From: Seema Patel
To: Clerk
Cc: City Council (San Mateo)
Subject: Minimum Residential Densities in Mixed-Use Development Date: Monday, August 19, 2024 3:33:32 PM
Hello Councilmembers!
I am excited that the City Council is exploring minimum residential densities in future development and have some thoughts to share. While I currently serve as the Chair of San Mateo's Planning Commission I am submitting these comments on my own behalf as a resident of San Mateo.
I believe that establishing minimum residential densities, and other policy mechanisms for ensuring balanced commercial and residential growth, is an important step in addressing our housing crisis and reversing a four decade trend of creating more jobs than housing.
I respectfully suggest that Council consider the following:
Other cities in the Peninsula have successfully implemented commercial-residential ratios including Redwood City (in their Downtown Specific Plan) and Mountain View (in their East Whisman Specific Plan). Redwood City has specified overall maximums (sqft) of commercial, retail and residential development in their downtown specific plan area while Mountain View has mandated that a unit of housing be built for every 300sqft of commercial in their East Whisman specific plan area. I suggest contacting these cities and asking them to share lessons learned from implementing these policies.
I do not think that a percentage of floor area is the right metric for ensuring balanced commercial and residential growth given that significantly more square feet is necessary for a unit of housing than a single employee.
Current commercial trends are approximately 200sqft per employee while the City's minimum floor area for residential dwellings are 350sqft for a studio, 540sqft for a one-bedroom, 750sqft for a two-bedroom and 950sqft for a three- bedroom.
The Building Industry Association deems 1.5 jobs per unit of housing a healthy jobs:housing ratio. This translates to 200sqft per employee * 1.5 employees = 300sqft of commercial to one unit of housing. (This is presumably why Mountain View's requirement is one unit of housing per 300sqft of commercial.) The Staff Report notes that Housing Element Policy H 1.9 includes an implementation action to "Amend the Zoning Code to require that properties designated for mixed-uses, in the Sites Inventory List, allow 100 percent residential use and require that residential use occupy 50 percent or more of the total floor area of a mixed-use project..."
Using 50% of floor area as the metric, a 10,000sqft project would be mandated to provide at least 5,000sqft of residential (~9 one-bedroom units) leaving 5,000sqft for commercial use (25 employees). This is jobs:housing ratio of 2.8:1, which is nearly double the healthy ratio.
Floor area also includes lobbies, circulation, mechanical / electrical rooms, and other uses that don't directly translate into number of units.
Rather than use percentage of floor area I suggest requiring a unit of housing per amount of sqft of commercial (like Mountain View).
There should be a mechanism for obtaining an exception to the residential requirement
Some sites may not be suitable for multiple uses due to their small size (e.g.
Donut Delite) or to residential use due to access, neighboring uses, etc. Requiring residential uses at all mixed use zoned sites may disincentivize or prohibit redevelopment of these sites.
Applicants should be able to request an exception from the City Council. The City could require that applicants who are granted an exception pay an in-lieu fee equivalent to the cost of building the required residential units. The in-lieu fee could be dedicated towards affordable housing.
Applicants should be given the flexibility to achieve residential requirements across multiple projects
The more uses provided within a single building, the more redundancy is required (separate entrances, circulation, etc.) and the more inefficient the use of space.
Less efficiency = higher per unit cost, and so applicants should be given the flexibility to combine requirements across multiple projects to deliver the total required residential at a single site.
Council may want to consider allowing any applicant to pay an in-lieu fee equivalent to the cost of building the required residential units This would provide flexibility and more efficient use of space and funds.
Ensure that tiered incentives do not exacerbate the jobs:housing imbalance and worsen the housing crisis.
EPS suggests a sliding scale of incentives such that projects that are greater than 50% residential would be entitled to a 20% increase in density, FAR or height for their commercial component. A 10,000sqft project at maximum FAR that proposes 5,000sqft of residential would be entitled to an additional 2,000sqft of commercial floor area, resulting in a project that is 5,000sqft residential and 7,000sqft commercial, which is only 41.6% residential. Such a project would accommodate 35 employees and only ~9 one-bedroom units, resulting in a jobs:housing ratio of 3.9:1 which is more than double the healthy 1.5:1 ratio.
I suggest that any bonuses be applied to residential use, not commercial use, or that the incentive be adjusted so that the maximum commercial incentive still results in a project that has a healthy 1.5:1 jobs:housing ratio.
Applying residential minimums to projects within a geographic boundary of public transit (e.g. 1 mile from a Caltrain station) makes sense That said, significant commercial development that is not near public transit should include residential and retail development in order to create walkable neighborhoods and reduce traffic / GHG.
It does not make sense to treat projects on the Housing Element Site Inventory differently from other development projects. As staff has repeatedly explained, housing is often developed on parcels that weren't included on the Site Inventory.
Ultimately, I think Council should consider whether they would like to use this policy to ensure balanced growth moving forward (e.g. require 1 unit of housing for every 300sqft of commercial), or to try and remedy 40 years of unbalanced growth by incentivizing more residential growth through the time period of this General Plan (e.g. require 2 units of housing for every 300sqft of commercial).
Thank you for your consideration of my comments!
Regards,
Seema Patel