailed in Program H 1.2.1. BMR units must be comparable in quality, size and mix to the other units in the development. b) Initial sales price for at least two-thirds of the BMR units must be affordable to a household making 80 to 100 percent of the Santa Clara County median income. The initial sales prices of the remaining BMR units may be set at higher levels affordable to households earning between 100 to 120 percent of the County’s median income. For the projects with a 25 percent BMR component, four-fifths of the BMR units must be affordable to households in the 80 to 100 percent of median range, and one- fifth may be in the higher price range of between 100 to 120 percent of the County’s median income. In all cases, the sales price should be sufficient to cover the estimated cost to the developer of constructing the BMR unit, including financing, but excluding land, marketing, off-site improvements, and profit. c) If the City determines that on-site BMR units are not feasible, off-site units acceptable to the City, or vacant land determined to be suitable for affordable housing, construction, may be provided instead. Off-site units should normally be new units, but the City may accept rehabilitated existing units when significant improvement in the City’s housing stock is demonstrated. d) If the City determines that no other alternative is feasible, a cash payment to the City’ Residential Housing Fund, in lieu of providing BMR units or land, may be accepted. The in-lieu payment for projects subject to the basic 15 percent BMR requirement shall be 7.5 percent of the greater of the actual sales price or fair market value of each unit. For projects subject to the 20 percent requirement, the rate is 10 percent; for projects with a 25 percent requirement, (as described in Program 1.2.1 regarding the loss of rental housing) the rate is 12.5 percent. The fee on for-sale projects will be paid upon the sale of each market unit in the project. e) When the BMR requirement results in a fractional unit, an in-lieu payment to the City’s Residential Housing Fund may be made for the fractional unit instead of providing an actual BMR unit. The in-lieu fee percentage rate shall be the same as that otherwise required for the project (7.5 percent, 10 percent, or 12.5 percent). The fee on for-sale projects will be paid upon the sale of each market unit in the project. Larger projects of 30 or more units must provide a whole BMR unit for any fractional PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 8 of 8 unit of one-half (0.50) or larger; an in-lieu fee may be paid, or equivalent alternatives provided, when the fractional unit is less than one-half. f) Within fifteen days of entering into a BMR agreement with the City for a project, the developer may request a determination that the BMR requirement, taken together with any inclusionary housing incentives, as applied the project, would legally constitute a taking of property without just compensation under the Constitution of the United States or of the State of California. The burden of proof shall be upon the developer, who shall provide such information as is reasonably requested by the City, and the initial determination shall be made by the Director of Planning and Community Environment. The procedures for the determination shall generally be those described in Chapter 18.90 of the Palo Alto Municipal Code, including the right of appeal to the City council under Chapter 18.93, or such other procedures as may be adopted in a future BMR ordinance. Notice of the hearing shall be give by publication but need not be sent to nearby property owners. If the City determines that the application of the BMR requirement as applied to the project would constitute a taking of property without just compensation, then the BMR agreement for the project shall be modified, reduced or waived to the extent necessary to prevent such a taking. g) Consider allowing smaller BMR units than the market rate units if the developer provides more than the required BMR amount in the R-1 Zoning district for new single family residential subdivisions subject to compliance with appropriate development standards. h) Revise BMR policy language to clarify the City’s BMR program priorities in producing affordable housing units including exploring the option of requiring land dedication as the default option on sites of three or more acres. i) Evaluate revising the method of calculating the number of required BMR units by basing the number of BMR units required on the maximum density allowable on the site instead of the total number of proposed units in the development. j) Conduct a nexus study to identify the impacts of market rate housing and the need for affordable housing and develop BMR rental policies based on the results of the study. Five-Year Objective: Provide 10 affordable units through implementation of the City’s BMR program. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing – implementation of existing program H3.1.3 PROGRAM Continue implementation of a Below Market Rate (BMR) Program Emergency Fund to prevent the loss of BMR units and to provide emergency loans for BMR unit owners to maintain and rehabilitate their units. Five-Year Objective: Use the BMR Program Emergency Fund to prevent the loss of up to 2 affordable units. Funding Source: BMR Emergency Fund PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 9 of 9 Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.1.4 PROGRAM Consider expansion of the BMR Program Emergency Fund to provide financial assistance to help BMR homeowners maintain and rehabilitate older BMR units. Five-Year Objective: Assist in maintenance and rehabilitation of 4 older BMR units. Funding Source: BMR Emergency Funds Responsible Agency: Planning & Community Environment Time Frame: Expand Program within two years of Housing Element adoption H3.1.5 PROGRAM Preserve affordable housing stock by monitoring compliance, providing tenant education, and seeking other sources of funds for affordable housing developments at risk of market rate conversions. The City will continue to renew existing funding sources supporting rehabilitation and maintenance activities. Five-Year Objective: Prevent conversion of affordable housing to market rate and renew funding sources for rehabilitation and maintenance of housing stock. Funding Source City, CDBG funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 10 of 10 H3.1.6 PROGRAM Encourage the use of flexible development standards including floor area ratio limits, creative architectural solutions and natural resource conservation, in the design of projects with a substantial BMR component. Five-Year Objective: Increase opportunities for BMR development through use of flexible development standards. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.1.7 PROGRAM Amend the Zoning Code to allow Single Room Occupancy (SRO) units in commercial and high density residential zoning districts subject to development standards that would encourage the construction of the maximum number of units consistent with the goals of preserving the character of adjacent neighborhoods. Sites that have access to community services and public transportation for SRO residents are highly desired. Five-Year Objective: Provide affordable efficiency units on appropriate sites. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Amend the Zoning Code within one year of Housing Element adoption H3.1.8 PROGRAM Require developers of employment-generating commercial and industrial developments to contribute to the supply of low- and moderate-income housing through the provision of commercial in- lieu fees as prescribed in a nexus impact fee study. Five-Year Objective: Generate in-lieu fees to contribute toward the creation of low and moderate income housing. Funding Source: City Housing Fund Responsible Agency: Planning & Community Environment Time Frame: Continue to update the commercial in-lieu fee on an annual basis. H3.1.9 PROGRAM Ensure that the Zoning Code permits innovative housing types, such as co-housing, and provides flexible development standards that will allow such housing to be built provided the character of the neighborhoods in which they are proposed to be located is maintained. Five-Year Objective: Review the Zoning Code and determine appropriate amendments to allow innovative housing types with flexible development standards. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Consider changes to the Zoning Code within two years of Housing Element adoption PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 11 of 11 H3.1.10 PROGRAM Adopt a revised density bonus ordinance that allows up to a maximum zoning increase of 35 percent in density and grants up to three concessions or incentives. The density bonus ordinance will meet State standards for the provision of housing units for very low- and lower-income renters, seniors and moderate-income condominium buyers in compliance with Government Code Section 65915, et seq. Five-Year Objective: To provide opportunities for increased density as outlined in State law. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Density Bonus Ordinance is being considered by the Planning Commission in January 2013; Council to consider adoption in early 2013 H3.1.11 PROGRAM Recognize the Buena Vista Mobile Home Park as providing low- and moderate income housing opportunities. Any redevelopment of the site must be consistent with the City’s Mobile Home Park Conversion Ordinance adopted to preserve the existing units. To the extent feasible, the City will seek appropriate local, state and federal funding to assist in the preservation and maintenance of the existing units in the Buena Vista Mobile Home Park. Five-Year Objective: Preserve the 120 mobile home units in the Buena Vista Mobile Home Park as a low and moderate income housing resource. Funding Source: City, State and Federal Funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.1.12 PROGRAM Continue enforcing the Condominium Conversion Ordinance. Five-Year Objective: Maintain the City’s rental housing stock. Funding Source: N/A Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.1.13 PROGRAM Annually monitor the City’s progress in the construction or conversion of housing for all income levels including the effectiveness of housing production in mixed use developments. Five-Year Objective: Provide information on the effectiveness of City programs. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Provide annual reports PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 12 of 12 H3.1.14 PROGRAM Evaluate the provisions of the Below Market Rate (BMR) Program to determine if additional incentives are needed to encourage development of housing given current market conditions. Five-Year Objective: Engage in discussions with the development community and determine if additional incentives are needed to improve the BMR Program. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Evaluate the Program within one year of Housing Element adoption H3.1.15 PROGRAM When using its Housing Development funds for residential projects, the City shall give a strong preference to those developments which serve extremely low-income (ELI) households. Five-Year Objective: Provide funding opportunities for development of housing for Extremely Low Income (ELI) households. Funding Source: City Housing Development funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.1.16 PROGRAM Amend the Zoning Code to provide additional incentives to developers who provide extremely-low income (ELI) housing units, above and beyond what is required by the Below Market Rate (BMR) program, such as reduced parking requirements for smaller units, reduced landscaping requirements and reduced fees. Five-Year Objective: Provide incentives for development of housing for Extremely Low Income (ELI) households. Funding Source: City Housing funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H3.1.17 PROGRAM Any affordable development deemed a high risk at market rate conversion, within two years of the expiration of the affordability requirements, the City will contact the owner and explore the possibility of extending the affordability of the development. Five-Year Objective: To protect those affordable developments deemed a high risk to converting to market rate. Funding Source: City Housing funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H3.2 POLICY Reduce the cost of housing by continuing to promote energy efficiency, resource management, and conservation for new and existing housing. PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 13 of 13 H3.2.1 PROGRAM Continue to assist very low-income households in reducing their utility bills through the Utilities Residential Rate Assistance Program (RAP). Five-Year Objective: Provide assistance to with utility bills to 10 low income households. Funding Source: City Funds Responsible Agency: Palo Alto Utilities Department Time Frame: Ongoing PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 14 of 14 H3.2.2 PROGRAM Use existing agency programs such as Senior Home Repair to provide rehabilitation assistance to very low- and low-income households. Five-Year Objective: Provide rehabilitation assistance to 10 very low and low-income households. Funding Source: CDBG & General Fund Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.3 POLICY Support the reduction of governmental and regulatory constraints and advocate for the production of affordable housing. H3.3.1 PROGRAM Where appropriate and feasible, require all City departments to expedite processes and allow waivers of development fees as a means of promoting the development of affordable housing. Five-Year Objective: Continue to reduce processing time and costs for affordable housing projects. Funding Source: City funds Responsible Agency: All City Departments Time Frame: Ongoing, continue implementation upon adoption of Housing Element H3.3.3 PROGRAM Continue to exempt permanently affordable housing units from any infrastructure impact fees that may be adopted by the City. Five-Year Objective: Reduce costs for affordable housing projects. Funding Source: City Funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.3.4 PROGRAM Promote legislative changes and funding for programs that subsidize the acquisition, rehabilitation, and operation of rental housing by housing assistance organizations, nonprofit developers, and for-profit developers. Five-Year Objective: Continue as an active member of the Non-Profit Housing Association of Northern California to promote legislative changes and funding for programs relating to housing. Funding Source: City Funds Responsible Agency: Planning & Community Environment, City Manager Time Frame: Ongoing H3.3.5 PROGRAM Support the development and preservation of group homes and supported living facilities for persons with special housing needs by assisting local agencies and nonprofit organizations in the construction or rehabilitation of new facilities for this population. Five-Year Objective: Review existing development regulations and amend the Zoning Code to reduce regulatory obstacles to this type of housing. Funding Source: City & CDBG Funds Responsible Agency: Planning & Community Environment PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 15 of 15 Time Frame: Amend Zoning Code within one year of Housing Element adoption. H3.3.6 PROGRAM Continue to participate in the Santa Clara County Homeless Collaborative as well as work with adjacent jurisdictions to develop additional shelter opportunities, and Five-Year Objective: Continue City staff participation as members of the Collaborative’s CDBG and Home Program Coordinators Group. Funding Source: City, CDBG & HOME funds Responsible Agency: Planning & Community Environment, City Council Time Frame: Ongoing H3.3.7 PROGRAM Continue to participate with and support agencies addressing homelessness. Five-Year Objective: Continue City staff participation in prioritizing funding for County-wide programs. Funding Source: City, CDBG & HOME funds Responsible Agency: Planning & Community Environment, City Council Time Frame: Ongoing H3.3.8 PROGRAM Amend the Zoning Code to allow transitional and supportive housing by right in all multifamily zone districts which allow residential uses only subject to those restrictions that apply to other residential uses of the same type in the same zone. Five-Year Objective: Provide appropriately zoned sites for transitional and supportive housing. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H3.4 POLICY Pursue funding for the acquisition, construction or rehabilitation of housing that is affordable to very low, low, and moderate-income households. H3.4.1 PROGRAM Maintain a high priority for the acquisition of new housing sites near public transit and services, the acquisition and rehabilitation of existing housing, and the provision for housing-related services for affordable housing. Seek funding from all appropriate state and federal programs whenever they are available to support the development or rehabilitation of housing for very low, low, or moderate-income households Five-Year Objective: Allocate CDBG funding to acquire and rehabilitate housing for very low, low, or moderate income households. Funding Source: CDBG, State Local Housing Trust Fund Responsible Agency: Planning & Community Environment Time Frame: Ongoing PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 16 of 16 H3.4.2 PROGRAM Support and expand local funding sources including the City’s Housing Development Fund, Housing Trust of Santa Clara County, CDBG Program, County of Santa Clara’s Mortgage Credit Certificate Program (MCC) or similar program. Continue to explore other mechanisms to generate revenues to increase the supply of low- and moderate- income housing. Five-Year Objective: Increase the supply of affordable housing stock. Funding Source: City Housing Development Fund, Housing Trust of Santa Clara County, CDBG, Santa Clara County MCC Responsible Agency: Planning & Community Environment Time Frame: Ongoing H3.4.3 PROGRAM Periodically review the housing nexus formula as required under Chapter 16.47 of the Municipal Code to fully reflect the impact of new jobs on housing demand and cost. Five-Year Objective: Continue to evaluate the housing nexus formula and adjust the required impact fees to account for the housing demand from new development. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Ongoing H3.4.4 PROGRAM The City will work with affordable housing developers to pursue opportunities to acquire, rehabilitate and convert existing multi-family developments to long term affordable housing units to contribute to the City’s fair share of the region’s housing needs. Five-Year Objective: Identify potential sites for acquisition and conversion and provide this information to developers. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Identify sites within one year of Housing Element adoption. H3.5 POLICY Support the provision of emergency shelter, transitional housing and ancillary services to address homelessness. H3.5.1 PROGRAM Enter into discussions with local churches participating in the City’s year round Hotel de Zink emergency shelter program to establish a permanent emergency shelter in each church within a year of Housing Element adoption. Five-Year Objective: To determine interest from local churches in establishing permanent emergency shelters. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Enter into discussions within two years of Housing Element adoption PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 17 of 17 H3.5.2 PROGRAM Amend the Zoning Code to allow emergency shelters by right with appropriate performance standards to accommodate the City’s unmet need for unhoused residents within an overlay of the ROLM zone district located east of Highway 101. Five-Year Objective: Provide appropriately zoned sites for emergency shelters. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Within one year of Housing Element adoption H3.6 POLICY Support the creation of workforce housing for City and school district employees if feasible. H3.6.1 PROGRAM Conduct a nexus study to evaluate the creation of workforce housing for City and school district employees. Five-Year Objective: Create the opportunity for up to 5 units of workforce housing. Funding Source: City of Palo Alto Commercial Housing Fund Responsible Agency: Planning & Community Environment Time Frame: Conduct study within two years of Housing Element adoption. HOUSING DISCRIMINATION H4 GOAL PROMOTE AN ENVIRONMENT FREE OF DISCRIMINATION AND THE BARRIERS THAT PREVENT CHOICE IN HOUSING. H4.1 POLICY Support programs and agencies that seek to eliminate housing discrimination. H4.1.1 PROGRAM Work with appropriate state and federal agencies to ensure that fair housing laws are enforced. Five-Year Objective: Continue to coordinate with state and federal agencies to support programs to eliminate housing discrimination. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing H4.1.2 PROGRAM Continue to support groups that provide fair housing services, such as Mid-Peninsula Citizens for Fair Housing. Five-Year Objective: Continue to provide financial support through CDBG funding for fair housing services such as Mid-Peninsula Citizens for Fair Housing and Project Sentinel. Funding Source: CDBG funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 18 of 18 H4.1.3 PROGRAM Continue the efforts of the Human Relations Commission to combat discrimination in rental housing, including mediation of problems between landlords and tenants. Five-Year Objective: Continue to provide mediation services for rental housing discrimination cases. Funding Source: City funds Responsible Agency: Human Relations Commission Time Frame: Ongoing H4.1.4 PROGRAM Continue implementation of the City’s ordinances and state law prohibiting discrimination in renting or leasing housing based on age, parenthood, pregnancy or the potential or actual presence of a minor child. Develop written procedures describing how Palo Alto will process and treat reasonable accommodation requests for projects proposing housing for special needs households. Five-Year Objective: Implement existing ordinances regarding discrimination and develop reasonable accommodation procedures. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Implementation – Ongoing; Establish reasonable accommodation procedure within one year of Housing Element adoption H4.1.5 PROGRAM Continue the City’s role in coordinating the actions of various support groups that are seeking to eliminate housing discrimination and in providing funding and other support for these groups to disseminate fair housing information in Palo Alto, including information on referrals to pertinent investigative or enforcement agencies in the case of fair housing complaints. Five-Year Objective: Continue to provide funding and other support for these groups to disseminate fair housing information in Palo Alto. Funding Source: City Funds, Human Services Resource Allocation Process (HSRAP) Responsible Agency: Office of Human Services Time Frame: Ongoing H4.1.6 PROGRAM Amend the Zoning Code to provide individuals with disabilities reasonable accommodation in rules, policies, practices and procedures that may be necessary to ensure reasonable access to housing. The purpose of this program is to provide a process for individuals with disabilities to make requests for reasonable accommodation in regard to relief from the various land use, zoning, or building laws, rules, policies, practices and/or procedures of the City. Five-Year Objective: Allow for reasonable accommodation for persons with disabilities in interpreting land use regulations. Funding Source: City funds Responsible Agency: Planning and Community Environment Time Frame: Amend the Zoning Code within one year of Housing Element adoption PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 19 of 19 H4.1.7 PROGRAM Continue to implement the “Action Plan” of the City of Palo Alto’s Community Development Block Grant (CDBG) Consolidated Plan or its successor documents. Five-Year Objective: Provide for increased use and support of tenant/landlord educational mediation opportunities as called for in the CDBG Action Plan. Funding Source: CDBG funds, General Fund Responsible Agency: Planning & Community Environment Time Frame: Ongoing H4.2 POLICY Support housing that incorporates facilities and services to meet the health care, transit, and social service needs of households with special needs, including seniors and persons with disabilities. H4.2.1 PROGRAM Ensure that the Zoning Code facilitates the construction of housing that provides services for special needs households and provides flexible development standards for special service housing that will allow such housing to be built with access to transit and community services while preserving the character of the neighborhoods in which they are proposed to be located. Five-Year Objective: Evaluate the Zoning Code and develop flexible development standards for special service housing. Funding Source: City funds Responsible Agency: Planning & Community Environment Time Frame: Evaluate the Zoning Code within one year of Housing Element adoption H4.2.2 PROGRAM Work with the San Andreas Regional Center to implement an outreach program that informs families in Palo Alto about housing and services available for persons with developmental disabilities. The program could include the development of an informational brochure, including information on services on the City’s website, and providing housing-related training for individuals/families through workshops. Five-year objective: Provide information regarding housing to families of persons with developmental disabilities. Funding Source: General Fund Responsibility: Planning and Community Environment Time frame: Develop outreach program within two years of adoption of the Housing Element. PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 20 of 20 SUSTAINABILITY IN HOUSING H5 GOAL REDUCE THE ENVIRONMENTAL IMPACT OF NEW AND EXISTING HOUSING. H5.1 POLICY Reduce long term energy cost and improve the efficiency and environmental performance of new and existing homes. H5.1.1 PROGRAM Periodically report to the City on the status and progress of implementing the City’s Green Building Ordinance, intended to improve indoor air quality and assess the environmental performance and efficiency of homes in the following areas: - Greenhouse gas emissions - Energy use - Water use (indoor and outdoor) - Material efficiency - Stormwater runoff - Alternative transportation - Site preservation Five-Year Objective: Prepare reports evaluating the progress of implementing the City’s Green Building Ordinance. Funding Source: City funds, Development fees Responsible Agency: Planning & Community Environment, Building Division Time Frame: Ongoing H5.1.2 PROGRAM Continue providing support to staff and public (including architects, owners, developers and contractors) through training and technical assistance in the areas listed under Program H5.1.1. Five-Year Objective: Provide educational information regarding the City’s Green Building Ordinance. Funding Source: City funds, Development fees Responsible Agency: Planning & Community Environment, Building Division Time Frame: Ongoing H5.1.3 PROGRAM Participate in regional planning efforts to ensure that the Regional Housing Needs Allocation (RHNA) targets areas that support sustainability by reducing congestion and greenhouse gas emissions. Five-Year Objective: Provide a regional framework for sustainability in creating new housing opportunities. Funding Source: City Funds Responsible Agency: Planning & Community Environment Time Frame: Ongoing PALO ALTO REVISED DRAFT HOUSING ELEMENT 5.2 HOUSING GOALS POLICIES AND PROGRAMS March 26, 2013 Page 21 of 21 H5.1.4 PROGRAM Review Federal, State, and regional programs encouraging the improvement of environmental performance and efficiency in construction of buildings and incorporate appropriate programs into Palo Alto’s policies, programs and outreach efforts. Five-Year Objective: Continue to update regulations for environmental sustainability. Funding Source: City funds Responsible Agency: Planning & Community Environment, Public Works & Utilities Time Frame: Ongoing H5.1.5 PROGRAM Enhance and support a proactive public outreach program to encourage Palo Alto residents to conserve resources and to share ideas about conservation. Five-Year Objective: Provide up to date information for residents regarding conservation through educational brochures available at City Hall and posted on the City’s website. Funding Source: City funds Responsible Agency: Planning & Community Environment, Public Works & Utilities Time Frame: Ongoing H5.1.6 PROGRAM Provide financial subsidies, recognition, or other incentives to new and existing home owners or developers to achieve performance or efficiency levels beyond minimum requirements. Five-Year Objective: Establish a program to recognize home owners and developers who achieve incorporate sustainable features beyond what is required by the Green Building Ordinance. Funding Source: City funds Responsible Agency: Planning & Community Environment, Building Division Time Frame: Establish program within two years of Housing Element adoption Housing Element Housing Sites Inventory March 26, 2013 Page 1 of 7 ZONING_RESIDENTIAL LAND_USE_LOT_REALISTIC ON_SITE_CONSTRAINTS/ OPPORTUNITIES ASSESSED_ APN SITE_ADDRESS DISTRICT DENSITY MAXIMUM YIELD DESIGNATION SIZE_(ac)CAPACITY EXISTING USE VALUE_ ALLOWED RATIO 132-37-019 423 Page Mill Rd.CS(D)30 du/ac 4 CN 0.15 2 Vacant SFD 0.12 132-37-018 433Page Mill Rd.CS(D)30 du/ac 4 CN 0.15 2 Vacant SFD 0.12 132-37-017 441 Page Mill Rd.CS(D)30 du/ac 4 CN 0.15 2 Vacant SFD 0.26 132-37017 451 Page Mill Rd.CS(D)30 du/ac 4 CN 0.15 2 Vacant SFD 0.27 132-41-085 3707 El Camino Real CN*15 du/ac 3 CN 0.18 3 1 Story Personal Service; Retail Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.99 124-32-013 470 Cambridge Av CC (2)30 du/ac 7 CC 0.23 5 1 Story Religious Institution: Surface Parking Existing Non-Residential Use 1.64 124-33-005 410 Sherman Av CC (2)30 du/ac 7 CC 0.24 5 2 Story Office Commercial Existing Commercial Use 4.17 124-29-007 251 California Av CC (2)(R)(P)30 du/ac 7 CC 0.26 5 1 Story retail Existing Commercial Use 1.19 124-32-035 334 California Av CC (2)(R)(P)30 du/ac 8 CC 0.27 5 2 Story Retail; Eating Drinking; Commercial Existing Commercial Use 0.74 124-33-061 479 California Av CC (2)(R)(P)30 du/ac 7 CC 0.24 5 1 Story commercial; Financial Service Existing Commercial Use 0.55 120-15-090 595 Bryant St CD-C (GF)(P)/40 du/ac 8 CC 0.22 5 1 Story Retail; Eating Drinking Small lot ; consolidation opportunity 0.75 120-03-021 581 University Av CD-C (P)40 du/ac 10 CC 0.26 5 1 Story Financial Service Existing Commercial Use 0.73 120-03-037 578 University Av CD-C (P)40 du/ac 8 CC 0.22 5 1 Story Office Existing Commercial Use 3.45 120-03-067 541 Cowper St CD-C (P)40 du/ac 9 CC 0.23 5 1 Story commercial Existing Commercial Use 1.47 120-15-007 401 Waverley St CD-C (P)40 du/ac 8 CC 0.22 5 1 Story Retail; personal Service Small lot ; consolidation opportunity 1.09 120-15-013 420 Cowper St CD-C (P)40 du/ac 10 CC 0.25 5 2 story office Existing Commercial Use 2.12 120-26-109 542 High St CD-C (P)40 du/ac 10 CC 0.25 5 ! Story Commerical; Retail office Existing Commercial Use 1.38 120-26-111 135 Hamilton Av CD-C (P)40 du/ac 8 CC 0.22 5 Surface parking Parking serving adjacent commercial uses 0 124-31-059 2101 El Camino Real CN*15 du/ac*5 CN 0.25 5 1 Story Retail; Personal Service; Surface parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.91 132-40-062 480 Wilton Av CN*15 du/ac 5 CN 0.25 5 1 Story Eating Drinking; Surface parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.91 132-46-106 4112 El Camino Wy CN*15 du/ac 5 CN 0.25 5 1 Story Eating Drinking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 2.41 137-01-116 2000 El Camino Real CN*15 du/ac 5 CN 0.27 5 1 Story Eating Drinking; Surface parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 1.13 137-08-078 3636 El Camino Real CN*15 du/ac 5 CN 0.25 5 1 Story Eating Drinking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.09 137-08-097 3666 El Camino Real CN*15 du/ac 5 CN 0.25 5 1 Story Retail: Commercial; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.44 137-11-091 3972 El Camino Real CN*15 du/ac 5 CN 0.25 5 Gas Station Underground Storage Tanks; Current Maximum Residential Density is 15 du/ac 0.27 137-11-098 3780 El Camino Real CN*15 du/ac 5 CN 0.24 5 1 Story Retail; Commecial; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.13 120-33-024 711 El Camino Real CS 30 du/ac 7 CS 0.24 5 1 Story Commercial; Office Existing Commercial Use 0 132-38-011 3275 Ash St CS 30 du/ac 8 CS 0.27 5 1 Story Office; Commercial; Surface Parking Existing Commercial Use 2.47 132-38-017 460 Lambert Av CS 30 du/ac 6 CS 0.22 5 Surface parking Small lot ; consolidation opportunity 0.04 Vacant; Small lot; Consolidation Opportunity. An application has been submitted to merge these lots and develop an 8-unit multifamily project, the project will include 3 units affordable to low inclome residents through density bonus program Table 3-7 Table of Commercially Zoned Sites 2. *CN Parcels to be rezoned to 20 units per acre. 1. Parcels highlighted in orange denotes zoning density greater than 20 units per acre; parcels with proposals for market rate housing are excluded. Notes: 3. Parcels with an Assessed Value Ratio greater than 1.5 were determined to have an artificially low assessed land value from parcels under the same ownership for more than 10 years; the assessed land value is far below current market land values. Housing Element Housing Sites Inventory March 26, 2013 Page 2 of 7 ZONING_RESIDENTIAL LAND_USE_LOT_REALISTIC ON_SITE_CONSTRAINTS/ OPPORTUNITIES ASSESSED_ APN SITE_ADDRESS DISTRICT DENSITY MAXIMUM YIELD DESIGNATION SIZE_(ac)CAPACITY EXISTING USE VALUE_ ALLOWED RATIO 132-38-018 460 Lambert Av CS 30 du/ac 6 CS 0.22 5 Surface parking Small lot ; consolidation opportunity 0.04 132-38-025 455 Portage Av CS 30 du/ac 6 CS 0.22 5 1 Story Commercial Office Small lot ; consolidation opportunity 4.26 132-38-032 3159 El Camino Real CS 30 du/ac 7 CS 0.24 5 2 Story Commercial Existing Commercial Use 1.06 132-38-047 3260 Ash St CS 30 du/ac 6 CS 0.22 5 SFD Small lot ; consolidation opportunity 5.62 137-08-079 3516 El Camino Real CS 30 du/ac 6 CS 0.23 5 1 Story Personal Service Existing Commercial Use 0.09 137-08-088 3508 El Camino Real CS 30 du/ac 7 CS 0.24 5 Automotive Service; Surface Parking Existing Commercial Use 0.16 124-28-003 2260 Park Bl CC (2)30 du/ac 8 CC 0.29 6 Surface parking Parking serving adjacent commercial uses 0 124-29-011 2555 Park Bl CC (2)30 du/ac 8 CC 0.29 6 2 Story Office Commercial Existing Commercial Use 2.46 124-28-033 250 California Av CC (2)(R)(P)30 du/ac 8 CC 0.28 6 1 Story Eating Drinking Existing Commercial Use 0.57 124-32-034 300 California Av CC (2)(R)(P)30 du/ac 8 CC 0.27 6 2 Story Eating Drinking; Commercial Existing Commercial Use 0.73 120-15-045 353 University Av CD-C (GF)(P)40 du/ac 12 CC 0.3 6 1 Story Commerical; Retail; Office Existing Commercial Use 2.95 120-16-020 635 Waverley St CD-C (P)40 du/ac 12 CC 0.31 6 2 Story Office Existing Commercial Use 0.9 120-27-038 658 High St CD-C (P)40 du/ac 12 CC 0.32 6 2 Story Commercial Surface Parking Existing Commercial Use 1.89 124-30-015 1963 El Camino Real CN*15 du/ac 6 CN 0.28 6 Gas Station Underground Storage Tanks; Current Maximum Residential Density is 15 du/ac 0.04 132-35-045 3705 El Camino Real CN*15 du/ac 6 CN 0.28 6 1 Story Retail Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.26 120-33-004 67 Encina Av CS 30 du/ac 8 CS 0.27 6 1 Story Commercial; Office Existing Commercial Use 1.17 132-37-055 3051 El Camino Real CS 30 du/ac 9 CS 0.3 6 1 Story Retail; Surface Parking Existing Commercial Use 0.45 132-38-058 320 Lambert Av CS 30 du/ac 8 CS 0.28 6 1 Story Office Commercial; Light Industrial Existing Commercial Use 6.46 132-38-060 280 Lambert Av CS 30 du/ac 8 CS 0.28 6 1 Story Office Commercial; Light Industrial Existing Commercial Use 0.53 132-38-061 292 Lambert Av CS 30 du/ac 9 CS 0.32 6 1 Story Office Commercial; Light Industrial Existing Commercial Use 0.93 132-39-087 455 Lambert Av CS 30 du/ac 9 CS 0.32 6 1 Story Commercial Existing Commercial Use 0.56 142-20-055 3160 El Camino Real CS 30 du/ac 8 CS 0.29 6 2 Story Office; Surface Parking Existing Commercial Use 0.03 132-31-071 2747 Park Bl GM 6 LI 0.3 6 Vacant Lot Needs Rezoning to allow Residential Use 0.51 124-32-040 414 California Av CC (2)(R)(P)30 du/ac 11 CC 0.37 7 2 Story Financial Services; Surface Parking Existing Commercial Use 0.49 120-15-015 469 University Av CD-C (GF)(P)40 du/ac 13 CC 0.34 7 1 Story Commercial; Retail; Eating Drinking Existing Commercial Use 1.7 120-15-103 360 University Av CD-C (GF)(P)40 du/ac 13 CC 0.34 7 1 Story Retail Existing Commercial Use 1 120-16-011 630 Cowper St CD-C (P)40 du/ac 13 CC 0.34 7 1 Story Office Existing Commercial Use 0.45 120-26-002 130 Lytton Av CD-C (P)40 du/ac 13 CC 0.34 7 2 Level Parking Structure Parking serving adjacent commercial uses 0.36 132-46-100 4115 El Camino Real CN*15 du/ac 7 CN 0.35 7 1 Story Eating Drinking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 1.03 137-08-081 3630 El Camino Real CN*15 du/ac 7 CN 0.37 7 2 Story Office; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.36 137-11-078 3700 El Camino Real CN*15 du/ac 7 CN 0.36 7 1 Story Personal Service; Retail; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0 137-11-083 3896 El Camino Real CN*15 du/ac 7 CN 0.32 7 1 Story Retail; Eating Drinking; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.56 132-37-033 2905 El Camino Real CS 30 du/ac 9 CS 0.32 7 2 Story Commercial: Surface Parking Existing Commercial Use 0.17 132-37-052 2951 El Camino Real CS 30 du/ac 9 CS 0.32 7 1 Story Retail; Commecial Existing Commercial Use 0.62 132-37-056 3001 El Camino Real CS 30 du/ac 9 CS 0.33 7 1 Story Retail; Surface Parking Existing Commercial Use 1.08 Housing Element Housing Sites Inventory March 26, 2013 Page 3 of 7 ZONING_RESIDENTIAL LAND_USE_LOT_REALISTIC ON_SITE_CONSTRAINTS/ OPPORTUNITIES ASSESSED_ APN SITE_ADDRESS DISTRICT DENSITY MAXIMUM YIELD DESIGNATION SIZE_(ac)CAPACITY EXISTING USE VALUE_ ALLOWED RATIO 132-38-048 268 Lambert Av CS 30 du/ac 10 CS 0.35 7 1 Story Office Commercial; Light Industrial Existing Commercial Use 0.64 132-41-088 3801 El Camino Real CS 30 du/ac 10 CS 0.35 7 1 Story Office; Surface Parking Existing Commercial Use 1.14 132-46-119 4195 El Camino Real CS 30 du/ac 10 CS 0.35 7 1 Story Automotive Services Existing Commercial Use 0.88 132-46-120 4193 El Camino Real CS 30 du/ac 10 CS 0.36 7 1 Story Medical Office; Automotive Services Existing Commercial Use 0.56 120-03-030 528 University Av CD-C (GF)(P)40 du/ac 15 CC 0.38 8 1 Story Commercial; Retail Existing Commercial Use 1.46 124-33-066 2585 El Camino Real CN*15 du/ac 8 CN 0.4 8 Surface parking Parking serving adjacent commercial uses 0 132-40-059 3609 El Camino Real CN*15 du/ac 8 CN 0.42 8 Gas Station Underground Storage Tanks; Current Maximum Residential Density is 15 du/ac 0 132-41-083 3783 El Camino Real CN*15 du/ac 8 CN 0.42 8 1 Story Eating Drinking; Retail; Commercial: Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 1.33 137-01-070 2200 El Camino Real CN*15 du/ac 8 CN 0.41 8 Gas Station Underground Storage Tanks; Current Maximum Residential Density is 15 du/ac 0.11 132-38-027 425 Portage Av CS 30 du/ac 12 CS 0.4 8 1 Story Commercial; Office Existing Commercial Use 0.31 132-38-045 3200 Ash St CS 30 du/ac 11 CS 0.39 8 1 Story Office; Surface Parking Existing Commercial Use 4.6 132-38-046 3250 Ash St CS 30 du/ac 11 CS 0.38 8 2 Story Office Commercial Existing Commercial Use 1.13 148-09-010 4335 El Camino Real CS 30 du/ac 12 CS 0.4 8 2 Story Commercial; Office Existing Commercial Use 1.21 120-34-014 98 Encina Av CC 30 du/ac 13 CC 0.44 9 Surface parking Parking serving adjacent commercial uses 0.01 124-30-017 1921 El Camino Real CN*15 du/ac 9 CN 0.43 9 1 Story Eating Drinking; Surface parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.97 132-46-104 4128 El Camino Wy CN*15 du/ac 9 CN 0.45 9 2 Story Office Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.32 137-01-113 2280 El Camino Real CN*15 du/ac 9 CN 0.43 9 1 Story Eating Drinking; Surface parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.06 137-01-125 2257 Yale St CN*15 du/ac 9 CN 0.43 9 2 Story Office; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 1.23 132-38-026 435 Portage Av CS 30 du/ac 13 CS 0.45 9 1 Story Commercial Office Existing Commercial Use 0.34 132-39-071 429 Lambert Av CS 30 du/ac 13 CS 0.45 9 1 Story Automotive Services; Office Existing Commercial Use 0.23 167-08-036 4232 El Camino Real CS 30 du/ac 12 CS 0.43 9 1 Story Daycare School Existing Commercial Use 1.07 137-01-069 559 College Av CN*15 du/ac 10 CN 0.47 10 2 Story Retail; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 1.81 124-33-067 2501 El Camino Real CN*; CC (2)15/30 du/ac 10 CN 0.51 10 1 Story Eating Drinking Existing Commercial Use; Current Max Res Density is 15 du/ac on portion of lot 0.33 132-39-090 415 Lambert Av CS 30 du/ac 15 CS 0.51 10 1 Story Commercial Existing Commercial Use 3.44 132-41-096 3885 El Camino Real CS 30 du/ac 14 CS 0.47 10 1 Story Eating Drinking; Surface parking Existing Commercial Use 3.51 167-08-030 4230 El Camino Real CS 30 du/ac 15 CS 0.52 10 1 Story Automative Service Existing Commercial Use 0.04 167-08-035 4200 El Camino Real CS 30 du/ac 14 CS 0.48 10 1 Story Automotive Service Existing Commercial Use 0 124-29-020 150 Grant Av CC (2)30 du/ac 17 CC 0.59 12 1 Story Commercial; Office Existing Commercial Use 0.23 132-38-062 435 Acacia Av CS 30 du/ac 18 CS 0.62 12 1 Story Office Existing Commercial Use 7.47 167-08-042 4256 El Camino Real CS 30 du/ac 17 CS 0.59 12 1 Story Eating Drinking Existing Commercial Use 0.14 132-36-077 2675 El Camino Real CN*15 du/ac 13 CN 0.63 13 1 Story Eating Drinking; Surface parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.59 132-44-022 4115 El Camino Wy CN*15 du/ac 13 CN 0.64 13 1 Story Commercial: Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.75 137-08-080 3606 El Camino Real CN*15 du/ac 13 CN 0.65 13 Vacant Lot Current Maximum Residential Density is 15 du/ac 0 120-34-001 841 El Camino Real CS 30 du/ac 19 CS 0.64 13 Automotive Service Existing Commercial Use 0 167-08-037 4222 El Camino Real CS 30 du/ac 19 CS 0.63 13 1 Story Eating Drinking Existing Commercial Use 0.41 Housing Element Housing Sites Inventory March 26, 2013 Page 4 of 7 ZONING_RESIDENTIAL LAND_USE_LOT_REALISTIC ON_SITE_CONSTRAINTS/ OPPORTUNITIES ASSESSED_ APN SITE_ADDRESS DISTRICT DENSITY MAXIMUM YIELD DESIGNATION SIZE_(ac)CAPACITY EXISTING USE VALUE_ ALLOWED RATIO 132-43-153 4085 El Camino Wy CN*15 du/ac 14 CN 0.71 14 1 Story Retail; Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0.7 132-38-042 3201 El Camino Real CS 30 du/ac 20 CS 0.68 14 1 Story Retail; Surface Parking Existing Commercial Use 0.27 132-44-100 4135 El Camino Wy CN*15 du/ac 15 CN 0.75 15 2 Story Office; Underground Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 4.06 137-01-129 2390 El Camino Real CN*15 du/ac 15 CN 0.76 15 2 Story Commercial Surface Parking Existing Commercial Use; Current Maximum Residential Density is 15 du/ac 0 132-38-065 440 Portage Av CS 30 du/ac 22 CS 0.76 15 Surface parking Existing Commercial Use 6.23 142-20-054 3150 El Camino Real CS 30 du/ac 22 CS 0.75 15 1 Story Eating Drinking; Surface parking Existing Commercial Use 0.3 132-39-088 3399 El Camino Real CS; CN*30/15 du/ac 15 CS;CN 0.74 15 1 Story Eating Drinking; Surface parking Existing Commercial Use 0.29 142-20-013 2450 El Camino Real CS (AS1)30 du/ac 17 CS 0.57 17 2 Story Office; Surface Parking 1.32 142-20-014 2470 El Camino Real CS (AS1)30 du/ac 17 CS 0.57 17 2 Story Office; Surface Parking 0.96 142-20-047 2500 El Camino Real CS (AS1)30 du/ac 19 CS 0.64 17 2 Story Office; Surface Parking 1.19 142-20-012 507 California Av CS (AS1)30 du/ac 22 CS 0.75 19 1 Story Financial Service; Surface Parking 1 137-08-083 3400 El Camino Real CS (H); RM-15 30/15 du/ac 19 MF;CS 0.96 19 1 Story Eating Drinking Existing Commercial Use 1.74 132-38-056 430 Lambert Av CS 30 du/ac 30 CS 1.03 21 2 Story Office Commercial Existing Commercial Use 4.49 124-28-045 154 California Av CC (2)(R)(P)30 du/ac 34 CC 1.14 23 2 Story Retail Existing Commercial Use 0.29 148-09-014 4291 El Camino Real CS 30 du/ac 34 CS 1.16 23 1 Story Eating Drinking; Surface parking Existing Commercial Use 0.33 132-31-042 130 Sheridan Av GM 34 LI 1.13 34 Vacant Lot Needs Rezoning to allow Residential Use 0 142-20-035 3128 El Camino Real CS 30 du/ac 35 CS 1.18 24 1 Story Eating Drinking; Surface parking Existing Commercial Use 0.93 142-19-006 1501 California Av RP (AS2)30 du/ac 117 RO 3.93 55 1 to 2 Story Professional Office; Surface Parking 16.09 142-19-007 1451 California Av RP (AS2)30 du/ac 135 RO 4.52 55 2 Story Professional Office; Surface Parking 7.82 142-19-017 1601 California Av RP (AS2)30 du/ac 255 RO 8.51 70 3 Story Professional Office; Surface Parking Existing Commercial Use; Mayfield Agreement; 70 affordable units proposed 11.88 Subtotal 1,806 1,177 RESIDENTIAL DENSITY MAXIMUM YIELD ON SITE CONSTRAINTS/ASSESSED ALLOWED (based on FAR) (based on avg of 35 du/ac)OPPORTUNITIES VALUE RATIO 120-27-073 718 Emerson St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 2 1 Story; Automotive Service Small lot ; consolidation opportunity 0.53 120-28-084 918 Emerson St RT-35 25-50 du/ac 3 SOFA II CAP 0.08 2 1 Story; Automotive Service Small lot; consolidation opportunity 0 120-27-072 721 Emerson St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Professional Office; Surface Parking Small lot ; consolidation opportunity 0.93 120-28-004 160 Homer Av RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 Surface Parking Small lot ; consolidation opportunity 0.05 120-28-033 839 Emerson St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Personal Service; Surface Parking Small lot ; consolidation opportunity 0.02 120-28-036 825 Emerson St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Personal Service; Surface Parking Small lot ; consolidation opportunity 0.31 LAND USE DESIGNATION Existing Commercial Use; Mayfield Agreement; per agreement, application for market rate units to be submitted Existing Commercial Use; Mayfield Agreement; per agreement, application for market rate units to be submitted 3. Parcels with an Assessed Value Ratio greater than 1.5 were determined to have an artificially low assessed land value from parcels under the same ownership for more than 10 years; the assessed land value is far below current market land values. 2. *CN Parcels to be rezoned to 20 units per acre. Table 3-5 Table of SOFA II Housing Sites 1. Parcels highlighted in orange denotes zoning density greater than 20 units per acre; parcels with proposals for market rate housing are excluded. Notes: EXISTING USEZONING DISTRICTSITE ADDRESSAPN REALISTIC CAPACITYLOT SIZE (ac) Housing Element Housing Sites Inventory March 26, 2013 Page 5 of 7 ZONING_RESIDENTIAL LAND_USE_LOT_REALISTIC ON_SITE_CONSTRAINTS/ OPPORTUNITIES ASSESSED_ APN SITE_ADDRESS DISTRICT DENSITY MAXIMUM YIELD DESIGNATION SIZE_(ac)CAPACITY EXISTING USE VALUE_ ALLOWED RATIO 120-28-080 943 Emerson St RT-35 25-50 du/ac 3 SOFA II CAP 0.11 3 1 Story Professional Office Small lot; consolidation opportunity 1.04 120-28-081 935 Emerson St RT-35 25-50 du/ac 3 SOFA II CAP 0.11 3 1 Story Personal Service Small lot; consolidation opportunity 0.59 120-28-082 929 Emerson St RT-35 25-50 du/ac 3 SOFA II CAP 0.11 3 1 Story SFD Small lot; consolidation opportunity 0.01 120-28-085 926 Emerson St RT-35 25-50 du/ac 3 SOFA II CAP 0.11 3 2 Story Personal Service; Office Small lot; consolidation opportunity 0.34 120-28-090 931 High St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 story light manufacturing Small lot ; consolidation opportunity 0.19 120-28-091 925 High St RT-35 25-50 du/ac 5 SOFA II CAP 0.14 3 Vacant; Auto Storage Small lot ; consolidation opportunity 0.01 120-28-093 960 High St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Automotive Service Small lot ; consolidation opportunity 0.59 120-30-048 1027 Alma St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Professional Office Small lot ; consolidation opportunity 0.79 120-30-049 1019 Alma St RT-35 25-50 du/ac 4 SOFA II CAP 0.12 3 1 Story Retail; Surface Parking Small lot ; consolidation opportunity 1.25 120-28-003 815 High St RT-35 25-50 du/ac 4 SOFA II CAP 0.13 4 1 Story Professional Office Small lot ; consolidation opportunity 1.55 120-28-005 160 Homer Av RT-35 25-50 du/ac 5 SOFA II CAP 0.14 4 Surface Parking Small lot ; consolidation opportunity 0.02 120-28-051 190 Channing Av RT-35 25-50 du/ac 6 SOFA II CAP 0.17 5 1 Story Professional Office Small lot ; consolidation opportunity 1.45 120-28-092 940 High St RT-35 25-50 du/ac 6 SOFA II CAP 0.18 5 1 story light manufacturing Small lot ; consolidation opportunity 0.62 120-28-094 145 Addison Av RT-35 25-50 du/ac 6 SOFA II CAP 0.17 5 1 Story Professional Office Small lot ; consolidation opportunity 0.77 120-28-099 829 Emerson St RT-35 25-50 du/ac 6 SOFA II CAP 0.19 5 1 Story Personal Service; Office; Surface Parking Small lot ; consolidation opportunity 0.89 120-27-048 700 Emerson St RT-35 25-50 du/ac 8 SOFA II CAP 0.24 6 1 Story Professional Office; Surface Parking Existing Commercial Use 1.55 120-27-049 701 Emerson St RT-35 25-50 du/ac 8 SOFA II CAP 0.22 6 1 Story Personal Service; Surface Parking Existing Commercial Use 1.04 120-28-040 849 High St RT-35 25-50 du/ac 8 SOFA II CAP 0.24 6 1 Story Professional Office Existing Commercial Use 0.89 120-28-050 901 High St RT-35 25-50 du/ac 11 SOFA II CAP 0.32 6 Vacant; Auto Storage Existing Commercial Use 0 120-28-095 999 Alma St RT-35 25-50 du/ac 8 SOFA II CAP 0.24 6 1 Story Retail Existing Commercial Use 1.3 120-30-050 100 Addison Av RT-35 25-50 du/ac 8 SOFA II CAP 0.24 6 1 Story Retail; Surface Parking Existing Commercial Use 0 120-28-097 925 Alma St RT-50 25-50 du/ac 8 SOFA II CAP 0.24 6 1 Story Professional Office Existing Commercial Use 1.2 120-28-038 882 Emerson St RT-35 25-50 du/ac 8 SOFA II CAP 0.25 7 2 Story Personal Service; Medical Office; Surface Parking Existing Commercial Use 8.86 120-28-086 930 Emerson St RT-35 25-50 du/ac 8 SOFA II CAP 0.25 7 1 Story Automotive Service Existing Commercial Use 2.04 120-28-089 965 High St RT-35 25-50 du/ac 12 SOFA II CAP 0.35 9 1 Story Professional Office; Surface Parking Existing Commercial Use 0.47 120-27-046 700 High St RT-50 25-50 du/ac 12 SOFA II CAP 0.36 9 1 Story Office Existing Commercial Use 1.64 120-27-075 774 Emerson St RT-35 25-50 du/ac 16 SOFA II CAP 0.48 13 1 Story Retail Existing Commercial Use 1.76 120-28-037 840 Emerson St RT-35 25-50 du/ac 16 SOFA II CAP 0.48 13 Surface Parking Parking serving adjacent commercial uses 0.03 Subtotal 220 171 Housing Element Housing Sites Inventory March 26, 2013 Page 6 of 7 ZONING_RESIDENTIAL LAND_USE_LOT_REALISTIC ON_SITE_CONSTRAINTS/ OPPORTUNITIES ASSESSED_ APN SITE_ADDRESS DISTRICT DENSITY MAXIMUM YIELD DESIGNATION SIZE_(ac)CAPACITY EXISTING USE VALUE_ ALLOWED RATIO 132-41-025 397 Curtner Ave.RM-30 30 du/ac 6 MF 0.19 4 2 story duplex Existing Residential 0.73 003-02-021 725 University Av RM-30 30 du/ac 7 MF 0.25 5 1 Story Office; Surface Parking Existing Commercial Use 0.4 003-02-022 489 Middlefield Rd RM-30 30 du/ac 7 MF 0.25 5 1 Story Office; Surface Parking Existing Commercial Use 0.12 120-04-043 704 Webster St RM-30 30 du/ac 7 MF 0.22 5 1 Story Professional Office; Surface Parking Existing Commercial Use 0.67 120-16-046 720 Cowper St RM-30 30 du/ac 7 MF 0.23 5 1 Story Office; Surface Parking Existing Commercial Use 0.49 124-27-038 2185 Park Bl RM-30 30 du/ac 7 MF 0.25 5 2 Story Office; Surface Parking Existing Commercial Use 1.21 124-27-039 2149 Park Bl RM-30 30 du/ac 7 MF 0.25 5 2 Story Office; Surface Parking Existing Commercial Use 0.74 120-03-038 610 University Av RM-40 40 du/ac 8 MF 0.22 5 2 Story Professional Office; Surface Parking Existing Commercial Use 0.22 003-02-043 575 Middlefield Rd RM-30 30 du/ac 8 MF 0.28 6 2 Story Office; Podium Parking Existing Commercial Use 0.19 132-41-072 405 Curtner Av RM-30 30 du/ac 8 MF 0.28 6 Vacant Lot Portion of lot serves as a driveway to adjacent surface Parking 0 003-02-048 547 Middlefield Rd RM-30 30 du/ac 10 MF 0.36 7 2 Story Office; Surface Parking Existing Commercial Use 1.61 124-28-043 2211 Park Bl RM-30 30 du/ac 10 MF 0.34 7 1 Story Office; Surface Parking Existing Commercial Use 1.26 003-02-047 720 University Av RM-30 30 du/ac 12 MF 0.41 8 1 Story Office; Surface Parking Existing Commercial Use 0.37 137-01-121 531 Stanford Av RM-30 30 du/ac 12 MF 0.4 8 2 Story Hotel: Surface Parking Existing Commercial Use 4.91 120-16-041 400 Forest Av RM-40 40 du/ac 18 SOFA I CAP 0.45 9 1 Story Medical Office; Podium Parking Existing Commercial Use 1.6 120-16-042 430 Forest Av RM-40 40 du/ac 20 SOFA I CAP 0.51 10 1 Story Automotive Service Existing Commercial Use 0.91 137-37-004 4102 El Camino Real RM-30 30 du/ac 19 MF 0.64 13 1 Story Religious Institution Existing Non-Residential Use 0.02 137-24-034 4146 El Camino Real RM-15 15 du/ac 15 MF 0.77 15 Vacant Lot Current Maximum Residential Density is 15 du/ac 127-15-023 4151 Middlefield Rd RM-15 15 du/ac 18 MF 0.93 18 2 Story Office; Surface Parking Existing Commercial Use 1.46 132-42-074 3945 El Camino Real RM-30; CS 30 du/ac 26 MF;CS 0.89 18 1 to 2 Story Professional Office; Surface Parking Existing Commercial Use 1.35 132-42-073 3901 El Camino Real RM-30 30 du/ac 33 MF 1.1 22 2 Story Motel; Surface Parking Existing Commercial Use 1.39 132-38-059 340 Portage Ave RM-30 30 du/ac 374 MF 12.47 75 1 Story Commercial/Retail Existing Commercial Use 4.68 000-00-000 1170 Welch Rd RM-40 40 du/ac 84 RO 2.11 71 Vacant Lot Opportunity for expansion of adjacent existing multifamily residential 0 Subtotal 723 332 Total Number of Units 1,680 1. Parcels highlighted in orange denotes zoning density greater than 20 units per acre; parcels with proposals for market rate housing are excluded. 2. *CN Parcels to be rezoned to 20 units per acre. Table 3-6 Table of Residentially Zoned Sites with Commercial Uses 3. Parcels with an Assessed Value Ratio greater than 1.5 were determined to have an artificially low assessed land value from parcels under the same ownership for more than 10 years; the assessed land value is far below current market land values. Notes: Housing Element Housing Sites Inventory March 26, 2013 Page 7 of 7 ZONING_RESIDENTIAL LAND_USE_LOT_REALISTIC ON_SITE_CONSTRAINTS/ OPPORTUNITIES ASSESSED_ APN SITE_ADDRESS DISTRICT DENSITY MAXIMUM YIELD DESIGNATION SIZE_(ac)CAPACITY EXISTING USE VALUE_ ALLOWED RATIO 132-41-091 3877 El Camino Real * RM-30; CS 30 du/ac 22 MF;CS 0.75 15 1 Story Eating Drinking; Commercial; Surface Parking Existing Commercial Use 0.08 Parcel designated to meet the City's previously unaccommodated need from 1999-2006 Housing Element per AB2348 From: Sam Tepperman-Gelfant [mailto:stepperman-gelfant@publicadvocates.org] Sent: Monday, September 10, 2012 5:21 PM To: Paul McDougall; Melinda Coy Cc: Richard Marcantonio Subject: Palo Alto Draft Housing Element Hi Melinda and Paul, Our review of Palo Alto’s draft Housing Element has left us with a lot of serious questions. Since the City has asked you for an expedited review, we are sharing some of those with you, and hope that we can set up a time to discuss these and other concerns by phone. Table 3-10 tells us that the City has a remaining lower-income (VLI/LI) need of 1,044 units, but does not include AB 1233 units. The draft notes that its rezoning program in the prior element (program H-14) was not implemented as to 3 sites on the inventory, and that “As required by State law, sites that were proposed for rezoning in the previous housing element but were not rezoned during the planning period will be rezoned.” (Draft, p. 172.) The draft, however, does not quantify or address the portion of the lower-income RHNA that carries over into this planning period. Since the draft does not differentiate VLI and LI site capacity from capacity on sites on which the remaining moderate and above-moderate income need will be met (another 624 units), it is impossible to tell which sites will accommodate what portion of the need at what income level. Table 3-10 goes on to tell us that “total capacity of housing inventory sites at 20 DU/AC” of 1,784 units. In a footnote, the draft then tells us that, actually, most of the Mayfield development is not at 20 DU/AC, and also that 15 units attributed to APN 137-24-034 and the 15 second units are not zoned at that density. Actually, that does not begin to tell the full story about these purported 1,784 units: • This total includes at least 347 units on at least 35 sites that do not currently allow residential development at 20 du/acre, and therefore cannot be claimed to accommodate lower-income housing needs. (There does not even appear to be a rezoning program for these sites – while a “Program 2.2.2” is referenced in the text on page 81, no such program actually appears in the Element. In any event, the implied rezoning with respect to these sites would not meet the requirements of AB 2348 since nearly all of the sites are mixed-use, there do not appear to be minimum densities proposed, and few, if any, of the sites would accommodate a minimum project size of 16 units.) • The inventory includes 250 units in the Mayfield Development. There are a number of problems with this. First, it seems unlikely that all of these units can be constructed by the end of the planning period -- the development agreement contemplates a development proposal for just 185 of these units by the end of 2013, with the remainder to be proposed no later than 2020. Second, even if all 250 units are constructed by the end of the planning period, between 180-200 of these units are planned to be market-rate units, and the affordability level of the remaining 50-70 BMR units is unspecified. • The inventory includes 113 units of capacity through the inclusion of condominiums in hotel projects, calculating that number as 25% of the units in 3 hotel projects that have already been proposed. No evidence is provided, however, that the developers of these projects actually plan to include condo units, or if so, at what affordability levels. • The inventory relies very heavily on very small sites – 137 sites are less than ½ acre (accounting for 850 units, nearly half of the claimed inventory capacity), and an additional 29 sites are between ½ and 1 acre (accounting for 412 units). Of the 507 units supposedly accommodated on sites larger than 1 acre, 75 would require rezoning and 69 are theoretical condominium units in hotel projects discussed above. • The City claims it will permit another 15 second units by the end of the planning period, despite having produced only 13 second units in the first five years of the planning period. Moreover, all 13 of those prior second units were affordable at the moderate income level. (See 2011 Annual Report, p. 3 of 5.) There is no reason to expect that any second units will count toward the lower-income RHNA share. Obviously, the City has a lot of work to do before we can say definitively what its true unmet RHNA (including AB 1233 units) is, and how much can be accommodated on the inventoried sites. But from what we can see in the draft, it looks like a lot of these sites are not actually suitable for lower-income units. In fact, it’s not clear that the inventory is even sufficient to meet the total RHNA at all income levels. Please let me know if there is a good time for you to check in with you this week about these issues. Thanks, Sam Sam Tepperman-Gelfant
Senior Staff Attorney
131 Steuart Street | Suite 300 | San Francisco CA 94105
415.431.7430 x324 
stepperman-gelfant@publicadvocates.org

 Public Advocates Inc. | Making Rights Real | www.publicadvocates.org CONFIDENTIAL COMMUNICATION
 This email message and any attachments are intended only for the use of the addressee named above and may contain information that is privileged and confidential. If you are not the intended recipient, any dissemination, distribution, or copying is strictly prohibited. If you received this email message in error, please immediately notify the sender by replying to this email message or by telephone. Thank you. ********************************************************* This email and any files attached are intended solely for the use of the individual or entity to which they are addressed. If you have received this email in error, please notify the sender immediately. This email and the attachments have been electronically scanned for email content security threats, including but not limited to viruses. PUBLIC INTEREST LAW FIRM Oficina Legal de Interés Público Law Foundation of Silicon Valley 152 North Third Street, 3rd Floor San Jose, California 95112 Telephone (408) 293-4790 • Fax (408) 293-0106 www.lawfoundation.org September 24, 2012 SENT VIA E-MAIL ONLY: tim.wong@cityofpaloalto.org. Tim Wong. Senior Planner City of Palo Alto, Planning & Community Environment 250 Hamilton Avenue Palo Alto, CA 94301 Re: City of Palo Alto Draft 2007-2014 Housing Element Dear Mr. Wong: I write to provide comments regarding the City of Palo Alto’s draft housing element1 on behalf of Public Interest Law Firm (PILF), a project of the Law Foundation of Silicon Valley. PILF’s mission is to protect the human rights of individuals and groups in the Silicon Valley area who face barriers to adequate representation in the civil justice system, using impact litigation and advocacy. One of our advocacy priorities is ensuring access to affordable housing throughout Santa Clara and San Mateo Counties. We acknowledge the work that the City has done in the preparation of its draft housing element. However, the draft housing element has a number of serious deficiencies, as discussed in detail below. Programs The draft housing element’s programs section lacks sufficient detail to ensure that that the programs will be effective in meeting their stated objectives. Many of the programs fail to set forth any concrete actions; few indicate which agency or agencies of the city will be responsible for implementing the program; and none has a specific timeline in which actions must be taken. According to HCD, each program should set forth: • Definite time frames for implementation (e.g., by June 2009, ongoing, annually during the planning period, upon adoption of general plan amendment, etc.). 1 All references to the draft housing element refer to City of Palo Alto Housing Element, available at http://www.cityofpaloalto.org/civicax/filebank/documents/30833 [last accessed Sept. 22, 2012]. 2 • Identification of agencies and officials responsible for implementation (e.g., planning department, redevelopment agency, county community development department, city building official, housing manager, public housing authority, etc.). • Description of the local government’s specific role in program implementation (e.g. a description of how the City will market the availability of rehabilitation funds). • Description of the specific action steps to implement the program. • Proposed measurable outcomes (e.g., the number of units created, completion of a study, development of a homeless shelter, initiation of a rezone program, preservation of at-risk units, annexation of land within a sphere of influence). • Demonstration of a firm commitment to implement (e.g., the City will apply for HOME funds by June 2009). • Identification of specific funding sources, where appropriate (e.g., dollar amounts of annual funding entitlements or allocations – CDBG, HOME, ESG, HOPWA, Continuum of Care, redevelopment agency’s low/moderate-income housing funds, bond proceeds, tax credit allocations, and other federal, State and local resources).2 In contrast, the draft housing element’s programs tend to be only one or two sentences, with very little in the way of concrete actions or timelines. In light of the fact that Palo Alto is finalizing its housing element so near the end of the planning period, it is imperative that every program includes clear actions and timelines to ensure that programs are completed in a timely manner. A particularly stark example of the program section’s inadequacy is the program for preservation of affordable units, which reads, simply: “Preserve affordable housing stock and continue to renew existing funding sources supporting rehabilitation and maintenance activities.”3 State law requires a much higher level of detail in the preservation program: the program must contain a discussion of funding sources for affordable housing preservation, and the statute also encourages cities to include strategies for preserving at- risk developments.4 Given that Palo Alto is at risk of losing 400 affordable units during the planning period,5 its housing element should include a more robust program regarding preservation of those units. Site Inventory We agree with the concerns regarding the draft housing element’s site inventory raised by Sam Tepperman-Gelfant of Public Advocates in his earlier correspondence. Additionally, we note that the City appears to rely on many sites with existing uses to 2 HCD, “Program Overview and Quantified Objectives,” available at http://www.hcd.ca.gov/hpd/housing_element2/PRO_overview.php. 3 Draft housing element, supra, at p. 156. 4 Gov. Code, § 65583, subd. (c)(6). 5 Draft housing element, supra, at pp. 60-61. 3 meet its housing need.6 However, the draft housing element does not provide information or analysis regarding these sites’ potential for redevelopment. According to HCD, “[t]he inventory must consider the impact of existing development when calculating realistic development capacity.”7 The analysis of sites with existing uses should include whether existing uses are expected to continue, whether those uses are compatible with housing development, and the likelihood that housing will be developed on those sites within the planning period. Claiming Credit for Already-Permitted Units The draft housing element seeks to credit 1206 units that have been permitted, entitled, and/or constructed since the beginning of the planning period toward its RHNA obligation.8 This total includes 325 units at the very low-, low-, and moderate-income levels.9 However, to credit already-permitted units toward its lower income RHNA obligation, the housing element must demonstrate the affordability of those units through one or more of the following: • subsidies, financing or other mechanisms that ensure affordability (e.g., MHP, HOME, or LIHTC financed projects, inclusionary units or RDA requirements); • actual rents; and • actual sales prices.10 The City should amend its housing element to include this information about the units it seeks to credit toward its lower-income housing need. If this information is unavailable for particular units, those units should be counted toward Palo Alto’s above-moderate- income housing need. If doing so increases Palo Alto’s unmet RHNA need for lower- income households, the City may need to amend its programs and site inventory to ensure that it will be able to meet that need during the planning period. Governmental Constraints The draft housing element identifies second units as a potential source of affordable housing during the planning period. However, the City’s parking requirements for second units are relatively restrictive: “one covered and one uncovered parking space for second units greater than 450 square feet.”11 The housing element should analyze whether these restrictions constrain the development of second units. 6 Draft housing element, supra, at pp. 83-88. 7 HCD, “Analysis of Sites and Zoning,” available at http://www.hcd.ca.gov/hpd/housing_element2/SIA_zoning.php. 8 Draft housing element, supra, at p. 66. 9 Ibid. 10 HCD, “Regional Housing Needs Assessment (RHNA),” available at http://www.hcd.ca.gov/hpd/housing_element2/HN_PHN_regional.php. 11 Draft housing element, supra, at p. 124. 4 Along the same lines, the housing element should evaluate whether site and design review in the D and PF zones constraints the development of housing in those zones.12 It should also describe any input it received from developers regarding fees, permitting procedures, land use controls, or other potential constraints.13 Constraints to the Development of Housing for People with Disabilities The housing element should include a more comprehensive analysis of constraints to the development of housing for people with disabilities. While the draft housing element notes that Palo Alto properly allows residential care facilities for six or fewer individuals by right in all residential districts,14 it does not indicate how larger residential care facilities are treated. The housing element should discuss larger residential care facilities, including whether any of the zoning requirements for these facilities constrain their development. While the draft housing element indicates that the City grants reasonable accommodations to facilitate the development of housing for people with disabilities,15 it does not state whether or not the City has a reasonable accommodation policy or ordinance. If the City does not have a formal reasonable accommodation policy, we encourage it to include adoption (and advertisement) of such a policy as a program in its housing element. Non-Governmental Constraints The draft housing element suggests that new housing development in Palo Alto faces opposition from the community.16 However, it fails to identify community opposition as a non-governmental constraint to the development of new housing. 12 Draft housing element, supra, at p. 129. 13 See HCD, “Fees and Exactions,” available at http://www.hcd.ca.gov/hpd/housing_element2/CON_fees.php. 14 Draft housing element, supra, at pp. 145-146. 15 Draft housing element, supra, at pp. 146-147. 16 See draft housing element, supra, at p. 121 (“There is community concern that additional new housing would introduce more new students into the school district and would further impact its facilities which are already near or at capacity.”) 5 Conclusion Thank you very much for considering these comments regarding Palo Alto’s draft housing element. I would be happy to speak with the City regarding the concerns described above. If you would like to set up a time to talk, please call me at (408) 280- 2429 or email me at melissam@lawfoundation.org. Sincerely, /s/ Melissa A. Morris Senior Attorney cc: Melinda Coy, HCD Sam Tepperman-Gelfant, Public Advocates City of Palo Alto Page 1 Planning and Transportation Commission 1 Verbatim Minutes 2 April 10, 2013 3 DRAFT 4 EXCERPT 5 6 Public Hearing 7 8 Housing Element Update: Review and recommendation to City Council regarding the Draft 9 Comprehensive Plan Housing Element for the 2007-2014 Housing Cycle. 10 11 Chair Martinez: With the Commission’s consent to that we will move forth with Agenda Item 12 Number 1 and that is to review the Draft Housing Amendment, excuse me, Housing Element as 13 approved by the California Department of Housing Community Development (HCD) and receive 14 our comment and recommendation for approval and incorporation into the Comprehensive Plan. 15 Let me start with a couple words. When the Chair of the Planning Transportation Commission 16 asks you to volunteer to serve on a subcommittee pay careful attention. I was asked by former 17 Chair Garber to serve on the Comprehensive Plan Subcommittee in 2009. We thought it was a 18 slam dunk. Housing Element was our first task to consider. We thought we’d be done in three 19 months and (slapping sound) note for the record the Chair kind of slapping his hands as to clear 20 the dust, but it takes longer than that. 21 22 We’re pleased that we have before us tonight the approved Draft Housing Element and we will 23 begin with a presentation by staff. Let me add, well, I’ll come back to it. I really want to try to 24 give new members of the Commission a chance to talk about the Housing Element and weigh in, 25 provide their comments. We are under limitation however that we have very limited ability to 26 change the Housing Element as it now has been approved. Nevertheless you should have the 27 opportunity to ask questions and comment and perhaps recommendations for next time. So we’ll 28 have a chance to do that. I’m sure there are members of the public that would care to hear those 29 comments as well, so that time will be well served. But let’s begin with the staff report and then 30 we’ll go to open the public hearing. Staff? 31 32 Aaron Aknin, Assistant Director: Thank you. You stole my thunder a little bit. I was about to 33 say similar things to what you just said. In the context of tonight’s conversation the Chair 34 actually provided staff with a number of questions which I think act as a good foundation for 35 tonight’s discussion. I believe there were about 10 questions here that were distributed to the 36 Commission along with initial staff answers here and those are also back for the public on the 37 table in back. And I think they do provide a good framework for discussion tonight. 38 39 The City Attorney could go a little bit more into what are some of the constraints of tonight’s 40 discussion, but I think there’s two overall things that could be answered tonight. Number one, 41 answer some of the questions that the public is asking in general about housing elements. And 42 Number two, to point out policies and programs and things that you like about this housing 43 element that could help as we go in transition to the next Housing Element Cycle, which is just 44 around the corner. So at this point I’ll turn it to Cara. 45 46 Cara Silver, Sr. Assistant City Attorney: Thank you. Cara Silver, Senior Assistant City 47 Attorney. We have discussed the Housing Element several times in the past and as you all know 48 City of Palo Alto Page 2 we are now at the home stretch of approving the 2007 through 2014 Housing Element. There are 1 a couple of legal issues that we’ve discussed in the past, but it does bear repeating. And that is 2 that the significance of having an effective certified Housing Element is very important. If the 3 City does not have a certified Housing Element there is a potential that applicants could sue the 4 City for noncompliance and the remedies for not having a certified Housing Element are 5 extremely stringent. They include a possible moratorium on all development in the City. It 6 includes of course attorney’s fees and there could be other remedies imposed as well that limit 7 the City’s land use authority. So it is extremely important to bring this across the finish line as 8 quickly as possible. 9 10 Second ramification that we’ve talked about in the past about not having a certified Housing 11 Element, and in particular not getting this particular Element certified before the next cycle 12 begins is the potential for a carry over. And that is that any unfulfilled housing units that are not 13 built in this current cycle are in fact by statute carried over to the next cycle and we would have 14 to find additional housing sites for those carryover units as well in the event that we were not to 15 get this Element certified by the end of the cycle. 16 17 So those are the important issues. This Housing Element has been conditionally approved by 18 HCD. They have, we’ve gone through several rounds of negotiations with them. They’re very 19 familiar with all of the programs and policies and they took a special look at the inventory sites 20 and any changes or modifications will be obviously scrutinized by HCD. That does not mean 21 that the City does not have the discretion to make changes at this late stage, but it does 22 jeopardize City’s ability to get it finally certified by HCD. Thank you. And with that, Tim are 23 you going to give an additional presentation? 24 25 Tim Wong, Senior Planner, Affordable Housing: So good evening. I’m Tim Wong, Senior 26 Planner and I have a brief presentation for you. As Aaron and Cara both noted, yeah we’re 27 getting to the end of a very long process. And let’s go ahead, just some basic information about 28 Housing Element. It’s updated or it’s supposed to be updated every five years. We’re a little 29 behind with that. But one of the unique things about the Housing Element is it’s the only State 30 mandated element that requires State approval. 31 32 As part of the Housing Element as Cara was mentioning it must provide, it must identify 33 sufficient sites for the Regional Housing Needs Allocation (RHNA) cycle. And so for the 2007-34 2014 RHNA cycle the City had to find sufficient sites to accommodate 2,860 units. That doesn’t 35 necessarily mean the City has to build, it just means that it has to zone or accommodate for that 36 number during, between 2007 and 2014. And again as Cara mentioned there are some legal 37 implications if the Housing Element is not certified; again, subject to lawsuit and also the 38 potential for carryover for the next cycle. 39 40 Just a quick timeline of where we came from. Last time the Planning and Transportation 41 Commission (PTC) reviewed the draft Housing Element was in April of 2012. The City Council 42 in July 2012 approved it being submitted for HCD review and it was submitted to HCD in 43 August 2012. We received our response letter from HCD about some of their concerns about the 44 draft Housing Element, which I’ll be going into later. And the City responded to the HCD 45 response letter in January 29 of this year and with some back and forth, additional back and 46 forth, the City submitted its final response to HCD on March 26th and on the 29th is when HCD 47 mailed their letter stating that the City with these proposed programs would be in compliance 48 with State Housing Element law and now it’s in front of the PTC for review. 49 City of Palo Alto Page 3 1 I would like, there were many, a number of revisions made to the Housing Element based on 2 HCD’s comments. However a majority of the changes were to the Housing Inventory Sites and 3 also with the programs. Many programs were revised and a number of programs were added so 4 this presentation will focus on that. To start with the Housing Inventory Sites, again our 5 allocation was 2,860 units and as of March of 2013 the City has either a process, units in 6 building permit stage or built 1,217 units which meant that the City had to find the sites to 7 accommodate 1,643 sites or units, excuse me. 1,643 units. And based on Council direction 8 given in May of 2010 these sites were primarily focused on California Ave., that corridor, El 9 Camino Real, and University Avenue. And they also gave the direction that there would be no 10 rezoning of commercial sites to residential. No loss of retail sites. 11 12 In addition staff when selecting certain sites looked at lots larger than 10,000 square feet with 13 minimum density of 20 units per acre. And the final product which you have before you is a 14 Housing Inventory Sites list of 1,680 units. So we have a “surplus” of 37 units currently at this 15 time. 16 17 Just to refer to the HCD letter dated October 18th. They had a number of comments. I believe 18 the letter is in your staff report as Attachment C, but you have their response. There were a 19 number of comments, but I’ll only highlight the significant comments that they made. One of 20 their comments was about realistic capacity. HCD had a concern that since many of our 21 identified sites were commercial or mixed use we’re depending for a lot of mixed use to fulfill 22 our RHNA allocation. Therefore they were concerned about the viability of mixed use and also 23 the size of lots seeing how we’re looking at lots down to 10,000 square feet. And so as part of 24 the City’s response we created Program 2.2.7, which we will look into providing incentives for 25 lot consolidation to try to get a greater yield from these smaller lots and also to help incentivize 26 or increase the probability of these mixed use developments on the smaller lots. 27 28 In addition, staff added Program 2.2.9, which monitors the development of the properties on the 29 Housing Inventory Sites. HCD again was concerned about our, since our surplus was so small 30 and if a couple of the Housing Inventory Sites were not developed at their realistic capacity at 20 31 units per acre they were concerned that we would not be able to fulfill our requirements therefore 32 this monitoring program has been implemented or will be implemented to make sure that if the 33 existing sites are not developed at 20 units per acre staff will look for other sites to backfill that 34 shortage. And lastly additional review and greater analysis of each site was done to help meet, 35 help satisfy HCD’s concerns in regards to those sites. 36 37 Another significant comment was about emergency shelters. In State law requires that each 38 jurisdiction designate a zone or zones to help accommodate an emergency shelter. And the 39 shelter with whatever zone is designated must be done by right. In other words a ministerial type 40 permit and no discretionary action or Conditional Use Permit (CUP) could be required of the 41 emergency shelter. The City’s unmet need right now is 107 beds, which we calculated a shelter 42 would need approximately 107 beds. Therefore, we designated, staff has designated the 43 Research Office and Limited Manufacturing Embarcadero ROLM (E) Zone District as the zone 44 district to accommodate the emergency shelter. Therefore staff also added Program 3.5.2, which 45 will amend the ROLME Zone District to allow emergency shelter by right. 46 47 And smaller, another issue was a previous unaccommodated need. This kind of refers back to 48 Cara in that there was a small rollover from our current Housing Element. There was one parcel 49 City of Palo Alto Page 4 in the previous Housing Inventory list that was not rezoned. Therefore we had unaccommodated 1 need of 15 units. Therefore as part of this Housing Element we had to find a site that would 2 accommodate 15 units in addition to the 2,860 that were required of this Housing Element and as 3 part of that staff has designated 3877 El Camino Real as the site to help fulfill our AB2348 4 requirement. 5 6 And just moving on last, couple more comments that HCD made is that they wanted clear 7 identifiable objectives for each of the City’s programs. And each program as they suggested 8 should include the City’s role in implementation, implementation timelines, objectives, and 9 identification of responsible agencies. So as a response staff has included a five year objective, a 10 funding source of how the implementation would be funded, who the responsible City agency 11 would be in implementing the program, and a timeframe, and that has also met with HCD’s 12 approval. 13 14 Let’s see… and also there were a couple other comments. Hotel condominiums. What had 15 happened is after PTC had reviewed the draft Housing Element in 2012 when the Council 16 reviewed the Housing Element they had also requested that hotel condominiums be included as 17 part of the Housing Inventory Sites, but after review it was found that they would, hotel 18 condominiums do not meet the definition of housing units. They don’t have a kitchen. 19 Therefore those have been removed from the previous draft Housing Element. And also there 20 was also a State law that cities must analyze housing needs for persons with developmental 21 disabilities so that additional text has been added. 22 23 Couple last things, a little less significant. HCD had requested further explanation about the 24 City’s agreement, the Mayfield agreement and how just additional details about what, how many 25 units were for affordable, how many for market, and also what the timeline is in developing 26 those additional 250 units. And lastly, rezoning programs. Those weren’t included. There are 27 some CN zoned parcels in the Housing Inventory Sites. Currently CN zones have a maximum of 28 15 units per acre and all those CZ zoned parcels in the Housing Inventory Sites will be up zoned 29 to 20 units per acre. In addition there are a couple GM zoned sites that will be rezoned to allow 30 for residential uses. 31 32 And we have received comments from a couple law firms, Public Advocates and the Public 33 Interest Law Firm. And staff has worked closely with them and their comments were many of 34 HCD’s comments were driven by these two law firm’s comments including they were concerned 35 about reliance on small sites, talking about the previous unaccommodated need and about the 36 Mayfield agreement. So pretty much whatever comments Public Advocates and the Public 37 Interest Law Firm made were rolled into HCD’s comments. So both the law firm’s comments 38 have been addressed as part of these revisions. 39 40 And the next steps. It’s anticipated that staff will take the revised Housing Element to the 41 Regional Housing Mandate Committee in May with a possible date with the City Council in 42 June. And we’re anticipating HCD certification also in June. From June 2013 staff has one year 43 to implement many of the zoning changes as listed in the programs. And finally it’s time to gear 44 up for the 2015 to 2022 Housing Element, which they’re looking at a deadline of December of 45 2014. So that concludes staff’s presentation. 46 47 Chair Martinez: Great, thank you Tim. Let’s open the public hearing. There aren’t any members 48 of the public that wish to speak… pardon? We do have some cards. Vice-Chair. 49 City of Palo Alto Page 5 1 Vice-Chair Michael: We have a speaker, Patricia Saffir, and you’ll have three minutes. Thank 2 you very much. 3 4 Patricia Saffir: Good evening. My name is Patricia Saffir and I’m speaking tonight on behalf of 5 the League of Women Voters of Palo Alto. Chairman Martinez and Members of the 6 Commission, the League of Women Voters is very pleased as you’ve stated that you were that 7 you have before you tonight a Housing Element proposal that has received the approval of the 8 State Department of Housing and Community Development and they found it fulfilled the 9 requirements of the Housing Development law. We appreciate the hard work of the staff and the 10 Commission in getting us finally to this point. The League generally supports the contents of the 11 document although we still believe the vision statement should include a sentence concerning 12 our desire that our neighborhood supply adequate diverse housing and be free of discrimination. 13 We are however happy that the document now clearly states the City’s intention to do its part to 14 work to fulfill the Association of Bay Area Governments (ABAG) fair share housing mandates. 15 16 We approve the new programs added at the behest of the State HCD and believe they will help 17 towards meeting the goals of the Housing Element. We also like the addition of the five year 18 objectives, funding sources, responsible agency, and timeframe for each program. This greatly 19 clarifies the needed actions. We recognize that the Housing Element has been written over a 20 long time and is a complicated document. It would be helpful however if more of the tables and 21 charts were dated to indicate when they were prepared. 22 23 In conclusion, we urge you to approve the Housing Element before you tonight so we can soon 24 be in compliance with State law and therefore be eligible for housing, transportation, and 25 infrastructure funding programs from the State. Thank you very much for listening. Good 26 evening. 27 28 Chair Martinez: Thank you. 29 30 Vice-Chair Michael: And our next speak will be Bob Moss. 31 32 Robert Moss: I’m all done. Thank you Chair Martinez and Commissioners. I think the Housing 33 Element that you have so far is about the best compromise we can come up with, but there are a 34 few aspects of developing Palo Alto that I did not see really discussed or emphasized and I don’t 35 want them to be overlooked. The first one is Palo Alto housing is one of the four or five most 36 expensive in the entire country. During the collapse from the Great Recession a couple of years 37 ago typical housing prices nationwide went down between 30 and 50 percent. In Palo Alto the 38 worst they did was drop 13 percent. We have now recovered all of that plus an additional 8 to 10 39 percent. So when they talk about low income or affordable housing in Palo Alto unless the 40 people who are asking for it are willing to come up with the money it isn’t going to happen. 41 42 So one of the first things to point out is that Palo Alto was the first city, as far as I know, in this 43 State that required a proportion of developments to include low income housing. Subsidized 44 Below Market Rate (BMR) units originally started at 40 percent. That didn’t last too long 45 because nobody would build any housing 20 units or more. In fact the first development that 46 was built when the City adopted that is kitty-corner across the street. 19 units so they wouldn’t 47 have to put any BMR units in. So they cut that down to 10 percent and they cut the threshold to 48 five units. But that being said we are not going to be able to build the amount of housing that 49 City of Palo Alto Page 6 they’re talking about, the amount of affordable housing they’re talking about unless somebody 1 else comes up with a lot of money. 2 3 Second I notice there were some complaints because most of the areas which were identified for 4 housing increases were already occupied. Like upper store commercial buildings. Well that’s 5 what we’ve got in Palo Alto. That’s all we have to build on. There is no vacant land. So it 6 should be emphasized that we’re doing what we can to identify those sites. But if nobody wants 7 to tear down existing perfectly valid commercial building and build multifamily on it that’s their 8 choice, not ours. 9 10 Finally one of the things that you keep in mind that is overlooked frequently is every housing 11 unit which is built in Palo Alto, especially multifamily units cost the City between $1,600 and 12 $2,000 per year more for services than it pays in taxes. So at some point when you build an 13 additional 2,000 or 3,000 units our budget is taking a hit. So there are real problems both with 14 area and with costs building a large amount of housing in Palo Alto. 15 16 Chair Martinez: Thank you Mr. Moss. We shall leave the public hearing open in case 17 Commissioners have questions of those speakers. So the way in which I wanted to frame our 18 discussion tonight Commissioners is that we permit ourselves the luxury of talking about the 19 Housing Element in terms of what we would like to have seen, questions we have about how 20 we’ve undertaken this; really to help ourselves and help the public sort of understand how we’ve 21 come to tonight’s place in proposing to recommend the Housing Element and in recognition that 22 there are several Commissioners who didn’t have the chance to participate at all in the draft of 23 this Element. 24 25 The second thing that I wanted to do is give us a chance to look ahead and talk about sort of 26 where we go from here and how we make it more effective and questions about housing that Mr. 27 Moss raised in Palo Alto that really are germane to us having a workable housing policy. And 28 third I wanted us to reserve a period of time where we focus on the environmental review. so 29 rather than going back and forth from questions about the environmental document from one 30 Commissioner to move to questions of policy I’d like us to focus on the environmental review 31 portion of our recommendation for our third round. 32 33 So let’s see if that works, I’m not sure I’m clear, if you need clarifications. So commissioners 34 let’s start with a round of five minutes each. You don’t have to participate, but if you have 35 questions or comments about the Housing Element presented tonight let’s start with that. And 36 I’m going to start with Commissioner Panelli. Surprise. So as a new Commissioner if you have 37 questions about sort of how we got to where we are or questions about why we have a Housing 38 Element or anything of a nature of the process, I think this is a fair time for us to discuss in 39 general or specifically your questions or your concerns about our Housing Element. 40 41 Commissioner Panelli: So we’re going to talk about process and policy now and reserve 42 (interrupted) 43 44 Chair Martinez: Yes. Let’s see how that goes. Start a great (interrupted) 45 46 Commissioner Panelli: Ok, thank you Mr. Chair. I want to first just before I launch into a couple 47 of questions echo the sentiments of our esteemed Chair that the way to position this is what can 48 we do better for the next one. I think we’re sort of backs up against the wall; we’ve got to get 49 City of Palo Alto Page 7 this thing done, and it’s very good. But I do have a couple of questions. One is just a simple 1 question. Tim, you’d mentioned that we have a little bit more than we’re required. Do we get to 2 carry credits over? Is it only that we get to carry forward debits so to speak? 3 4 Mr. Wong: No, any of the parcels that are not developed we can carryover. So right now we’ve 5 identified approximately 1,600 units on X amount of parcels. If those don’t get developed within 6 the next year or so those can be carried over to the 2015-2022 cycle. 7 8 Commissioner Panelli: Maybe I, sorry. I probably mischaracterized the way I was phrasing it. 9 You had mentioned there were something like 37 units more than we would’ve been required to 10 have. Assuming all of those got developed, would we get to carry over that 37 or no? 11 12 Mr. Wong: Oh, I don’t think we can with the 37. 13 14 Mr. Aknin: No at that point they would just be kind of frozen within this cycle. You only get 15 credit for things that you’re planning for in the future that haven’t been built already. 16 17 Commissioner Panelli: Things that are entitled but not developed? That’s what gets carried over 18 to future (interrupted) 19 20 Mr. Aknin: No, not even entitled, things that are zoned. Sorry, things that are zoned not entitled. 21 22 Commissioner Panelli: Things that are zoned, not entitled, not developed. 23 24 Mr. Aknin: Correct. 25 26 Commissioner Panelli: Get carried over? 27 28 Mr. Aknin: Correct. 29 30 Commissioner Panelli: Ok. My next question is can you talk a little bit about how HCD, just 31 give, I know some of it, but I think it would be helpful for all of us as well as members of the 32 public who are interested to understand how HCD works together, comes up with their numbers 33 for what’s required in the State and then parcels that out and how that jives with what ABAG 34 sort of pushes on us. 35 36 Mr. Aknin: Ok, I’ll try to give the simplest answer possible because it’s somewhat complicated. 37 So the Department of Finance (DOF) creates population projections. And the way that State law 38 is formulated it says those DOF population projections then are created to household projections 39 and HCD is supposed to base their household projections on those population projections. So 40 then HCD says statewide we have to have X number of units built and then they distribute those 41 to each one of the regional agencies. So ABAG gets an allocation from HCD based on those 42 numbers. Then ABAG then distributes the units to either sub regions or to individual cities. 43 44 Commissioner Panelli: And then just building off of that though is it parceled out equally 45 meaning if the State says we need to have 11 percent more units to accommodate the population 46 growth does that mean every region gets 11 percent, or do they say these guys get more? Is it 47 percentage based, is it numbers based, is it… are there policies that say we want to promote more 48 City of Palo Alto Page 8 density in smaller areas or we want to promote continued conversion of farmland into suburbs? 1 What, can you help a little bit there? 2 3 Mr. Aknin: So the way it works now is they do population projected based on certain regions. 4 And then the way it is now SB375, which is basically the Land Use and Transportation Element 5 of AB32, which was the law that the Commission knows is aimed to reduce greenhouse gasses. 6 The law as its stated now states that it basically is encouraging higher density housing 7 development near transit locations to reduce the need for single occupancy vehicle trips long 8 distances. So what we’re seeing now is the trend to require cities that have additional transit 9 stops that are located near higher employment areas, higher employment regions to take on more 10 of a share of the overall housing. 11 12 Commissioner Panelli: Ok, so one last… so I kind of set you up a little bit there because what I 13 was trying to get at is my final question, which is if HSR goes through as planned and if Palo 14 Alto becomes one of the, what is it? The four stops in between San Jose and the city; does that 15 mean that we’re going to start to bear a greater share of housing units because of the transit 16 oriented housing policy that we see, we observed? 17 18 Mr. Aknin: I don’t know exactly how the methodology works, but I would say no. I think it has 19 to do more with how local rail stations work and local commuting rail station works and it’s 20 actually even more tied to what regions have additional job growth. So it’s not exactly how 21 many jobs does Palo Alto have. For instance, how many jobs does Santa Clara County projected 22 to have within a certain amount of time frame and then how many housing units are to follow 23 after that. 24 25 Commissioner Panelli: I’ll let some of the other Commissioners build off of my questions if they 26 choose. 27 28 Chair Martinez: Thank you Commissioner. Commissioner King. 29 30 Commissioner King: Thank you. So real basic question, can you define a housing unit? I know 31 that you presented that the hotel condominium because they do not have a kitchen were not 32 acceptable as a housing unit, but I’m curious for instance the Opportunity Center, the housing 33 there, is that a housing unit? And are there any income limits associated, you’re giving us a 34 gross required housing units. Are those broken down by income or is it just any additional 35 housing units you zoned for meet the criteria? 36 37 Mr. Wong: Commissioner King those numbers are broken down into income categories: very 38 low, low, moderate, and above moderate incomes. And I believe that is in Chapter 2 or Chapter 39 3, but there is a breakdown. 40 41 Commissioner King: And how are we then measured? Do they measure and say, “Oh, you.” 42 What happens the next round then if we don’t meet those? Let’s say we only have above 43 moderate income housing units developed and no below market units developed. Then what 44 would happen? 45 46 Mr. Wong: There isn’t really a penalty per se. For example, in our current we produced over 150 47 percent of what is allocated for above moderate, but we fell short in our very low and low, but 48 City of Palo Alto Page 9 there isn’t any legal penalty or anything from there. There is no rollover as far as I’m concerned 1 (interrupted) 2 3 Commissioner King: So you’re not really measured, it’s a goal, but you’re not measured on that 4 outcome? 5 6 Mr. Aknin: Correct. What I would think would happen is that during the next housing cycle 7 HCD would pay more attention to what type of affordable housing policies you have within your 8 Housing Element and be more focused on creating policies which is going to encourage the level 9 of affordability that’s needed. 10 11 Commissioner King: Thank you. And then just to finish then could you clarify any, is there a 12 size limit or type of occupancy other than human that’s specific to housing unit? What defines 13 that? 14 15 Mr. Wong: No there is no minimum size, but a kitchen is definitely part of the definition of a 16 housing unit and I believe they have to be separate, sorry. 17 18 Commissioner King: Separate entry maybe? 19 20 Mr. Wong: Yeah, a separate entry to access the kitchen also. In other words group quarters are 21 not considered living units. 22 23 Commissioner King: Such as a dorm room or something with one kitchen? Ok, ok thank you. 24 And then let’s see, then you had a comment in there on your PowerPoint it said one of the 25 Council’s directions was no rezoning of commercial to housing, but I thought you used the word 26 actual “retail.” Was that specific to retail or all types of commercial to housing were not to be 27 converted? 28 29 Mr. Wong: Excuse me, yeah. It’s all types of commercial, not just specifically retail. 30 31 Commissioner King: Ok. 32 33 Mr. Wong: Nonresidential. 34 35 Commissioner King: Ok thanks. I’ll come back I think in the later sessions. And then the other 36 question I’ve got is regarding the carryover. So there’s no penalty now, let me back up. We 37 haven’t met our goal of actually developing or having built what we zoned for for this Housing 38 Element. So now we’ll have a new Housing Element requirement number of units for the next 39 period. Does that, does the fact that we didn’t actually build those units get factored into our 40 allocation next time at all? 41 42 Mr. Wong: Not for the number themselves, no. so if we’re, for example, a 100 we did not, we’re 43 100 units short of low income, those 100 units will not be carried over to the new. We will not 44 have to plan for 100 more units of low income units for the next cycle. 45 46 Commissioner King: So that new number is completely independent of what happened in the 47 past? 48 49 City of Palo Alto Page 10 Mr. Wong: That is correct. 1 2 Commissioner King: Got it. And so that’s a quirk. Obviously I guess the reason why the 3 realistic capacity comes in is they don’t, the game the City could play is zoning things that will 4 never get built and then if none get built they just get to carry them over to the next time, the next 5 time if they don’t actually get built. So I guess that’s the tug of war with HCD is they want to 6 make sure they’re realistic. Ok. And then it introduces a whole bunch of potentially strange 7 behaviors on the part of the City such as slowing down approval times so that, because you really 8 want to carry, if you were gaming the system you’d really want to carry over those units to the 9 next time. And also then if you exceed as Commissioner Panelli asked you’re sort of it’s that no 10 good deed goes unpunished. You don’t get to carry those over for your success, is that right? 11 12 Mr. Wong: That is correct. 13 14 Commissioner King: Ok. Thank you. 15 16 Chair Martinez: Commissioner Alcheck. 17 18 Commissioner Alcheck: Ok. I want to start by saying that I thought the staff report was 19 excellent. I think it’s the best staff report that we’ve have in the seven months that I’ve been 20 here. It was a really well organized and very, very clear. I also think that the Housing Element 21 is an excellent read. I think that it’s really informative and I think if more community members 22 read it they’d really understand what we’re dealing with here. 23 24 I want to mention one thing real quick before it gets away from me, which is that you said in 25 your presentation and it’s a bullet point in slide two that there’s no requirement to approve or 26 build the units. And that seems to suggest that down the road there will be greater oversight and 27 discretion and I believe there will be. So quick question, doesn’t the process, doesn’t this 28 process and the rezoning that will result sort of pave the way for an approval free development 29 process for projects that comply with the new zoning? 30 31 Ms. Silver: Yes, Commissioner Alcheck I did want to correct one statement there. if a particular 32 site is on the Housing Inventory and an applicant comes forward the City either needs to approve 33 the project at the density as set forth on the inventory or if the City decides to exercise its 34 discretion not to approve the project if there is some discretionary permit that is in play and the 35 City decides not to approve the project then the City needs to actually substitute another site for 36 that site in order to stay within its allocated number on the inventory. So that slide may have 37 been a little bit misleading in terms of (interrupted) 38 39 Commissioner Alcheck: Thank you because I just want to make sure that we appreciate that if 40 density is coming in these rezoned parcels it’s going to come, it won’t necessarily be because we 41 want it or we don’t want it. There is going to be some automatic intensity, more intense 42 development as a result of the rezoning effort and I know that there’s a lot of I think fear about 43 that and I want to make sure that it’s not directed at the wrong place. 44 45 I want to make another point. I did a little research before tonight’s meeting. I’ll say at the 46 beginning here that the numbers I received from staff, so if you question them… in 1950 Palo 47 Alto’s population was approximately 25,000 residents. And there were 8,800 units. In the 10 48 years that followed the population increased by 27,000 and the housing units increased by, 49 City of Palo Alto Page 11 excuse me, the housing units increased by approximately 10,000. That’s in 10 years. In the 50 1 years from 1960 to 2010, in the 50 years since that period the population has increased 12,000. 2 Over 50 years. And the housing units have increased by 10,000. In 50 years. I make that point 3 because I think the likelihood of us missing a credit, if you will, or a debit, whatever one it is is 4 really unlikely. We are not going to exceed in five years our allocation. And we may not exceed 5 it in 20 years. And I mention that because we are developed. There is very little open land to 6 develop. And I think those numbers are really impressive. The notion that our City doubled in 7 10 years from 1950 to 1960 and since then has increased, since 1990 to 2010 there’s been 3,000 8 units is sort of astonishing. 9 10 The legal requirement to have a Housing Element is actually well articulated here and there is an 11 obligation to make room. And I think that increasing our, making an effort to create the 12 opportunity for these developments is important. There are environmental justifications for it, 13 there are moral justifications for it, and I know that there’s a lot of controversy involved in this 14 process, but I think that the notion that our City will change dramatically as a result of our effort 15 to comply with the State law is inaccurate. And so I certainly will not stand in the way of 16 supporting a Motion to recommend the approval of this Housing Element. 17 18 Chair Martinez: Ok, thank you. Commissioner Keller. 19 20 Commissioner Keller: Thank you. So I think it’s apt that the City Attorney used the expression 21 that we’re in the home stretch because I think it’s certainly a stretch for Palo Alto to absorb the 22 number of housing units that are in the Housing Element if they were fully built. Especially with 23 the new Housing Element that we’ll have to do coming in, starting in 2015 that we’ll start 24 working on in December 2014. It’s sort of like the Golden Gate Bridge. Once you’ve finished 25 painting one end you start at the beginning and paint it again. 26 27 So there is, I assume that we can control the maximum unit size so if we want to have, zone for 28 more units we could have smaller unit sizes as being maximum allowed? Would that make 29 sense? 30 31 Mr. Wong: I don’t think you can control, you can provide incentives for certain unit sizes, but to 32 control the maximum unit size I don’t think is (interrupted) 33 34 Commissioner Keller: Through our zoning ordinance? 35 36 Ms. Silver: You can’t control the occupants. The number, the maximum number of occupants, 37 but I think you can control the unit size. Although that’s not a program we’re proposing in this 38 particular Housing Element. 39 40 Commissioner Keller: I understand, but we’re talking about the future so I just asked that. And 41 in terms of the emergency shelter in the Embarcadero region is that in existing buildings or in a 42 new building? 43 44 Mr. Wong: That is up to the developer. This program is just to make an emergency shelter 45 permitted by right, but if it’s vacant land in the ROLME district or if it’s existing that’s up to the 46 developer. 47 48 City of Palo Alto Page 12 Commissioner Keller: Thank you. So in terms of substituting sites there was a question as to if a 1 site is built by City forcing a developer, preventing a developer from building on that site with 2 housing when the Housing Inventory has housing on it. If a developer comes along and for a site 3 on the Housing Inventory and chooses not to develop housing does the City also have to find 4 additional places on the Housing Inventory to cover those sites, the number of units that are not 5 built? 6 7 Ms. Silver: Yes, unfortunately we do. 8 9 Commissioner Keller: So it doesn’t matter whether it’s the developer that comes along or the 10 City. In either case we have to do that. Ok. Another thing is that during the previous Housing 11 Element in ancient history we had a Housing Element that I think was 1999 to 2007 I believe, or 12 2006. And that Housing Element we were allocated about 1,400 housing units. We built about 13 2,100 housing units in that period of time. So I’m not, and at that time we were not allowed to 14 carry, I think at one point in time it was counted as 2,500, I’m not sure how the number was, but 15 we were not allowed to carry forward that excess of housing built in that old Housing Element to 16 the current Housing Element we were working on if I remember correctly. Although apparently 17 there was some fudges that were done. and also if you, that there were some things that were 18 counted and some things we could count to this Housing Element, but essentially we did not get 19 credit for the excess housing that was built in the last Housing Element. 20 21 Also the issue is that if we, is that if you talk about to address the issue that Commissioner 22 Panelli brought up, the data from Natural [unintelligible] and Transportation Commission is that 23 jobs near transit is twice as transit use inducing as housing near transit. And so therefore it 24 makes sense because to build jobs near transit and housing near transit people can actually drive 25 to transit or other ways to transit but near, on the other end it’s hard to get from the transit to 26 your work unless there’s facilities for doing that. 27 28 I agree with the concept of no good deed goes unpunished. The more housing that’s built, the 29 more that we have to build. Part of the reason that our ABAG RHNA allocation is high this time 30 is because we were so successful at building housing between 1999 and 2006 and they’re saying 31 you’re good at it, do more of it now. And the less housing we build, it actually that’s part of the 32 feedback loop in how much housing we get in the RHNA. So that’s another thing to consider. 33 34 A very minor thing is you pasted as an image Excel tables into Word rather than pasting it as 35 content and that’s why they are kind of squeezed and not readable. So just a, I can tell you about 36 that if you want to know more for next time. 37 38 And I’ll close my comments with an idea that I’ve been kicking around for a while now. And 39 that is, may I? May I finish? 40 41 Chair Martinez: Yes, of course. 42 43 Commissioner Keller: Thank you. And that idea is that essentially Market Rate housing crowds 44 out Below Market Rate housing. And if we allow more Market Rate housing to be built then the 45 RHNA allocation of Market Rate housing then essentially it makes Below Market Rate housing 46 less economic because it has to compete with land values for Market Rate housing. So if we 47 instead have a rule that throttles the amount of Market Rate housing that can be built to no more 48 than the RHNA allocation of Market Rate housing for the eight year period and you know 49 City of Palo Alto Page 13 ratably over a period of time and if you under build you can build more next time. If there are 1 more requests for permits then you can auction it off with the extra money going for Below 2 Market Rate housing to subsidize that and promote the building of very low income housing 3 which is not built through Market Rate Housing inclusionary zoning. 4 5 And you exempt all Below Market Rate housing from this cap and if a housing development is a 6 least 50 percent Below Market Rate in terms of units and square footage and no more than 50 7 percent for Market Rate, for example, the project that’s being developed at Maybell is an 8 example of that. That could be built and those 15 units or so would not be counted towards the 9 Market Rate cap. Then you have a system that would essentially promote Below Market Rate 10 housing. It would preserve land for Below Market Rate housing and it would allow our Market 11 Rate Housing to be built at a rate that we could absorb more appropriately then the free for all 12 that’s happening now. So I would encourage us to seriously consider adopting such a plan for 13 the next Housing Element and I’m wondering if our City Attorney has any comments about the, 14 that she’d like to offer at this point about the legality of such an approach to the extent that 15 you’ve studied it. 16 17 Ms. Silver: Cities are starting to explore programs like that and I know that this program was 18 looked at for this Housing Element cycle as well and frankly I can’t recall if we included that as 19 something that we would study in this Housing Element cycle, but it’s certainly something that is 20 worth pursuing. We would have to look at it more closely in terms of legal limits on growth 21 control because there are some constraints in that area. 22 23 Commissioner Keller: I think I proposed it as a study item and it was taken out by a Council 24 Member. 25 26 Chair Martinez: Ok Commissioner. You’re encroaching on, now the Vice-Chair only has two 27 minutes. Can I do a brief follow up on that before? Excuse me. How would that be received by 28 HCD and in terms of ABAG’s RHNA goals to say this is how we’re going to do it, we’re going 29 to do a cap on housing? To me it, the cap on housing, to me it doesn’t seem like that’s what they 30 want to hear. Can I get any response on that? 31 32 Mr. Aknin: In general, yes. I mean things that are going to slow down housing projection are not 33 looked upon favorably by HCD. I think they would like to see goals and polices that both 34 promote Market Rate housing as well as BMR housing. 35 36 Chair Martinez: Ok, thank you. Vice-Chair Michael. 37 38 Vice-Chair Michael: So hearing the comments from my esteemed colleagues about the mandate 39 from the State and the regional authorities and the operation of the free market I wonder what 40 Margaret Thatcher would say about what we’re doing here? When the Housing Element came 41 up for the Planning Commission most recently we were not looking at a 200 page book, which is 42 quite impressive and thanks for all the hard work. But instead we were focused on the material 43 which is primarily on pages 163 to 170 in the draft plan, which is the vision, goals, policies, and 44 programs. And I wondered if you could just give us a quick tutorial as to the relationship 45 between what the City is proposing to adopt in terms of its vision, goals, policies, and programs 46 versus what is in Chapter 3 of the document in terms of the hard numbers for the allocation of 47 the units. Because we have this quantitative target, but we have this qualitative ambition in 48 City of Palo Alto Page 14 terms of our vision for the City and the housing and whatnot and how do those two things work 1 together? 2 3 Mr. Wong: I’d be happy. The programs that are being proposed help expedite or incentivize 4 some of the development to possibly achieve the production of affordable housing and housing 5 in general. For example, there is a policy that if you build units of a certain size of nine units or 6 less it provides the incentive that you will be able to “skip” site and design. So that’s trying to 7 help incentivize multifamily production of a certain size. In addition we have our programs for 8 lot consolidation that if they take advantage of a lot consolidation program then the City may 9 achieve a higher yield from those smaller lots. So these programs are to help implement or 10 achieve some of those numbers. In addition the BMR policies have been slightly revised to try 11 to get additional low income housing production. So these programs again are to help meet 12 some of those RHNA numbers. 13 14 Vice-Chair Michael: Excuse me. My next question is that the, on the Commission and on the 15 Council and in the community we have a lot of very thoughtful and analytical people who have 16 been skeptical of the forecasts that come down from the State Department of Finance and ABAG 17 and whatnot. And so we have also an ongoing activity, the Regional Housing Mandate 18 Committee, which includes four members of the Council, two members of the School Board, and 19 one representative of the Planning and Transportation Commission. To the extent that this is an 20 ongoing challenge for Palo Alto to both understand or maybe challenge the assumptions relating 21 to what would be a realistic set of targets how do we stand in terms of making sure that we do 22 the best we can in the future to have a realistic target for Palo Alto what we can actually do and 23 what we should do in terms of our land use planning. 24 25 Mr. Aknin: That’s a multi-level answer. I mean I think, and this was brought up at the last 26 Regional Housing Mandate Committee and the Mayor brought this up. These allocations are 27 handed down to us by the State and that is the system that’s set up right now. That seems to be 28 the system that’s going to be there for the foreseeable future. ABAG recently released their One 29 Bay Area Plan that projects growth out to 2040 and it shows increased, I mean the way they, 30 their methodology shows increased growth even more than the 2014 to 2022 housing cycle 31 where Palo Alto was allocated about 20, a little bit more than 2,179 units. So right now that’s 32 the system in place. We do have ongoing conversations with our local State legislators to see if 33 there can be changes within the system to have a more realistic forecast. 34 35 I think the thing that is set up there is that on a positive side is that you do get the rollover units. 36 So if we do zone for units and the market isn’t there to create those units you do get a credit 37 towards the next cycle. For instance, as Tim pointed out right now we’re estimating about 1,600 38 units, 1,600 sites that have not been built. Well if we have a requirement in the next housing 39 cycle of 2,179 units we’re already 1,600 units of 2,179 on our way there. So we really only have 40 to find 579 more housing sites. So there is kind of that built in mechanism there where if the 41 market demand isn’t there it doesn’t count against you. 42 43 Chair Martinez: So I have two areas that I want to try to take over and talk about in my five 44 minutes. One is the sort of what our City Attorney called the “home stretch” and the second is 45 about the Comprehensive Plan itself. The latter is kind of easy, so I’ll save that. It seems to me 46 like once you’ve gotten to know me a bit that the most important thing that this body does is look 47 at policy. So here we are in the home stretch. We spent four years of our lives really being 48 City of Palo Alto Page 15 intimately involved in the dialogue about the Housing Element. We’ve taken it very seriously all 1 of us and I’ve enjoyed working with all of you. 2 3 But the home stretch, you get a letter from HCD it says, “What about this and that?” And you 4 get together and you respond back to them says, “Well, we can do this.” And they said, “What 5 about this?” And then you said, “Well, we can do this.” Where’s the sort of public process in 6 that? I was, not that I so much disagree with all of what you’ve proposed. I think largely I agree 7 with it, but I’m a little bit, a lot concerned that as hard as we worked as a group that the staff has 8 taken upon itself to propose policies and programs that are different than what came before us. 9 And it’s not so great, but some of it is like providing incentives like reusing parking for mixed 10 use housing. Well, parking is a big issue right now in our town and I think it needed some input 11 from us. 12 13 So in the home stretch I think we kind of left our process, our public process and moved quickly. 14 And I understand why you wanted to do it quickly, but looking ahead and looking at this and 15 what we’re going to recommend to the Council I feel sort of like abandoned that there should 16 have been built in some time for the Planning Commission to weigh in on this. And I think it’s a 17 great oversight that these important policies and programs that were altered were not run by your 18 Planning Commission for our support for it. I’m sure you would have gotten it for most of it, but 19 I’m sure there’s a couple of us that would’ve asked them to be stated a little bit differently. So 20 what’s done is done. We’re approved; great job for that. But I don’t want to see that, because 21 that’s the most important thing we can help with. 22 23 Ms. Silver: Chair Martinez, may I respond to that briefly? 24 25 Chair Martinez: Sure. 26 27 Ms. Silver: I think that’s very good feedback and we had some internal discussions about that 28 process. From a staff perspective I think that if we were in the early years of this process that 29 that’s what would, that would be the best protocol. But if we were to stop the negotiation with 30 HCD to bring each, to hold public hearings on each of those items it just simply would not have 31 been feasible to get this approved by the end of the cycle. However, this is the time for the 32 Planning Commission to weigh in and so there certainly is that opportunity and so staff used its 33 professional judgment on recommending to you programs that it thinks will be viewed in a 34 favorable light by HCD but if you don’t agree with those programs of course now is the time to 35 weigh in. 36 37 And also I would say that maybe for the next housing cycle what we might want to do is think 38 about forming a subcommittee, a Planning Commission subcommittee that would be more 39 involved in those negotiations with HCD if the body as a whole felt comfortable delegating that 40 authority. But in very time sensitive issues like this it’s very hard to go before all three boards 41 and actually get responded to HCD in a timely fashion. 42 43 Chair Martinez: I understand that. I’ll save my second part for the next round. I understand that 44 and there’s no way that I believe this body would jeopardize what’s been achieved by saying 45 well we want to pull back and hold a public hearing on this or propose significant changes. 46 Because in addition as important as the City’s liability is on having a certified Housing Element 47 to me the most important thing is that we have a Housing Element that, the most important thing 48 going forward as the our speaker from the League of Women Voters is to be proud that we 49 City of Palo Alto Page 16 achieved this and it’s the right thing to do. So I’m going to actually in the interest of time just 1 wait on the Comp Plan issue and I’ll pick it up if I get a chance to speak next time. 2 3 Commissioners do you want to carry on a discussion or further comment on this item? Yes, 4 Commissioner Alcheck and then Commissioner Keller. 5 6 Commissioner Alcheck: I don’t want you to take this the wrong way, but what was the 7 bottleneck you think that got us to a point where we’re approving a plan that will essentially 8 lapse in 2014 in 2013? And have we taken the steps you think to make sure that the next 9 Housing Element is approved sort of early in the cycle so that we’re not sort of in this situation 10 again? And can you kind of elaborate on that a little bit? 11 12 Steven Turner, Advance Planning Manager: Well I think certainly, Steven Turner, Advance 13 Planning Manager. I think certainly what we would like to complete the update sooner than 14 later. Alright excuse me. Steven Turner, Advance Planning Manager. Certainly the length of 15 time to prepare this Element exceeded our expectations. I think probably as part, actually a very 16 good accomplishment by the City for this Element is that essentially was done in house. We did 17 use some consultants to assist us on the technical aspects of the report. But for a large part the 18 City saved I think quite a bit of money actually doing this in house and building upon our 19 analysis on the technical portions of the chapter utilizing a PTC subcommittee for the goals, 20 policies, and programs, doing the outreach that we did with the volunteer group, the Technical 21 Advisory Group that was involved in very early stage development and review. That was a very 22 public process and the Technical Advisory Group had how many members Tim? 23 24 Mr. Wong: Approximately 15. 25 26 Mr. Turner: 15 members of the community from representing various disciplines participated in 27 the review of and preparation of this document. And so we had a very extensive public process 28 at the beginning kind of through the early draft stages involving the Planning Commission again 29 in the goals, policies, and programs and essentially doing this all in house I think extended the 30 timeline. I think we are ahead of the game for the next Element. One of the benefits of 31 completing this current cycle’s Housing Element near the end of the cycle is that it will allow us 32 to move forward I think that much more quickly while the issues and topics are still fresh in our 33 minds, still very much of a public issue and concern, that we can move forward I think very 34 quickly and meet the initial deadlines that have been established for us. 35 36 Chair Martinez: Thank you. Commissioner Keller. 37 38 Commissioner Keller: Yes, couple of quick things, just cleaning up. It was not mentioned that 39 the One Bay Area Grant program eligibility is to some extent conditioned on having an approved 40 Housing Element. Is that correct? 41 42 Mr. Wong: That is correct. However, they offered extensions for eligibility for One Bay Area 43 Grants and the City applied and received extensions that we have until January 30th of 2014 now 44 I believe to get our Housing Element Certified. 45 46 Commissioner Keller: Thank you. So that’s one more reason to have it done. The second thing 47 is I just want to clarify units that are proposed by developer, but not yet approved are considered 48 under the old Housing Element; in other words, not rolled over to the next time. Is that correct? 49 City of Palo Alto Page 17 1 Mr. Wong: Sorry, one more time? 2 3 Commissioner Keller: Let’s suppose that a developer comes along in 2014 and proposes a 4 housing development on one of the Housing Inventory Sites. 5 6 Mr. Wong: Ok. 7 8 Commissioner Keller: That development is considered as if it was built and because it’s being 9 proposed isn’t rolled over to the new Housing Element from 2015 to 2022. 10 11 Mr. Wong: I believe we can roll it over. Yeah. 12 13 Mr. Aknin: No, the only way it gets counted towards the current housing cycle is if it’s entitled. 14 15 Commissioner Keller: Ok. 16 17 Mr. Aknin: Without those entitlements it has the same weight as not being proposed. 18 19 Commissioner Keller: And two other things quickly. We do have a Housing Element 20 subcommittee. I believe I’m on it. So that could have been consulted in terms of these 21 questions. And the second thing is regarding the expansion that happened from 1950 to 1960 22 there was a lot of vacant farmland in Palo Alto south of Oregon Expressway that has since gotten 23 filled between 1950 and 1960. So that’s one of the reasons why there was a great expansion. 24 There also at one point and time 24 elementary schools and about close to half of those were 25 closed and often sites sold off. So while the School District once had over 15,000 students at its 26 peak we’re approaching that but with a lot fewer school sites to have students to attend our 27 schools. 28 29 Chair Martinez: Anyone else on this round before we… yes, Vice-Chair? I wanted to spend a 30 little time talking about the environmental review of the… Ok. Vice-Chair Michael. 31 32 Vice-Chair Michael: So I have a question that goes back to the Regional Housing Needs 33 Allocation and how that affects Palo Alto. When the Regional Housing Mandate Committee last 34 met there was a presentation from Stephen Levy who is the Director for the Center for 35 Continuing Study of the California Economy and he helped clarify exactly what the process was 36 in terms of the forecasting by the State and by ABAG. And what I took away from Mr. Levy’s 37 presentation, which was excellent, was that the biggest driver of population increase is jobs. So 38 when population increases there’s the need for housing. So what we’re seeing is an allocation of 39 what’s believed to be the share that Palo Alto should create or contribute or enable relative to 40 housing, which is driven by jobs, dives population. And currently Palo Alto has sort of more 41 jobs. We have a bigger daytime population than we have a nighttime population. So our 42 daytime population is about 110,000 more or less and our nighttime population is 65,000 more or 43 less. And we have a goal that we’d like to continue to stimulate the vibrant Palo Alto economy 44 and create more jobs. So this situation is in many ways desirable, but it leads to this deficit of 45 more housing or the deficit in housing relative to jobs. And when people aren’t close, aren’t able 46 to live close to the jobs then they have to have transportation to get to the jobs and that creates 47 our issues with traffic and transportation and parking, which is a great concern. 48 49 City of Palo Alto Page 18 So one of my questions is are we learning anything, sort of out of the box thinking other than sort 1 of acknowledging that we have this built out city, this wonderful city, this quality of life and 2 great community character, but because we’re driving with all this innovation and economic 3 vitality to have a lot of jobs in excess of housing, is there something about the future that’s going 4 to… is there going to be a breakthrough in terms of how we might approach this opportunity or 5 this challenge different from what we’ve seen in the past? 6 7 Mr. Aknin: That’s another good question. There’s no, I think the answer, you know, a lot of 8 cities have the same challenges as Palo Alto, especially along the peninsula. We’re constrained 9 by a bay on one side and we’re constrained by a mountain range on the other side so and then we 10 had the typical suburban type development pattern during the 1950’s and 1960’s which really 11 leaves us little land to work with. I think the general state as I had stated before, the general 12 State policy goals is that you build higher density developments, whether that be office or 13 housing near transit so that people don’t have to drive in their cars and they can get from… I 14 think there’s a, you know, the term jobs/housing balance was used a lot. It’s used a little bit less 15 at this point, but I think the idea is that if you don’t have jobs right next to housing and people I 16 think it’s unrealistic to think that everyone’s going to live in the exact same community that they 17 work. But I think that what we’re going for as planners as well as transit planners is that we set 18 up a transportation network and a housing network that is connection based so that even if you 19 live in another region you’re able to take the train and able to take another form of transportation 20 in to get to your office space or to get to your back home. So I think it’s really looking at these 21 connections between transit and housing is the way that we’re going to have to grow as a region. 22 23 Chair Martinez: I’m going to take the opportunity to come back to my final part of my 24 questions/comments. In the last stretch the HCD focused a lot on our goals, policies, programs 25 and cited them as the reason they support certification of our Housing Element. And I think staff 26 should be commended for the hard work of getting that together. But it also points how 27 important those goals, policies, programs are to our Comprehensive Plan. So in the questions I 28 sent out to you I asked well can we accept the certification of that Housing Element document 29 but reorganize in the Comprehensive Plan our goals, policies, and programs so they provide that 30 kind of readability, transparency, ease of use that we’re reaching for in the update. Not changing 31 any language, not changing any substance, but trying to get it to work in the same manner that 32 the other six elements work. And I think the response I got was are you asking can we change 33 the Element? And my response is no. So I’m going to ask the question again: can we accept the 34 certified Housing Element in that bound document that you gave us, but also use it as part of our 35 Comprehensive Plan and the way in which we have designed it for the 2014 update or whatever 36 the date is? Steven? 37 38 Mr. Turner: Yes. As you’re aware one of the improvements that we’re looking to make with this 39 Comprehensive Plan update is to make this element or this document more accessible, more 40 usable to members of the public and City staff and boards and commissions. We’re looking to 41 achieve that in a number of different ways. One of them is to reformat each element so that a lot 42 of the narrative discussion occurs at the beginning of the element followed by a simple list of 43 goals, policies, and programs that we want to achieve over the long term. I think that we can do 44 that with the Housing Element as well. This is our Housing Element and its part of the 45 Comprehensive Plan. It’s the only element that the State requires certification or approval of at 46 the State level so it has to contain certain elements. But for the purposes of our public, our staff, 47 our boards and commissions I think we can create a document that retains the goals, policies, and 48 programs, retains the narratives that are contained in here that provide that context for our goals, 49 City of Palo Alto Page 19 policies, and programs over the long term and still create a useable, readable document. So I 1 think we can adapt this document. 2 3 This document is our Housing Element of the Comprehensive Plan, but I think for public 4 consumption and public ease of use we can certainly create a tool or a document that is more 5 easily assessable. And then as you’re aware we are trying to also determine a good way to make 6 this available online through a searchable tool, through an application where folks who have a 7 particular interest in the Comprehensive Plan or a specific part or chapter of the Comprehensive 8 Plan that they can have easy access to that. So I think because we’re offering the Comprehensive 9 Plan up in a variety of different ways for people to consume, I think we can create products that I 10 think can be accessible by most people. 11 12 Chair Martinez: Thank you for that. And then my last comment in this section; one of the nice 13 things in the report was the assessment of the success of the previous Housing Element. I 14 thought that was very useful. It would have been nice to have it earlier so that we could also use 15 it in sort of going forward with our new programs and policies. But it also would be, will be a 16 useful tool in future years for all of the elements. When staff comes to the Planning Commission 17 and asks for our input in starting an update to have an evaluation of how successful the 18 Transportation Element goals, policies, and programs have been I just think it said so much 19 about what we needed to have worked on. So going forward I would really like to, I don’t know 20 who’s going to be here in 2022 or whatever it is, but to consider that as a vehicle for really 21 looking at where we’ve been successful and where we haven’t been. 22 23 So I’d like us to spend our remaining time talking about the environmental review of the 24 Housing Element and perhaps our City Attorney might give us some insight of why this is 25 required. Thank you. 26 27 Ms. Silver: Sure. The adoption of a Housing Element is a discretionary action that invokes 28 California Environmental Quality Act (CEQA) and so some type of environmental review is 29 required. And what you do when you decide on what level of environmental review is 30 appropriate is you look at the type of land use changes are anticipated by this Element. And for 31 the most part this Element takes advantage of existing zoning to accommodate the land use, the 32 housing sites. And there are some rezonings that are going to be required and those are the 33 commercial zones that will be up zoned to allow for greater residential density. And so since 34 that’s the major land use that’s anticipated in this Housing Element cycle that’s what the 35 environmental review focused on. 36 37 And so it’s a Negative Declaration is being proposed and there really weren’t any impacts 38 associated with some modest up zoning in those commercial sites that were identified in the 39 Negative Declaration. And so it’s relatively straightforward for this particular Housing Element. 40 In the next cycle we will have to accommodate a few hundred more units and so we would again 41 look at whether a higher level of environmental review is required. But at this level there were 42 not any significant environmental impacts that were identified. 43 44 Chair Martinez: Ok, and if I may ask in other situations where we are reviewing an area plan or a 45 study you have said these, we’re not proposing a project and so there is no environmental impact 46 for us to weigh in or something like that without putting words in your mouth. Is that the general 47 nature here that the impact is really the future projects that come forward and at this point it’s 48 really a review of a plan? 49 City of Palo Alto Page 20 1 Ms. Silver: Yes. We do do environmental review for area plans, but the level of environmental 2 review is much broader. We look at the plan level we look at, we try to look at the maximum 3 density that would be contemplated in the plan and but then as particular projects come online 4 we also do an additional level of environmental analysis and it may be that as we go from the 5 overall plan policy level to the more micro project level you do start to see additional 6 environmental impacts that are exposed as you drill down further. For instance, as you start to 7 look at particular footprints for where a project will or a building will be located a particular, 8 there might be a groundwater plume for instance that you want to drill down further and look at. 9 Or there may be some kind of particular aesthetic component or impact based on the proximity 10 of the building vis-à-vis other buildings. And so it is more typical at a project level 11 environmental review to get more specific. And thank you for that clarification. 12 13 Chair Martinez: And then one last and I’ll stop. What if we, can we arbitrarily decide to set the 14 bar higher for environmental review? For example, could we say we’re going to under land use 15 planning focus more on the category of potential impact, significant impact if not mitigated and 16 say that’s where we are going to make sure we address measures that need to be followed or is 17 there something in environmental law that limits us from taking that kind of posture? Does that 18 make sense to you? 19 20 Ms. Silver: Yes. I think you’re talking about the local thresholds of significance? 21 22 Chair Martinez: Yes. 23 24 Ms. Silver: So the CEQA statute and the guidelines provide some general thresholds of 25 significance. There is a checklist that’s contained in the State law and for the most part cities 26 rely on the State mandated or State recommended thresholds of significance. So for instance, 27 there are certain key areas like transportation and greenhouse gas impacts and aesthetic impacts 28 that CEQA contains recommended ways to analyze those impacts. Local agencies do have the 29 ability though to adopt their own local thresholds and, as long as they comply with the minimum 30 State thresholds and some agencies do have more area specific thresholds and sometimes those 31 thresholds are more stringent than the State. Palo Alto has some thresholds that were adopted 32 through a formal process a number of years ago and more recently though we have some 33 thresholds that we’ve been using in larger projects that have been updated at an administrative 34 level. They have not been formally adopted by this body or by the Council, but they are in 35 practice. We have been using them fairly consistently. And those local thresholds that we have 36 been using are largely consistent with the State law, but there are some areas where they are a 37 little bit different, perhaps a bit stricter than State law. 38 39 Chair Martinez: Thank you. Commissioner Keller you want to begin? 40 41 Commissioner Keller: Yes, thank you. So I read the Negative Declaration as basically saying 42 that there are no impacts because the barn door has been opened and all the horses have left and 43 not many horses will leave in the next year and a half. That’s my interpretation. And the reason 44 I believe that is because in the previous Comp Plan and the Housing Element the Comp Plan 45 remember was from 1998 and the Housing Element being from 1999 to 2006, that studied 2,400 46 housing units if I remember correctly. And we far exceed that without any analysis of exceeding 47 that. And it’s true that we have zoning, we have, that we’re limited by zoning, but the reason 48 that the impacts are useful to look at from a broad perspective as opposed to project by project is 49 City of Palo Alto Page 21 because of cumulative impacts. And you can’t really effectively, we don’t really effective, 1 maybe you can, but we don’t really effectively study cumulative impacts on a project by project 2 basis. So looking at the Housing Element overall is how you look at cumulative impacts. And 3 it’s essentially on a year and a half not much is going to happen is the answer. So I think that 4 when we get to the next Housing Element I hope that we do an adequate CEQA review that 5 looks at the cumulative impacts of all the housing that could be built based on that and we 6 understand what the effect of that is and then we appropriately mitigate it as needed. 7 8 One thing that we are precluded from unfortunately and correct me if I’m wrong, but I believe 9 we’re not allowed to consider school impacts under CEQA. And that’s because school impacts 10 are supposedly fully mitigated by the pitiful amount that developers are required to pay under 11 State law, which doesn’t cover the amount that the impact is on our schools based on the price of 12 land and the price of construction in Palo Alto. So essentially unless we form an assessment 13 district or things like that we’re kind of stuck in that regard. 14 15 The other, the last thing is that in terms of these impacts and thinking about where people are 16 going to live there’s really a thresholding effect. And that is that the average commute based on 17 the latest data, which is from 2004 data from 2000 census and we should be getting data from 18 DC in 2014. Next year we’ll be getting some, the new data from the 2010 census. But that data 19 shows that the average Palo Alto resident commutes 11 miles each way to work. Now a lot of 20 them are commuting less, some of them are commuting more and the average person who works 21 in Palo Alto commutes 16 miles to work. And so there’s not a lot of commuting going on to and 22 from Palo Alto. There’s a handful of people coming from San Francisco and things like that. 23 There’s more commuting into Stanford. But there’s not, the distances are not really that great. 24 But what happens is the people who commute into Palo Alto are commuting from Mountain 25 View and Sunnyvale and Menlo Park and such and a lot of them are taking, a significant number 26 of them are taking bicycling and things like that. But essentially that means that the people who 27 live in Mountain View would be pushed out further. So essentially there are these rings of where 28 people live and where people work. And so people in Palo Alto tend to, tend to not all of them 29 but tend to make more money and they tend to live closer, but that essentially pushes people 30 further out if they’re living further out. So that’s essentially the pattern that we have. 31 32 So essentially there’s a big ecosystem that’s going on and so when you look at the environmental 33 impacts there’s different layers that you can think of it. There’s the layer for Palo Alto, there’s 34 the effect of what happens in Palo Alto and how it affects other cities, and there’s the cumulative 35 effects here. We can consider the cumulative effects here, but it’s hard to consider the 36 cumulative effects elsewhere. 37 38 Just closing on one thought, which is interesting about this phenomenon. When a commercial 39 building is built, like for example when Stanford did its, the Stanford Medical Center expansion, 40 they said that a certain percentage of those people who live in Palo Alto and a certain percentage 41 of those people who live elsewhere. We can only consider the impact of the people living in 42 Palo Alto, who would live in Palo Alto. And developments that happen in Menlo Park from 43 Facebook causes developments in Palo Alto, but we don’t consider them. So essentially there’s 44 this cumulative impact that gets technically and legally ignored. That’s unfortunate, but 45 essentially it’s a system for considering impacts that both limits the amount we can consider and 46 ignores certain impacts as well. Thank you. 47 48 City of Palo Alto Page 22 Chair Martinez: Commissioner Panelli, comment? You good? To the other end, Commissioner 1 Alcheck? 2 3 Commissioner Alcheck: I share Commissioner Keller’s sentiments on the, on my opinion on the 4 Negative Declaration and its, I guess I don’t want to say relevance, but significance particularly 5 because of the time frame. I want to add though I think it’s, I don’t know what the right word is, 6 it’s peculiar for me the discussion about environmental impact of what I would consider infill 7 housing. I know that we’re specifically talking about Palo Alto and that is the context, but it is 8 significantly more environmentally friendly to develop in this town than it is to continue 9 developing all the way from one side of 680 to the other. And that is essentially what all of the 10 Bay Area municipalities have to consider is that the development that doesn’t occur in their 11 neighborhoods will just move farther and farther out into the abyss. And those commutes will 12 increase. I know that that’s not a component of this environmental analysis, but again, I just 13 think there’s an irony in suggesting that the environmental impact of infill housing is so 14 significant that it justifies not developing as opposed to the development of housing in areas 15 where the environmental impact is just so significant it shouldn’t be ignored. But that’s a side 16 note. 17 18 Chair Martinez: Thank you for that. Commissioner King? Ok, Vice-Chair Michael? 19 20 Vice-Chair Michael: So I’m not really an expert on the nuances of the environmental impact 21 analysis, but one of the things I’m coming to appreciate about the work of the Planning 22 Commission as we take up this topic of the Housing Element is that it relates to a lot of the other 23 things that we work on in the course of our meetings. If you have sort of a holistic view of the 24 scope of topics that we consider and I’ll shortly give you a list, I am curious how this plays into 25 the environmental impacts which relate to things like traffic and parking and impact on schools 26 and infrastructure and the biology and natural resources of the area and wildlife, and so on. Air 27 quality, water, public works, and so on. But among the topics that we have taken up a very 28 serious study include the Rail Corridor Study, the Bicycle Pedestrian Master Plan, obviously 29 there’s a lot of tension on the possibility of High Speed Rail, El Camino transit, the Grand 30 Boulevard. We’re, on our upcoming agenda we’ll see the California Avenue Concept Plan. 31 We’ll see the Downtown Development Cap and maybe more work on the Arts and Innovation 32 District proposal. 33 34 There’s concern about, in the Housing Element, about Below Market Rate housing. Assistant 35 Director Aknin talked about in response to an earlier question that you have sort of, that housing 36 relates to jobs/population imbalance relates to the importance of regional connections, proximity 37 to transit, housing proximity to transit, jobs proximity to transit. And all of this kind of goes to, I 38 mean the environmental impact is really a very focused analytical study, but it goes to the quality 39 of life and the character of the community. And so and I’m imagining that although 40 Commissioner Alcheck had the data about the extent to which changes happened in the past or 41 didn’t happen at different times in the past, I suspect that we’re going to see more changes in the 42 future and hopefully those are going to be positive changes and changes that we manage 43 successfully. So I guess my question about the environmental impact is if there’s any sensible 44 way to look at it not in isolation as it relates to housing, but how it relates to these other 45 important concerns to the community along these other master plans and studies and concept 46 plans and so on that we and the Council and staff work so hard on? 47 48 City of Palo Alto Page 23 Chair Martinez: So where was I going with my question about what are the impacts? You know 1 I understand that we want to move on beyond our Housing Element and having this Neg Dec is 2 an important part of it. But this is also one of the places where we can have a discussion about 3 what would it be like if we were building 2,000 housing units downtown, Cal Avenue, El 4 Camino Real, and not skirt away from well less than significant to it’s only a study, it’s a plan, 5 it’s on paper, it’ll never happen, probably never happen, we don’t have to do this. But I think 6 what it would do is that it would inform the discussion for the next cycle and with HCD and with 7 ABAG that this is what we would really have to do to meet our housing allocation. 8 9 So what I’m trying to say is that maybe this is the place. Let’s move the category over to the left 10 and say this under land use planning this could have significant impact without these kinds of 11 mitigations if we built 1,000 units downtown we would have to do something about 12 transportation and this is what the impacts could be. The impact on our schools, the impact on 13 our sewer… it could be theoretically large, but it also points to the unlikeliness that this would 14 happen and so we go into the next cycle with another 2,000 units that we have to spend the time 15 and effort to prepare a plan which goes into the next one and it gives us the opportunity to begin 16 a dialogue with HCD and ABAG that says there’s got to be a better way for One Bay Area 17 community to address commuting and housing needs and where people work that’s more 18 reasoned than this; that this is not taking us to where we need to be. 19 20 And I’ve suggested maybe it’s, we’re going to continue to be a job center, but Mountain View is 21 much better at building housing for us and that’s half of the commute from San Jose and so the 22 way we look at jobs to housing imbalances is really more regionally and not on what can we do 23 with the cost of land and the limit, supply of vacant land and so maybe it isn’t environmental 24 review. Maybe we need to put that to rest, but it’s one possibility. And rather each time where 25 we can say, “Well, it’s less than significant, let’s close it out,” let’s take the opportunity, the 26 challenge to say, “Well it could be significant,” and therefore we need to say here is what it 27 could be and what the conversation should be going forward for the next round, the next time we 28 have to do this. Because we’ve all agreed and you will all agree that we don’t, the likelihood of 29 us building housing of that nature in this cycle is very, very remote and we need to find another 30 way in which we can do this. So Commissioners… yes, Assistant Director Aknin. 31 32 Mr. Aknin: I would just like to clarify one thing. When doing a cumulative impact analysis 33 within an environmental document you do have to take into consideration things that are going 34 on in nearby communities and that’s something that we do look at within our documents. So if 35 something’s going on on the other side of the border on Menlo Park that impacts traffic along the 36 El Camino Real that is something that we have to look at within an environmental document and 37 something that’s not ignored. 38 39 And the second thing I’d like to touch upon is with CEQA and doing the environmental analysis 40 I have a feeling by the time we get to our next Housing Element cycle there’s going to be 41 changes within CEQA and that’s something that we do have to track closely as a city. And my 42 guess is that, you know, there’s been a lot of talk especially related to infill housing and potential 43 categorical exemptions for infill housing and I think the general theory behind that and why 44 there’s a lot of pressure to categorically exempt or create laws at the State level that categorically 45 exempt local infill housing is that they believe the intent behind the law is that any localized 46 impact is far less of an impact then the regional impact the large commutes are having within 47 regions within California. So I think that’s something that we’ll end up seeing and end up 48 City of Palo Alto Page 24 participating in a discussion at the local and State level on is that as CEQA legislation is 1 proposed. 2 3 Chair Martinez: Thank you. Commissioner Panelli. 4 5 MOTION 6 7 Commissioner Panelli: I’m going to take this opportunity to make a Motion to approve or I’m 8 sorry, to recommend. Pardon me; I need to be very clear about that. A Motion to recommend 9 the adoption of this HCD approved Housing Element. I’m going to speak to this Motion though. 10 11 SECOND 12 13 Chair Martinez: Can we get a second? Motion by Commissioner Panelli and second by 14 Commissioner Keller. 15 16 Commissioner Panelli: Thank you. 17 18 Ms. Silver: And just as clarification I assume you also include the recommendation of the 19 Negative Declaration. 20 21 Commissioner Panelli: Yes, I’m also making a Motion to approve the Negative Declaration as 22 part of this recommendation that we adopt. It’s interesting to talk about this in the Housing 23 Element of the Comprehensive Plan. I’m sort of used to thinking of a plan as something you, to 24 map out the future and this is more of a, well it’s five and a half years of historical record and 25 maybe a year and a half of planning. And I understand there are things that are contributed to 26 that. I sincerely hope that we can achieve this goal of as I understand it submittal by December 27 2014 (interrupted) 28 29 Mr. Aknin: It’s approval actually. 30 31 Commissioner Panelli: Yeah, I know. I understand that. That seems, given what we’ve 32 experienced already that seems ambitious. But I like that ambition. I’m hesitant for us, there are 33 many reasons to approve it. It’s a good package. I also think it’s a poor use of resources to 34 continue to spend time on something that is effectively a historical record now. I’d rather see us 35 focus our time, staff’s time, on the future, which is the 2015 to 2022 plan. I also think it’s a 36 really interesting timing issue in that the next Housing Element can be done in conjunction or in 37 parallel with the development and finalization of some of the specific plans with downtown and 38 California Avenue as well as hopefully a little bit more clarity around things like High Speed 39 Rail. So I think it actually, the timing works out really well. So I’d just rather spend more time 40 on what I think our esteemed Chairman has said before, which is I want to spend more time on or 41 we should spend more time on policy and holistic planning. And I think focusing our energies 42 on that is, there’s a better return on our investment. 43 44 Chair Martinez: Commissioner Keller on your second? 45 46 Commissioner Keller: Thank you. So I have taught computer programming and one of the 47 things I’ve taught my students is that spending more time on planning reduces the 48 implementation time, but I think this is taking it to a little bit of extreme. But, I think that this is 49 City of Palo Alto Page 25 an excellent report and it produces, it represents excellent work by staff and by members of the 1 public that contributed and by the various members over a period of time by the Commission and 2 by the Council and other bodies that have reviewed it. So I think that this is something that we 3 should at this point approve and certainly not approving it as we’ve pointed out is too onerous a 4 thing to do even if we were, even if we thought it was not a great thing. And I’m not saying we 5 do think it’s not a great thing, but even if that were the case it would be too onerous not to 6 approve at this point. 7 8 So I hope that next time we do earlier planning so we have more time to see the effects of the 9 Comp Plan, I mean of the Housing Element over the planning cycle and that we as suggested by 10 the Chair actually do a more thorough analysis of what the cumulative impacts are and what 11 things would be like if we built it to that level. And I think that that exercise will be very 12 instructive when we get to the Comp Plan, the Housing Element that starts in I guess 2023, that 13 that exercise will feed into what we do for the, to our input to ABAG for the next RHNA and 14 those policies and I think that that will be a valuable exercise in that cycle. So at this point I’m 15 pleased to recommend approval to the Council of the Housing Element and recommend approval 16 to the Council of the Negative Declaration for the 2007 and 2014 Housing Element update. 17 Thank you. 18 19 VOTE 20 21 Chair Martinez: Thank you. Commissioners, the vote. Those in favor of the Motion say aye 22 (Aye). Ok, the Motion passes unanimously with Commissioner Tanaka absent. Thank you very 23 much. 24 25 MOTION PASSED (6-0-1, Commissioner Tanaka absent) 26 27 I would like to see if the members, the applicant is here for 2035 and anybody else that wishes to 28 speak on it before we take a break? Let’s give the staff a minute to organize for this and then 29 we’ll move right into the next item. The third item in place of the second item if it’s… no, we’re 30 going to just. Let’s go for that. We’ll take a break after this next item if you don’t mind. Ok. 31 Thank you. 32 33 And by the way did I close the public hearing on item number and if not? I did now. Thank you. 34 35 Commission Action: Recommended approval of Housing Element as recommended by staff, 36 Motion by Commissioner Panelli, second by Commissioner King (6-0-1, Commissioner Tanaka 37 absent) 38