To City Council and Staff


I am writing to comment on item C1, specifically the proposed zoning changes downtown and elsewhere in Menlo Park. Thank you staff for working on a detailed and comprehensive plan, as part of our commitment to rezoning in the Housing Element.


I support the proposed zoning changes downtown, but I believe the base density should be increased to at least 100du/ac. This will encourage development, revitalize downtown, and help meet our RHNA numbers.


Many residents, including myself, would like to see downtown revitalized with new buildings, additional housing, and new amenities for residents. I see this potential rezoning as a big step towards that, but we need to make it viable.


Since the city will have control over the city-owned parking lots, I am setting those aside.


My concern lies in privately owned buildings/land. I believe that our local economics mean we need much higher base densities than what is being proposed in order to encourage development to take place.


First, I believe most of these properties would not be suitable for 100% affordable housing due to high acquisition costs in the private market, and I have heard the same from affordable housing developers. There is a floor for the acquisition cost: keeping the current use, which seems to be around $1000/sft downtown based on loopnet. That means even a small 2,000sft shop on Santa Cruz Ave would cost $2m+ just to bid out someone looking to keep it as-is. Furthermore, the sample 100% affordable developments listed in attachment D from the planning commission staff report are all on much bigger lots than we have downtown (closer to 1AC).


Here’s a real market example:


1075-1077 El Camino Real is listed for $4.8m on loopnet currently. Its a 2600 sft lot (.06 AC).


1. As discussed, an affordable housing developer is unlikely to pay $4.8m to build 6 100% affordable units (that would cost $800k/unit at 100du/ac max density)

2. For a market rate developer, the max is 60du/ac, so we are talking about $4.8m to have a chance to build 3 housing units. Meanwhile the proposed height limit is 60’! Those are some huge condos!


Given this example, it seems obvious that we should bump the base density up to something like 120du/ac which may yield 6 entry level condos. At the current proposed densities, I fear it will yield nothing.


If we want downtown building owners to list their properties for sale (many of which are small in size), and we want those properties to be bought and turned into housing, we need to greatly increase the base density to encourage market liquidity. This strategy will help us revitalize downtown, and meet our RHNA numbers via the % inclusionary BMR units that are required for all new housing.


I believe at minimum we should be looking at 100du/ac base density, if not more. Further study is needed, to be sure.


I realize the staff report says any additional upzoning would require a new EIR, and we do not have time to complete it before HCD’s deadline for upzoning. But this has to be balanced with HCD’s requirement that we zone for housing in good-faith and show evidence that development will take place. Since the current plan is weak at best, we should continue pushing for stronger upzoning while trying to meet HCD’s timelines. Otherwise, our housing element will continue to be out of compliance and we will be subject to proposals that don’t fit our community, such as the one on Willow and Middlefield.


Thank you for your consideration,


Misha Silin

Allied Arts resident