June 23, 2026
The proposed amendments create a new zoning district, MU4 (High Density Mixed-Use), that correlates with the Mixed-Use High designation in the General Plan. The Agenda Report (page 4) indicates height limits for nonresidential buildings in the new zone will be five stories and the height limit for residential buildings will be eight stories:
This is further reflected in the proposed ordinance (Attachment 1, Exhibit A, pages 22-23) at Section 27.53.070:
June 23, 2026
However, the redlined version (Attachment 2, page 22) shows a height limit of four stories and 50 feet for nonresidential buildings and six stories and 75 feet for residential or mixed-use buildings, which would be inconsistent with the Agenda Report and the General Plan:
We assume that this is a typo and wanted to bring it to your attention for correction.
Additionally, it is not clear that the distinction between the height limit for the residential and nonresidential uses is consistent with the General Plan. Moreover, the proposed zoning amendments do not appear to reflect the General Plan direction that height limits in the Mixed- Use High designation are 5-8 stories, with commercial buildings within 1/4-mile of Caltrain stations reaching eight stories through community benefits (see Policy LU 2.3 on page 49):
We request clarification of how General Plan policy will be reflected in the Zoning Code.
Floor Height Assumptions
We note that it appears the assumed floor plate heights for nonresidential buildings in the proposed zoning district are 13’ per floor (per the 5 floor / 65’ height limit). This is not reflective of a marketable, high-quality commercial space. A typical marketable office building has an 18’ floor-to-floor height at the ground floor and 15’ floor-to-floor heights on upper levels.
We request that more realistic assumptions are utilized.
SAN MATEO, SANTA CLARA & SAN BENITO COUNTIES
June 23, 2026
Via Email:
[email protected]
[email protected]
[email protected]
Subject: Key Issues for Comprehensive Zoning Code Update Dear Mayor Loraine and Members of the San Mateo City Council, Planning Commission and City Staff,
The Sierra Club Loma Prieta Chapter's Sustainable Land Use Committee (SLU) advocates on land use issues in San Mateo and Santa Clara Counties.
SLU offers the comments below as an overview of some key issues that we believe need to be addressed in the Comprehensive Zoning Code Update (CZCU). We appreciate the White Papers as a strong starting point for the Comprehensive Zoning Code Update (CZCU). Below are our recommendations to help guide the update process.
1. Housing Production Emphasis needed, with a Strong Emphasis on Affordable Housing The Comprehensive Zoning Code Update (CZCU) should prioritize housing production over new commercial office development, with particular emphasis on expanding affordable and workforce housing. As noted in the February 23, 2026 Staff Report, the CZCU is intended to modernize the City's Zoning Code and incorporate current best practices. It should also simplify the development of new housing by reducing unnecessary costs and delays while maintaining appropriate environmental review, public safety protections, and input from residents, whenever possible.
Prioritize Affordable Housing
Expanding affordable housing and preventing displacement should be among the highest priorities of the CZCU. Affordable housing has consistently been the most difficult housing type to produce, as reflected in the City's failure to meet affordable housing goals, while market-rate housing targets have generally been achieved. Most recent residential development has focused on market-rate as well as luxury housing, thereby contributing to rising housing costs, gentrification, and the displacement of lower- and moderate-income residents.
1 To increase the supply of affordable housing, the City should provide special additional incentives for 100% affordable housing projects and projects with a higher percentage of affordable units, including the following:
● Making publicly-owned land available at reduced or no cost, ● Actively acquiring existing apartment buildings for preservation or conversion to permanently affordable housing,
● Protecting existing affordable housing from demolition or conversion, ● Reducing or waiving development fees, and
● Providing expedited review and approval processes.
These improvements should result in more affordable housing being approved and built.
2. Comments on “Building Heights” White Paper
Use building height strategically to increase open space.The CZCU should encourage the strategic use of building height to create more meaningful open space at the ground level. In appropriate locations, allowing increases in building height—without increasing overall development density—can reduce a building's footprint and preserve larger areas for parks, landscaping, tree canopy, habitat, and other common open spaces.
The City should consider offering incentives for projects to exceed minimum open space requirements.
Potential incentives could include modest height flexibility, reduced setbacks where appropriate, or other development bonuses in exchange for publicly accessible parks, greenways, trails, urban forests, natural habitat areas, or other high-quality green infrastructure.
3. Comments on “Open Space” White Paper
The policy paper should begin with a clear statement of why people in urban areas need open space.
It is important to note that the benefits of nature and living plants extend well beyond just space for recreation or gathering places for people. Urban parks and green spaces—with living plants and open sky—are vital for public health, mental well-being, and environmental health.
A. Improve Terminology
The term Open Space is currently used too broadly, combining two fundamentally different land use categories. The CZCU should clearly distinguish between areas intended for public recreation and those intended primarily for habitat protection and conservation. The definitions should differentiate:
● Human-centered open spaces: Parks, plazas, urban green spaces, and other areas designed primarily for public recreation and community use. Maybe use “Recreational Open Spaces” ● Natural conservation areas: Habitat lands, limited-access conservation areas, and permanently protected open space, such as Sugarloaf Open Space, that are managed primarily for ecological preservation rather than recreation. Maybe use “Natural Open Spaces” Making this distinction will provide greater clarity, improve land use planning, and help ensure that environmentally sensitive areas are managed and protected according to their conservation purpose. 2 B. Recognize Parks and Natural Open Space as Ecological Infrastructure The CZCU should recognize parks and natural open space not only as places for recreation, but also as essential ecological infrastructure that provides critical environmental services. These areas support biodiversity, improve climate resilience, enhance public health, and preserve natural ecosystems.
The City's policies should distinguish between recreational parks and open space designated primarily for habitat conservation and environmental protection. Open space should not be defined solely as land intended for public access or active recreation. Protected natural areas that are not intended for human use provide significant public benefits, including the following:
● Wildlife habitat and biodiversity conservation,
● Air quality improvement and carbon sequestration,
● Stormwater retention and groundwater recharge,
● Reduced runoff and flooding,
● Noise attenuation,
● Wind protection,
● Privacy screening, and
● Climate resilience and urban heat reduction.
Examples include habitat preserves, vegetated freeway buffers, green corridors, riparian areas, street tree corridors, wildlife movement corridors, and landscaped buffers between buildings and major transportation corridors. Wide vegetated buffers of mature trees and native vegetation can substantially reduce air pollution, mitigate traffic noise, capture stormwater, provide windbreaks, and support wildlife, even where public access is neither practical nor appropriate.
The CZCU should therefore recognize these natural landscapes as critical infrastructure deserving long-term protection and enhancement, rather than evaluating them solely for their recreational value.
To further strengthen the City's green infrastructure network, the CZCU should incorporate the principles outlined in the Sierra Club Sustainable Land Use Committee's Guidelines for a Sustainable Green Street Network, which explains how best to create a connected system of safe, slow, tree-lined streets that prioritize pedestrians and bicyclists while expanding urban canopy, habitat connectivity, and climate resilience.
C. Emphasize the Urban Forest as a critical aspect of the City’s Open Space The CZCU should recognize the urban forest as a fundamental component of the City's open space and green infrastructure network. Livability comes not from empty land, but from trees, vegetation and biodiversity within it. For example, Detroit has abundant vacant land, however, Barcelona, which is much denser, is richer in street trees, greenery and livability.
Existing stands of mature trees and native vegetation are invaluable community assets that contribute significantly to the urban canopy and biodiversity. They should be preserved through stronger tree protection and landscape conservation ordinances that minimize unnecessary removal during development and promote long-term biodiversity. Urban forests provide the following:
3 ○ Shade and urban heat reduction,
○ Improved air quality and carbon
sequestration,
○ Stormwater capture and
groundwater recharge,
○ Reduced runoff and flooding,
○ Wildlife habitat and biodiversity,
○ More attractive, walkable
streetscapes, and
○ Improved public health, comfort,
and quality of life.
Barcelona’s tree lined streets increase urban livability and biodiversity D. Increase Parks as Density Grows and Population Increases As the City plans more housing and higher density, it must also simultaneously significantly increase parks and public open space. Creative solutions should also be explored, to improve livability, including: Green Streets, Green Corridors, Pocket green parks, Rooftop and podium green space, Linear parks and trail connections
4. Comments on White Paper “Setbacks and Buffers”
There is much good information in this white paper. We have only a few observations.
A. Setbacks should be designed to create usable green space, tree planting zones, and visual buffers rather than leftover paved strips. With more high density housing required to meet RHNA targets and to meet the housing deficit, including green open space is increasingly important for quality of life in a dense urban context.
See Sierra Club Loma Prieta’s Guidelines for Open Space for High Density Housing for some important suggestions on this topic.
B. The CZCU should seek to provide incentives to encourage more off-street parking and this is noted in the Staff Report of June 9, 2026. The ideas listed in the Staff Report regarding 4 Tandem Parking, Parking in Required Setbacks and Parking Exempt from FAR Calculation are good concepts to consider as well as other ideas that may meet the objective of encouraging off-street parking. In addition, since currently each single family site is allowed to support up to six dwellings (SB-9 plus ADUs) and recent code changes allow some enclosed garages to convert to living space for ADUs, additional parking space is needed.. Encouraging more off-street parking will allow more use of the public right-of-way for future safe bike lanes, improved pedestrian access, etc. See Guidelines for a Sustainable Green Street Network.
C. Balconies or decks should, if possible, not overhang required open space. Open space loses value when covered by another deck or roof, though resulting rain protection has some value.
Alternating left-right balcony placement can reduce shading. Similar standards should apply to commercial office developments.
5. 15-Minute Neighborhood Strategy in White Paper
Consider a citywide planning approach based on the 15-minute neighborhood concept. Areas that are more than a half mile from transit should be evaluated for neighborhood nodes with the following possibilities:
● Mixed-use buildings. Ground-floor commercial, or other uses, with housing above. ● Small-scale retail,
● Cafés and seating
● Secure package lockers e.g. Amazon,
● Mailboxes,
● Shared EV charging,
● Spaces for Car-share,
● Autonomous taxi parking zones, and
● “Missing Middle” housing: allow 3-story buildings, at nodes, in 2-story neighborhoods.
A network of neighborhood centers can reduce vehicle trips and greenhouse gas emissions, improve access to everyday goods and services, encourage walking and bicycling, strengthen neighborhood identity, and support future transit expansion. The CZCU should provide zoning flexibility and development incentives to encourage the creation of these complete, walkable neighborhoods while respecting the scale and character of adjacent residential areas.
6. Climate Resilience, Sea Level Rise and Associated Ground Water Rise Consider a Sea Level Rise Overlay Zone
Sea level rise adaptation should be integrated into the CZCU and General Plan. Applicable areas could require higher finished floor elevations, flood-resilient site design and consideration of groundwater rise. The Bay edge may be suitable for nature-based adaptation measures offering near-term flood reduction, lower long-term costs and greater resilience benefits.
The overlay zone could include areas directly impacted by SLR as well as related impacts like creeks backing up with higher tides and causing flooding. It could also include a timeline for capital outlays to raise roads and, especially, utilities out of corrosive rising brackish ground water.
The Health and Safety Element of the General Plan may also need modification to recognize the 5 impacts of flooded infrastructure and other health and safety impacts of flooding from rising sea levels and ground water levels.
7. Biological Safety Levels (BSL)
In office, commercial, manufacturing, life science, and similar zoning districts, only Biosafety Level 1 (BSL-1) and Biosafety Level 2 (BSL-2) laboratories should be permitted. Higher-risk laboratory operations should be prohibited in these areas due to the potential for biological accidents, including the potential for exposure to unknown viruses or other infectious disease agents. For additional public safety protection, zoning standards should also require appropriate setbacks from residential uses, schools, childcare facilities, and other sensitive receptors.
The City of San Carlos has already adopted this approach by limiting life science facilities to BSL-1 and BSL-2 laboratories.
The City of Redwood City takes a further step in its Downtown Precise Plan (DPP) area, which includes high-density mixed-use development. There, BSL-1 and BSL-2 laboratories are allowed only as conditional uses, enabling additional review of health, safety, and nuisance impacts associated with laboratories operating in close proximity to 24-hour residential and commercial uses.
Based on these precedents, we recommend that life science and laboratory zoning be limited to BSL-1 and BSL-2 facilities, consistent with the San Carlos ordinance. In addition, Redwood City’s conditional-use framework should be considered as a model for mixed-use areas to ensure appropriate oversight and safeguards where laboratories are located near sensitive uses.
We recommend that in the zoning for Life Sciences and Laboratories, safety levels be restricted to BSL-1 and BSL-2 as in the San Carlos ordinance . Redwood City’s more detailed 1 conditional use ordinance for BSL-1 and BSL-2 should be considered for Mixed-Use zones. 2 SLU looks forward to further discussions with you on the CZCU.
Respectfully,
Gita Dev, FAIA, Chair, Sustainable Land Use Committee
Chair, Conservation Committee
Sierra Club Loma Prieta Chapter
Cc: James Eggers, Chapter Director, Sierra Club Loma Prieta Chapter 2 Redwood City Downtown Precise Plan Section 2.2.4. Use Permit Process 1 See San Carlos Code Chapter 18.07 INDUSTRIAL DISTRICTS Table 18.07.020: Land Use Regulations- Industrial Districts
6 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
Outlook
San Mateo Zoning Update - July 20th City Council Special Meeting - Item 3 FromKevin Choy < >
Date Mon 7/20/2026 3:27 PM
To Sung H. Kwon <[email protected]>; Shelby Donohoe <[email protected]> Cc Joanna Winter <[email protected]>; Zachary Dahl <[email protected]> Sung & Shelby,
Per my call with Sung just now, the Harvest team noticed that the definitions of stories and height for non- residential buildings within the new Mixed-Use High-Density zone is different than we would have expected. As written the requirement for stories and height for non-residential construction is 5 stories and 65 feet respectively. We understand that with community benefits the number of stories and height can be increased but our concern is that five stories is not equivalent to 65 feet in commercial construction. In commercial developments, to solve for the market’s expectation on new class A office, it is typical to provide an 18’ ground floor and 15’ upper floor heights; this results in a structure that is 5 stories being 78’ in total height. Providing less than these heights will automatically remove us from prospective tenants touring lists as heights are a black and white requirement for many groups inclusive of auto tech and robotics.
Our team respectfully asks your team to consider amending the story/height limitation for non-residential construction to 5 stories and 78’ to allow our groups to attract the best tenants in the Bay Area. Thank you for the consideration!
Thanks,
Kevin Choy, P.E. | Director
Harvest Properties, Inc.
235 Montgomery St | Suite 2500 | San Francisco, CA 94104
HarvestProperties.com
8/4/26, 3:24 PM Inbox - Shelby Donohoe - Outlook
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Outlook
Concern Regarding Multifamily Development and Neighborhood Impact FromJerry Davis < >
Date Tue 9/1/2026 6:52 PM
To Shelby Donohoe <[email protected]>
Cc City Council (San Mateo) <[email protected]>; [email protected] <[email protected]>; Clerk <[email protected]> Dear Members of the Central Neighborhood Association and City of San Mateo Officials:
I am writing as a longtime San Mateo single-family homeowner to express my serious concern about the direction of development in our city.
San Mateo has consistently approved multifamily housing projects that, in my view, are larger and more intensive than what is appropriate for the surrounding neighborhoods. At the same time, I believe that insufficient consideration has been given to the resulting traffic congestion, parking difficulties, and the impact these developments have on established residential communities.
People who live in single-family neighborhoods have often spent many years working and saving to purchase their homes. For many of us, part of the value of that investment was the expectation of living in a relatively quiet residential environment. I find it deeply troubling to see that character changed through continued development without what I believe is adequate consideration of the people who already live here.
I fully recognize that San Mateo needs housing and that responsible development is an important part of a growing community. However, development should also be balanced against the capacity of existing streets, available parking, traffic conditions, infrastructure, and the character of established neighborhoods.
I am also concerned about whether the burden of accommodating new development is being distributed fairly among San Mateo and neighboring communities. I would appreciate greater transparency regarding how development decisions are made and what consideration is given to alternative locations and the cumulative impact of these projects.
There is an old expression, "follow the money." I am not making an accusation, nor am I suggesting that anyone has acted improperly. I mention it only because major development decisions involve substantial financial interests, and I believe the public is entitled to understand clearly how these decisions are reached, who benefits from them, and how the interests of existing residents are weighed against the interests associated with new development.
I respectfully ask the City and the Central Neighborhood Association to take a closer look at the scale and pace of multifamily development in San Mateo and to consider whether additional development should be approved until the existing traffic, parking, infrastructure, and neighborhood impacts have been adequately addressed.
9/2/26, 8:06 AM Inbox - Shelby Donohoe - Outlook
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I care deeply about San Mateo and about preserving the qualities that have made it a desirable place to live. My objection is not to change or growth in itself. It is to development that I believe is occurring without sufficient regard for the residents and neighborhoods that are already here.
I hope that my concerns, and those of other homeowners who share them, will be given serious and thoughtful consideration.
Respectfully,
Jerry Davis
Single-Family Homeowner
Sent from my iPhone
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