EAST PALO ALTO CITY COUNCIL
STUDY SESSION AGENDA
Tuesday, September 24, 2024, 6:00 PM
EPA Government Center
2415 University Avenue, First Floor
East Palo Alto, CA 94303
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International numbers available: https://zoom.us/u/aMWYF4KT East Palo Alto City Council September 24, 2024 Agenda
1 1. CALL TO ORDER AND ROLL CALL
2. APPROVAL OF THE AGENDA
3. POLICY AND ACTION
3.1 Draft Ravenswood Business District / 4 Corners Specific Plan and SEIR Study Scenarios
4. COUNCIL REPORTS
5. ADJOURNMENT
Recommendation:
Conduct a Study Session on the Ravenswood Business District / 4 Corners Specific Plan Update Project, including providing additional comments and direction to staff on the preferred maximum development scenario (#2) and the draft Community Benefits Framework.
Upcoming meetings:
Regular Meeting October 1, 2024 6:30 PM
Regular Meeting October 15, 2024 6:30 PM
East Palo Alto City Council September 24, 2024 Agenda
2 This AGENDA is posted in accordance with Government Code Section 54954.2(a) This Notice of Availability of Public Records: All public records relating to an open session item which are not exempt from disclosure pursuant to the Public Records Act, that are distributed to the majority of the City Council will be available for public inspection at the City Clerk’s Office, 2415 University Avenue, East Palo Alto, CA at the same time that the public records are distributed or made available to the City Council. Such documents may also be available on the East Palo Alto website www.cityofepa.org subject to staff’s ability to post the documents prior to the meeting. Information may be obtained by calling (650) 853-3100.
The City Council meeting packet may be reviewed by the public in the Library or the City Clerk's Office. Any writings or documents pertaining to an open session item provided to a majority of the City Council less than 72 hours prior to the meeting, shall be made available for public inspection at the front counter at the City Clerk's Office, 2ND Floor, City Hall, 2415 University Avenue, East Palo Alto, California 94303 during normal business hours. Information distributed to the Council at the Council meeting becomes part of the public record. A copy of written material, pictures, etc. should be provided for this purpose.
East Palo Alto City Council Chambers is ADA compliant. Requests for disability related modifications or accommodations, aids or services may be made by a person with a disability to the City Clerk's office at (650) 853-3127 no less than 72 hours prior to the meeting as required by Section 202 of the Americans with Disabilities Act of 1990 and the federal rules and regulations adopted in implementation thereof.
DECLARATION OF POSTING
This Notice is posted in accordance with Government Code §54954.2(a) or §54956. Members of the public can view electronic agendas and staff reports by accessing the City website. Under penalty of perjury, this Agenda was posted to the public at least 72 hours prior to the meeting.
POSTED: September 19, 2024
ATTEST:
James Colin
City Clerk
East Palo Alto City Council September 24, 2024 Agenda
3 POLICY AND ACTION ITEM 3.1
EAST PALO ALTO
CITY COUNCIL
STAFF REPORT
DATE: September 24, 2024
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Amy Chen, Community & Economic Development Director Elena Lee, Planning Manager
SUBJECT: Draft Ravenswood Business District / 4 Corners Specific Plan and SEIR Study Scenarios
Recommendation
Conduct a Study Session on the Ravenswood Business District / 4 Corners Specific Plan Update Project, including providing additional comments and direction to staff on the preferred maximum development scenario (#2) and the draft Community Benefits Framework.
Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:
Promote Housing, Economic and Workforce Development
Promote Health & Public Safety
Ensure Our Financial and Organizational Health
Executive Summary
Selecting the larger maximum development scenario (#2, or 3.35 million square feet of office/R&D space) is recommended. Staff continues to recommend that Council implement the RBD/4 Corners Specific Plan with the larger of the two study scenarios analyzed in the SEIR as the differences in environmental and local impacts between both scenarios are comparatively minor, but the larger scenario potentially offers greater economic, fiscal, and community benefits by capturing 4 POLICY AND ACTION ITEM 3.1
more higher-density development in the Plan Area. The proposed Community Benefits Framework works under either scenario (though it is currently designed with the larger scenario in mind), but depending on future economic conditions, it is potentially more beneficial under the larger scenario since the additional development capacity offers greater flexibility and potential for the City. If Council selects the smaller scenario (#1, or 2.82 million square feet), core elements of the Community Benefits Framework (its Tiers and/or maximum FARs) would need to be adjusted. There is a close relationship between the Framework and the maximum development capacity (assuming the City wishes to ensure that all major projects can entitle at least a Standard Tier project, which has been a key objective from the start of this update). If the smaller scenario is selected, staff would revise the Framework by removing the Exemplary Tier (or by reducing the maximum FARs for both the Standard and Exemplary Tiers). In response to comments received on the draft Community Benefits Framework, staff is recommending several revisions to the Specific Plan and the Framework (these comments and responses are summarized in Table 2 below). Members of the EPA community requested additional benefits or to strengthen the Framework, while several major property owners asked to scale back the benefits targets.
However, nothing in the comments changes the staff’s recommendation to select the larger scenario (#2) and to not reduce the benefits targets/expectations associated with higher-density Tiers in order to improve feasibility for higherdensity projects. Even with the recent market downturn, the Community Benefits Framework and its proposed FARs, Tiers, and Targets remains a recommended and workable policy approach for the City and community, both now and if/when market conditions improve such that higher-density development is again financially feasible.
Background
In September 2020, the City Council recommended exploring a focused amendment to the Ravenswood Business District / 4 Corners Specific Plan (“Specific Plan”) and Subsequent Environmental Impact Report (“SEIR”). The Specific Plan and SEIR update analyzed the impacts of increasing the amount of office and research and development (R&D) space and housing in the Specific Plan area. The key objectives for the Specific Plan update were to evaluate the relative impacts and benefits of allowing more office/R&D square footage and define policies that address: 1) traffic congestion and trip reduction; 2) wet utility infrastructure; 3) fiscal impacts; 4) indirect displacement and housing affordability; and 5) local jobs, while articulating a clear framework with community benefits.
To date, the City Council has held 11 public meetings or study sessions to discuss the Specific Plan Update, including a study session on the release of the first 11 draft chapters of the Specific Plan on April 25, 2024, and another study session on the release of the 5 POLICY AND ACTION ITEM 3.1
Subsequent Environmental Impact Report (SEIR) on July 25, 2024. Public comments on the SEIR were accepted during the 46-day review period (through September 10, 2024).
A Planning Commission meeting was scheduled to be held on September 9 to close out the DSEIR public review period. The meeting was adjourned before the item was heard due to technical difficulties. A summary of the comments are attached to the PC staff report. The PC agenda is available online1. Per the State Guidelines for the California Environmental Quality Act (CEQA), a public meeting during the DSEIR public review period is not required and the meeting adjournment will not impact the SEIR schedule.
At the last Council Study Session on July 25, 2024, staff received clear direction on two key questions:
1. Do you have any questions about the draft mitigation measures or impact findings of the SEIR?
2. Does Council agree with staff’s recommendation to remove the Loop Road as a required improvement and thus not be included in the calculation of the Transportation Impact Fee (TIF)?
a. Council directed staff to remove Loop Road from the list of required improvements in the Specific Plan and the Capital Improvements Program/Transportation Impact Fee, due to a combination of concerns about neighborhood impact, environmental impact, and constructability.
3. Does Council agree with staff’s recommendation to add a policy monitoring (but not limiting) the amount of industrial/flex/advanced manufacturing-type projects being built in the Plan Area?
a. Council directed staff to add a policy to monitor/track the total square footage of industrial development in the Plan Area, but not to outright limit it. In effect, this could take the form of an annual report to Council on the amount and type of development allocated and permitted.
4. Does Council support the staff recommendation to move forward with the proposed community benefits framework coupled with the larger growth scenario (Scenario 2, 3.35 million square feet) to give the City more flexibility in the future? However, Council did not reach consensus on the fourth question which pertained to the selection of the maximum growth scenario. Staff did hear broad support for the Community Benefits Framework as proposed in the draft Plan, though some Councilmembers articulated a desire for additional discussion and clarification.
Building off the last meeting, the purpose of this Council report and presentation are to provide further opportunity to provide direction on the two maximum growth scenarios being studied, and to consider revisions in response to the public comments on the draft 1 Link to September 9, 2024 Planning Commission Agenda Packet (see item 6.1):
https://d3n9y02raazwpg.cloudfront.net/cityofepa/9dd1777e-609c-11ef-bafe-005056a89546-88739655- 4535-4dfb-8d17-688f5e5d89b8-1725577728.pdf
6 POLICY AND ACTION ITEM 3.1
Community Benefits Framework (and its FARs, Tiers, and Targets) and other policy issues in the Specific Plan.
Analysis
SEIR/Specific Plan Update Maximum Study Scenarios
The Adopted 2013 Specific Plan allows approximately 1.44 million square feet of office/R&D space, 175,000 square feet of industrial space, and 835 housing units. The SEIR for the updated Specific Plan analyzed two maximum development scenarios, both larger than the Adopted 2013 Plan:
1. Scenario 1 – up to 2.82 million square feet of office/R&D space, 250,000 square feet of industrial space, and 1,350 housing units.
2. Scenario 2 – up to 3.35 million square feet of office/R&D space, 300,000 square feet of industrial space, and 1,600 housing units.
Recommendation for the Maximum Scenario
As discussed on April 25th and July 25th, staff recommends that the Specific Plan be implemented with the larger of the two scenarios (#2, or 3.35 million square feet of office/R&D space) analyzed for the SEIR, for the following reasons:
In general, the larger development scenario could potentially provide more City revenues, more impact fees, and result in the provision of greater community benefits overall, particularly if the Council exercises its discretionary power to allocate more square footage to projects which offer community benefits that are aligned with the proposed targets and categories in the Community Benefits Framework. As has been noted before, the City is not required to approve either scenario, and could fall back upon the existing development scenario of 1.44 million square feet of office/R&D space (from the Adopted 2013 Specific Plan). The larger scenario offers the City more flexibility, enabling a wider possible range of outcomes (between mostly lower-density and mostly higher-density development). Approving the larger scenario does not guarantee that 3.35 million square feet is actually developed but it allows for the possibility of increased community benefits and increased fiscal benefits (property, sales, and special taxes such as Measure HH) over the long run commensurate with the increase in density.
The proposed Community Benefits Framework (and its system of Tiers and maximum FARs) is maximized through the larger scenario. As designed, there is enough development capacity to allow for two tiers of bonus FAR, which maximally incentivizes the provision of community benefits through the Exemplary Tier, which is calibrated to an FAR corresponding to higher-density development (at approximately six stories for the Standard Tier and eight stories for the Exemplary Tier).
7 POLICY AND ACTION ITEM 3.1
The larger development capacity permits a greater amount of square footage to be held in reserve for minor projects (projects less than 150,000 square feet in size).
The differences in CEQA-related environmental impacts between the two scenarios are minimal, which the DSEIR (Draft Subsequent Environmental Impact Report) analyzed in more detail2. Mitigations for traffic and utility mitigations (additional water storage, sewer capacity, & stormwater improvements) are scaled proportionally as appropriate.
Non-CEQA impacts are similar between the smaller Scenario and the larger Scenario. The larger scenario differs only in that it potentially could add 12% more total daily vehicle trips, requiring four additional traffic signals to mitigate. At the same time, the larger scenario has the potential to provide 15% higher ongoing net fiscal revenues, up to 2,000 more jobs, and substantially more gathering and placemaking spaces.
Through implementation of standards in the updated Specific Plan and required CEQA mitigations, under either scenario the City would try to achieve as many of the community’s objectives as possible (primarily limiting traffic, visual, and displacement impacts while boosting local employment, entrepreneurship, and ownership). For example, the Specific Plan contains a set of ‘stepback’ standards which would apply to either scenario and are intended to mitigate visual impacts by reducing building heights adjacent to residential neighborhoods and sensitive natural habitats.
In sum, while the Community Benefits Framework works under either scenario, it can potentially be more beneficial for the larger scenario. The larger scenario has the potential for greater benefits to the community. The nexus feasibility study confirms that development projects are extremely challenging to finance and construct in the shortterm, but these current market conditions do not negate the proposed framework approach overall, which is that lower-density development is expected to support fewer benefits while higher-density developments is expected to provide a commensurately greater amount of benefits in the future when the market supports larger-scale projects.
Review of the Draft Community Benefits Framework
This section provides an overview of the contents and structure of the draft Community Benefits Framework. The Community Benefits Framework is best viewed as a means of conceptualizing potential benefits to the community, rather than a final or exhaustive list of benefits. The proposed Framework contains three tiers with increasing maximum commercial FARs: Base, Standard, and Exemplary. The requirements for the tiers scale up proportionately as follows:
2 https://cityofepa.granicus.com/AgendaViewer.php?view_id=1&clip_id=108 8 POLICY AND ACTION ITEM 3.1
Base Tier development at this level does not require a negotiated Community Benefits program. Such projects will still require compliance with “hard-wired” baseline legal requirements (i.e., impact fees, ordinances, and other measures the City has imposed as part of its police power consistent with applicable law), as shown in Figure 1 below. Impact fees, for example, while not a community benefit, must be paid prior to pulling building permits because they possess the requisite nexus and proportionality to project impacts and thereby may be used to ensure developers pay their fair share of public infrastructure required to support their projects.
o Note: the maximum FARs for the Base Tier (i.e., lower-density development projects) are the same under both scenarios. In other words, a property owner could construct the same Base Tier project under Scenario 1 or 2. To be considered for a Standard Tier allocation/development, the project must demonstrate how it earns at least 4 (four) points through a combination of strategies as identified in the Targets table contained within the Framework and shown in Figure 2 below. Proposed points - and the entire community benefits program proposed by a major commercial project applicant - will be reviewed by staff and presented to Council as part of the discretionary allocation process. To be considered for an Exemplary Tier allocation/development, the project must demonstrate how it earns at least 8 (eight) points. Same as with the Standard Tier, Exemplary Tier FARs may be awarded at Council’s discretion for projects that earn enough points by meeting or exceeding the Targets identified in the Framework. It is at the Council’s discretion to determine whether the proposed community benefits are sufficient to earn the points necessary for that Tier (staff will provide a recommendation); it is not automatically earned by achieving the points required.
The point system is not absolute but is intended to provide guidance for correlating the provision of community benefits to the allocation of additional FAR beyond the Base Tier. Any allocation is ultimately at the discretion of the Council. The point system and priority benefits should be regularly revisited and recalibrated as needed to reflect changing community values and priorities, economic conditions, and land/development costs.
9 POLICY AND ACTION ITEM 3.1
Figure 1: Proposed FARs and Tiers
Benefits targets are specified for utilities, affordable housing, local jobs and community space/support, public parks and open space, and transportation. These targets can be revisited by Council regularly as community priorities or the market changes. 10 POLICY AND ACTION ITEM 3.1
Figure 2: Community Benefits Framework Targets (or “Scorecard”) Worth 1 point Worth 2 points Worth 3 points
1. District Utilities * $ $$ $$$
2. Affordable Housing
** $
Build affordable
housing or donate
land above
Commercial Linkage
Fee requirement
$$
Build affordable
housing or donate land
above Commercial
Linkage Fee
requirement
$$$
Build affordable housing or
donate land above
Commercial Linkage Fee
(previously discussed as
Jobs/Housing Target)
3. Community, Civic
& Jobs Space *** 2.5% 5% 7.5%
4. Public Parks and
Open Space**** WO 10%
REC 10%
4C 10%
WO 20%
REC 15%
4C 20%
WO 30%
REC 25%
4C 25%
5. Transportation
***** $ $$ $$$
* To be negotiated with Public Works. “$” signs represent increasing orders of magnitude of contributions towards that category, i.e., slightly more than impact fees (10% more) -> moderately more than impact fees (>20% more) -> significantly more than impact fees (>33% more). Stated simply, the greater the amount of contribution (above impact fees), the greater the potential point value that may be awarded.
** To be negotiated with Housing Department. $ signs represent increasing orders of magnitude of contributions towards that category. To earn 3 points ($$$), the City’s expectation is that projects build affordable housing with a value that is significantly more than required by commercial linkage fees (i.e., >$7/s.f. more); this $$$ value was previously presented as the “jobs/housing linkage target” of 1 affordable unit per 30,000 square feet of office/R&D space. *** Measured as a percentage of the project’s commercial square footage. **** Measured as a percentage of a project’s total developable site area. ***** To be negotiated with Public Works. “$” signs represent increasing orders of magnitude of transportation contributions towards that category, as with utilities above. Could be achieved through building infrastructure (not already required by CEQA) or by proposing to create TDM program that would trip reductions in excess of the 40% already required by City Ordinance.
Other examples could be Bay Road improvements (beyond required frontage upgrades and impact fees), spearheading a shuttle bus program, donating land for a water tank or pump station, or taking the lead to acquire public right-of-way instead of the City.
Relationship between Framework FAR/Tiers and Scenario/Development Capacity This section discusses the implications of moving forward with the smaller scenario (2.82 million square feet (M.S.F.)) compared to the larger (3.35 M.S.F.) scenario. If the smaller scenario is selected by Council, it will be necessary to make changes to the Community Benefits Framework. Such changes are discussed below and shown graphically in Figure 11 POLICY AND ACTION ITEM 3.1
3. Changes will be needed since the maximum FARs for each Tier are based around the total office/R&D capacity and a key assumption regarding the four proposed major projects. In other words, the proposed community benefits framework is calibrated so that the FARs for the Standard and Exemplary Tiers allow progressively higher-density development and require correspondingly more benefits from these higher-density projects. Therefore, there are ramifications to the proposed Framework if Council selects the smaller scenario (2.82 million square feet). The Benefits Framework (and its FARs, Tiers, and Targets) is set up such that Base Tier projects generally represent lowerdensity development (2-4 stories), Standard projects generally represent middle-density development (4-6 stories), and Exemplary projects would be the highest-density development (at 6-8 stories).
Setting aside potential minor projects (which have access to a separate development reserve and thus are not competing for the same square footage as the major projects), Table 1 illustrates the relationship between the maximum development capacity for the four major proposed projects and the proposed Tiers:
If all four proposed major projects (Emerson, Harvest, Sandhill, and 2020 Bay Rd) were built at the Standard Tier, approximately 2.82 million square feet would be developed, roughly equivalent to Study Scenario 1 (2.82 M.S.F.). If some of the four major projects were built Standard Tier and some were built at Exemplary Tier, approximately 3.35 million square feet would be developed, roughly equivalent to Study Scenario 2 (3.35 M.S.F.).
Under the proposed Framework, which is designed with Scenario 2 in mind, all four major applicants cannot build Exemplary Tier projects – this would represent 20%+ more development than the 3.35 M.S.F. of capacity being analyzed as Scenario 2 in the SEIR. All four applicants initially proposed projects that would fall within the Exemplary Tier, representing a total of 4.2 million square feet, an amount deemed too impactful by Council in 2021. The SEIR would need to be amended to accommodate development at this level (4.2 M.S.F.), as it currently considers
3.35 M.S.F. the maximum scenario.
Table 1: Relationship between FAR/Tiers and Development Capacity All Major Projects
Built at Base Tier
All Major Projects
Built at Standard Tier
Some Major Projects
Built at Standard and
Others at Exemplary
Emerson, Harvest,
Sandhill, & 2020 Bay
Rd (major projects)
1,600,000 2,700,000 ~3,250,000
Job Train (entitled
office project) 108,000 108,000 108,000
1.7 MSF 2.82 MSF
(Study Scenario 1)
3.35 MSF
(Study Scenario 2)
12 POLICY AND ACTION ITEM 3.1
Under the proposed Community Benefits Framework based on the larger 3.35 M.S.F.
Scenario 2, all four major project applicants (Emerson, Harvest, Sandhill, and 2020 Bay Rd) could be entitled and build projects at the Standard Tier. If the City Council instead selects the 2.82 M.S.F. scenario (#1) and the City wants to maintain access to the Standard Tier for all four major projects, the Tiers would need to be adjusted to reflect the smaller capacity. Specifically, the Framework would be revised by eliminating the Exemplary Tier and the higher level of community benefits associated with the Exemplary Tier. The maximum FAR for the Standard Tier remains unchanged, and there would only be one bonus Tier remaining in the Framework (the Standard Tier). An illustration of how the Framework would be adjusted is shown in Figure 3.
Figure 3: Revised Framework under Scenario 1 (2.82 million s.f.) It is important to note that leaving the Tiers and FARs unchanged while selecting the smaller scenario would constrain the higher-density potential of development projects occurring later (since earlier projects would have claimed the majority of the limited development capacity).
Summary of Comments Received on the Community Benefits Framework and Staff Recommendations
The public draft of the Specific Plan was available for review during a three-month period (April 25th to July 25th). The City accepted public comments via email and via an online feedback form during this time. Over 40 comments were registered through the online form (mostly from members of the community), and approximately 8 comment letters were emailed to staff (mostly from property owners and regional organizations). The commenters include representatives from Youth United in Community Action (YUCA), Ravenswood Shores Business District, Sierra Club Loma Prieta Chapter, Citizen’s Committee to Complete the Refuge, Sequoia Audubon Society, Green Foothills, Midpeninsula Regional Open Space District, Sand Hill Property Company, Harvest Properties, and Emerson Collective.
13 POLICY AND ACTION ITEM 3.1
Table 2 below summarizes the comments that pertain to the Community Benefits Framework or its implementation from Council members, community members, major property owners, local stakeholders, and open space and wildlife experts. Attachment 1 to this report contains a complete list of all comments received on this topic (the Community Benefits Framework).
The project website3 contains a complete list of all public comments received on all topics for the draft Specific Plan.
Staff is recommending the key changes below to the Specific Plan and Framework. Staff reiterates that nothing in the comments or responses changes the staff recommendation to select the larger scenario (#2). Staff does not recommend reducing the proposed benefits targets/expectations associated with the higher-density Tiers in order to improve feasibility for higher-density projects in the near term. The proposed Community Benefits Framework and its FARs, Tiers, and Targets remains a workable policy approach for the Specific Plan.
The key changes being recommended by staff are as follows:
a. Add references to youth shelters and childcare in the Community Benefits Priorities Table.
b. Extend the Local Jobs Narrative requirement to the Base Tier (this is a description of how the project will contribute to providing local job opportunities across a broad range of educational and skill levels).
c. Soften proposed ten-year trigger for affordable housing development backstop (before Council can trigger return of land to the City) to “achievable milestones/anticipated schedule.”
d. Add guidelines preferencing allocations to projects that emphasize the affordable housing category (as a priority benefits option)
e. Change the Immediate Allocation Window to a process that can be triggered flexibly by Council (for instance, an Annual Review of Allocation Requests whereby all proposals received during the previous calendar year or six months would be considered simultaneously).
f. Modify the duration of entitlements obtainable through Development Agreements:
for Standard and Exemplary Tier developments, an initial five-year term is the starting point for negotiations, but the City can consider a longer term. g. Clarify/establish City timeline and process for reviewing Benefits Programs.
Along with those changes, staff recommends maintaining the following key components of the framework:
1. Maintain the number of points required to earn the Exemplary Tier (at least 8 points).
2. No reduction in the Standard or Exemplary targets (other than clarifying that the jobs-housing linkage ratio is no longer a requirement but rather a metric used to 3 RBD Project Website Link: https://www.cityofepa.org/planning/page/rbd-specific-plan-update 14 POLICY AND ACTION ITEM 3.1
evaluate/score affordable housing contributions correlated with the achievement of 3 points in that category).
3. No change to the Affordable Housing targets/expectations (other than the guidelines mentioned above) or community-established AMI preferences.
4. Continue to not allow a Conditional Allocation or “HOLD” at the Exemplary Tier.
Table 2: Comments on Community Benefits Framework & Allocation Process Comments on Community
Benefits Priorities
Staff Recommendation
Youth shelters and
daycare/childcare be added
throughout the Framework.
Staff recommends adding explicit references to
these uses as part of the Framework Benefits
Priorities table, under Civic/Community space.
What kind of jobs would be
expected under
implementation of the Plan’s
development scenarios?
The market is too unpredictable/unknowable to be
able to conduct a reliable employment forecast.
However, a Local Jobs Narrative is currently
required of projects requesting a bonus Tier
allocation, which requires that applicants describe
how the project will contribute to providing local
job opportunities across a broad range of
educational levels. The Local Jobs Narrative
provides information to the community about how
the project intends to promote local employment.
Staff recommends extending this requirement to
Base Tier projects.
Affordable housing should be
prioritized at
different/additional income
brackets (one asking for 20-
25% AMI and the other for
100-120% AMI). The Plan
currently prioritizes housing
for 35-60% and 60-100% AMI
households.
Staff recommends no change unless directed by
Council – these priorities were developed through
broad community input, and the Plan allows for an
applicant to choose a different AMI mix than
required by Inclusionary Ordinance. Changes to
the City Ordinance can be considered as part of
an upcoming county-wide nexus study.
Ten years is an unrealistic
timeframe for affordable
projects seeking tax credit
financing. The Plan includes
a provision that Council may
trigger the land being
returned to City control after
ten years of nondevelopment.
Staff agrees and recommends softening the
language to "anticipated schedule" and creating
requirements for achievable milestones such as
project approvals/entitlements.
15 POLICY AND ACTION ITEM 3.1
Comments on Community
Benefits Targets or Tiers
Staff Recommendation
Seeking to strengthen/require
more benefits in the Targets
table in the Benefits
Framework.
Staff recommends maintaining the Framework as
written. Staff will add a note that the Exemplary
Tier may be achieved with "a minimum of 8
points" but stress that this is only a suggested
target, and achievement over 8 points will be
reflected in the staff's positive recommendation to
Council. Targets and priorities should be regularly
revisited (every few years) to consider changing
market conditions, community priorities, and
development costs. Targets are expectations, not
absolutes; Council has discretion to adjust based
on a project’s conditions.
Increase the targets or
expectations for affordable
housing contributions for
projects requesting Standard
or Exemplary Tier allocations.
Staff recommends adding to the Plan’s guidelines
relating to the review of proposed Benefits
Programs. The guidelines will operate as a rubric
for evaluating a community benefits package. The
guidelines will state that the City expects to see at
least 1 point earned in the Affordable Housing and
Community Space categories for projects
requesting Standard or Exemplary Tier. The
guidelines will also state that in the event of two
projects being in competition for a limited
allocation during the same allocation cycle, staff’s
preference will be to reward the project with the
greater affordable housing contribution.
Reduce the
targets/expectations at
Standard and Exemplary Tier.
Staff does not recommend lowering or reducing
the community benefits expectations for higherdensity development – staff believes that the City is best served by maintaining the targets as
proposed and waiting until the market rebounds to
ensure that benefits are maximized from more
impactful (i.e., larger-scale/higher-density)
projects. However, targets should be periodically
reevaluated to ensure the Framework is working
as intended.
Remove the jobs/housing
linkage ratio from the Specific
Plan.
Staff clarifies that the jobs-housing linkage ratio is
not a requirement but rather this previously
established level of housing contribution is now
associated with achieving the highest (i.e., 3
points) target under the affordable housing
category in the Community Benefits Framework.
16 POLICY AND ACTION ITEM 3.1
Comments on Development
Allocation Process
Staff Recommendation
Allow Conditional
Development Allocation or
“Hold” for a project requesting
the Exemplary Tier for 12 to
18 months given current
market conditions.
Staff does not recommend allowing a Conditional
Allocation or “HOLD” at the Exemplary Tier, as
this would be likely to result in one or more of the
major four projects being unable to build a viable
project. See staff’s recommendation below about
changes to the immediate allocation window.
Rethink the proposed 120-
day “Immediate Allocation
Window.”
Staff agrees and recommends a change to this
mechanism by dropping it altogether in lieu of
adding a provision allowing Council to trigger a
Review of Allocation Requests Received (whereby
all proposals received during the previous
calendar year or another pre-determined length of
time would be considered simultaneously). Staff
notes that Council would then have the discretion
to initiate an Immediate Allocation Window later
on in the future, as the market becomes more
favorable.
Lengthen the duration of
entitlements obtainable
through a Development
Agreement. Per 11.2.3
“Entitlements for Major
Office/R&D Projects shall last
five years with an option for a
five-year extension to be
granted automatically if
significant development
progress has occurred,
otherwise the extension is at
Council discretion.”
Staff recommends a slight change to the five
years plus potential extension policy: for Base Tier
developments, the 5 years applies, and an
extension may be considered by Council. Staff will
also clearly define significant development
progress (or provide a checklist to assess
progress).
Define a timeline for the
community benefits review
process with deadlines for
developers and City staff to
respond to each other’s
submittals and consequences
for failure to meet deadlines.
Staff agrees and recommends that the Plan
contain a timeline for the community benefits
review process.
Clarify whether the
Community Benefits program
requirements apply to Base
Tier development.
These obligations (detailed program, scorecard,
and financial analysis) apply only to the Standard
and Exemplary Tier; Base Tier projects are only
responsible for City baseline requirements.
17 POLICY AND ACTION ITEM 3.1
Table 3: Key Comments and Recommendations related to Infrastructure Comment Staff Recommendation
Clarify SAFER Bay flood
control project obligations and
alignment.
Staff recommends an outward alignment of
SAFER Bay just north of the end of Bay Road (on
the bay side of the City Limits, east of the Infinity
Salvage site) of SAFER Bay; see Figure 4 below.
This alignment maintains more usable land for the
City and its residents.
Staff recommends an inland alignment north of
391 Demeter Street but is continuing to work with
Emerson Collective and the JPA on the design of
the northern reach of the SAFER Bay project.
Concern over the
responsibility for acquisition
of rights-of-ways not within
project boundaries. Cost of
acquisitions should be
incorporated into the nexus
study/Transportation Impact
Fee.
Staff will continue discussing these comments in
order to develop a recommendation. City has
engaged a consultant to prepare a nexus study to
capture the cost of acquisition.
Adjust parking maximums up
to 3.0 for R&D uses. How
would a midpoint reduced
parking maximum for office
projects be implemented
given the varying timelines
and phasing for
projects/allocations?
Staff recommends adjusting the maximum parking
ratio for R&D uses from 2.5 up to 3.0, to maintain
competitiveness with other cities and reduce
neighborhood spillover. Staff also recommends
removing the midpoint parking reduction for office
uses but will consider adding ‘vehicle parking
reductions’ under the Community Benefits
Transportation category. The 40% trip reduction
required by Ordinance applies regardless of how
much on-site parking is provided. In the future, the
TMA and the City Council will have the option to
reevaluate and reduce the maximum parking ratio
if trip reductions are not adequately achieved as
required.
18 POLICY AND ACTION ITEM 3.1
Figure 4: Preferred SAFER Bay Alignment
The blue line indicates an earth berm levee (typically dimensions would be ~80 feet wide, and 7 feet above grade). The red line indicates a much narrower floodwall.
Next Steps and Timeline
19 POLICY AND ACTION ITEM 3.1
The Public Draft Specific Plan was released on April 5, 2024. The City Council was asked to provide feedback and initial comments on the Draft Plan on April 25, 2024. The formal public comment period for the Specific Plan ran through July 26, 2024. Comments from the public received at tonight’s study session will also be considered by staff.
The public draft of the Subsequent Environmental Impact Report (DSEIR) related to this project was released on July 26th. A Planning Commission meeting took place during the DSEIR public review period on September 9th. Although the DSEIR was not discussed on September 9 due to technical difficulties and an early adjournment of the meeting, public comments were accepted during a 46-day review period through September 10th.
Subsequently:
The Final DSEIR will be released on October 11th, pending the completion of the City’s response to public comments.
A public hearing will be scheduled for the Planning Commission on November 18th, 2024, to seek a recommendation regarding certification of the DSEIR and adoption of the Specific Plan.
Following Planning Commission, City Council hearings on the adoption of the Plan and certification of the SEIR will begin. The first meeting is tentatively scheduled for December 3rd, 2024. Rezoning and a General Plan Amendment will be considered concurrently with Plan adoption.
Key Discussion Questions for Council
1. Does Council support the staff recommendation to move forward with the proposed community benefits framework coupled with the larger growth scenario (Scenario 2, 3.35 million square feet) to give the City more flexibility in the future?
2. Does Council support the staff’s recommended changes relating to comments received on the Community Benefits Framework, Development Allocation Process, and other key Policy Items?
Fiscal Impact
There is no fiscal impact to the City from this staff report. Any project that benefits from a future update to the RBD Specific Plan would be required to reimburse the City for all Plan Preparation expenditures on a proportional square foot basis. When the developers submit their payments to reimburse the City, it would also include a 10% administrative fee to cover city overhead.
Public Notice
The public was provided notice of this agenda item by posting the City Council agenda on the City’s official bulletin board outside City Hall and making the agenda and report 20 POLICY AND ACTION ITEM 3.1
available at the City’s website and at the San Mateo County Library located at 2415 University Avenue, East Palo Alto. Additionally, the public was provided electronic advance notice of the study session through notifications sent from the City’s email contact database which contains hundreds of resident and stakeholder emails (on September 19th and 24th).
Environmental
A Public Draft SEIR has been prepared as part of the subsequent environmental review process needed to evaluate the proposed changes to the Ravenswood Business District Specific Plan (increased square footage of allowable non-residential development as well as additional housing units) analyzed in the previously certified 2013 Ravenswood Specific Plan FEIR. In accordance with Section 15082 of the CEQA Guidelines, the City previously prepared a Notice of Preparation (NOP) for this SEIR. The NOP4 was circulated to local, state, and federal agencies on April 15, 2022. The standard 30-day comment period concluded on May 16, 2022.5 A list of all public comments received on the Draft SEIR can be viewed on the project website.6
The Public Draft SEIR was released on July 26, 2024. The 46-day public comment period opened on the same day and will be held open through September 10, 2024.
A Notice of Availability (NOA) has been distributed as required by CEQA law, and the document will be posted on the project website. The 46-day public comment period has ended as of September 10th, and the City is now considering and responding to substantive comments received on the draft SEIR and compiling a response to comments document and Final SEIR. Once the responses and revisions are complete, a Final SEIR will be released, consisting of the response to public comments on the draft SEIR and outlining any updates or revisions to the DSEIR. The final SEIR will be considered by the City Council for certification in compliance with CEQA.
Government Code § 84308
Applicability of Levine Act: No, as the proposed action does not yet involve an entitlement.
Analysis of Levine Act Compliance: Not applicable.
4 Link to the Notice of Preparation:
https://www.cityofepa.org/sites/default/files/fileattachments/planning/page/22862/nop_rbd_sp_update_- _full_version_oprcounty_clerk_4.13.22_1.pdf
5 Link to comments on the Notice of Preparation:
https://www.cityofepa.org/sites/default/files/fileattachments/planning/page/22862/rbd_nop_comments_su mmary_memo_and_attachments_final.pdf
6 Link to comments on the Subsequent EIR (SEIR):
https://www.cityofepa.org/sites/default/files/fileattachments/planning/page/16201/dseir_comments_all.pdf 21 POLICY AND ACTION ITEM 3.1
Attachments
1. List of Public Comments Received on the Community Benefits Framework and its Implementation7
Glossary
RBD. Ravenswood Business District, the primary area within the Plan (in addition to Four Corners).
SPU. Specific Plan Update, or “this project.”
SEIR. Subsequent Environmental Impact Review, the legally required environmental study and analysis of the potential impacts of new development.
DSEIR/FSEIR. Draft and Final SEIR documents.
CEQA. California Environmental Quality Act, the State law requiring EIRs.
FAR. Floor Area Ratio, or a measure of how large/intense a development is.
SFCJPA. San Francisquito Creek Joint Powers Authority, the entity that is leading the SAFER Bay flood control effort.
BCDC. Bay Conservation and Development Commission, a body that reviews and approves developments located adjacent to the Bay.
EPASD. East Palo Alto Sanitary District, the entity which currently provides sanitary sewer services in the City and oversees the sewer infrastructure.
R&D. Research and Development, a broad land use category that encompasses a variety of scientific/technical, medical/pharmaceutical, and laboratory/life science uses.
S.F. Square feet, a common measurement of a development’s total interior building size.
R+A. Raimi + Associates, primary consultant overseeing the Specific Plan Update. 7 Link to all comments received on the Public Draft Specific Plan are saved on the RBD webpage:
https://www.ci.east-palo-alto.ca.us/planning/page/rbd-specific-plan-update 22 # Commenter Comment - Did we get the Priorities and Community Benefits Framework right? Page Number
Response
5 Lavain, YUCA Make the language more understandable and they didn't add any youth shelters also maybe add water fountains that dispenses cold water
315 Staff recommends adding explicit references to these uses as part of the Framework Benefits Priorities table, under Civic/Community space.
6 Lavain, YUCA No we don't want to prioritize a police station and you guys didn't add youth shelters 315 Staff notes that any decision regarding the disposition of the current or future police station will be subject to Council discretion and Capital Improvement Program (CIP) schedules/priorities, in compliance with the Surplus Lands Act to the extent applicable. 11 Moana, YUCA The city being better about advocating for community members when they are bringing in new developments and making sure that part of that development is accessible to the residents of East Palo Alto. 315 Staff notes that several Plan policies support this request, see 124 and Chapter 10 12 Moana, YUCA Yes and No. You emphasized affordable housing but not specific on what kind of affordable housing at a low income community rate. Would like to see ADU and affordable units to keep our young people in our community. Funding a police station under community facilities does not sound right, they do not even meet the community's needs, why would we fund these pigs?- if this is prioritized please make it the last last option or when they are ready to treat people like human. 315 See 6
17 Sam, YUCA The frame work could be better, could build more that’ll be beneficial for the community. 315 Staff recommends maintaining the Framework as written. Staff will add a note that the Exemplary Tier may be achieved with "a minimum of 8 points" but stress that this is only a suggested target, and achievement over 8 points will be reflected in the staff's positive recommendation to Council.
Targets and priorities should be regularly revisited (every few years) to consider changing market conditions, community priorities, and development costs. Targets are expectations, not absolutes; Council has discretion to adjust based on a project’s conditions. 18 Sam, YUCA I think we are missing implementing youth shelters. Which is something I wanna see to make a big impact on youths life’s and being a big help for them. Also putting water fountains that keep water cold and filtered would make a huge impact.
As well as keeping housing affordable.
315 Staff recommends adding explicit references to these uses as part of the Framework Benefits Priorities table, under Civic/Community space.
22 Dani, YUCA I would like to see this a little better but for a start its good and I really hope from now on this will help be beneficial for our community
315 See 17
23 Dani, YUCA For Affordable housing I didn't see youth shelter, to come into the RBD area, much needed and should be here in EPA, if you keep police station for community facilities and local business support it should be the very last thing to focus on. 315 See 6
27 Litzi, YUCA Could be better 315 See 17
28 Litzi, YUCA Keep low-income people there and we realized there is no youth shelter. We would like to see youth shelters. 315 See 5 32 Julia, YUCA I think we could charge them more to encourage them to build more benefits and make sure the community is getting the best use of the benefits.
315 See 17
33 Julia, YUCA For the most part yes. Love to see the affordable housing for low-income people but you all are missing a youth shelter.
Personally to me it is very important for the community. I do think the police station is one of the lowest priorities for me and most likely a lot more other people. Another thing I would like to see is water fountains that dispense cold water around the city. Especially for these hot days.
315 See 5
39 Estefani, YUCA Encouraging them to ask for more benefits in order for more space. This is because we have already seen companies come in the community without them giving anything in return. 315 See 17
40 Estefani, YUCA no, making sure that there are youth shelters while still focusing on affordable housing! keep affordable housing for low income people in this community. Not putting police at the top of the priority, keeping it at the bottom of the list. 315 See 6
44 Xenia, YUCA Something that was missing that is really important is a youth shelter. Don't prioritize a police station that should be one of the last things that should be thought of.
315 See 5
50 n/a Is y'all really go give these benefits though cuz y'all always say that 315 See 17 56 1889 e bayshore rd I feel like you guys have a lot of great ideas and it would be great if you guys can add some outdoor workout equipment as well.
315 Noted
63 Sulie No, what's the cost to Residents? 315 Noted, see Nexus Study 75 Hanne Bentz Need more info 315 Noted
76 Hanne Bentz I think that we also need housing for people with 100% and 100%+ AMI to possibly accommodate more people who will work in EPA or nearby. People who work in EPA may have preferences for housing in EPA. Otherwise, I want a walkable green beautiful and lively city. The plan looks good.
315 Staff recommends no change unless directed by Council – these priorities were developed through broad community input, and the Plan allows for an applicant to choose a different AMI mix than required by Inclusionary Ordinance. Changes to the City Ordinance can be considered as part of an upcoming county-wide nexus study.
93 Don Willett Parks and nearby retail. Look at San Mateo! 315 See Priorities Table 23 105 Isabel Lopez Maravi We should provide as many low income units as possible and give East Palo Alto residents priority for all units. 315 See Priorities Table 110 Mary Frances The proposed development is on marshland that should not be used for commercial development and more than 30 years ago, a group of citizens from the village University village have fought to keep that area to be continued to be wetland and not to be developed
315 Noted
117 Armollo Access to public restrooms if these can be cleaned periodically. Great the promotion of community art and engagement.
Would love to see development of community vegetable gardens. 315 See Priorities Table
124 Fili, YUCA I believe that the community, civic, and job space percentages could receive an overall increase. I generally do enjoy the tier system but maybe would like to see a point up in the system and more incentive to focus on housing and jobs. When smaller projects are being brought to the table for development, make sure that the jobs they may bring are going to be attainable for East Palo Alto residents. Some kind of process to make sure that local entrepreneurs can get some of the first opportunities to rent out spaces that are brought.
315 Staff notes that several Plan policies support this request, including:
- Policy HCB-3.2 Support small, local, and startup businesses through a) Favoring projects that include these spaces for allocation of office/R&D floor area and b) Prioritizing these businesses when leasing community-serving spaces.
- Policy HCB-3.3 Through the completion of the scorecard and phasing plan, ensure that developers articulate clear commitments for their proposed provision of community space, including the length of subsidy, amount of subsidy, deed restrictions, maintenance requirements, and more. - Policy HCB-3.8 As feasible, give preference to formerly displaced local businesses in future RFP processes established for leasing/occupancy of subsidized community spaces.
The Plan also allows that Council may establish a process in the future if any community spaces are permanently deeded over to the City.
125 Fili, YUCA I believe that these make a lot of sense, but would want to see an expansion of the low-income AMI to include 20-25%.
Also a decrease in the middle income AMI to cap out around 80-90%. The jobs and workforce priorities are all in line. I do not think that police stations should be a priority, I would rather have an increase in overall care including mental health services, youth homeless shelters, emergency services, animal care, and rehab centers. I would like to make sure that public art and art programs are culturally competent so that they reflect the culture and history of our city. 315 See 76
131 Sean Ripley To me, the most essential element is robust, well attended community forums to provide needs and feedback once design proposals have been presented to the city. Overall, though, please prioritize communal spaces, like the library, community meeting rooms, community film and TV viewing spaces (a place to watch the Olympics together, for example), a communal kitchen and cafeteria, communal marketplace stalls, communal dance and music rooms, and more. We are a community that likes to come out and share the space and be together. And our small businesses will thrive if they have the spaces to rent or use for free that they otherwise could not afford to buy or lease on a long-term basis. Priorities table - looks good right now.
315 See 124
142 Yesi I believe the areas will be a great addition to the community. Depending on what retail shops move in there will be many people accessing them and the park will be a nice meeting place for the neighborhood. A jardin type area like they have in Mexico would be great to hold small events. Or even like they have in Redwood City where they have summer movies or other small vents/fairs. Please don’t add hostile architecture when adding seating the areas. And add plenty of shade for people to be able to enjoy the outdoors more. I’ve been walking the Ravenswood trail since it opened and every year it gets busier, which is definitely a great thing to see. Additional green spaces closer to home will contribute to more people using them.
315 See Priorities Table
143 Yesi Definitely agree with all of these and am glad they are being addressed. 315 Noted 151 Kristy I think this is a good list of priorities. 315 Noted 228 Jeff Poetsch, Ravenswood
Shores Business District
General - As I have noted many times previously, I find the Community Benefits aspect of the specific plan cumbersome, confusing and awkward. I’m guess there is little that can done about this now, given how many times this has gone before Council. Basically, what is lacking are a few examples as to how this would work. Is the Harvest Landing project a base, standard or exemplary tier? How do you incorporate something like Emerson’s Center for Economic Mobility into the equation - or their proposed housing project at 391 Demeter into the evaluation of their future office project comprising 350 Demeter, 2555 Pulgas and 151 Tara? Unfortunately, I’m pretty sure that you don’t have an answer to this. Also, given where we seem to be in the economic cycle, it is unlikely that anything will be developed on the 4 main office / r&d sites, regardless of the option for additional FAR if exemplary community benefits are achieved by a projects design. 315 In the final Specific Plan, staff will clarify how the Framework applies to phased projects (applicants would be able to take credit for affordable residential or community-serving components completed as part of an application for Office/R&D Allocation. 255 Harvest Properties For Policy HCB-3.9 (p. 315), it states: “Consider establishing Community Opportunity to Purchase (COPA) first right of offer and first right of refusal requirements for surplus or underutilized lands in the Plan Area.” Please clarify this language of ‘surplus or underutilized land.’ We are assuming that this would only apply to publicly owned lands, not privately owned, but please confirm.
315 Applies to publicly owned lands only
256 Harvest Properties Community Benefits Requirements to receive Allocation of Development Capacity (p. 319) - Can you please clarify if these are the requirements for all Tiers (including Base), or just Standard and Exemplary? 319 These obligations (detailed program, scorecard, and financial analysis) apply only to the Standard and Exemplary Tier; Base Tier projects are only responsible for City baseline requirements. 24 257 Harvest Properties Exemplary Framework Targets/Expectations (p. 331) - How do you plan to define ‘maker space’? 331 Refer to Section 6.2.1 of the Public Draft Specific Plan for definitions and standards relating to maker spaces.
289 Harvest Properties Affordable Housing Standards (p.329) “Housing Agreement j. Details regarding the location and development program for the site/building at which the units will be constructed (note comparability requirements in MuniCode 18.38)” - With respect to ‘comparability requirements,’ according to Harvest’s non-profit affordable housing partner, it would be best to add language that if the project is financed with low-income housing tax credits (LIHTC), then so long as the project meets the TCAC standards for a project and unit sizes that these comparability requirements will be waived. 329 Agreed.
290 Harvest Properties “Housing Agreement l. Timing commitments for delivery of the units,..” - Please note that this is inconsistent with the 10- year allowance and/or the reality of what it takes to finance affordable housing. It is very competitive to obtain various sources, and therefore very challenging to make timing commitments. We recommend softening this language to "anticipated schedule" and create requirements for certain achievable milestones, such as project approvals. 329 Staff agrees and recommends softening the language to "anticipated schedule" and creating requirements for achievable milestones such as project approvals/entitlements. 291 Harvest Properties “Housing Agreement o. Draft marketing, outreach and tenant selection plan to maximize local live/work preference to the full extent allowable by State and fair housing law.” - Recommend adding underlined language to the end of this statement: “ and fair housing law and any other funding regulations for funds secured to build the project.” The addition of this underlined language will allow a future non-profit affordable housing organization to secure County and State money that often will not allow local preferences.
329 Agreed.
292 Harvest Properties “Income Levels. Affordable housing is assumed to be provided at the same AMI percentages as is prescribed in the City’s adopted Inclusionary Ordinance (for rental units, 25% at 35% AMI, 50% at 50% AMI, 25% at 60% AMI). However, applicants may choose to provide a different AMI breakdown (i.e., more units at 80% to 100% AMI) - the value of these units would be discounted to reflect the true subsidy required to close the gap between projected income and construction costs (the affordability “gap”). The blended average in-lieu value of one rental unit is currently set at $273,400 for FY 2023-2024. - Please clarify how the underlined language above would be calculated. 329 The Housing Department will provide in-lieu values for rental units provided at various AMIs, reflecting the amount currently required to subsidize affordable units at different household income levels.
293 Harvest Properties Bonuses for Standard / Exemplary (p. 330) - Developers should be able to request a Conditional Development Allocation or “Hold” for Exemplary for 12-18 months given current market conditions. This should not only be limited to Base and Standard Tier projects.
330 Staff does not recommend allowing a Conditional Allocation or “HOLD” at the Exemplary Tier, as this would be likely to result in one or more of the major four projects being unable to build a viable project. However, see staff’s related recommendation below about changes to the immediate allocation window.
362 Sand Hill Property
Company
Community Benefits Review Process. The Specific Plan does not have sufficient definition associated with the community benefits review process. Define a timeline for the community benefits review process. The timeline should articulate deadlines for developers and the city to respond to each other’s submittals and clear consequences for failure to meet the deadlines.
323 Staff agrees and recommends that the Plan contain a timeline for the community benefits review process.
363 Sand Hill Property
Company
Jobs-Housing Linkage Benefits. The jobs-housing linkage targets are not realistic. For example, Table 10-2, in Hypothetical Project 1, anticipates a new job-housing requirement of 1 per 30,000 square feet, including 17 affordable housing units to be built on site. This requirement further burdens an already financially infeasible commercial development called out in the city’s financial feasibility study. The concept of an additional jobs-housing linkage benefit should be eliminated or include the possibility of alternative compliance.
328 Staff clarifies that the jobs-housing linkage ratio is not a requirement but rather this previously established level of housing contribution is now associated with achieving the highest (i.e. 3 points) target under the affordable housing category in the Community Benefits Framework. 364 Sand Hill Property
Company
Exemplary Targets/Expectations. Table 10-3: Exemplary Framework Targets/Expectations thresholds are too high, especially in light of the City’s recent feasibility study. Reduce the targets/expectations at every tier, especially for community space and public parks, plazas & greenways.
331 Staff does not recommend lowering or reducing the community benefits expectations for higherdensity development – staff believes that the City is best served by maintaining the targets as proposed and waiting until the market rebounds to ensure that benefits are maximized from more impactful (i.e., larger-scale/higher-density) projects. However, targets should be periodically reevaluated to ensure the Framework is working as intended. 25