Five Issues with the Comp Plan 1

Now is the time for you to have an impact on the City’s new Comprehensive Plan.

When one looks at the whole Comprehensive Plan it is clear that the Plan is pushing us to becoming an expanding business center rather than a well-balanced community of residents and workers. Below are five key issues. Sign the petition or send your own comments to the City Council (


High Non-Residential Growth

Over the next fifteen years, the Plan would allow up to three million square feet of non-residential growth. This is an annual growth rate twice the rate experienced over the last 27 years. Already, the City’s Annual Citizen Survey shows more than two-thirds of residents consistently have high levels of concern about congestion, traffic and parking.

Palo Alto already has a very high commute ratio. It has three jobs in town for every employed resident. This 3:1 ration is just about the highest in the country for cities over 50,000 in population (along with Washington DC and higher than Manhattan County within New York City).  This long-standing issue led the Council to start monitoring commercial growth in nine commercial areas in 1989. From 1989 to 2015, commercial growth in these areas averaged 57,000 sq ft per year. The new Plan permits an annual average of 113,000 sq ft, just about twice the historic 27 year average. If we look at total non-residential growth we have to include exempted properties within the City boundaries. Historically this includes health and medical facilities like the VA expansion and the new building for the Palo Alto Medical Clinic. It also includes the new Stanford Medical Center expansion. Over the past 27 years, the total non-residential growth came to an annual average of 94k sq ft per year. Under the current proposed Plan it would average 200,000 sq ft per year, well over twice the historical ratio. No matter if we are looking at commercial expansion in the commercial zones or total non-residential growth in the City, this year’s Comprehensive Plan would double the rate of non-residential expansion. (Data from the “Existing Conditions Report, August 2014, Table 8-3 updated). And this comes at a time when the most accurate survey of Palo Alto residents (City of Palo Alto ”The National Citizen Survey”, January 2017) shows that under current conditions more than two-thirds of residents consistently have high levels of concern about congestion, traffic and parking and that number has been growing in recent years.

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Weak Traffic Mitigations

The Plan keeps the ratio of jobs to employed residents at close to 3:1, one of the highest in the country. Transportation mitigations outlined in the Plan have all been under active discussion since the late 1980s with limited success. We need forceful language to provide clear definitions, objective monitoring and strict enforcement.

The City has long been aware of the issue of congestion, traffic and parking within the relatively small urban core. In 1980, the Council declared a moratorium on new commercial expansion in the Downtown area.  This led to a series of studies over the next few years to address the issue of traffic and parking. Important City studies included: “Downtown Report: A Summary” (January 1988) and “Citywide Land Use and Transportation Study: Final Report” (September 1988.)  The 1998 Comprehensive Plan included a total non-residential growth limit throughout the monitored areas of 3.25m sq ft. The Stanford Medical Center’s 1.3m sq ft was later exempted from the count. The mitigation recommendations from the various studies since the 1980s have included downzoning, new parking garages, annual monitoring, Traffic Management Associations, expanded transit and alternative means of travel like shuttles, car sharing and biking. Yet they have not been fully effective. The current concerns expressed in the Citizen’s Survey indicate that any traffic mitigations need to be clearly defined, objectively measured and strictly enforced.

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Businesses Should Pay Their Fair Share

Residents should not be subsidizing business growth. Businesses should pay to mitigate the impacts of congestion and traffic. Yet, other than at the Stanford Medical Center, the Plan does not contain substantial dedicated funding from business to deal with increased traffic and encroachment of parking into nearby neighborhoods.

Effective mitigation cost real dollars. When the Stanford University Medical Center added 1.3m sq ft of new space and approximately 2.3k new workers they agreed to a traffic mitigation plan for the Medical Center. They agreed to spend $2.6m per year for 51 years to get approximately one-third of their total Medical Center workers into alternative modes of transportation (non-single occupancy vehicles). This is a realistic measure of getting a relatively small portion of workers into alternative transportation. There is no similar financial commitment from any other employer group.  In fact, while the property tax remains the most important tax for all local governments (City, county, schools, community colleges), the most recent Comprehensive Annual Financial Report (June 2016) shows that in Palo Alto non-residential share of property taxes have been falling by about one percentage point per year and was down to 25% of the total. Businesses should be responsible for the costs of the traffic and parking issue they create.

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Businesses Should Pay More for Affordable Housing

The City has a clear obligation to subsidize Below Market Rate housing. Unfortunately, the majority of current subsidies come from construction of new housing, rather than the much larger amount of job-creating commercial construction. This imbalance makes new ‘affordable’ housing, available only for the most affluent.

The 2015-2023 Housing Element, approved by the City Council in November 2014, is a part of the City’s Comprehensive Plan. On page 78, it contains a review of the funds collected for Affordable Housing Projects from 2009-2014. It says these funds are particularly important because these local leverage other funding sources. The Element states that the Residential Housing Fund collected $13.69m over those six years and the Commercial Housing Fund collected $11.69m (Table 3-10). Note that the Commercial Housing Funds do not measure the additional value of below market rate units that are built in-lieu of paying the Residential Housing Fee. Thus, in total, new housing bears a substantially higher cost of the total funds raised for affordable housing projects. The Housing Elements states: “There is concern that the commercial developers are not paying an equitable share of funds for affordable housing.” The Comprehensive Plan calls for substantial investments in new housing but does not address this inequity.

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With dramatic increases in both jobs and population projected, the Plan states that we will not use more water than we do today, which is hard for many to believe. The Plan should address sustainability realistically.

According to the Final EIR (Table 2.4, the City will be adding between 8.4k and 10.5k new residents and between 9.9k and 11.5k new jobs. Yet the Final EIR shows that the City water demand will be lower under any scenario. This is justified by the statement that continued gains in efficiency will lead to falling demand for water. This is a noble goal but doesn’t address in detail how and with what cost will this be achieved.

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