(Wednesday, February 19, 2025)
Chair Gutierrez, Vice Chair Nunez, and Members of the Environmental Planning Commission,
Thank you for the opportunity to comment on item 5.1, R3 zoning district update: Increased densities.
While the Steering Committee of Livable Mountain View did not initially endorse the R3 zoning district project, we welcome the opportunity comment on the questions posed by staff to the EPC. We also thank staff for providing an honest assessment of how the state density bonus law is likely to be applied by those who seek to redevelop R3 parcels in our city. In particular, we appreciate the recognition that redeveloped R3 parcels are likely to take advantage of the 100% density bonus, with its corresponding allowance for zoning concessions and unlimited zoning waivers. Thus, areas zoned R3-D1 are likely to be developed at up to eight stories and those zoned at R3-D2 are likely to be zoned at up to twelve stories after the state density bonus is applied.
Question No. 1: Do the identified areas reflect Council’s goals and criteria? Should any areas be reconsidered based on the criteria?
We support recommending precisely the 14 areas identified by staff for high intensity areas (no more and no fewer). While it would be desirable to only have high density areas that are never immediately adjacent to existing ownership housing, and agree that the eight criteria selected by council are good criteria, we understand staff’s comment: “A strict adherence to utilization of all the above criteria would have eliminated every site in the R3 Zoning District.” In particular, the districts selected do support the aggregation of developable sites, hence development feasibility, with less impact on adjacent ownership housing.
Question No. 2: For the Change Areas selected, what density option should the city study as the R3 Zoning District Update is carried out?
We support Option 2 (R3-D1 Base), with the exception of the Del Medio South Area, for which we recommend Option 1 (R3-D2 Base). This would allow for up to eight stories when the state density bonus is applied in most areas. We support Option1 (R3-D2 Base) for the Del Medio South Area, as the staff report states applying R3-D1 would be a downsizing for the Del Medio South area and “pursuant to SB 330, an equivalent upzoning elsewhere may need to occur if Council selects this option”.
As the staff report notes, “This (staff and consultant) analysis shows and ownership projects at six to seven stories (roughly 75 to 135 dwelling units per acre, depending on unit size) are economically feasible.” There is no point in upzoning to allow higher developments that are not economically feasible due to the increased construction cost for materials and construction methodologies needed for such high-density developments. We also agree with staff that attempting to construct a local R3 zoning which will be preferable to the state density bonus is not worthwhile. The concessions and waivers imbedded in the state density bonus make it the obvious choice for developers seeking high densities.
Question No. 3: Does the EPC support or recommend modifications to the proposed criteria and density for upzoning R2 properties?
We support modifications in the areas selected by staff provided that the upzoning is not immediately adjacent to single family homes.
Thank you for considering our views on this important project.
Robert Cox, Louise Katz, Peter Spitzer, Muriel Sivyer-Lee, Li Zhang, Maureen Blando, Leslie Friedman, Hala Alshahwany, Jerry Steach, and Toni Rath
For the Steering Committee of Livable Mountain View
