July 20, 2026
City Council, City of San Mateo
330 W 20th Ave.
San Mateo, CA 94403
RE: Special City Council Meeting Agenda Item 3, Zoning Code Updates
To the honorable San Mateo City Council,
HLC supports the implementation of San Mateo’s zoning code updates in compliance with the City’s housing element policy commitments and the Measure T general plan update, all of which will facilitate housing for the entire community.
As written, the new zoning districts represent substantial clarity and simplicity relative to pre-existing zoning standards. However, to best promote flexibility in new housing that reflects the city’s standards and priorities, Council should direct staff to:
● Increase residential height limits to allow 85-foot tall buildings in R6 and MU3 six-story zones and 110-foot buildings in R7 and MU4 eight-story zones. Currently, the ordinance has 75-foot height limits in six-story districts and 100-foot height limits in eight-story districts. Greater height limits will incentivize elegant ground-floor commercial (typically 18 to 25 feet tall) along with residential (ideally 12 feet of height per floor, including sub floors, ceiling framing, and rooftop utility system). ● Eliminate Floor Area Ratios (FAR) in new and existing zoning districts. Floor Area Ratios are a duplicative zoning regulation that arbitrarily restricts building size. San Mateo already has height limits and setbacks that constrain the building envelope. Floor Area Ratio simply adds another layer of complexity with no additional benefit for the beauty or massing of buildings.
We would also like to better understand: Will there be additional reforms as part of the comprehensive zoning code update process?
San Mateo has ongoing opportunities to streamline existing residential zoning districts like the pre-existing residential districts (see appendix below). Various restrictions on housing—minimum parcel areas and widths, restrictive facade rules, bizarre massing requirements—characterize much of San Mateo’s pre-existing zoning code. These rules prevent land from being used for housing, push up the size of allowable units, and ultimately increase costs. The new zoning updates do not affect existing zoning districts outside narrow changes to
allowable uses, definitions, and retail rules. This is a missed opportunity the City can pursue further.
HLC’s recommendations have precedent elsewhere in the area. San Mateo County eliminated FAR rules and minimum lot sizes in its most recent zoning update. No other cities have such restrictive massing and bulk rules as San Mateo’s downtown, or such aggressive minimum lot sizes throughout the City. By increasing building heights and eliminating FARs in the new districts, and further amending pre-existing zones, San Mateo can best realize the promise of Measure T.
Thank you for your consideration,
Jeremy Levine, Policy Manager
Housing Leadership Council of San Mateo County
Addendum: Prohibitive Zoning Rules Persist in Pre-Existing Code
While HLC also supports the interim zoning amendments proposed to implement Measure T in the short term, the city can complete its comprehensive zoning update and realize the benefits of the general plan much faster than staff propose. San Mateo should aim to further simplify its zoning update and provide clarity.
San Mateo already underwent a six-year general plan update process in which it heard from a huge range of residents. The outcome of that process, Measure T, passed by an almost 20-point margin. One thing is clear: An overwhelming majority of San Mateo residents want a zoning code that works to facilitate new development reflecting the heights and densities of Measure T.
San Mateo has one of the most unnecessarily complex zoning codes in the Bay Area. I pdf’ed a copy and it runs 472 pages. While the new zoning update simplifies some portion of the old code, much of the original document remains intact.
Consider some examples of the complexity and minutiae of the zoning regulations, particularly in downtown: These rules include minimum lot widths and parcel areas mandating a certain amount of lot area per home, directly increasing the cost of housing by tying it to parcel size…
… as well as rules requiring street-facing sides of buildings to be shorter than half the width of an adjacent street…
… and yet more rules governing the maximum length of the diagonal line from one corner of an apartment building to the other.
I have illustrated just a small subset of San Mateo’s zoning rules. Beyond regulations on the height and density of buildings, San Mateo regulates building setbacks from adjacent lots and the street, maximum dwelling sizes, lot depths, lot frontages, parking requirements, the length of porches, “floor area ratios” (the ratio of floor area in a building to the size of the lot it sits on).
The list of rules goes on and on and on. There are more than six different rules governing building size on top of the very clear base height and density limits. Some of them are redundant (going back to FAR!)
1 From: Steve Carlson >
Sent: Friday, July 17, 2026 4:03 PM
To: Clerk
Subject: City Council Hearing of July 20, 2026 - Code Amendments Attachments: Letter to Honorable Mayor and City Council Regarding Zoning Code Amendments.docx Attached is a letter addressing my comments to the City Council.
Respectfully,
Steve Carlson
1 High-Density Mixed Use and Multi-family Districts and Zoning Code Clean-ups – Code Amendments
City Council Hearing July 20, 2026
Honorable Mayor and City Council,
The proposed Code Amendments creating four (4) new Zoning Districts should be continued off-calendar allowing the Planning Commission to conduct a Study Session and the City to hold Public Workshops.
The City is in the middle of a Comprehensive Zoning Code Amendment that is not scheduled to produce Draft Amendments until next year. Public Workshops and Study Sessions are projected to be conducted prior to the development and release of the Final Amendments and City adoption.
Adopting four (4) new districts that have not had the benefit of extensive public input is not in keeping with the City’s best efforts to maintain open communication with the community. This is a piecemeal approach, that is presumptive, premature, and riddled with problems – it is putting the cart before the horse and effectively places developers interests above local residents.
At the Commission Hearing of June 23. 2026, the staff provided little to no information, no comparative analysis with other jurisdictions nor with other San Mateo Residential or Commercial Zone Districts. By way of comparison the Planning Commission Study Session on June 9 involving several Zone Districts the staff report included a detailed comprehensive overview of development standards and a detailed comparative analysis with selected other Bay area jurisdictions.
Staff did explain that requirements for the limited standards for residential open space were derived from developer projects and that the requirements were less than other existing City Zone Districts. In the staff report no functional analysis 2 was presented for example of residential balconies with 30 square feet – little more than an outdoor storage space.
No information was presented as to how the uses for the Commercial Mixed Districts were determined. Because a Mixed Commercial Use District is intended to be placed abutting residential neighborhoods the types of uses is important and that residents have input. A few years ago the City tried to allow a 7-11 on North San Mateo Drive/Bellevue Avenue without public input with disastrous consequences for the City.
Staff advised that the Planning Commission could conduct a Study Session at a later date (after the fact) and be provided with much greater information and that changes could be made that would be incorporated in the Final Amendments.
Staff advised that they do not intend to reclassify any exiting lands to the new districts until after the Comprehensive Amendments are adopted. Staff also advised that individual property owners could request a property be reclassified after the Council adopted the new district and that this would be a benefit to developers who would have a better insight into City expectations.
Should the Final Amendments include different requirements, then properties reclassified (and possibly developed) between now and adoption of the Final Amendments would become legally established, but non-conforming prompting adoption of further provisions patching the problem. Owners of such properties having a vested interest in keeping the standards can be expected to lobby against any change that is not beneficial.
This approach unnecessarily places the interests and needs of developers over and above local residents breaking public trust in leadership.
No written explanation was offered as to the urgency of need to adopt the new districts at this time. The City adopted the General Plan two (2) years ago and reviewed several developments in areas that may be reclassified. So why now? Respectfully,
Steve Carlson
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