Needed Housing Element Changes
OK Palo Alto - Let’s Get Serious
For the second time this year, the California Department of Housing and Community Development (HCD) has advised the City of Palo Alto to strengthen its plan to build needed housing, known as its Housing Element, and bring it into compliance with state law.
We are grateful to city staff for their hard work throughout this process, it isn’t easy. Still, more work remains, to ensure our community meets its legal requirements to build a sufficient number of homes for people at all income levels.
What’s a Housing Element?
California law requires each city, every eight years, to update the Housing Element in its Comprehensive Plan. It must provide a path to build new homes, both overall and at different income levels, to meet our city’s Regional Housing Needs Allocation (RHNA). It must inventory sites appropriate for new housing, remove governmental constraints on new housing development, and affirmatively further fair housing. HCD determines whether a city’s Housing Element is consistent with state law.
How did we get here?
In 2021, the Association of Bay Area Governments (ABAG) assigned to Palo Alto a RHNA of 6,086 new homes. This includes 1,556 for very low-income people (earning less than half of the Area Median Income), 896 for low-income people (50% to 80%), and 1,013 for moderate-income people (80% to 120%). Our RHNA is high because we and most of our neighbors are a great place for low-income families and their children to live (good schools, lot of amenities and a good resource base for public services) if we can provide housing they can afford and because we have great auto and public transit access to jobs up and down the peninsula, which will help reduce long commutes and the associated GHG emissions and pollutants.
In December 2022, Palo Alto submitted its draft Housing Element to HCD. Palo Alto Forward sent a 63-page letter to city and state officials that raised many concerns. In March 2023, HCD sent Palo Alto a letter finding that “revisions will be necessary to comply with State Housing Element Law.”
In May, Palo Alto submitted to HCD a new Housing Element. Palo Alto Forward sent a new letter to HCD, urging that “more meaningful changes are required to have a compliant and effective Housing Element” - consistent with the state’s original comments. We explained that Palo Alto’s plan must align zoning standards with development that is financially feasible; mitigate government constraints on housing, like approval timelines; and update the site inventory.
What does the new HCD letter say?
The most current (August 3, 2023) letter from HCD emphasizes the same points as the previous letters. To really “fix” the Housing Element and avoid the consequences of continued non-compliance (Builders Remedy, loss of state dollars for affordable housing, infrastructure, and operations, etc.)
Allow housing in more areas and on more sites throughout the City - Much housing development is focused in an isolated area at the northeast corner of the city near San Antonio Road. New housing should be dispersed throughout the city to provide access to transit, schools, and services - which in turn makes for a better local economy and environment.
Change outdated and unrealistic zoning standards - This includes floor area, parking, heights, density requirements that prevent projects from being economically feasible given current construction standards and rising costs..
Speed up approvals - The process is unnecessarily convoluted and complicated - imagine the things we could accomplish if the process was simplified for development. This can largely be accomplished with zoning and process changes HCD wants to see.
Eliminate barriers - For example, update the tree ordinance and review impact fees, which are unfairly borne by smaller condos/apartment units and ADUs.
Moving FORWARD Together
Palo Alto Forward looks forward to working with the city and stakeholders throughout our community to ensure our city adopts a Housing Element that satisfies state law. This is an opportunity to build an inclusive community with abundant homes, a robust economy, a healthier environment, and even better schools.
We can only do this together! Write to the City Council and tell them you want action on the four points outlined above. They need our support and none of this will get done without our collective voices of support.