CITY OF SAN MATEO
RESOLUTION NO. ____ (2026)
APPROVING AN ALTERNATIVE MEANS OF COMPLIANCE PURSUANT TO SECTION VIII(d)OF THE CITY’S BELOW MARKET-RATE HOUSING GUIDELINES FOR PA-2026-0025, A HOUSING DEVELOPMENT PROJECT LOCATED AT 1700 SOUTH EL CAMINO REAL
WHEREAS, in March 2026, JEMCOR Development Partners (Applicant) filed a formal development application, PA 2025-0025, with the Planning Division for a Site Plan and Architectural Review (SPAR), Site Development Planning Application (SDPA), and Tentative Mapping (VTM) in order to demolish the existing fivestory office building at 1700 S. El Camino Real and construct two eight-story apartment buildings on a 3.1-acre site, located at the corner of El Camino Real and Borel Avenue; and WHEREAS, consideration of the SPAR, SDPA, and VTM for the underlying Project require review and approval by the Planning Commission, which will occur on a future date; and WHEREAS, Building A is a residential building with a total of 253 market-rate rental units, including 136 one-bedroom units, 88 two-bedroom units, and 29 three-bedroom units, and Building B is a 188-unit residential building, including 150 one-bedroom units and 28 two-bedroom units with deed-restricted lower-income units for senior citizens;
WHEREAS, under Section III(b)(ii) of the City’s Below Market-Rate (BMR) Guidelines, a project must provide 15 percent of the units in the project as affordable to low-income renters. The BMR requirement for the market-rate development in Building A, which has a total of 253 units, is 38 lower-income rental units; and WHEREAS, under Section VIII(d) of the BMR Guidelines, a developer may propose alternative ways to comply with the baseline requirement to provide 15 percent lower-income units on-site, if a developer provides City Council with substantial evidence that the project will provide as many as, or more BMR units at the same or lower income levels, or will otherwise provide a greater public benefit than the baseline requirement; and WHEREAS, the Applicant invokes BMR Guidelines Section VIII(d), and proposes to fulfill the Project’s BMR requirements within Building B, where all 188 units will be deed-restricted affordable rentals for seniors; and
WHEREAS, under Section VIII(d), the Affordable Housing Plan must be approved prior to the Project being deemed complete. The Affordable Housing Plan must comply with all five criteria set forth in the Guidelines.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SAN MATEO, CALIFORNIA, HEREBY FINDS:
1. The approval of an alternative means of compliance with the City’s Below Market Rate Housing Program is not a project subject to CEQA, because it is an organizational or administrative activity that will not result in direct or indirect physical changes in the environment. (CEQA Guidelines Section 15378(b)(5).)
2. All the requirements of the City’s BMR Guidelines are met:
Under Section VIII(d)(i), the number of affordable units in the proposed alternative plan must equal or exceed that required by the on-site requirement in Section III.
By offering 188 units of affordable senior housing in Building B, the Project will significantly exceed the standard inclusionary requirement of 38 BMR units.
Under Section VIII(d)(ii), the level of affordability provided by each of the BMR units must meet the affordability threshold or lower affordability thresholds, as required under the onsite requirements under Guidelines Section III.
The affordable units in Building B will be offered to low-income senior households, which is the same level of affordability as required by the City’s BMR Program for rental units.
Under Section VIII(d)(iii), if the Applicant-Proposed Alternative does not meet requirements in (i) and (ii), it will provide greater public benefit than that provided under the onsite requirement of Guidelines Section III.
The Project meets the requirements of subsections (i) and (ii) as noted above, and furthermore, the Project will create a greater public benefit by providing more than triple the number of required BMR units and provide affordable housing for seniors in a high resource area in within the City which is consistent with Housing Element goals and Affirmatively Furthering Fair Housing (AFFH) objectives.
Under Section VIII(d)(iv), the developer must demonstrate that a financing or a viable financing plan, which may include public funding, is in place for the Applicant-Proposed Alternative.
The Applicant does not plan to use City or County funds; the Applicant plans to use private activity tax-exempt bonds.
Under Section VIII(d)(v), the Applicant-Proposed Alternative must be consistent with the General Plan and Housing Element, and the provisions of the BMR Guidelines.
The Applicant-proposed alternative Affordable Housing Plan is consistent with the General Plan, Housing Element, and BMR Guidelines because (a) it transforms a commercial parcel along El Camino Real into high-density housing, thereby matching the City’s vision for transit and commercial corridors; (b) the development project is designated by the California Tax Credit Allocation Committee as a High Resource neighborhood with strong access to public transit, jobs, etc.; (c) the development of 441 total housing units go toward the City’s Regional Housing Needs Allocation (RHNA) goals established in the Housing Element; and (d) 188 of the 441 total new units will be deed-restricted affordable housing for low-income seniors, which furthers Policy H1.18 of the Housing Element, to Increase Senior Housing Production.
3. The Affordable Housing Plan for the Project in Exhibit A to this Resolution is hereby approved.
June 17, 2026
Rachel Horst
Housing & Neighborhood Services Manager
Community Development Department, City of San Mateo
330 W 20th Avenue
San Mateo, CA 94403
[email protected]
via email
Re: Applicant-Proposed Alternative Compliance Method for City of San Mateo BMR Program This purpose of this letter is to state an Applicant-Proposed Alternative compliance plan consistent with Section VIII(d) of the City of San Mateo’s Below Market Rent (Inclusionary) Program requirement (“BMR Requirement”) as it would apply to Applicant’s pending application to redevelop 1700 S El Camino Real (the “Project”), CDD file number PA-2026-0013.
As it relates to Section VIII(d) of the BMR Requirement, the following rationale is submitted:
- The BMR Requirement is designed to ensure that otherwise market-rate apartment developments reserve a portion of the total unit count for various levels of qualified below-market households. - Per the terms of the BMR Requirement, a total of 15% of the total proposed unit count would need to be offered for rental rates not exceeding a Lower Income threshold. (§ III(b).) As the Project currently proposes a total of 441 rental units, this calculates to a total requirement of 66 BMR units.
- Per Applicant’s proposed programming of the Project, a total of 188 BMR units will be provided at a Lower Income standard, or 43% of the Project’s total unit count. - The Project will comprise the development of two separate rental communities:
1. Building A: a 253-unit, 100% market-rate development (subject only to documentation the City would require to memorialize that its BMR Requirement has been satisfied by Building B)
2. Building B: a 188-unit, 100% senior affordable LIHTC development (subject to a Density Bonus regulatory agreement and also a governing regulatory agreement with the California Tax Credit Allocation Committee (“TCAC”))
- Although certain regulatory restrictions on Building B will be enforced through the bond issuer or TCAC rather than by the City’s Density Bonus Regulatory Agreement, the total public benefit the Project will provide to qualifying households (185 senior affordable housing units and 3 manager units) will greatly exceed what the IHO would itself require in isolation (66 affordable housing units).
- Because Building A and Building B would be separate buildings ultimately on separate parcels, their amenities, services, unit sizes, and finishes will not be shared as otherwise required by Section VII of the BMR Requirement. Rather, these elements will be distinct and appropriate to each building’s resident profile and market positions.
- Please note, however, that the unit plans for Building B will greatly exceed the square footage requirement for senior units stated in Section VII(e) of the BMR Requirement. Currently, the 1700 S. El Camino Real, Suite 400 | San Mateo, CA 94402 average rental square footage of a one-bedroom unit in the senior affordable development will be +/- 690 RSF versus a BMR Requirement minimum of 507 RSF; the average rentable square for a two-bedroom unit in the senior affordable building will be +/- 980 RSF versus a BMR Requirement minimum of 602 RSF.
In summary, the Applicant notes the following with respect to Section VIII(d) (i) -(iv) of the BMR Requirement:
i. The number of affordable units exceeds those required by Section III of the BMR Requirement by 285% (188 lower income units provided versus 66 required). ii. Consistent with Gov. Code § 65915, all 188 affordable units will be restricted by the Density Bonus regulatory agreement to a lower income qualification standard, consistent with Section III of the BMR Requirement. iii. The Project will create substantially greater public benefit not only by exceeding the BMR Requirement by nearly 3x, but also by provided much-needed deedrestricted affordable housing for seniors. iv. While the Project will not be funded with “public” funding (no City or County funds will be requested), it will utilize private activity tax-exempt bonds and federal (and also potentially state) low-income housing tax credits. The Applicant is a prominent developer of 100% affordable housing in the Bay Area. It is eminently qualified to develop Building B using this capital structure. v. Applicant believes its proposed alternative furthers the stated goals of the General Plan and Housing Element with zero cost to the City of San Mateo.
We appreciate Staff’s common-sense consideration of this request. Please contact us with any questions.
JEMCOR Development Partners