To City Council/ City Staff-
We have seen that you are considering an annual cap on office/R&D development in Palo Alto at your January 26 meeting.
The staff report includes data on the rate of annual additions to non-residential building stock, and also includes benchmarking data on what caps other California cities have put in place.
But why is the cap being proposed, and what should it accomplish? If the reason for the cap is to reduce traffic and parking problems in Palo Alto, then the most important data to understand is the relationship between new office/R&D development and traffic/ parking problems. Santa Monica decided to attack the heart of the problem (cars and parking) vs. one aspect of the problem (development): their goal is to “limit new trips” vs. “limit new construction”.
We hope that Palo Alto also approaches the core of this problem-- the cars-- versus the indirect problem-- developments. Addressing the number of cars is vital to 1) reduce traffic/congestion, 2) reduce demand for parking 3) keep our streets safe and, 4) reduce greenhouse gas emissions to help achieve our Sustainability/Climate Action Plan (S/CAP) goals. Analyzing the relationship between office/R&D, retail, residents, and transportation systems-- none of these exist in a vacuum. In the ideal world, we want a healthy retail sector coupled with minimal traffic and parking problems -- this should be the framing of the problem. We would ask that Council and Staff consider the following data as core to this discussion:
Relationship between commercial development in different locations and parking and traffic problems: There are studies of mode share of downtown employees that could be referenced by staff; these should be supplemented with studies of mode share of non-downtown employees. Perhaps the question to answer is: how many cars are added to Palo Alto roads due to the construction of each incremental 1000 SQFT of commercial space at different locations, and what can be done to minimize this number?
Relationship between commercial development in different locations and retail health: There has been a lot of discussion at Council regarding how to help promote local retail. Any retailer will tell you that they need (a) more customers; and (b) lower rent. Is there a connection between office/R&D and retail success in different locations? Can retail rents keep pace with strong office demand and lower office supply increases?
Rather than looking at a development cap, a more useful tool may be to look at where development is taking place. The detailed survey data for downtown businesses suggests that there can be successful strategies to encourage job growth, helping local retail, while limiting traffic and parking impacts. This may not be the case in locations further from transit corridors, and it may not be the case without effective TDM measures.
Below are some specific measures that should be considered, none of which are in the staff report:
A citywide annual limit on increases in Vehicle Miles Traveled instead of a citywide annual cap on office space development, or incentives for developers who can show reductions in Vehicle Miles Traveled
Higher fees to support Transportation Demand Management programs and penalties for developments that exceed the expected VMT promised prior to construction
Incentives to prevent free dedicated parking (free dedicated parking reduces effectiveness of TDM programs). For example, a parking cashout fee for building tenants, and mechanism to make freed spaces available to the public or other buildings that don't have parking or access to public garages
A density bonus to accommodate more housing square footage on the same site (some formula that ties office square footage to residential square footage, so that we reduce the number of new jobs created where employees need to drive into the city)
We suggest that the Council use this opportunity to request city staff to create an impact report of the different options for controlling trips, specifically including a comparison of a limit on car trips as compared to a limit on new construction