April 15, 2024 www.paloaltohousingelement.com
City Council &
Planning and Transportation
Commission
Joint Meeting
Adoption of
2023-31 Housing Element
1 Purpose
• Review HCD comments
• Discuss proposed response to HCD comments
• Review environmental impacts
• Take public comment
• Adopt revised 2023-31 Housing Element
2 Meeting Process
1. Presentation
2. Questions
3. Public comment
4. PTC deliberation and recommendation on Housing
Element
5. Council deliberation and action:
• Resolution adopting the revised Housing
Element
3 Recent Milestones
December 2022 — HCD Submittal #1
March 2023 — HCD comments received (1st letter)
May 2023 — Housing Element adoption
June 2023 — HCD Submittal #2
August 2023 — HCD comments received (2nd letter)
February – March 2024 — HCD informal discussion/review
April 2024 (tonight) — PTC & Council consider re-adoption May 2024 (anticipated) — HCD Submittal #3
July 2024 (anticipated) — HCD response (certification,
substantial compliance, or additional comments)
4 we are here
General themes:
1. RHNA – rationale for regional projections
2. Site inventory – criteria for site selection and locations/distribution
3. City’s development standards limit housing production
4. Application processing timeframes
5. Need for housing affordability and special needs housing
6. Support for programs that combat homelessness
7. Ambitious assumptions about ADU production
8. Need for tenant protection policies
9. Desire for a more inclusive community
Public Comments Received
5 HCD Comments
6 August 3, 2023 HCD Comment Letter
Comments focused on four areas:
• Affirmatively Furthering Fair Housing (App. B)
• Sites Inventory (Ch. 3/App. D)
• Constraints (Ch. 4)
• Programs (Ch. 5)
7 Work Completed in Response to Comments
• Revised Element in response to HCD comments
• Revisted Site Inventory
o Additions, deletions, modifications
o Links to fair housing improvements
• Met with community stakeholders and developers
• Held informal meetings with HCD reviewer
• Strengthened and streamlined programs to support
fair housing and sites inventory, reduce constraints
8 Affirmatively Furthering Fair Housing
HCD Comment Draft Response
Add local data to explain
Racially Concentrated
Areas of Affluence
• Expanded history of Palo Alto
• Described changes in land use policy and
programs to overcome past patterns
Analyze trends related to
disparities in access to
opportunities
• Expanded analysis of accessto opportunities
• Documented how specific Programs further
fair housing
Link sites inventory to
improvements in fair
housing
• Added discussion of the benefits of socio-
economic diversity
• Focused program implementation in specific
neighborhoods and/or populations
9 Sites Inventory
HCD Comment Draft Response
Explain why sites are likely to
develop and at indicated
affordability levels
• Added precedent projects
• Added building permit history
• Described recent rezonings
Confirm capacity assumptions
and likelihood of residential in
commercial zones
• Emphasized changes in office market
• Added more site-specific analyses
Expand non-vacant sites
analysis to assess constraints
• Expanded discussion of site suitability
• Refined criteria to match recent projects
Discuss opportunities for
emergency shelters in ROLM(E)
• Expanded discussion of recent
redevelopment trends in this zone
10 Sites Inventory
11 Very Low Low Moderate
Above
Moderate Total
RHNA 1,556 896 1,013 2,621 6,086
Credits
Entitled Units 133 108 144 82 100 23 490 239 867 452
ADUs 153 153 153 53 512
Remaining RHNA 1,270 1,295 599 661 760 837 2,078 2,329 4,707 5,122 Opportunity Sites
Planned Units 83 83 86 553 805
Multi-family Allowed 0 0 95 67 159 177 254 244
Rezone Completed 1,091 1,009 1,092 1,010 778 815 2,118 1,907 5,079 4,741 Subtotal 1,091 1,092 1,092 1,093 873 968 2,277 2,637 5,333 5,790 Total Units (Credits +
Opportunity Sites)
2,766 2,681 1,126 1,144 2,820 2,929 6,712 6,754
Total Unit Surplus 314 229 113 131 199 308 626 668
Total % Buffer 17 12% 16 15% 10 13% 13%
Constraints
HCD Comment Draft Response
Study land use controls in all
zoning districts
• Added site tests for all zoning districts
• Analyzed ability to meet max densities
Analysis of cost and financial
feasibility related to permit
procedures and processing
• Expanded analysis of City fees and
processing procedures and timelines
• Compared City’s fees to nearby cities’
Identify on- and off-site
infrastructure requirements
• Added discussion of improvement
requirements (e.g.,public works)
Expand discussion of Retail
Preservation Ordinance and
Tree Protection Ordinance
• Updated analysis of Tree Protection Ord.
• Clarified Retail Preservation Ord. exemptions
12 Programs
HCD Comment Draft Response
Clarify commitments to
specific housing outcomes
and deliverables
• Refined commitments to specific outcomes
and timelines (not just studies)
• Strengthened qualified objectives
• Focused dates on first half of planning period
Complete sites analysis;
comply w/ Surplus Lands Act
• Expanded sites analysis
• Confirmed compliance w/ Surplus Lands Act
Remove constraints to
housing for persons with
disabilities
• Reduced impact fees and processing
timelines
Refine programs to
affirmatively further fair
housing
• Expanded fair housing programs; added
targeted programming to specific
neighborhoods and populations
13 Programs (Key Changes - Modifications)
• Moved up timelines so that programs can be
impactful during the planning period
• Consolidated programs related to funding and
streamlining
• Focused entitlement streamlining on the programs
that are expected to be the most impactful
• Ex. Program 3.3 - Streamlined Review for 100%
Affordable Housing and revised procedures so
that affordable projects have priority processing
→ Realistic look at what can be achieved
14 Programs (Key Changes - Additions)
• Program 4.5 - Labor Practices: Develop a list of local labor unions and apprenticeship programs on the
City’s website and encourage developers and
contractors to hire local labor.
• Program 6.6 - Fair Housing: Prepare an area plan for
the San Antonio Road Corridor, including the
ROLM/GM Focus Area, to integrate housing with
multi-modal transportation, access to amenities,
parks and open space, placemaking improvements,
and mitigations for environmental impacts.
15 Environmental Impacts
16 CEQA: Environmental Review - Addendum
• City Council considered an Addendum to the 2017
Comprehensive Plan Update Environmental Impact
Report as part of the Rezoning Ordinance adopted in
December 2023
• No new or substantially more severe significant
impacts were identified beyond what was analyzed in
the 2017 EIR
• Addendum analyzed the current Sites Inventory
• No additional CEQA review or action required
17 CEQA Analysis - Conclusion
• Impacts of the HE were determined to be less than
significant and generally the same as the impacts
analyzed in the 2017 EIR.
• No new or substantially more severe significant
impacts were identified beyond what was analyzed
in the 2017 EIR.
18 Non-CEQA: Traffic Level of Service Analysis
• Level of service (LOS) is no longer a threshold under CEQA, but helps City understand potential
operational impacts
• LOS analysis conducted on Sites Inventory
• Generally, produced the same results as the 2017
Comprehensive Plan analysis
• Some modest changes in the findings, primarily as a
result of changes to the countywide traffic model
19 NEXT STEPS
20 Next Steps
April 2024
• PTC/Council
consider Housing
Element adoption
May 2024
• Submit adopted
draft for HCD
review
July 2024
• Receive HCD
Comments - letter
of substantial
compliance,
certification, or
continued
dialogue
Summer 2024+
• Implementation
ongoing
21 Staff Recommendation
Staff recommends the following actions:
Planning and Transportation Commission:
1. Review the staff responses to the HCD Comment Letter, as incorporated in the Draft 2023-31 Housing Element (Attachment A) and recommend City Council adopt the revised Draft 2023-31 Housing Element.
City Council:
1. Direct staff to make appropriate changes to the Draft 2023-31 Housing Element (Attachment A) and authorize staff to make minor revisions based on any further non-substantive changes required by HCD.
2. Adopt a Resolution (Attachment B) making the findings required under CEQA and Housing Element Law, and adopting the 2023-31 Housing Element, as revised, as an amendment to the City’s Comprehensive Plan. 22 Meeting Sequence
1. Staff Presentation
2. Public Comment
3. PTC Deliberation / Motion (Councilmembers move to reserved seating in audience)
4. Councilmembers Return, Questions/Comments of PTC deliberation/motion
5. PTC members move to reserved seating in audience
6. Councilmember Veenker recusal / Council deliberation on Stanford-related properties and programs and First Congregational Church
7. Councilmember Veenker returns / Council deliberation on remaining components of the Housing Element
8. Council Action
Recommended Motion: Based on consideration of the revised addendum to the 2017 Comprehensive Plan Final Environmental Impact Report, I move adoption of the resolution in Attachment B adopting the Revised 2023-2031 Housing Element with the following additional changes [if any]...
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