[https://linkprotect.cudasvc.com/url?a=https%3a%2f%2flh6.googleusercontent.com%2fulJLToUYQ6ATi-Sc5kgY1kvh8Q5bzK6conEIBGuZG4GGE0FJATPmnM-Pyzw3g5QIRgbrG0vgPCFCCDfu_GB2BMyqnsC3GX6UI0HlZLaX06imJNWwqZOEskCfJvpVdS4naOmU6zsyAdaL1FNpBJ7R7gM&c=E,1,Fl7oYjrPdM4b04IEtpq3Wg8zmqMhTxn7VVfnilX-rvTOtdBmoA_51BfH5TshF4-PNs_o0KvClGsUPqto_SjZQXZlif0l8s30PgawK2Fr8A,,&typo=1]
Campaign for Fair Housing Elements
fairhousingelements.org
[https://linkprotect.cudasvc.com/url?a=https%3a%2f%2flh3.googleusercontent.com%2fW7Z6w-zw--sZQAu8-wwUDSBkd-rPi-pHjJZQHEMxmMVQdRgNavhGjQKYp-6fIVCggVPnrJqKZ2Rjih_ZnE4c3qU2bMKtMRguqaOdz858yAIi1fzmc3rRuBxaZoVYUs1idq_V2N2OdFVVzg4YnIwjZHs&c=E,1,ueZhPabA81eA_uYWfwCaPOJyH8BygcZTWs36wwpLntfe9K6-jQKlfJSoPs3CvbwpNp6fKwaW_AUpGGrYVt42f_8qnP3dgbJhTLxnF-64DR_1h84UOJJZmD7u&typo=1]
June 27, 2023
Re: Agenda #J2 Housing Element
To Menlo Park City Council, Planning Staff, M-Group:
On behalf of the Campaign for Fair Housing Elements, HLC, and Menlo Together, we are writing to comment on Agenda item J-2, the revised housing element in response to HCD’s letter to the City from April 7th.
Our organizations are eager to see the City of Menlo Park adopt a housing element that is approved by the state, that achieves the goals of enabling housing for people of all income levels, preventing displacement, and furthering fair housing.
While we applaud some of the detailed changes made in the new version, such as more firm timelines and commitments in the programs section, we continue to have concerns that remain from our letter of March 22. We do not believe this draft sufficiently addresses the key issues raised in the letter from HCD.
Referencing the 4 issues raised in our March 22nd letter, as well as others preceding it (#89, 95, 122, 125, 138, 139 in Appendix 1-1 of the latest draft):
1. Unrealistic sites - this was called out in the letter from HCD in section A.2, as well as our previous letters. While we applaud the additional analysis done in Appendix 7-7, we do not believe it sheds any new light on the feasibility of the sites and zoning changes being proposed.
* As we have previously mentioned, the development trends cited for each site in the Housing Opportunity Sites and Redevelopment Factors table in Appendix 7-7, such as carve-out sites, adding housing to expensive office and retail sites with existing uses, or consolidation of small lots, do not have a demonstrated history of success in those specific neighborhoods. While we may have seen those trends region wide, or in District 1 of Menlo Park, more evidence needs to be provided that these are realistic near downtown or Sand Hill Rd.
* Also, as mentioned in our previous letter, the table in Appendix 7-7 as well as the site sheets in Appendix 7-5 assume that every parcel will use the maximum density bonus provided in the City’s AHO, which is a new program yet to be adopted.
2. Insufficient development standards - especially in and near downtown - to facilitate needed housing. This was called out in our previous letter as well as section A.3 and B.2 in HCD’s April 7th letter. This is particularly important given the implausibility of some of the sites as noted above
* We have not seen evidence that the current proposed upzonings for downtown and R3 zones will generate a sufficient amount of developer interest. The new draft merely provides more detail on the proposal, rather than addressing constraints (besides parking). Ultimately, the current proposal seems unlikely to yield a large amount of new affordable housing.
* While we are aware that staff/council “may consider additional increases in density” (page 4 of letter to HCD in staff report) as they move towards adopting some of these zoning changes, we are concerned that moving this outside of the housing element process, coupled with a vague commitment, means it may not happen. We would like to see additional increases incorporated into the housing element now.
3. Programs with vague commitments - this was mentioned in our previous letters as well as section B in HCD’s April 7th letter
* We applaud some of the changes in the housing element to further specify commitments for certain programs such as H1.H, H3.A, H3.E, H3.G, etc.. We also acknowledge the addition of details on outreach in table 4-26.
* We strongly support the commitment to "Develop an anti-displacement strategy for the City, particularly in the Belle Haven neighborhood, and initiate program implementation by January 2024 beginning with items f. tenant education, g. (inform tenants on rental assistance programs and "consider" continued funding beyond 2024*, h. expand Just Cause protections to tenancy of any duration, and i. (increase the time of relocation assistance paid by landlord), expanding to address other potential policies in the program through 2026." However, given the status of the city budget, we are concerned about funding and urge the City Council to ensure there is funding to staff and deliver the programs.
4. Affirmatively Furthering Fair Housing - while more analysis has been done in this new draft, given the dearth of promising sites and programs to increase affordable housing production, similar to our March 22nd letter we continue to find that the city is not meeting its obligation to AFFH by continuing to limit development in higher opportunity areas of the city.
Our overall recommendation is that instead of focusing on additional analysis, the city instead focus on improving our proposed sites and programs such that it creates a clear and aggressive path to getting a lot more affordable housing built.
Based on discussions with community members and city staff, we feel that there is support to revise our downtown rezoning plan to further add additional capacity for housing. That being said, we do not support taking this discussion out of the scope of the Housing Element. We think it makes sense to make downtown upzoning a high priority and submit an updated housing element to the state once more specifics are agreed upon.
Respectfully, Misha Silin - Menlo Park Resident and Campaign for Fair Housing Elements volunteer, on behalf of Menlo Together and Housing Leadership Council (HLC)
--
Misha Silin
M: (925) 323-7727
[https://linkprotect.cudasvc.com/url?a=http%3a%2f%2fcdn3.iconfinder.com%2fdata%2ficons%2ffree-social-icons%2f67%2flinkedin_square_color-24.png&c=E,1,pc7dEiB8AtVmQv4UMtKfk0hpNSio3nwStPeXF90jp-9u88g3f0x0fTLd8Afn8oGFVmu_ogjQKvoKSauUA5p8j4CWMsYmZtzSQhWcyQYG24tl0NQGP9jb8hxtwXM,&typo=1][https://linkprotect.cudasvc.com/url?a=http%3a%2f%2fcdn3.iconfinder.com%2fdata%2ficons%2ffree-social-icons%2f67%2ffacebook_square-24.png&c=E,1,a7YUveFIiwrSSVb8JKkpVTfJPjB2wvdqga3ViVT-iY5si8FHE9ml684YEEP0zqfIyun1lPWjCF5QVCfG4iAfDJBu4-KoHBsz89g7mJyxwFHy20E6uiBckzZy80A,&typo=1]
--
Misha Silin
M: (925) 323-7727
[https://linkprotect.cudasvc.com/url?a=http%3a%2f%2fcdn3.iconfinder.com%2fdata%2ficons%2ffree-social-icons%2f67%2flinkedin_square_color-24.png&c=E,1,FwhTDQYHasAsO9hET3nINQX04Gl3DEBQmIFO35RwxL7Zed8yPtKthon_DGtouqvGyuwq6fcQoSO0D1AZwegTniakNcQd_AubbtKBp3qBsUtQ2ZQcijY45w,,&typo=1][https://linkprotect.cudasvc.com/url?a=http%3a%2f%2fcdn3.iconfinder.com%2fdata%2ficons%2ffree-social-icons%2f67%2ffacebook_square-24.png&c=E,1,uOI9rDobJBQbHLF9ThseRYacD-Pi57DJw29L-ZrbpJWIOgLwyZnobcmYC_bPYRA6ajGtMHsS3pmz1_bHmCLGMP-7Ef0F81WFcPdm-gUxj3y23s1VC1ASDXnEFDo,&typo=1]
