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HomeMy WebLinkAboutStaff Report 2505-4725CITY OF PALO ALTO CITY COUNCIL Monday, June 16, 2025 Council Chambers & Hybrid 5:30 PM     Agenda Item     B.Summary of Downtown Housing Plan Community Assessment Report and Next Steps. CEQA Status: Exempt under CEQA Guidelines Section 15262. City Council Staff Report From: City Manager Report Type: INFORMATION REPORTS Lead Department: Planning and Development Services Meeting Date: June 16, 2025 Report #:2505-4725 TITLE Summary of Downtown Housing Plan Community Assessment Report and Next Steps. CEQA Status: Exempt under CEQA Guidelines Section 15262. RECOMMENDATION This is an informational report, no City Council discussion or action is required. EXECUTIVE SUMMARY The purpose of the Downtown Housing Plan is to increase housing production in a defined area of the University Avenue downtown. The plan advances the goals of the City’s 2030 Comprehensive Plan and 2023-2031 Housing Element by establishing policies, development standards, design guidelines, and the public infrastructure necessary to support additional housing. The Community Assessment Report1 documents existing conditions and regulations to identify key opportunities and factors influencing development. An Executive Summary of the Report (Attachment A) summarizes the assessment and includes a suitability map highlighting limited availability of parcels with redevelopment potential in the Plan area. Attachment B contains analysis of three sites within the Plan boundary. The report indicates that many sites may require revised standards or incentives to enable housing development. This information will support the discussion at the upcoming community workshop on June 18, 2025, at the Palo Alto Downtown Library. Community input will help finalize a feasibility analysis and inform policy recommendations to be presented to Council in September 2025. BACKGROUND 1 Refer to the Community Assessment Report on Project Webpage: https://www.paloalto.gov/Departments/Planning-Development-Services/Housing-Policies-Projects/Downtown- Housing-Plan The City Council designated the University Ave/Downtown Area as a Priority Development Area (PDA) on January 13, 2020,2 and accepted the MTC’s PDA grant funding of $800,000 on April 18, 2022,3 to initiate the preparation of the Downtown Housing Plan. This designation approved by the Association of Bay Area Governments (ABAG), encompasses approximately 206 acres within a half-mile radius of the Palo Alto Caltrain Station. PDAs as envisioned by the Metropolitan Transportation Authority (MTC) are established to guide growth around transit and connect housing to jobs and areas of interest. The approximately 90-acre Downtown Housing Plan project boundary is a part of the larger PDA boundary approved by MTC and has 33 identified Housing Element Opportunity Sites that account for roughly 334 housing units per standards set in the Housing Element. 4, to provide planning and consulting services for the Downtown Housing Plan. The project kicked off in March 2024 with the objective of increasing housing production in the downtown area while reducing the impact on the environment, aligning with the goals of the Comprehensive Plan, Housing Element, and Sustainability and Climate Action Plan (S/CAP). ANALYSIS •Development Feasibility: Factors such as high real estate costs, limited project scale and small lot sizes, all of which present challenges to constructing multi-family and mixed- 2 https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes-reports/reports/city-manager- reportscmrs/year-archive/2020/id-10717.pdf 3 https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development-services/long- rangeplanning/housing-work-plan/cc-downtown-housing-plan-staff-report_04182022.pdf 4 Attachment A - PA Downtown Housing Plan Contract, C24187236 use development. These challenges may be addressed through targeted incentives, policy adjustments, and other subsidies. •Regulatory Requirements: Conditions stemming from existing zoning and building regulations including setbacks, daylight plane, building heights, allowable Floor Area Ratio (FAR), ground floor retail), processing times, impact fees, parking requirements, Transfer of Development Rights (TDR) limitations, and the “shrink wrap rule” for existing legal non-conforming buildings. These issues may warrant an update to the City practices and procedures. •Process: Factors related to historical preservation policies, concerns regarding increased density and infill development, and other impacts tied to increased development in the project area. These factors may require education, engagement, and community acceptance. As a first step in the feasibility study currently underway, the team identified three sites within the project boundary and applied existing development standards and regulations to evaluate the conditions affecting housing production at a project site level. These are referred to as the “Sites for Development Feasibility Analysis.” Existing Development Standards and Applicability Following the Community Assessment Report, the project team conducted an evaluation of the City’s existing zoning standards within the Plan Area to visualize and analyze potential challenges and barriers to facilitating housing production. As further discussed in Attachment B, the site selection criteria excluded properties with a historic designation, recent or current construction, and City owned parking lots. The sites were evaluated based on their building-to land value ratio, floor area ratio, and parcel size/ownership. Three sites were chosen for a prototypical case study: 318 University Avenue, 635 Waverley Avenue, and the combination of 116 Hamilton Avenue, 136 Hamilton Avenue, and 650 High Street. Two to three mixed-use or multi-family residential scenarios were developed for each site. The sites are intended to represent a variety of contexts present within the project area. The first phase of the Site Development Feasibility Analysis process was to understand the existing development standard challenges in detail on a site-by-site basis. The next phase of the analysis process will support the feasibility analysis by determining which standards, if modified, could make multi-family or mixed-use development feasible to achieve the housing production goals of the Downtown Housing Plan: this phase is anticipated to be completed by Fall 2025. Next Steps A community workshop is scheduled for June 18, 2025, and will be held at the Palo Alto Downtown Library. The discussion with the community is expected to include exercises that will identify appropriate areas for increased residential density, ways to integrate other supporting amenities (such as public space), and trade-offs on alternative approaches developed by the project team. The project team will build pro forma models testing the financial feasibility of residential prototype development projects, each representing different intensities of development on the exemplar sites included in Attachment B. •Using this analysis, the consultant team will develop an interactive exercise with the community members to explore ways to appropriately distribute housing units within the Plan Area. Potential locations for concentrating density and intensity will be identified and represented as development prototypes that will be tested for financial feasibility. •The Housing Element opportunity site capacity within the Plan area is 334 units. This will serve as the minimum baseline capacity housing unit target for the Plan. The Downtown Housing Plan is intended to exceed this baseline capacity since the Plan’s goal is to further accelerate housing production in the downtown area. The project team will prepare a feasibility analysis that will test the potential of modified standards and the resultant housing numbers. The project team will then present the City Council with the feasibility analysis and feedback received from the community. Analysis will be provided examining the relative performance of different residential prototypes under current development standards in relation to the market demand. Based on the analysis and community feedback the project team will seek Council direction in advance of preparing policy recommendations and the draft Plan. POLICY IMPLICATIONS The City’s Comprehensive Plan Policies L-2.4, L-4.7, and L-4.8 and the Housing Element’s Implementation Program 1.4: City-Owned Land Lots and Downtown Housing Plan are specific to the downtown area; guiding the development of the Downtown Housing Plan and its objectives. The Downtown Housing Plan will be a focused policy document with relevant programs that support housing production goals within the identified boundary, incorporating development standards, design standards, necessary infrastructure improvements, implementation plan, and financing feasibility report. The adopted Downtown Housing Plan will be consistent with the Comprehensive Plan, specifically the Land Use and Housing Elements. FISCAL/RESOURCE IMPACT Project activities continue to be funded through the previously appropriated budget and authorized contract amount of $1,508,254 and there are no additional costs associated with the services being provided by Wallace Roberts & Todd, LLC. STAKEHOLDER ENGAGEMENT The project team understands that community engagement is the key to the success of the planning effort, in addition to the technical, design, and expertise provided by qualified consultants funded by the grant. There have been significant efforts from the project team to engage the resident community including a dedicated webpage, social media announcements, formation of the Community Advisory Group (CAG), a Technical Advisory Group (TAG), conducting stakeholder interviews, Community Open House, survey, and pop-ups including tabling at City events and Farmers Markets. •Organized a Community Open House on October 10, 2024, at the Community Meeting Room, City Hall. The event attracted a number of attendees from the community who provided the project team an insight on the key challenges and opportunities of the Downtown Area. •Facilitated a community survey soliciting input from residents was live from November 18, 2024, through December 20, 2024. We received approximately 406 responses, and the results are being consolidated by the project team. It will be included in the Community Assessment Report that the project team is working on. •Organized pop-ups at the City’s Tree Lighting Event, tabled at the Farmer’s Market and the 3rd Thursday event on California Avenue, and handed out fliers with project information to commuters at the Palo Alto Caltrain Station. •Convened the first CAG meeting on January 14, 2025, introducing the members of the CAG to one another and the project team, defining the scope of the Plan, roles, and responsibilities as members of the CAG, and seeking feedback and assistance in engaging with the community. ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: EXECUTIVE SUMMARY The Palo Alto Downtown Housing Plan Community Assessment Report represents an initial step in planning for downtown Palo Alto as a more inclusive livable neighborhood aligned with the City's housing production goals. Guided by the Housing Element (2023–2031) and Comprehensive Plan 2030, this assessment consolidates existing conditions based on technical analysis and community perspectives to inform opportunities for housing growth, affordability, and quality of life in the heart of the City. PROJECT PURPOSE AND AREA OVERVIEW The Downtown Housing Plan (DHP) aims to accelerate housing production in downtown Palo Alto. Spanning approximately 90 acres, the DHP area encompasses properties along Lytton Avenue, University Avenue, and Hamilton Avenue between Alma Street and Cowper Street. This area is a regional commercial and employment hub adjacent to Stanford University and the Caltrain station. The Housing Element Program 1.4 identified downtown as a Priority Development Area (PDA), offering prime opportunities for infill housing on underutilized and City-owned sites. UNDERSTANDING THE PALO ALTO COMMUNITY Palo Alto is a highly educated, high-income City with persistent affordability and equity challenges. As of 2022, the City had a population of 68,624 and a median household income of $214,118—well above County and State averages. Despite this, more than 25% of households earn under $100,000, and renter households face severe cost burdens, with 38% of households spending more than 30% of their income on housing. This number is even higher in the Plan area block groups, with 53% of renter households paying more than 30% of their income on rent and housing expenses in 2022. More detailed demographic and market data can be found in Chapter 2: Understanding Palo Alto Community, and Chapter 5: Affordable Housing and Job Analysis. PLANNING AND POLICY CONTEXT The Palo Alto Downtown Housing Plan aligns with Palo Alto’s Comprehensive Plan 2030 and its adopted Housing Element. The Comprehensive Plan designates downtown as a Regional Center with significant potential to integrate housing, employment, shopping, and transit in a pedestrian-oriented setting. The Housing Element prioritizes housing near transit and services and encourages redevelopment of underutilized public land. Key policy goals are summarized in Chapter 3: Planning Context and Chapter 6: Regulatory Landscape for Housing. Chapter 4 provides a detailed analysis of zoning districts and development standards in the downtown area, highlighting how current regulations affect development feasibility. It explores topics such as height restrictions, floor area ratios, use regulations, parking standards, and design challenges that hinder housing production. These challenges are summarized in Chapter 12, under Development Challenges, to provide a clear understanding of the limitations that can be modified to yield more housing. REGULATORY LANDSCAPE, EQUITY, AND HOUSING NEEDS ANALYSIS Chapter 5 details relevant local context, local policies, and programs that are unique to downtown Palo Alto and their applicability to the project area. The presence of City-owned land, underutilized properties, and other housing opportunity sites, proximity to high-quality transit, existing employment and commercial uses are identified opportunities that could facilitate housing production in the project area. Chapter 6 presents an Equity Analysis that traces historical patterns of exclusion and their impacts on housing access today. It identifies disparities in income, poverty rates, access to services, and housing burdens across racial and demographic groups, guiding strategies to promote fair housing. The Downtown Housing Plan explicitly aims to further equity by creating opportunities for lower -income households in a high-opportunity neighborhood. This includes a strong focus on seniors, workforce, and historically marginalized groups. Chapter 7 provides a profile of affordable housing and job market conditions in Palo Alto, connecting housing demand to employment centers. Since 2018, only 12% of permitted housing units in Palo Alto were affordable to low- or very low-income households, even though approximately 35% of local jobs pay wages that align with those affordability levels. This is below the RHNA targets for those i ncome categories, which collectively represent over 40% of the City’s assigned housing need. Most new housing units permitted during this time were market-rate, including a high share of single -family homes and accessory dwelling units. In contrast, cities like Mountain View and Menlo Park have delivered a larger number of new units through multifamily developments loca ted near transit and major arterials. Palo Alto has permitted fewer multifamily units and has not seen comparable levels of new housing construction. Within the Downtown Housing Plan area, only seven new housing units have been added since 2013, and the total number of units has declined due to the conversion of the President Hotel back to hotel use. The chapter also notes a growing mismatch between the City’s housing development patterns and the wages of its local workforce. Thirty-five precent of workers in Palo Alto earn wages that qualify them for very low- or low-income housing, yet most new housing caters to above -moderate-income earners. Many lower-wage workers employed in Palo Alto are commuting from increasingly distant locations, includ ing Alameda, Contra Costa, and San Joaquin counties, suggesting a broader regional affordability challenge. These findings contribute to the development opportunities outlined in Chapter 12, which highlight the potential for downtown to help address local and regional housing needs through zoning updates and more diverse housing types. DOWNTOWN CHARACTER AND DEVELOPMENT PATTERNS Chapter 8 explores the existing urban form and sense of place in downtown Palo Alto. It includes a block and figure-ground analysis, an overview of open space and parks, public realm features, and historic development patterns that have shaped downtown to its identity today. MOBILITY AND CLIMATE RESILIENCE CONSIDERATIONS There are a variety of mobility options available in the area including, but not limited to, Caltrain, buses, and local shuttles. The area features walkable blocks and Class II and Class III bike lanes. However, the safety and availability of active transportation options must be enhanced to support car -free living. The chapter also references State, regional, and local policies including Assembly Bill (AB) 2097 and its applicability to the downtown area. Refer to Chapter 9: Mobility and Interconnectivity Analysis for additional findings. Climate resilience is a guiding objective. While the plan area is not directly at risk from sea -level rise, flooding, or shallow groundwater due to its elevation, long -term resilience will depend on modernizing aging infrastructure and integrating climate -adaptive strategies. The area does experience moderate to severe urban heat island effects, which new development can mitigate through increased vegetation, green infrastructure, and energy-efficient building practices. Utility upgrades, water conservation measures, and shifts away from natural gas toward all-electric buildings are critical to meeting the goals outlined in the City’s Sustainability and Climate Action Plan. See Chapter 10: Resilience, Climate Adaptation, and Infrastructural Analysis. COMMUNITY ENGAGEMENT Public participation has been central to the Palo Alto Downtown Housing Plan process. Engagement efforts so far include: •A community-wide survey with over 400 recorded responses; •Pop-up events at public parks and neighborhood centers; •A community open house event; •Stakeholder roundtables with local businesses, nonprofits, and residents ; and •Targeted workforce outreach with downtown service and hospitality workers. Key takeaways from these engagements include widespread support for more affordable housing, concerns about parking loss and traffic, a desire for inclusive public spaces, and to preserve the area’s historic character. Participants emphasized the need for equitable access to housing, especially for workers, seniors, and people with disabilities. More details can be found in Chapter 11: Community Engagement Summary. KEY THEMES AND SUMMARY OF OPPORTUNITIES AND CHALLENGES Chapter 12 provides a synthesis of challenges and opportunities for housing development downtown, incorporating findings from land use, equity, mobility, and infrastructure analyses. Key findings and themes are summarized below. Development Challenges Several challenges that hinder housing production in Palo Alto’s downtown were identified. Foremost are zoning regulations that currently restrict building height, floor area ratios, and ground-floor use, particularly on key commercial corridors, Transfer of Development Rights (TDR), retail preservation requirements, and other challenges on rebuilding existing legal non-conforming floor area. These limitations make it difficult to design financially viable residential or mixed-use developments and may require targeted zoning updates or streamlined review processes to encourage investment. Infrastructure limitations, including utility capacity and aging systems, may also constrain development in some areas. Addressing these gaps will be essential to support higher-density housing and maintain service reliability. Additionally, the presence o f historic buildings and fragmented parcel ownership in parts of downtown complicates land assembly and redevelopment, potentially slowing the pace of change. Parking remains a sensitive issue, and while the City aims to maintain and/or replace public parking, it will need to explore alternative parking strategies and manage competing demands carefully. Clarifying parking requirements under AB 2097 and aligning them with urban design goals will be critica l. Development Opportunities Downtown Palo Alto’s designation as a high-opportunity area—with excellent access to transit, jobs, retail, and community services—positions it well to advance fair housing objectives to support diverse, mixed-income communities. This is further reinforced by supportive policies at the local a nd regional levels, including the City’s Comprehensive Plan, Housing Element, and Priority Development Area designation by MTC/ABAG, which align with the goal of increasing housing supply in the area. Additionally, the presence of City-owned land, particularly the underutilized surface parking lots in the project area offer advantages such as lower land acquisition costs and greater control over development outcomes. Community sentiment also reinforces these opportunities. Public engagement consistently revealed strong support for affordable and workforce housing in the downtown area. Residents and stakeholders expressed interest in promoting dense, mixed-use developments that complement the historic character while expanding housing options. Together, these factors create a favorable policy and social climate to reimagine downtown as a more inclusive and livable district. Chapter 12 ultimately concludes that with targeted zoning reforms, investment in public infrastructure, and a clear strategy for leveraging publicly owned land, downtown Palo Alto can accommodate new higher-density housing while preserving its cultural character and meeting community needs. CONCLUSION AND NEXT STEPS The Community Assessment Report provides the groundwork for evaluating changes to development standards, infrastructure, and zoning in the downtown area. It identifies key development opportunities that can unlock much-needed housing in a high-opportunity location. The strong policy alignment, community engagement, and planning momentum is expected to create sustainable and equitable urban infill when implemented. The next steps will include scenario planning to test alternative approaches to land use, zoning, and design. This process will help identify a preferred direction, which will then guide the development of targeted strategies, policies, and implementation tools. Continued technical analysis and community engagement will further refine the plan. By leveraging its assets and addressing long-standing barriers to housing production, Palo Alto can deliver its vision for a more inclusive, connected, and climate-ready future for the downtown area. For full findings, please refer to the complete Downtown Housing Plan Community Assessment Report. Figure 1: Downtown Housing Plan: Allowable FAR Figure 2: Downtown Housing Plan: Building Heights Maximum with Residential Buffer ATTACHMENT B: DOWNTOWN HOUSING PLAN SITE DEVELOPMENT FEASIBILITY ANALYSIS As part of the effort to illustrate the impact of current development regulations and other site constraints on development potential, the project team selected three sites and evaluated them for their potential for future housing development at varying intensities. The site selection process included Housing Element Opportunity Sites as well as other public and privately-owned parcels downtown. These typical exemplar sites were selected based on a specified site selection criteria described below. Site Selection Criteria The objective was to exclude parcels with low likelihood of redevelopment. The identified constraints in this case were: •Buildings with a historic designation; •Parcels that were developed in the last twenty years; •Approved and under-construction development project-sites; and •City-owned parcels with parking garages. The remaining parcels in the project area were evaluated using the following criteria to identify potential sites that can be tested: 1.Building-to-Land Value Ratio: compares a building’s improved assessed value to the land value. Sites with low-value improvements are more likely to redevelop, whereas those parcels with high- value improvements tend to be less likely to redevelop. Parcels in the project area that have a building-to-land value ratio of less than or equal to 100% (building and site improvements have less value than the value of the land) were considered as “low value” with higher likelihood of redevelopment and therefore identified as “underutilized sites.” 2.Floor Area Ratio (FAR): measures the existing intensity of development on a property. Parcels that have a ratio of less than or equal to 0.30 floor area ratio (FAR) are considered underutilized. The predominant zoning district in the downtown area is CD-C allowing mixed-use development with a non-residential FAR of 1:1 and a residential FAR of 2:1 on a parcel. A parcel within the CD-C zone with an existing FAR of less than 0.3 is significantly underutilized relative to the permitted development intensity. 3.Parcel Size and Ownership: The other important criteria that affects development feasibility is parcel size and ownership. Developers contacted as a part of the stakeholder engagement efforts indicated that parcels of 0.5 acres or higher are more viable to develop, resulting in its addition as a criterion for site selection. Additionally, parcel ownership plays a crucial role in redevelopment potential. For the purpose of site selection, both City-ownership and contiguous private- ownership were considered. Contiguous private ownership enhances feasibility by reducing the need for site consolidation, enabling larger, more cohesive developments. This systemic approach enabled the team to identify sites that have greater development potential given the existing constraints. The Opportunity Sites Map (Figure 1) contains sites considered for testing (red) based on the criteria discussed above. Of these sites shown in red, three sites were selected to represent a variety of contexts present within the project areas. The three sites tested are marked in blue to differentiate them from the other sites that were considered for testing based on the eligibility criteria. Site Development Feasibility Analysis The sites tested, assumptions considered, massing, and the results of the process are listed below. The evaluation includes the limitations related to current development standards that hinder housing production in the project area. 1.Site 1: 318 University Avenue 318 University Avenue is a mid-block Housing Element opportunity site adjacent to another opportunity site, with higher chances of parcel assembly. One characteristic of the site is that vehicular access is restricted from University Avenue. o Dimensions: 125 feet x 64 feet o Lot Area: 8000 square feet (0.18 acre) o Base District: CD-C (Downtown Commercial) o Combining District: GF (Ground Floor) and P (Pedestrian Shopping) Development Feasibility Analysis – 318 University Avenue Scenario 1: CD-C (GF) (P) designation Scenario 2: Assuming Housing Element Rezoning Achievable Unit Count 10 17 FAR, Maximum Commercial: 1.0 Residential: 2.0 Residential: 1.0 Height Maximum 49 feet 44 feet Usable Open Space/ unit 150 square feet/ unit (private) 150 square feet/ unit (private) Commercial Space 8000 square feet Parking Required: 46 spaces Required: 25 spaces Achieved: 10 spaces Achieved: 10 spaces 2.Site 2: 635 Waverley Street 635 Waverley Street is a mid-block site over 0.25 acres. It is also adjacent to the RM-40 district where special mixed-use and residential development standards apply. o Dimensions: 70 feet x 193 feet o Lot Area: 13,500 square feet (0.31 acre) o Base District: CD-C (Downtown Commercial) o Combining District: P (Pedestrian Shopping) Development Feasibility Analysis – 635 Waverley Street Scenario 1: CD-C (P) Vertical Mixed-Use Scenario 2: CD-C (P) Horizontal Mixed-Use Achievable Unit Count 16 18 FAR, Maximum Commercial: 1.0 Commercial: 0.75 Residential: 1.0 Residential: 1.25 Height Maximum 49 feet Commercial: 43 feet Residential: 45 feet Usable Open Space 2,400 square feet (common) 2,600 square feet (common) Commercial Space 13,500 square feet 10,200 square feet Parking Required: 70 spaces Required: 58 spaces Achieved: 15 spaces Achieved: 15 spaces 3.Site 3: 116, 136 Hamilton Avenue and 650 High Street The site including parcels on 116, 136 Hamilton and 650 High Street have common ownership facilitating parcel assembly and higher development feasibility. 650 High Street is a Housing Element opportunity site and is in relatively closer proximity to the Palo Alto Caltrain Station with a greater potential to test higher density and intensity. o Dimensions: 100 feet x 125 feet and 75 feet x 112.5 feet o Lot Area: 20,937 square feet (0.48 acre) o Base District: CD-C (Downtown Commercial) o Combining District: P (Pedestrian Shopping) Development Feasibility Analysis – 116, 136 Hamilton Avenue and 650 High Street Scenario 1: Vertical Mixed-Use Scenario 2: Horizontal Mixed-Use Scenario 3: Hybrid Achievable Unit Count 36 32 38 FAR, Maximum Commercial: 0.8 Commercial: 1.0 Commercial: 1.0 Residential: 1.25 Residential: 1.0 Residential: 1.25 Height Maximum 44 feet 44 feet Mixed-Use: 48 feet Residential: 44 feet Usable Open Space 9,925 square feet (common) 6,500 square feet (common) 7,100 square feet (common) Commercial Space 9,800 square feet 12,500 square feet 12,500 square feet Parking Required: 75 spaces Required: 82 spaces Required: 88 spaces Achieved: 23 spaces Achieved: 25 spaces Achieved: 25 spaces Figure 1: Downtown Housing Plan: Sites for Development Feasibility Analysis Johnson Park Cogswell Plaza Williams Park El Camino Park PALO ALTO STATION ALMA ST TASSO ST KIPLING ST HIGH ST EMERSON ST RAMONA ST BRYANT ST WAVERLY ST COWPER ST WEBSTER ST FO R E S T A V E HA M I L T O N A V E UN I V E R S I T Y A V E LY T T O N A V E EV E R E T T A V E FLORENCE ST PA Office Center Lytton Plaza 0.5 MILE City Hall 0 250 500Feet Parks Downtown Housing Plan Boundary Housing Element Sites Selected testing site