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Advice to Council on Housing Element Update

Sent: Wednesday, March 24, 2010 1:28 PM
Subject: Comp Plan / Housing Element Update

Dear Council and Planning Commission,

With regrets, time constraints force me to withdraw from the City of Palo Alto Housing Element Technical Advisory Group. I wish the process well and I am re-sending my technical and advisory recommendations from June 2009 because I still believe that these recommendations would assist the process.

In addition, I believe it would be worthwhile to consider what I'd call the "Schmid 50/120" Scenario. This would be a scenario producing only 50% of the California Department of Housing and Community Development (HCD) RHNA housing unit target while going beyond best practices on all the other constraints (120%). Such a scenario could set very important suburban smart growth precedents for reducing GHG a la SB375. I believe that HCD would give serious consideration to such a proposal. It might be appropriate for Palo Alto to take some sort of a public stand (such as a Council Resolution) in favor of regional/statewide smart growth climate protection efforts that support AB32. Given the possibility of a Jerry Brown governorship and given Brown's past battles with Pleasanton over growth, I believe that it is prudent for Palo Alto to move more rapidly towards an HCD-compliant Housing Element.

Best regards, Cities21

Sent: Wednesday, June 24, 2009 
Subject: June 24 Planning Commission session on Housing Element Update

Re: Planning & Transportation Commission June 24 6PM Session on the Housing Element Update

Dear Planning Commission:

1. The Comp Plan and Housing Element update is a complicated process with multiple competing constraints such as GHG minimization, city budget balancing, PAUSD budget balancing, affordable housing maximization, traffic minimization, and ABAG/HCD housing unit compliance. The analogy from algebra is that we have a "system of N equations (constraints) with N unknowns." Such a system of constraints necessitates examining feasible scenarios and picking the best scenario. A Holistic approach that comprehends tradeoffs between constraints is required.

My interpretation of the competing Comp Plan Update constraints:

  • Comply with state law by meeting the 2007-2014 housing unit allocation: 2,860 housing units needed, with 891 already approved.
  • Preserve Palo Alto's existing single family home residential neighborhoods. Stop approving major new auto-centered residential development in South Palo Alto. (IE outlaw Arbor Real.)
  • Stretch beyond best practices to minimize traffic/driving created by new residents. New residents should generate less than half of the VMT (vehicle miles traveled, a measure of total driving) that current residents generate. i) Intensify residential development near Caltrain stations. Reduce retail/recreational driving by putting more people within walking distance of CA Ave and University Ave activities. ii) Reduce commute driving by selecting new residents who will commute via green alternatives (Caltrain, bus, carpool, bike, etc.) and who will commute shorter distances. iii) Implement policies to encourage incoming 2-car families to transform into 1-car families. Optimize parking. iv) Taken together, these policies will minimize regional CO2 growth, protecting the climate. These policies will maximize sales tax receipts by capturing more shopping within the city, aiding the city budget. Should Palo Alto win a HSR station, these policies will maximize HSR ridership.
  • Ensure that new housing has a neutral or positive impact on city and PAUSD budgets. In pursuit of this fiscal objective, maximize new market rate senior housing.
  • Acknowledging that Palo Altans are compassionate, stretch beyond best practices to maximize affordable housing production within the allocation
  • Create an implementable plan that is deemed feasible by developers


1A. Hence, 3 or more feasible scenarios meeting the constraints should be developed ASAP. It is frustrating to not see more progress towards developing feasible scenarios. The delay in developing Comp Plan scenarios will tend to lead to piecemeal/opportunistic development rather than maximal mitigation. Citizen and government input comparing 3 or more feasible scenarios will be tremendously helpful. Likewise Comp Plan input without feasible scenario context leads to "unconstrained analysis/feedback."

I believe this is not an impossible exercise; there are feasible scenarios meeting the constraints.

1B. Exercises such as the Cal Ave Workshops are problematic when not considered within the context of tradeoffs within the overall Comp Plan Update. The issue isn't whether citizens object to 3 to 4 story residential on Cal Ave. In contrast, consider 3 scenarios: A, B, and C, where Scenario B might have 5-story in-fill of the Cal Ave area. The issue is how citizens and government weigh the respective benefits and drawbacks of scenarios A, B, and C. It may be that Palo Alto adopts the "least worst" scenario, but we have to adopt something.

It's natural to object to most forms of significant change within the Comp Plan Update, but it is far more productive to select between alternatives. We need to see the forest amidst the trees. If we look at each tree separately within the forest and object to each tree that is not helpful in creating a feasible forest plan. The discussion of tradeoffs can increase the creativity of the eventual preferred alternative.

1B. Exercises such as examining each current Housing Element Policy one by one are problematic, because:

  • The preferred scenario should precede development of policies that support the preferred scenario.
  • There's little justification for similar cities to adopt their own separate Policies when there should be a generic set of policies that work for similar cities. Likewise, the Housing Element Policy Revision process should first start with an examination of best practices from other cities, especially in light of the stated staff goal of simplifying PA's policies.


1C. Exercises such as developing the housing opportunity site inventory without developing an overall vision for the Comp Plan are counterproductive. Selection of a preferred scenario will lead to closer examination of parcels that will support the preferred scenario while reducing scrutiny of other parcels.

2. University Avenue Concept Plan Study

It is worthwhile to consider whether transit-oriented-development in-fill of University Avenue is a desirable way to meet Comp Plan Objectives. The city would be well-served by undertaking such a Concept Plan.

3. Current Smart Growth isn't sufficiently smart.

Typical Palo Alto residential growth is "bad" for traffic and GHG. Current smart growth practices are better than typical suburban growth, but still leave much to be desired. The City should understand that there isn't a simple template to follow to grow without significant negative traffic and GHG impacts. It cannot be overemphasized that the Comp Plan Update should envision stretching well beyond smart growth best practices. Luckily, Palo Alto itself has already helped pioneer some of the next generation of smarter smart growth.

4. As far as developing new affordable housing, we face a major funding crisis and will also need to stretch well beyond current affordable housing production best practices to meet Comp Plan objectives. It is encouraging that Stanford has offered a major contribution to the housing fund - that contribution will help, but not solve the crisis.

5. Regarding the May 5 Comprehensive Plan Fiscal Background Report. I recommend that this report be re-done as the conclusions are not only flawed, but they are misleading. The consultant (ADE) analysis relies on "average" impact of existing land uses to predict future impact. In a Proposition 13 world, a "marginal" analysis is required. We have many long-occupied homes that pay low property taxes, and many recently occupied homes that pay high property taxes. On page 2, ADE claims that average property tax for a single family home (SFH) is $946 compared to $115 for multi-family units. This is misleading because recent multifamily condos (including affordable units) such 800 High pay far higher property tax ($11,035 per year) than the average Palo Alto SFH.

We have practically zero homes that represent the arithmetic "average." Further, we need fiscal impact information segmented by housing type: SFH with 2 adults and 2 kids, market rate senior condos, 800 square foot (sf) - 2 bedroom market rate condos, 800 sf - 2 bedroom moderate income condos, 250 sf market rate SRO condos, Arbor Real / Echelon style 1600 sf 3-bedroom condos/townhomes, etc. Given a feasible scenario with a prescribed mix of residential home types and units, we should be able to develop a detailed, accurate model of City and PAUSD fiscal impact. For new housing that is located within walkable retail, associated per capita sales tax increase should be calculated.

6. One feasible Comp Plan Scenario is presented at:

Best regards, Cities21

Ex: City of Palo Alto Housing Element Technical Advisory Group