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ANALYSIS OF LAND USE CONTROLS
This section analyzes the i mpact of all relevant land use controls on whether, independently and cumulatively, they present a constraint on the development of a variety of housing types. In summary, this analysis reveals standards that represen t a constraint to achieving housing pro duction at densities specified in the existing regulations and/or rezonings identified to meet the RHNA. First, the ground-level landscaping requirement, generally 20 percent minimum, acts as a lot coverage limitation in the commercial mixed use districts and represents a constraint to housing production at densities identified in the Sites Inventory. The landscaping standard is proposed to be modified as part of the Program 1.1 zoning changes in order to achieve the stated density. Second, proposed density changes in the ROLM to meet the RHNA, from 30 du/ac to 65 du/ac, will mean that other existing standards, such as height, FAR, landscaping/lot coverage, or parking, will be constraints to achievin g the density threshold. These standards are also proposed to be modified as part of Program 1.1 to facilitate housing production at stated densities.
To evaluate constraints, t he City has prepared physical site test models of all development standards specified in the Zoning Ordinance and summarized in the tables above , including setbacks, coverage, density, FAR, open space, building height, and parking.
These models illustrate that multi-family development is physically feasible in all zones that allow housing, including on the smaller sites in the Sites Inventory. Townhomes are feasible in all scenarios. Stacked flats are generally feasible, but larger sites (above 10,000 sq. ft.) and/or corner lots are better for allowing parking and circulation access. Smaller sites and interior lots are generally more constrained. However, as detailed further below, in some instances, development standards need to be modified to achieve the RHNA densities projected for some properties in the Sites Inventory.
Notably, residential density and parking standards do not correlate. Since the City requires 1 space/unit for studios and 1 -bedrooms, but 2 spaces/unit for 2+ bedrooms , in a hypothetical project , the same amount of parking can serve either more studios/1-bedrooms (higher densities) or fewer 2+ bedroom units (lower densities). These parking requirements apply to all multifamily projects regardless of zone.
Multifamily projects are being approved and built in Palo Alto in townhome and stacked flat configurations, which sugge sts that projects are financially feasible for at least these projects. Some of these projects take advantage of the Housing Incentive Program or State Density Bonus Law for increased density, which generally improves financial feasibility for low and moderate-density buildings using wood construction.
Housing development projects that meet objective development and design standards have a high level of certainty for approval, potentially within 60 days of completeness for projects undergoing the City’s Streamlined Review Process (subject to one study se ssion with the ARB) or other State streamlining bills (e.g., SB35 or AB2162) and exempt from CEQA . Projects that seek exceptions and utilize the subjective Context-Based Design Criteria and Architectural Review Process are subject to subjective findings and up to three public hearings with the ARB.
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Figure 4-2 CD(C) Zone Model
This 5,125 square foot CD(C) site accommodates four dwelling units in a townhome typology. This district does not have setback or residential density standards, but does have a 50-foot height limit (which reduces to 40 feet at the front of the site which is within 150 feet of a lower density residential district ).
At 1.23 FAR, this model exceeds the base FAR of 1.0, but is still below the Housing Incentive Program limit of 3.0 FAR. FAR is the density limit for the district since there is no residential density standard expressed in du/ac. The model also achieves the ground-level 20 percent landscape and 150 square feet/unit open space requirements, average unit size maximum of 1,500 square feet, and provides 2 parking spaces per unit in a tandem configuration. The resulting 3 -story townhome attached townhome typology is a wood construction type that is cost effective and commonly found in the area.
Existing zoning and proposed Housing Element programs provide a path to achieve more units and change housing and construction types to stacked flats . . In the absence of a ma ximum density expressed in dwelling units per acre, various development standards would need to be modified to increase density on the site. For example, based the City’s analysis, the percent ground-level landscaping standard precludes the project from achieving the allowable density and therefore represents a constraint on housing production at the 50 du/ac threshold identified in the Sites Inventory for sites within 1/4 mile of major transit. As part of Program 1.1, standards will be modified to allow the landscaping standa rd to be met above ground-level (e.g., on a courtyard or the rooftop) . This change could allow podium construction, accommodate more unit s and parking, still within the existing height limit. Further, 100 percent below- market rate projects could benefit from other development standards through the existing HIP to achieve
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substantially more units per acre . AB2097 also exempts this site from parking requirements altogether, which would also increase unit yield beyond what is illustrated here.
Figure 4-3 CN Zone Model
This 15, 800 square foot C N site accommodates 12 apartments and ground-floor retail in a mixed-use typology. Key standards modeled include setbacks, 20 percent ground-floor landscape coverage, 35-foot maximum building height, and the land use requirement to provide ground -floor retail. There is no maximum residential density expressed in du/ac for sites on El Camino Real in this district, but FAR of 1.5 and lot coverage of 100 percent is permitted with the Housing Incentive Program. The model provides the required 21 parking spaces in a below-grade garage. Although subterranean parking is a high cost option, it is somewhat common in Palo Alto.
The ground -level landscaping requirement represents a constraint to achieving the 4 0 du/ac density threshold identified in the Sites Inventory for this site which is located within a ½ mile of a major tr ansit corridor. Program 1.1 addresses the zoning constraint imposed by modifying the landscaping coverage standard to achieve Sites Inventory densities.
To incentivize greater housing production potential, as an alternative to State Density Bonus Law, Program
3.4 proposes changes to the Housing Incentive Program . For example, greater building height and adjustments to the daylight plane, could be used to achieve mo re density, while bringing the parking above-grade. Further, the Housing Incentive Program offers 100 percent below-market rate projects relief from these other development standards, including parking as low as 0.75/unit, height up to 50 feet, and landscaping above the ground-floor.
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Figure 4-4 RM-20 Zone Model
This 10,000 square foot site accommodates four townhome units, achieving 18 du/ac in a zone that allows 20 du/ac. The model takes into account setbacks, 30 -foot height limit , daylight plane requirements, 35 percent lot coverage, 35 percent ground-floor landscaping an d 150 square feet per unit open space requirements and achieves the 8 parking spaces required for 3- and 4-bedroom units through tuck-under and surface parking . State law already allows up to at least 1.0 FAR. The resulting 3 -story attached townhome typology is a wood construction type that is cost effective and commonly found in the area.
Surface and tuck-under parking are likewise cost effective.
Existing zoning and proposed Housing Element programs provide a path for how to achieve even more units. Program 1.1A requires RM sites to receive a density increase, in this case from 20 to 30 du/ac. This would provide the option of more and smaller units (i.e., studio s and 1 -bedrooms) which carry lower parking requirements. Thus, this site could achieve five or six units (up to 26 du/ac) while still providing just seven or eight total parking spaces.
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Figure 4-5 RM-30 Zone Model
This 6,600 square foot site accommodates four townhome units, achieving 27 du/ac in a zone that allows 30 du/ac. The model takes into account setbacks, 3 5-foot height limit, daylight plane requirements, 40 percent lot co verage, 35 percent ground-floor landscaping an d 150 square feet per unit open space requirements, and achieve the 8 parking spaces required through tuck -under parking. State law already allows up to at least 1.0 FAR. The resulting 3 -story attached townhome typology is a wood construction type that is cost effective and commonly found in the area.
Existing zoning and proposed Housing Element programs provide a path for how to achieve even more units. Program 1.1A requires RM sites to receive a density increase, in this case from 30 to 40 du/ac. This would provide the option of more and smaller units (i.e., studios and 1 -bedrooms) which carry lower parking requirements. Thus, this site could achieve up to six units (up to 40 du/ac) while still providing six to eight total parking spaces.
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Figure 4-6 RM-40 Zone Model – Parking Compliant with City Code
This 5,000 square foot site accommodates four apartments, achieving 35 du/ac in a zone that allows 40 du/ac. The model takes into account setbacks, 40-foot height limit, daylight plane requirements, 4 5 percent lot coverage, 20 percent ground-floor landscaping and 150 square feet per unit open space requirements, and achieves the 7 parking spaces required through a ground -level garage . State law already allows up to at least 1.0 FAR. The resulting 3 -story attached townhome typology is a wood construction type that is cost effective and commonly found in the area.
State law, e xisting zoning and proposed Housing Element programs provide a path for how to achieve even more units. Program 1.1A requires RM sites, to receive a density increase, in this case from 40 to 50 du/ac. On smaller sites distant from transit, mechanical lifts may be necessary to meet parking requirements while still allowing for circulation in the driveway and garage . Mechanical lifts are allowed and have been used in Palo Alto as a viable way to shrink the footprint devoted to parking.
Larger sites (e.g., 10,000 sq. ft.) allow for improved garage and driveway circulation that can physically accommodate parking. But, the City also modeled a 5,000 square foot interior lot, as opposed to a corner lot, which proved to be more challenging to design driveways and garage circulation. On interior lots, no parking or reduced parking strategies allowed for higher unit yields. Sites located within ½-mile of transit may invoke AB2097 parking reductions that would allow for additional unit yield up to 50 du/ac.
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On this small site, to achieve five units (up to 50 du/ac), the model could develop a range of studios or 1- bedrooms (which carry lower parking requirements) thereby achieving the maximum de nsity while still providing up to seven total parking spaces, even without the use of mechanical lifts.
Figure 4-7 ROLM Zone Model – Existing Zoning: 16 du/ac Yield
This 1-acre ROLM site accommodates 16 townhome units, achieving 16 du/ac in a zone that allows 30 du/ac. This zone district generally follows the RM -30 zoning standards. Therefore, the model takes into account setbacks, 35-foot height limit, daylight plane requirements, 40 percent lot coverage, 35 percent ground-floor landscaping and 150 square feet per unit open space requirements, and achieves the 32 parking spaces required. The resulting 3-story attached townhome typology is a wood construction type that is cost effective and commonly found in the area.
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However, this model is not achieving the full allowable density, which allows for up to 30 dwelling units.
With the current standards, 30 units are not feasible on this 1 -acre site. This is prim arily due to the 40 percent lot coverage and 0.6 FAR limits, and to some extent the depth of the parcel which necessitates a full hammerhead design to accommodate Fire Department access. These standards represent a constraint to achieving the density set forth in the code. Ways to rectify this constraint are described below.
Figure 4-8 ROLM Zone Model – Existing Zoning: 30 du/ac Yield
The figure above explores what it will take to achieve 30 du/ac and transition from a townhome to an apartment typology, namely: (1) a taller height limit (from 35 to 45 feet) to accommodate unit sizes and allow for all tuck under parking, (2) increased lot coverage from 40 percent to 70 percent, (3) FAR of
1.25; (4) parking reduced to 1 space per studio/1-bedroom and 1.25 spaces per 2+ bedroom.
However, the Housing Element strategy for this portion of the GM/ROLM in Bayshore in the Sites Inventory anticipates a density of up to 70 du/ac, as shown below.
Figure 4-9 ROLM Zone Model – Proposed Zoning (Program 1.1): 70 du/ac Yield
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Proposed Housing Element programs provide a path for how to achieve a density of 70 du/ac. At this density, the housing typology transitions to stacked flats (apartments or condos). In addition to increasing density standards, this model assumes a number of possible changes to development standards that would reduce this constraint: (1) height limit from 35 to 55 feet; (2) lot coverage increase from 40 percent to 70 percent, (3) FAR up to 2.0; ( 4) allowance for the 20 percent landscaping requirement to be met above the ground-floor; and (5) 1 space per studio/1-bedroom and 1.25-1.5 spaces per 2+ bedroom.
Program 1.1 addresses th e zoning constraint imposed by existing zoning regu lations by modifying a combination of standards, such as height, FAR, lot coverage, landscaping, and parking to enable housing production at the density proposed in the Sites Inventory.
SINGLE ROOM OCCUPANCY UNITS
The Palo Alto Zoning Ordinance allows Single Room Occupancy (SRO) units as a multiple tenant structure with individual resident rooms. The City permits SRO units in CN, CC, and CS zones and multi -family residential zoning distri cts as shown in Table 4 -3 using development standards that encourage the construction of the maximum number of units. Sites that have access to community services and p ublic transportation are highly desired for SRO residents. Tenants typically share bathrooms and/or kitchens, while some rooms may include kitchenettes, bathrooms, or half-baths.