October 21, 2017 Newsletter

Comprehensive Plan Update enters final stretch

Monday, October 23 offers the last best chance for resident input to influence the Comp Plan Update that will set city land use policy for the next 15 years. This newsletter issue offers a quick primer on what’s at stake.

Don’t miss your final chance to weigh in. You can speak up at the 10/23 City Council meeting or send your comments by email to city.council@cityofpaloalto.org. On October 23, Council will consider Planning Commission recommendations and community input, provide any further direction to staff and certify the Final Environmental Impact Report (FEIR). On November 13, City Council will adopt a final plan.

Guest Commentary

By Hamilton Hitchings

Currently Palo Alto is a great place to live with its family neighborhoods, and to work with its leading technology companies like Tesla. I hope it will still be like that in 15 years. However, Palo Alto faces several major challenges due to its popularity.

Resident Concerns

The National Citizen Survey is conducted every year for the Palo Alto city government to provide a statistically sound measure and solid data on how its residents feel about Palo Alto. These areas have recently been declining sharply in key areas of livability.

  • In 2012 residents rated the quality of life as good or excellent for 94% of respondents and by 2016 that had dropped to 85%.
  • As a place to raise children it fell from 92% in 2012 to 84% in 2016
  • As a place to work it fell from 88% in 2012 to 82% in 2016

Why?  Well according to the survey, the following areas highlight the major concerns:

  • Availability of affordable quality housing was rated as good or excellent by only 6% of residents
  • Cost of living in Palo Alto – 7%
  • Ease of travel by public transportation in Palo Alto – 28%
  • Traffic flow on major streets – 30%
  • Ease of public parking – 33%
  • Land use, planning and zoning – 37%

In summary affordable housing, traffic and parking are major areas of dissatisfaction for Palo Alto residents and should be more effectively addressed by the Comprehensive Plan Update.

The Cause – Recent Office Boom

This has been caused by the office boom where recently about 20 office buildings have been built relative to only a couple of small multi-unit apartments in part because office is more profitable. The recent office building boom can also be quantified with data. According to the City of Palo Alto’s 2014 Existing Conditions Report, page 8-33, the average annual non-residential square footage growth from 1989 to 2008 was approximately 38,000 square feet per year but it’s rate of growth tripled from 2008 – 2014 to an average of approximately 112,000 square feet per year in the 9 monitored areas.

Housing Affordability Challenges

While many argue that building smaller, market rate housing units will improve affordability, the evidence on the ground locally doesn’t bear that out. For example, the new apartments at San Antonio Shopping Center called Carmel The Village are between 547 and 638 square feet and rent for $3,000 to $5,000 dollars per month. I have heard many folks say small units are affordable but without including explicit mention of subsidized or Below Market-Rate (BMR) the result will likely be luxury 1 bedroom apartments like Carmel The Village.

In terms of massive housing building we do not have the transportation infrastructure or the acreage to support that and CalTrain trenching will absorb the majority of our available transportation dollars for the next 15 years.

Equally importantly, the new comprehensive plan would build too much new office space, add too many jobs and not enough housing. The Comprehensive Plan Update allows for 3 million more square feet of office to be built over the next 15 years, crowding out housing. Despite the fact most folks in Palo Alto agree the priority needs to be on zoning for more affordable housing including below market and subsidized and despite strong statements about supporting affordable housing by all city council members, often the majority of the city council votes against affordable housing. This includes:

  • reducing proposed developer fees for new office construction to help fund below market housing,
  • watering down the office cap via a rollover, and eliminating prioritizing projects designed for better environmental quality, mitigation of impacts, public benefit, or inclusion of housing, retail and cultural amenities
  • removing the downtown total office cap, and
  • allowing 3 million square feet of new office space to be built over the next 15 years instead of rezoning some of that for housing.

And that’s just votes in 2017!

Traffic and  Parking Impacts

In addition to frustrating residents, growing traffic and parking problems hurt all Palo Alto businesses. Traffic congestion and poor Level of Service (LOS) at intersections result in not only longer commute times but shorter employee retention and an increased difficulty of attracting top talent. For retail, they also hurt their ability to attract customers.

In terms of parking, as long as we are using residential neighborhoods to park office employees, unlike almost all other cities in the Bay Area, we should require new buildings to be fully parked for the parking demand it creates and its loading zones usage.

Lastly, I’d like to address one of the Highest Priority Changes recommended by the PTC. That is to study to converting parts of University Ave to pedestrian only (PTC High Priority item #5 on page 11 of the City Council Staff Report 10/23/2017). I think introducing a major change this late in the process is too radical and was not discussed as a program during the Comprehensive Plan Update Citizens Advisory Committee, which would have been the time to bring it up. University connects Stanford and 101 and until we have solved our parking and traffic problems and dealt with Caltrain grade separation it’s premature to study this.


Thus in summary, our parking, traffic and affordable housing problems will continue to grow unless we limit office development, refocus on housing with a stronger emphasis on affordability including BMR and make meaningful progress on transportation and parking management. I hope you can find time to come speak at the City Council meeting Monday on these issues. Let’s make Palo Alto a great place to live and work 15 years from now!

Hamilton Hitchings has been a Palo Alto Resident and previously served on the Comprehensive Plan Update Citizen’s Advisory Committee, which has now completed and these views are his own.

Comp Plan Wrap-up

First four, then six different growth scenarios were studied in the Draft Environmental Impact Report (DEIR) for the Comp Plan Update, released in February 2016 and revised in February 2017. Council then opted for a seventh, a hybrid of those analyzed, that is reflected in the Final Environmental Impact Report (FEIR). So if you were unclear on what Council’s preferred scenario would mean for Palo Alto, you’re in good company.

Below we highlight the latest big picture impact data revealed in the FEIR as well as policy issues that continue to linger. While the FEIR establishes a legal foundation for the proposed Comp Plan Update under the California Environmental Quality Act (CEQA), it is up to City Council to decide whether the growth targets are appropriate and the impacts are acceptable for Palo Alto.

If you have strong opinions on these or other Comp Plan issues, it’s not too late to be heard. Speak up at the October 23 City Council meeting (Comp Plan discussion is scheduled to begin at 7:45pm) or send your comments by email to city.council@cityofpaloalto.org.

By the Numbers

Note: These data do not include Stanford’s proposed expansion that would produce additional 2.275 million square feet of new development plus 3,150 new on-campus housing units/beds. Click here for more info on Stanford’s plan.

Growth Targets

School Enrollment Impacts

Understanding what the FEIR tells us about school impacts is tricky business. Under State law, any need for additional school facilities is presumed to be fully mitigated with the payment of school fees (set by the school district and applied to each development project) regardless of the number of students generated. Therefore, no matter what the EIR analysis shows in terms of anticipated new student enrollment under the Comp Plan, it will lead to a finding of “less than significant impact” for CEQA purposes.  CEQA does not offer legal protection to a community from overcrowding of schools.

Nonetheless, the school impacts analysis in the Comp Plan FEIR can and should inform City Council whether their chosen growth targets are appropriate and sustainable. And the community should understand the assumptions on which the analysis is based. Those assumptions are described on p. 5-7 of the FEIR. Here they are in a nutshell:

  • Assumes that all net new housing will be multi-family units (apartments and condos), the housing type likely to generate the fewest new students. For example, at the elementary level, single-family attached units (town homes) would be expected to produce 35 percent more students per unit. Detached single family homes would produce 65 percent more.
  • Assumes that PAUSD schools can operate at maximum contractual capacity. The PAUSD Superintendent indicated that this would result in elimination of space for “wellness services, project-based learning, music and arts activities, special education, maker spaces, and other purposes.” PAUSD Trustee Todd Collins suggested that realistic operational capacity is 90 to 95 percent of maximum capacity.

Even with those generous assumptions, the FEIR analysis shows that under the preferred Comp Plan scenario PAUSD elementary and middle school capacity will be exceeded at both the low- and high-end range of projected housing growth.

Transportation Impacts

The Comp Plan Update includes several mitigation measures designed to reduce motor vehicle traffic. However, even if all are fully successful, the FEIR anticipates significant unavoidable impacts including increasing time delays at intersections, increasing freeway delays, and impeding the operation of transit systems due to congestion.

  • Total motor vehicle trips (city only) expected to increase by 9 to 11 percent.
  • Total vehicle miles traveled (VMT) expected to increase by 10 percent.
  • Daily public transit boardings to, from and within Palo Alto (including BART, Caltrain, VTA, Shuttles, etc.) are expected to increase by 36 percent.

Parkland Impacts

  • Net increase in urban parkland deficit:  33.7 to 41.8 acres

Air Quality Impacts

Even with full implementation of included mitigation measures, the FEIR anticipates significant and unavoidable impacts that could violate an air quality standard, worsen an existing or projected air quality violation, and/or result in a cumulatively considerable net increase of a regulated pollutant for which standards already are not met.

Utilities Impacts

  • Water demand (city + SOI) expected to increase by six percent or 255,298,236 gallons per day.
  • Wastewater demand (city + SOI) expected to increase by six percent or 630,854 gallons per day.
  • 28 percent increase in solid waste generation (city +SOI) over 2014 baseline.
  • 13 percent increase in total electricity use (city +SOI) over 2014 baseline.
  • 14 percent increase in natural gas use (city +SOI) over 2014 baseline.

Lingering Issues

In addition to concerns about identified growth impacts, issues remain about the adequacy of substantive policies to carry out the vision embodied in the Comp Plan.

Planning and Transportation Commission (PTC)

The PTC’s recommendations (beginning on page 8 of the staff report for October 23) suggest that the proposed Comp Plan Update hasn’t quite hit the mark yet. Among other things, the PTC recommends:

  • more actionable goals and better monitoring tools to track progress toward achievement;
  • stronger commitment to creating below market-rate (BMR) housing inventory;
  • stronger policies to ensure available space for community-serving professional and personal services, non-profits and small medical offices;
  • language to ensure full participation among Palo Alto employers in Transportation Management Association (TMA) efforts;
  • policies that encourage family-oriented housing for all demographics and place more emphasis on creating neighborhoods, not just building housing units.


Not surprisingly, Palo Alto residents hold diverse views on the priorities, strengths and weaknesses of the Comp Plan Update.

Traffic and Parking

Many believe that the proposed Plan allows too much commercial growth or that the combined commercial and residential growth proposed will severely exacerbate already problematic traffic and parking challenges. Some want to improve transportation infrastructure and traffic management before accelerating growth or to grow at a more measured pace to allow transportation solutions to catch up. Others are more optimistic about the City’s current efforts to reduce driving and manage parking and argue that overemphasis on those impacts creates an unnecessary barrier to housing creation.

Differences also remain about how traffic impacts should be measured. Some argue that the state-mandated Vehicle Miles Traveled (VMT) metric, (that takes a higher level look at travel time and distance and accounts for regional environmental impacts), is sufficient and offers the benefit of allowing more development near transit. Others contend that the traditional Level of Service (LOS) metric (that monitors localized impacts by rating wait times at highly travelled/congested intersections) is critical to understanding and managing impacts where they are directly felt in the community. The Comp Plan Advisory Committee recommended using both and considering the addition of a multi-modal LOS that would monitor localized road delays for all modes of transportation.

Commercial and Residential Use

In addition to how much, the nature of both commercial and residential growth encouraged in the Comp Plan Update remains controversial. In contrast to current policy, this year’s Council asked that the Comp Plan Update explicitly allow tech companies in the downtown commercial area and significantly increase the allowable size for hotels, both downtown and in other areas. In competition for limited space, some think other uses should be prioritized.

The Comp Plan Update creates significant opportunities for market-rate housing, with an emphasis on smaller units. However some argue that the Update should more strongly emphasize and facilitate BMR units, while others think it should go further in encouraging all types of housing. And of course many feel like the focus on growth overshadows and neglects immediate concerns about housing displacement.

After years of debate and compromise, City Council will surely adopt the Comp Plan Update as scheduled on November 13. Whether and how they address impacts, lingering issues and competing community perspectives on Monday night, like those highlighted above, will be revealing both as to the condition of the city’s partnership with the community and council members’ priorities.

Notable Upcoming Action

October 23, 2017

Comprehensive Plan: City Council on the Comprehensive Plan Update. October 23, beginning at 7:45 pm (City Hall). Click here for staff report.

Mixed-use Project at former “Mike’s Bikes”: City Council to consider Site and Design approval for a three- and four-story development at 3001 El Camino Real including 50 housing units and 19,800 sf of retail that requires a Design Enhancement Exception and a Director’s Parking Adjustment for shared parking. October 23, beginning at 6:30 pm (City Hall). Click here for staff report.

October 30, 2017

Rooftop Decks Downtown: City Council will prescreen a proposal for development exceptions to allow rooftop decks in the downtown area, including 285 Hamilton. October 30, beginning at 6:45 pm (City Hall). Click here for staff report.

Marijuana Sales: City Council will adopt an ordinance banning medical marijuana dispensaries and commercial cannabis activities, except deliveries, in Palo Alto. October 30, beginning at 8:20 pm (City Hall). Click here for staff report.

Retail Protection Waiver: City Council will consider a request for a waiver from the retail preservation ordinance for 999 Alma Street (former Anthropologie bldg). October 30, beginning at 9:00 pm (City Hall).

November 13, 2017

Comprehensive Plan: City Council is expected to vote on final adoption of the Comprehensive Plan Update. Agenda and staff report will be available here on Nov. 2.

November 30, 2017

Stanford Expansion: Special County Planning Commission meeting to receive public comments on the DEIR for the Stanford GUP. November 30, 7:00-9:00 pm (Palo Alto Art Center Auditorium).