2951 El Camino Real – PAN Position Paper

2951 El Camino — Godzilla Proposed for El Camino Real

Palo Alto Neighborhoods (PAN) fully supports truly affordable housing, but 2951 El Camino Real is not an example of how to achieve it.

On January 19, 2021, a proposal to develop 2951 El Camino Real is coming before Council.  This complex’s height, density and massing:

  1. Covers 5 separate parcels in North Ventura
  2. Violates current zoning Laws
  3. Are out of proportion to the character of the adjacent single family neighborhood
  4. Exceeds what the City’s own development tools to incentivize housing allow (namely HIP and PHZ)

The Council should say NO to 2951 because it:

  1. Violates the law of the City.
  2. Encourages other developers to do the same.
  3. Encourages other developers to wait and see what concessions they might get from the city; developer giveaways disincentivize other developers to build now.
  4. Makes developers unequal before the law. Compadres and Olive Garden complied, but 2951 doesn’t want to.
  5. Victimizes homeowners and renters. Anyone who lives within 150 feet of a commercial or mixed-use zone anywhere in the City could confront new height and massing.
  6. Drives up the price of commercial/mixed-use land because giveaways add value to the land.
  7. Higher prices make it harder for non-profits like Alta Housing to buy land. It will make it harder for the City to create affordable housing, as is being proposed by many residents.  What if we want to issue bonds or use a proposed new business tax to build BMR housing and address the camper crisis?  The value of the UPZONED land will make it very hard for beneficial builders to acquire land.
  8. Steady up-zoning of properties along El Camino Real disproportionately affects neighborhoods nestled behind El Camino Real in South Palo Alto. Up-zoning is not allowed in other neighborhoods, why in these neighborhoods?
  9. The City hands the developer millions of dollars in value in exchange for a handful of BMR units which the developer would have had to provide anyway (the ones we need) and more at market and above market rate housing (which would be nice, but we don’t need.) There is no value to the city in this bargain.
  10. Municipalities are obligated to look after the long-term health, diversity and viability of its community; therefore, providing developers with massive giveaways is not compatible with sustaining a robust civic life nor solving the problem at hand, the need for more affordable housing.
  11. Furthermore, the housing crisis was not caused by the residents, but by the previous Council Members and City Manager who encouraged runaway office development as a source of funds for the city. Palo Alto now suffers from a 3-1 jobs-to-housing imbalance, the highest housing costs in the land, and high property values.  2951 not only does not abide by our laws but it makes our housing crisis worse.

How 2951 ECR Violates The Zoning Code

Here are some of the ways 2951 ECR violates the City’s Zoning Code including HIP and PHZ tools:

  • Upzones R-1 to Dense PC
    • Violates our Comprehensive Plan to change zoning in this manner
    • Violates the NVCAP consensus to preserve or only slightly upzone R-1
  • Exceeds 35 ft. Height Limit within 150 Ft. of Low-Density Residential
    • Violates §18.13.150(b) for PCs
    • Violates the NVCAP consensus to retain the 35 ft. transition zone
  • Exceeds Other Height Limits (proposes 58 ft. maximum)
    • Violates CS Zone general 50 foot height limit per §18.16.060(b)
    • Violates R-1 Zone 30 foot height limit per §18.12.040(a)
  • Exceeds Allowed Floor Area (proposes 2.55 FAR)
    • CS Zone allows 1.0 FAR per §18.16.060(b)
    • R-1 Zone allows 0.43 FAR per §18.12.040(a) for the sites in the project
  • Exceeds Allowed Footprint (proposes 63%)
    • CS Zone allows 50% per §18.16.060(b)
    • R-1 Zone allows 35% for multistory homes per §18.12.040(a)
  • Eliminates Current Ban on Underground Garages in R-1 per §18.12.060(e)

Current Zoning Situation:

  • Currently the city has a zoning code which is the law of the city.
  • Recently the redevelopment of the old Compadres site and the old Olive Garden site were approved under current zoning tools.
  • The City has on its books the Housing Incentive Program which relaxes the building code to incentivize developers to build housing.
  • Recently 788 San Antonio was approved under the HIP with a few concessions.
  • Additionally, last year the city brought back the controversial PC zoning (Planned Community Zoning) under a new name Planned Housing Zone.
  • Even with all zoning for housing concessions, 2951 wants even more, ushering in a floodgate of developers watching, waiting and wanting “more.”
  • If developers believe Council is soft on code enforcement, developers will continue to waste Staff, Council and Commission time on projects that should never be entertained in the first place.

Context – RHNA Goals:

Palo Alto has met or is close to meeting its RHNA allocation goals for market rate and above market rate housing for this last 8 year cycle.  (We only have confirmed data from RHNA up through 2018 so estimates based on city data have us at 117% of our goal.)  Where we are woefully behind is the production of Below Market Rate housing.

Every 8 years, ABAG–working with the Housing Methodology Committee (HMC)–distributes a share of the region’s housing need (RHNA) to cities throughout the Bay Area.  This triggers the production of a new Housing Element for our Comprehensive Plan which brings together city staff and community members to review possible parcels and their zoning to make sure it’s possible to meet our allocation.  The next housing work plan process begins in 2021 and will be seeking applicants.

Relevant Documents

Council Agenda for January 19, 2021:

Staff Report for January 19, 2021:

City Project Page for 2951 ECR:

Proposed Plans for January 19, 2021:

Minutes from October 5, 2020 Prescreening: