HomeMy WebLinkAboutStaff Report 2510-5386CITY OF PALO ALTO
CITY COUNCIL
Monday, December 15, 2025
Council Chambers & Hybrid
4:30 PM
Agenda Item
A.Feasibility of Marketing Different Housing Typologies without On-Site Parking (2023-2031
Housing Element Program 3.9(B)). CEQA Status: Exempt under CEQA Guidelines Section
15378.
City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: Planning and Development Services
Meeting Date: December 15, 2025
Report #:2510-5386
TITLE
Feasibility of Marketing Different Housing Typologies without On-Site Parking (2023-2031
Housing Element Program 3.9(B)). CEQA Status: Exempt under CEQA Guidelines Section 15378.
RECOMMENDATION
This is an informational report, and no Council action is required.
EXECUTIVE SUMMARY
The City of Palo Alto’s 2023-2031 Housing Element (Housing Element) includes Program 3.9(B),
requiring staff to conduct outreach concerning the “feasibility of marketing different housing
typologies without on-site parking (paid through in-lieu fee) and implications to City parking
resources,” and present findings to the City Council by December 31, 2025. This informational
report summarizes the outreach and analysis for Program 3.9(B) (Attachment A). The program
also requires that amendments to the Palo Alto Municipal Code (PAMC) directed as a result of
this Program be adopted by December 31, 2026.
Because State law (including AB 2097) eliminates minimum parking requirements within ½ mile
of major transit stations, the City cannot impose or rely on residential parking in-lieu fees in
areas where Program 3.9(B) was intended to apply. As a result, staff do not recommend any
amendments to the PAMC related to Program 3.9B.
This reports fulfills the City’s obligations under Program 3.9(B), and related, though separate,
parking policy work is expected to continue as part of broader mobility and parking
management efforts beginning in 2026.
BACKGROUND
The City’s Housing Element contains a number of programs intended to increase housing
supply, including Programs 3.1 through 3.9, intended to remove existing potential constraints
to residential development. Program 3.9 considers the constraints impacting the conversion of
commercial uses to mixed-use residential development. The program is based on the tenets
that:
Mixed-use projects are a more efficient use of land and can make housing development
more profitable and therefore more likely to be constructed and are appropriate in
certain areas.
Mixed-use development downtown or near high quality transit and rail service can
enhance the local economy and support small businesses.
The City’s jobs/housing balance can be improved by encouraging mixed-used residential
development over commercial development.
Palo Alto will implement development standards that incentivize greater housing
production and temper the strong market demand for commercial development.
ANALYSIS
State Law (namely Assembly Bill [AB] 2097 adopted in 2022) precludes the City from
enforcing minimum parking requirements near the Downtown and California Avenue
Caltrain stations for most uses, including residential development. Because in-lieu fees must be
tied to a minimum parking requirement that is being waived, AB 2097 also eliminates the legal
basis for imposing parking in-lieu fees in these transit-rich locations.
If residential developers voluntarily elected to pay a fee to obtain off-site parking spaces
or the City implemented a new parking impact fee, the existing commercial in-lieu fee of
$130,823 per space for non-residential development would be cost-prohibitive and
infeasible for residential projects.
On-site parking is still the norm for multi-family and mixed-use developments along the
Peninsula. Generally, 1 to 1.2 spaces per unit is the minimum typically required by
lenders, investors and developers. There is support among developers for eliminating or
reducing parking requirements beyond what is prescribed in State law to allow the
market to determine appropriate parking needs, however, because State law already
eliminates most residential parking minimums near transit, any further reductions
would apply only in areas where justifying such reductions is more challenging.
Furthermore, there are existing measures developers can take to request a site-by-site
parking reduction if warranted (e.g., State Density Bonus Law concessions or objective
parking reductions).
Some stakeholders believe that potential tenants will self-select, for example, residents
who do not own cars will choose to live in units that do not have a parking space. Other
stakeholders believe that, especially given high rents and amenities of units in Palo Alto,
a parking space is required and expected as part of a unit. According to property
managers, units that do not have any parking can be difficult to lease.
Consider a parking impact fee, or other fees or regulations to support alternative modes
of transportation, such as walking, biking, and transit, instead of parking in-lieu fees in
areas within ½ mile of the transit stations.
Consider a lower parking fee for residential developments if underutilized space in City
lots and garages can be identified for such a purpose. Once completed, staff could
monitor the City’s California Avenue and Downtown Automated Parking Guidance
Systems (APGS) to identify if there are excess parking spaces which could be set aside
for permit parking.
Consider in which instances off-site parking may be in the interest of both the
developers and residents (existing and future) in targeted locations. Off-site parking may
be viable for some developers and some projects (e.g., smaller projects, missing middle
projects), but would need to be provided within a block or two of a project site. Off-site
parking facilities would need to be available at occupancy to address tenants’ needs and
community concerns about spillover.
Consider when on-site parking may not be desirable for the community on smaller or
mid-block projects in pedestrian oriented commercial areas; due to the addition of more
curb cuts and traffic crossing pedestrian sidewalks and bike lanes.
Consider funding of bicycle and pedestrian improvements (as identified in the City’s
Comprehensive Plan and Bicycle Pedestrian Transportation Plan) and transportation
demand management measures by either the City or private developers to encourage
households to shift away from reliance on personal vehicles, reducing the long-term
need for parking.
While some relatively minor changes could be made at this time to City policies or ordinances
to further reduce parking requirements for residential development, the most appropriate
locations to consider initially are transit rich areas where State Law already supersedes local
zoning requirements. The downtown area would be appropriate to consider broader, holistic
parking demand management solutions as part of a future policy review. OOT staff expects to
begin discussions in 2026 concerning potential parking policy changes that may address current
challenges. This work is expected to consider parking issues for businesses and visitors, and
future resident parking options might also be included. These discussions will incorporate a
more contemporary understanding of how parking demand works, including how excessive
parking resources induce vehicle miles traveled (VMT), traffic congestion, and car dependency.
Potential topics include opening up City parking resources to wider paid use cases, including
long-term residential tenant leases of public parking, which could support housing affordability,
how parking cash out programs could fund transportation demand management (TDM) and
active transportation priorities, and how trip generation fees could be assessed to support
mobility programs rather than parking capital projects. Additionally, Planning and Development
Services staff will monitor applications from developers who are either exempt from or request
a waiver from PAMC parking minimums to determine if there are market trends where future
code amendments may be warranted.
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
www.lexingtonplanning.com
MEMORANDUM
Date: November 26, 2025
From: Jean Eisberg
To: Planning and Development Services, City of Palo Alto
Subject: Housing Element Implementation – Task 3.9B Parking Research
PURPOSE
This memo provides background research and summary of stakeholder interviews to support the
following Housing Element program (3.9B):
B. Conduct outreach with home builders and other stakeholders regarding the feasibility of
marketing different housing typologies without on-site parking (paid through in-lieu fee) and
implications to City parking resources; present findings to the City Council with options on how
to proceed, including extension of the University Ave In-Lieu Parking program to residential
projects and creation of an in-lieu parking program for the California Avenue area.
SUMMARY
The project team conducted a review of applicable Palo Alto parking programs, requirements, and
reports, as well as State Law, to understand the existing parking situation, with a focus on the transit-
rich areas of Downtown and California Avenue. Additionally, the project team conducted
stakeholder interviews to understand public perception of parking in Palo Alto. The below findings
and analysis are based on current practices, which could change in the future. Palo Alto’s Office of
Transportation (OOT) is tasked with beginning a public conversation in fiscal year 2025-2026
concerning potential parking policy changes available to the City, and how such changes might
impact current parking concerns primarily for businesses and visitors, however future resident
parking options might also be included.
Key findings are as follows:
• State Law (namely Assembly Bill [AB] 2097) precludes the City of Palo Alto (City) from
enforcing minimum parking requirements in Downtown and California Avenue for most
uses. As a result, it also prevents the City from assessing parking in-lieu fees within 1/2 mile
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of major transit locations (i.e., Downtown and California Avenue Caltrain stations). The City
could instead consider a parking impact fee, or other fees or regulations to support
alternative modes of transportation, such as walking, biking, and transit.
• Off-site parking may be viable for some developers and some projects (e.g., smaller projects,
missing middle projects), but would need to be provided within a block or two of a project
site. Sufficient off-site parking facilities would need to be available to address: (1) tenants’
needs; and (2) community concerns including both spillover parking and use of the City’s
residential permit parking program by residents in new developments.
• If residential developers voluntarily elected to pay an in-lieu fee to obtain off-site parking
spaces, or the City implemented an impact fee, the existing fee of $130,823 per space for
non-residential development would be too expensive to be feasible.
• Some stakeholders believe that potential tenants will self-select—i.e., residents who do not
own cars will choose to live in units that do not have a parking space. Other stakeholders
believe that—especially given high rents and amenities of units in Palo Alto—a parking
space is required and expected as part of a unit. According to property managers, units that
do not have any parking can be difficult to lease in Palo Alto.
• Stakeholders support eliminating or reducing parking requirements to allow the market to
determine appropriate parking needs. Generally, 1 to 1.2 spaces per unit is the minimum
required by developers and investors based on developer feedback.
• From an urban design perspective and alternative transportation advocate’s perspective, on-
site parking may not be desirable. Additional curb cuts degrade the pedestrian experience,
can be especially challenging for small sites and mid-block locations where parking garage
circulation is tight.
ANALYSIS
State Law Context
State law limits the City’s ability to enforce its minimum residential parking standards—and in turn
in-lieu fees—for housing projects close to major transit stops and for affordable housing projects. A
developer would have to specifically want and request off-site parking and/or voluntarily pay into a
parking district to obtain off-site parking spaces.
AB 2097 (Gov. Code Section 65863.2) enables 100% reductions in required parking spaces for most
residential and commercial uses within 1/2-mile of the three Caltrain stations, as shown in Figure 1
below. AB 2097 also applies in locations with intersecting bus lines with service at least every
20 minutes during peak commute hours.
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Figure 1: AB 2097 Applicability in Palo Alto
Source: City Council Staff Report Attachment B, August 12, 2024:
https://cityofpaloalto.primegov.com/api/compilemeetingattachmenthistory/historyattachment/?historyId=9c8478b3-
8641-4b68-b55d-adab62632f8e
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Figure 2: Downtown Parking District Boundaries
Source: City of Palo Alto.
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In Downtown Palo Alto, AB 2097 applies to nearly the entire Downtown Parking Assessment
District, as shown in Figure 2 above. The exception is a few parcels between Tasso and Webster
Streets at the far east end of the District. As a result, most multifamily housing projects would
already be exempt from the City’s minimum parking requirements and can therefore choose the
amount of parking to provide or whether to provide parking at all. In other words, such projects
would not be required to pay an in-lieu fee, except in the small area outside of the ½-mile boundary.
Senate Bill (SB) 35 provides alternate parking requirements for housing projects with a certain
amount of affordable housing (currently 50% in Palo Alto). It sets a maximum of one space per
dwelling unit, but requires no parking if the project meets certain standards, including but not
limited to:
• The development is located within 1/2 mile of public transit (including bus stops);
• The development is located within an historic district, such as the Professorville and
Ramona Street Historic Districts; or
• On-street parking permits are required but not offered to the occupants of the development.
Similar to AB 2097, these provisions of SB 35 would preclude the City from requiring an in-lieu fee
payment for off-site spaces within 1/2 mile of major transit. A developer would need to choose to
pay into a parking district to park off-site because it is too expensive or physically infeasible to locate
parking on-site.
Stakeholder Feedback
Feedback from five stakeholders, including residential developers, property managers, and a housing
and transportation advocate, is summarized below. In total, these developers/property managers
manage hundreds of units in Palo Alto, and have thousands of units proposed within Palo Alto.
Stakeholders generally support reduced parking minimums. Eliminating or reducing residential
parking requirements allows the market to determine the appropriate parking requirement for a
given project. Generally, developer stakeholders indicated that a ratio of 1 to 1.2 spaces per unit is
the rule of thumb to meet tenant demand and investors’ expectation. By comparison, for multi-
family housing units, the City’s zoning ordinance requires a minimum of 1 space per studio/1-
bedroom unit and 2 spaces per 2-bedroom unit or larger. According to developer stakeholders, in a
suburban location like Palo Alto, investors will not finance a project with a parking ratio of less than
one space per unit, especially for ownership units and even in locations near transit or other modes
of travel.
Perspectives on alternative parking strategies are mixed. Parking stackers can be a good
way to fit more parking, but decision-makers and community members have expressed
concerns. Some developers are concerned about whether stackers actually get used by
tenants, but others think they are a great option. Educating decision-makers and community
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members through videos or site visits to completed projects in the region to see how
stackers operate could be a way to improve understanding about these options.
Similarly, there was mixed support for residential permit parking programs. Stakeholders
generally acknowledge the sensitivity among existing residents about street parking and the
potential for “spillover” of parking into existing neighborhoods. Developer stakeholders see
providing sufficient parking on-site as a way to address those concerns during entitlement.
Off-site parking within a block or two of a project site could work, but is less desirable
according to developer stakeholders, especially given high rent levels in Palo Alto. Some
developers indicated that for small lots and small projects (e.g., 4-10 units), off-site parking
may be viable since it’s just a few cars. Others indicated that there may be a missing middle
market of residents who are willing to park off-site in exchange for more modest rent levels
for units that do not come with parking.
The market for housing without parking/tenants without cars is unclear. Stakeholders
provided a range of feedback regarding whether or not the market would support housing without
parking. Some stakeholders believe that potential tenants will self-select—i.e., residents who do not
own cars will choose to live in units that do not have a parking space. Some stakeholders believe
that the market for housing without parking will improve over time, as tenants have access to shared
driverless vehicles among other advanced technologies. Some project proponents are trying to be
more forward looking now to attract a more missing middle housing market of residents who are
willing to forego a nearby parking space, and potentially vehicle ownership, in exchange for reduced
rent.
Other stakeholders believe that—especially given high rents and amenities of units in Palo Alto—a
parking space is required and expected as part of a unit. Units that do not have any parking can be
difficult to lease. One stakeholder looked up the data on residents in Palo Alto who own cars and
found that their database shows that over 98% of their tenants own at least one vehicle. According
to the City’s Rental Registry database for FY24-25, of the 7,653 registered rental units in the City,
over 90% of units offered parking on-site and included parking in the monthly rent amount. This
finding does not necessarily correlate with car ownership, but one can conclude that parking is a
typical amenity provided with rental housing.
Moreover, stakeholders did not believe that the types of housing affected these findings that parking
is an expected amenity. There are parking demands for both ownership and rental units, market rate
and affordable units, and units geared toward young professionals vs. families. Rental and affordable
units tend to have larger household sizes and may have more vehicles per household. There was
generally a sense among developers that even if residents only use their vehicles on the weekends,
they still have vehicles that need to be parked somewhere. In Downtown, near Caltrain and close to
Stanford campus, parking demand may be lower, but a minimum 1:1 ratio is still appropriate.
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Development typologies with no parking are common in highly urban areas and strong
student housing markets. Developers are building multifamily without parking spaces in certain
markets of the Bay Area. However, according to developer stakeholders, more suburban conditions
in Palo Alto do not support these types of developments.
The images represent two recent housing developments on small lots (< 5,000 sq. ft.) that contain no parking spaces.
Located in Downtown Berkeley, these developments are walkable, near bus and rail lines, and target students (i.e.,
studios with built-in furniture).
The current in-lieu fee, assessed on commercial developers, may be too high for residential
developers. The FY24-25 Parking In-Lieu Fee for Downtown Assessment District is $130,823.17
per space. This generally exceeds the cost of constructing a parking space, which is roughly $80,000
to $100,000 per space, for at-grade structured and underground, respectively, according to
stakeholders. The City can impose an impact fee in an amount below the actual cost to construct
new parking and fund the balance of the cost through operating revenues (permits or leases), but the
fee amount still needs to be financially feasible. The fee assessed on non-residential projects is
unlikely to be viable for residential projects, especially since it is less attractive than having access to
a space on-site. There is a sense that fees are already high and that projects cannot take on more
fees.
Mountain View and Redwood City allow residential projects to make fee payments in-lieu of
providing parking in the Downtown Zones. However, these cities are also subject to AB 2097 given
the proximity of their downtowns to transit and therefore may no longer require those fees. Still,
Mountain View’s fee is substantially lower at $64,472 per space.
There was somewhat more support among stakeholders for off-site parking in existing garages as
opposed to funding in-lieu fees for future parking supply.
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Fees to support alternative modes of transportation as an alternative. Additionally, some
stakeholders suggested that in-lieu fees could instead be used to support transportation demand
management (TDM) measures or other related transportation improvements within the vicinity of a
project site. Such alternative transportation strategies could better support tenants who do not own
cars to encourage alternative modes of travel. Some stakeholders believe there may be less need for
parking in the future as alternative modes increase and technologies improve. Stakeholders agree
that on-site parking is expensive and drives site planning and reduces the number of units achievable
on a site. Finding ways to reduce on-site parking supplies can make room for more housing units.
CONCLUSION AND RECOMMENDATIONS
In conclusion, based on feedback from developer stakeholders, at present the market is unlikely to
bear housing development projects without parking, even in locations near transit. In the future,
with mode share shifts, availability of shared and autonomous vehicles, and expansion of
transportation alternatives, this trend could change and projects with reduced or no parking could be
viable as way to lower construction costs and in turn rental rates. To monitor these trends over time
the City could:
• Monitor parking levels for projects approved within ½ mile of major transit. Identify
parking ratios for housing projects approved within and outside areas where AB 2097
applies. Determine whether projects are choosing to use AB2 097 parking exemptions or
whether they are building on-site parking consistent with anticipated tenant demand.
Compare parking ratios approved for individual projects to the City’s minimum parking
requirements to identify potential changes to City standards.
• Monitor parking garage usage. Once completed, monitor the City’s California Avenue
and Downtown Automated Parking Guidance Systems (APGS) to identify if there are excess
parking spaces which could be set aside for permit parking.
This memo concludes that expanding parking districts to residential uses is not viable in Downtown
and California Avenue given AB 2097 exemptions which prevent the City from collecting
residential parking fees in-lieu of on-site parking. Instead, the City could consider other impact fees
and/or transportation demand management (TDM) measures as part of holistic parking policies
considered by the OOT, which continue to make alternative modes easier to choose and use, and in
turn may reduce on-site parking demand.
• Consider assessing transportation impact fees and expanding TDM: The more that
the City is able to fund and construct bicycle and pedestrian facilities identified in the
Comprehensive Plan and Bicycle and Pedestrian Transportation Plan, the more one can
expect community members to shift at least some trips to alternative transportation modes.
Likewise, as TDM measures fund free transit passes and public transit reliability and speeds
improve, transit ridership may expand as well. However, any new fee or requirements will
need to balance these potential benefits against effects on financial feasibility. At present,
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commercial development is likely to be able to bear additional development costs, but
housing development—especially rental housing—may not.
Over time, these mode shifts may reduce the need for car ownership and therefore reduce demand
for on-site parking spaces.