24 From: Ken Hayes
To: Council, City
Subject: December 16, 2024 CC Meeting Consent Calendar #24 Date: Thursday, December 12, 2024 8:39:03 AM
Attachments: imaae0011331.pna
241212CPA CC 24combined.pdf
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Good Morning Mayor Stone and fellow council members,
Please see attached letter addressing concerns I have about the proposed ordinance language modifying PAMC 18.52.040 Off-Street Parking and the potential impact this will have on the production of housing within ½ mile of public transit.
Further consideration of the appropriate policy direction needs to be evaluated by the city's consultants and the Housing Advisory Committee.
Thank you for your consideration.
Best regards,
Ken
HAYES
GROUP
ARCHI
TECTS
Ken Hayes
Principal, AIA
[email protected]
2657 Spring Street. Redwood City, CA 94063
350 Sansome, Suite 750, San Francisco, CA 94104
www.thehayesgroup.com
P 650.365.0600x115
C 415.203.2597
F 650.365.0670
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HAYES
GROUP
ARCHI
TECTS
December 12, 2024
Honorable Mayor Stone
and City Council Members
City Of Palo Alto
Office of the City Clerk: City Hall, 7* Floor
250 Hamilton Avenue
Palo Alto, CA 94301
Sent Via Email:
City. [email protected]
RE: December 16, 2024, COUNCIL MEETING
CONSENT CALENDAR #24
First Reading Reintroduced State Housing Laws.....
Honorable Mayor Stone and Council Members,
I am writing to express my concern regarding the proposed modifications to the parking exemptions under AB 2097, which are being considered as Consent Calendar item #24.
Especially, now that your consultants and the Downtown Housing Citizen's Advisory Committee is about to start work, I urge you to remove this item from the Consent Calendar for further discussion and analysis, given the complexity of its potential outcomes and impacts on the downtown area and other locations within a ½-mile radius of public transit.
The proposed ordinance modifies PAMC 18.52.040 Off-Street Parking, Loading and Bicycle Facility Requirements (a) Parking Requirements by adding the following language:
(1) For projects within one-half mile of public transit, as defined in California Government Code Section 65863.2:
B) The project shall provide the number of EVSE-installed parking spaces and parking spaces that are accessible to persons with disabilities that would be required if on-site parking were provided in accordance with this Section and in the absence of Government Code Section 65863.2.
Main Office: 2657 Spring Street, Redwood City, CA 94063 Phone 650.365.0600 SF Office: 350 Sansome Street, Suite 750, San Francisco, CA 94104 thehayesgroup.com
This provision has serious implications for the feasibility of creating more housing opportunities in the areas of Palo Alto within ½ mile of Public Transit. Consider how the proposed ordinance would impact a typical 5,000 sf (50 ft wide x 100 ft deep) site.
A hypothetical Housing Development Project, as defined in 65589.5(h)(2), would have 2/3 of a mixed-use project in multi-family use. With current FAR standards, a 5,000 sf site could have 5,000 sf of commercial space and 10,000 sf of residential accommodating 10 units (½ two bedroom and ½ one bedroom).
For the commercial portion, this hypothetical project would require the following EVSE installed spaces and accessible parking spaces:
EVSE Installed: 1 space (5% of 20 required spaces). Van accessible Accessible Space: 1 space (for the first 25 required spaces). Van accessible Commercial Subtotal: 2 spaces
For the residential portion, this hypothetical project would require the following EVSE installed spaces and accessible parking spaces:
EVSE Installed: 2 spaces (10% of 15 EV Ready spaces - 1 per unit). 1 van accessible Accessible Space: 1 space (5% of the 15 unassigned spaces). Van accessible Residential Subtotal: 3 spaces
Total 5 spaces
A 9-foot wide van accessible space requires an unloading zone 8 feet wide on the passenger side of each vehicle. Each of the residential and commercial van spaces above will require the unloading zone, making the width of one space 17 feet and the width required for all spaces 77 feet (17 ft/space x 4 spaces + 9' space). If the site is fortunate to have an alley at the rear - not all do - it could only provide this required parking if the site was 77+ feet in width. See attached Exhibits A and B depicting this requirement for a 50-foot wide site (infeasible) and a 75-foot wide site (infeasible).
Since the majority of sites in Palo Alto's Cal Ave and Downtown districts are 50 feet wide or less, requiring ADA and EVCS spaces on-site' as proposed would effectively render most sites in our densest, most walkable neighborhoods useless for housing development or office-to- housing conversions and mixed-use projects. It is the cost and physical constraints of parking that deters many projects.
1 The commercial portion could participate in the in-lieu downtown parking assessment district, but an applicant would likely use AB2097 to exempt this in-lie fee requirement. And, the city would still impose the requirement for providing the EVSE and Accessible spaces in accordance with the text of the ordinance.
Main Office: 2657 Spring Street, Redwood City, CA 94063 Phone 650.365.0600 SF Office: 350 Sansome Street, Suite 750, San Francisco, CA 94104 thehayesgroup.com
These simple case studies (exhibit A and B) are damning, but deeper examination exposes even more challenges for site planning for new housing projects. Here is an incomplete list of additional constraints and considerations for study:
1. Interaction with accessible entry requirements.
Accessible entries cannot be through the back door unless it is the main entrance or leads to the main entrance. Locating accessible and EVSE-accessible parking at the rear of buildings, off an alley, forces disabled users to navigate dark alleys at night to reach the main building entrance via public sidewalks. This is hazardous, inequitable, and unsafe. But off the alley is where these spaces would be accommodated.
2. Rear parking layouts reduce retail space significantly.
Dedicating parking at the rear of buildings, off alleys, consumes otherwise usable retail floor area, reducing it by as much as 28%. (See Exhibits A and B.)
3. Impact on owners who wish to add housing while preserving commercial space.
Parking at the rear of buildings consumes 28% of the ground floor area (Exhibits A and B). To make up for this loss of area on the ground floor, upper stories would cover the ground floor parking and extend to the rear property line, increasing the area of the upper stories; however, when the commercial parking at grade is "covered" by stories above, the covered commercial parking area counts as FAR, reducing otherwise viable commercial floor area. This is a deterrent to applicants who want to maintain commercial floor area and introduce housing in a mixed-use building.
4. Project-by-project EVSE requirements overburden small developments.
Imposing EVSE-installed and accessible parking requirements on individual projects results in disproportionately large demands on small buildings and the downtown.
For instance, a 10-unit project could face nearly the same requirements for van- accessible EVSE and accessible spaces as a larger development due to minimum thresholds for accessible and EVSE installed spaces, and van-accessible spaces occupying twice the area of a regular space, displacing other valuable land uses.
5. Sites without alley access may become unbuildable for housing.
Housing sites without alley access and prohibited from having curb cuts may fail to meet the ordinance's parking requirements, rendering them unusable for residential development.
6. Excessive vehicular infrastructure undermines walkability.
Requiring parking, driveways, curb cuts, and accessible unloading spaces for numerous small projects diminishes downtown walkability and livability. This conflicts with AB2097's goals of reducing automobile dependence and making housing less Main Office: 2657 Spring Street, Redwood City, CA 94063 Phone 650.365.0600 SF Office: 350 Sansome Street, Suite 750, San Francisco, CA 94104 thehayesgroup.com
expensive to build.
7. Interaction with Housing Element yield assumptions and stated programs.
Downtown sites identified as housing opportunities sites or sites where potential housing could be provided could be rendered ineffective in meeting the city's RHNA goal with this proposed policy direction.
Rushing this decision risks undermining the city's critical goal of creating more housing in the downtown area. Parking requirements are a nuanced issue that demand careful study and informed policymaking, rather than expedited action without a full understanding of the consequences. As currently written, the ordinance language could unintentionally discourage housing development.
For example, our proposed mixed-use project at 640 Waverley Street has been in development since 2013, undergoing numerous design iterations over the years. It wasn't until AB 2097 was adopted in January 2023 that a viable path forward was established in collaboration with the city and the property owner. This project, which is in the final stages of approval, will deliver four residential units on a 5,000-square-foot site?-an important contribution to downtown housing, especially if there are many of them. It is essential that pipeline projects like this be allowed to proceed, regardless of how the Council ultimately decides on changes to parking requirements.
At a time when the city is initiating a study on housing opportunities downtown, I urge the Council to pause and allow the Citizen's Advisory Group and consultants to complete their analysis. Their recommendations, including considerations for EVSE-installed and accessible parking spaces, will ensure that any changes align with our shared goal: creating more housing.
I strongly recommend that item #24 be removed from the Consent Calendar and revisited after a thoughtful and thorough review. Let's ensure that the city's actions are deliberate, data-driven, and supportive of our collective vision for a vibrant and sustainable downtown.
Sincerely,
Ken Hayes, AIA
Principal
Encl: Exhibits A and B
2 Most potential housing sites are 5,000 SFor less in the downtown and though the resulting number of housing units is small many of these projects combined will make a difference in creating living opportunities in the downtown and are essential Main Office: 2657 Spring Street, Redwood City, CA 94063 Phone 650.365.0600 SF Office: 350 Sansome Street, Suite 750, San Francisco, CA 94104 thehayesgroup.com
20' ALLEY
25'-0"
43'-0" 34'-0"
RESIDENTIAL COMMERCIAL
48'-0"
ADA EV EV ADA
VAN VAN VAN VAN
R R C
18-0" 28'-0" FROM P.L. MIN
5.000 SF COMMERCIAL
10.000 RESIDENTIAL
10 DWELLING UNITS
RESIDENTIAL PARKING (R)
HALF 2 BEDROOM = 5 X 2 SPACES/UNIT = 10
HALF 1 BEDROOM = 5 X 1 SPACE/UNIT = 5
TOTAL RESIDENTIAL PARKING SPACES = 15
ADA 15X.05 = .75 SPACES OR 1 VAN SPACE
EVSE READY = 15 BUILDING
EVSE INSTALLED 10% X 15 = 1.5 OR 2(1VAN) GROUND FLOOR
REDUCED BY 1,400 SF
COMMERCIAL PARKING (C) BY PARKING -
ADA 5,000 SF = 20 CARS = 1 VAN (FOR 1-25 CARS), 28 % REDUCTION EVSE INSTALLED = 20 X 5% = 1 VAN
NOTES:
• PARKING REQUIREMENT CANNOT BE MET
SINCE 77 FEET IS NEEDED AND SITE IS
ONLY 50 FEET WIDE. NON COMPLIANT
SPACES IN RED.
• COMMERCIAL PARKING, IF COVERED BY
BUILDING COUNTS TOWARDS
COMMERCIAL F.A.R.
P.L. 50°
STREET
HAYES
GROUP
ARCH EXHIBIT A 5,000 SF SITE
TECTS DATE: 12.12.24 CD-C DISTRICT
• 20' ALLEY
25'-0"
52'-0" 52'-0"
48'-0"
EV ADA ADA EV EV ADA ADA
R VAN VAN VAN VAN C VAN
R R C C
18'-0" 28'-0" FROM P.L. MIN
7,500 SF COMMERCIAL
15,000 SF RESIDENTIAL
15 DWELLING UNITS
RESIDENTIAL PARKING (R)
SEVEN 2 BEDROOM = 7 X 2 SPACES/UNIT= 14
EIGHT 1 BEDROOM = 8 X 1 SPACE/UNIT = 8
TOTAL RESIDENTIAL PARKING SPACES = 22
ADA 22X.05 = 1.1 SPACE OR 1 VAN SPACE
EVSE READY = 22 BUILDING
EVSE INSTALLED 10% X 22 = 2.2 OR 3(1VAN) 00 GROUND FLOOR REDUCED BY 2,100 SF
COMMERCIAL PARKING (C) -ROM PARKING -
ADA 7,500 SF = 30 CARS = 2(1 VAN) 28 % REDUCTION
EVSE INSTALLED = 30 X 5% = 1.5 OR 2 (1 VAN)
NOTES:
• PARKING REQUIREMENT CANNOT BE MET
SINCE 104 FEET IS NEEDED AND SITE IS
ONLY 50 FEET WIDE, NON COMPLIANT
SPACES IN RED.
• COMMERCIAL PARKING, IF COVERED BY
BUILDING COUNTS TOWARDS
COMMERCIAL F.A.R.
-.- -. -..
P.L.— 75'
STREET
HAYES
GROUP
ARCH EXHIBIT B 7,500 SF SITE
TECTS DATE: 12.12.24 CD-C DISTRICT