How the Housing Element disproportionately and negatively affects East Belmont residents

Dear Planning Commissioners, City Council Members, and staff,

I am a 15-year Belmont resident, living with my husband and our two sons in the Sterling Downs neighborhood.  I am writing to express my opposition to several parts of the Draft Housing Element of the General Plan, including the extreme concentration of Housing Opportunity Sites in the eastern area of Belmont, and the proposed Zoning Ordinance changes.

Specifically, I oppose the following proposed zoning changes:

1. To rezone identified Service Commercial (SC) sites along Old County Road to Corridor Mixed Use (CMU) to allow for residential development.

2. To raise the height limits in the Village Station Core (VSC) and Corridor Mixed Use (CMU) zones to 65 feet (from 45 ft and 50 ft, respectively)

 3. To increase the maximum floor area ratio and eliminate the maximum density metric in the Corridor Mixed Use (CMU) zone.

Below, I lay out my concerns and make recommendations for specific changes to the Draft Housing Element and additional actions by the City that could address these concerns and result in a better outcome for all.

Concern 1: Negative effects of the zoning changes on affordable housing and community benefit programs

It is critical to note that the VSC and CMU zones already allow for increased FAR, increased residential density, and heights up to 60 and 65ft respectively, “with provision of community benefits”.  These benefits include creation of additional on-site Affordable Housing beyond what is otherwise required, as well as quality of life benefits such as public plazas and art, wider sidewalks, and public rights of way.  Rather than sticking with our current approach of trading increased height and density for more affordable housing units and public benefit, the proposed zoning changes would give away that height and density for nothing at all.  With these zoning changes, Belmont will be at increased risk for failing to meet our RHNA-6 obligations for Very Low and Low Income housing, and the high-rise character of the resulting development would be contrary to the Village Specific Plan (VSP) vision of a welcoming, vibrant and pleasant neighborhood.  These proposed changes go against our own stated goals for Belmont.

Concern 2: geographically inequitable distribution of Draft Housing Opportunity sites & new population

Slide 30 of the May 17 staff presentation states: “Programmatic EIR analyzes building housing on 144 Draft Housing Opportunity Sites throughout City”.  However “throughout the city” is a deceptive mis-characterization.  If the current Draft Housing Element is adopted and built out, those 144 sites would result in 3,300 new dwelling units and 8250 additional residents for Belmont.  Of this total, approximately 35 units (0.4%) would be built west of the ECR corridor, consisting entirely of single-family homes.  In contrast, approximately 3,265 units (99.6%) would be built in the eastern area, consisting almost entirely of dense multi-unit high-rise buildings.

The current population of the eastern area is ~7000 residents, so adding over 8000 people would more than double the population of eastern Belmont, while adding only 100-150 residents over the rest of the city’s area.  Such a geographically concentrated development plan is inequitable in the extreme!  The burden of housing obligations for the entire city would be borne entirely by 25% of the current residents.  As the western region of the city is also the least diverse in terms of race and income, the proposed development plans will maintain and possibly worsen Belmont’s moderately segregated housing pattern.

The claim that all development needs to be in the east because “that’s where transit is located” is specious.  The only true east/west Belmont difference in transit accessibility is distance from the CalTrain station.  SamTrans bus service is available on the Ralston and Alameda de las Pulgas corridors, including Cipriani Blvd, Carlmont Dr, Village Dr, Lyall Way, Continentals Way and others.  These routes easily link western Belmont to the train and to the ECR corridor; and anyhow, if needed, bus routes can be updated to serve new development in the west.  The popularity of the existing multi-family units along the listed streets shows that dense residential units in the western part of the city would be just as desirable, if not more so, as in the eastern corridor.

Concern 3: Insufficient provision for parks and recreation and schools.

The City of Belmont has a standard of 5 acres of parkland per 1,000 residents, divided into 3 acres of larger community parks and 2 acres of neighborhood parks.  Alexander Park and O’Donnell Park are currently the only neighborhood parks in the area east of ECR, and our community park is Twin Pines.  So with a projected addition of 8100 residents in this area, we would need 16.2 additional acres of local parks!  The land for these parks needs to be identified now, preserved from development, and possibly purchased by the City.  Clearly, this will not be easy -- so where is the effort, where are the plans and the funding to do this?  The Draft Housing Element addresses the need for infrastructure upgrades in the east like water and sewer pipes, yet it is silent on parks.  This is a major oversight.  If we add 8100 more residents without new park space, we will fail to meet our own city standards, the quality of life in the eastern area will be reduced, and new development will be significantly less attractive to new residents, thus lowering property values.

In addition, there is a clear need for additional school capacity.  Sadly, the VSP mentions putting additional school buildings on the existing campuses, which would increase crowding and reduce opportunities for physical activity for students.  It would also further reduce the recreational facilities (e.g. sports fields and playgrounds) for residents in the area who access the school grounds under the shared use approach.  Using the VSP rate of 0.2 additional K-8 students per residential unit, the current Draft Housing Element would result in 3300 * 0.2 = 660 more students!  Adding hundreds more children and new buildings to Nesbit, Central, and Ralston Middle School is not an acceptable approach, and work with the Belmont-Redwood Shores School District on alternative plans needs to begin now.

Concern 4: Lack of planned upgrades to roads and intersections to handle increased traffic

Unfortunately, the Sterling Downs neighborhood has only 3 roadway exits for thousands of residents: OCR to the north (into San Mateo), OCR at Ralston, and Hiller at Ralston.  We already experience heavy traffic congestion at peak times, including lines of cars that can stretch from the light at Laurie Meadows all the way south to Mountain View Avenue.  When the Hiller/Ralston/Masonic backup merges with the drop-off & pickup traffic at Nesbit School, the resulting tangle can add 15-20 minutes for residents just trying to get out of our neighborhood, and can prevent some residents from even pulling out of their driveways.  Adding thousands of residents along Masonic Avenue and along OCR between Ralston and Laurie Meadows will be a disaster for traffic in our area.

Although improvements to the Masonic/OCR intersection are now planned, neither the Village Specific Plan nor the Draft Housing Element contain any mention of improvement to the Hiller / Masonic / Ralston intersection, nor any discussion of working with the City of San Mateo to find solutions for the traffic backups at 42nd St/OCR/Laurie Meadows.  We cannot create housing development plans without also putting into place plans and funding for associated road and intersection upgrades.

Concern 5: Degradation of aesthetics and property enjoyment for current residents of Sterling Downs and Homeview

The proposed new maximum height limit of 65 feet will allow 6 story buildings to be constructed in the Sterling Downs and Homeview neighborhoods, which are almost exclusively 1 and 2 story buildings at this time.  This huge change would alter the character of the neighborhoods dramatically, and impact not just abutting lots but all nearby residents.  Such tall buildings will block sunlight needed for gardening and rooftop solar panels, and contribute directly to nighttime light and noise pollution.  It will also eliminate privacy, as residents in the top of a 6-story building will be able to see into practically every backyard in the area!

One of the most serious impacts of this zoning height and density change would be to the planned redevelopment at 580 Masonic Way.  This parcel is bounded by Masonic, Hiller, Wessex and Granada, all narrow local streets.  This means that 2 of the 4 lot edges are directly across from and quite close to single-story single family homes, and a 3rd edge of the lot is directly across from small detached 2-story apartment buildings.  Constructing a monolithic 65-foot building in this area will be a shocking disruption, completely out of character for the neighborhood.  Unlike the buffer provided by High Density Residential districts that border other Village Station Core and CMU lots, 580 Masonic directly borders single family residential, providing no transition zone whatsoever.  This lot simply must not be developed to 65 feet in height and with increased density.

Concern 6: Increase in noise and air pollution

Almost the entire eastern area of Belmont is already exceeds the City’s own standard (<65 dB) for outdoor noise pollution, as acknowledged in the VSP.  Adding 8100 new residents and the associated auto and truck traffic will clearly worsen this noise pollution, as well as the particulate matter associated with engine exhaust.  Although an increase in air pollution is mentioned in the draft CEQA (as summarized in the staff presentation), no mitigation is offered; and the only mention of noise pollution is construction noise.  The City and the Planning Commission need to acknowledge the significant and sustained increase in both noise and air pollution that will result from this Draft Housing Element plan, and add additional approaches to reduce and mitigate these pollutants.

Given these major deficiencies and inequities with the current Draft Housing Element, what steps can the Planning Commission and City Council take to address these concerns?  I have the following suggestions:

1. Reject the proposed changes to the Zoning Ordinances.

Do not increase maximum height and density in the VSC and CMU districts.  Keep the existing zone maximums, and encourage developers to provide substantial community benefits that will qualify them for increased height and density.

2. Rebalance the burden of additional housing and development more fairly across all of Belmont.

Eliminate the planning assumption that Housing Opportunity Sites must not be current residential sites.  While it is true that redeveloping existing housing for higher density does not result in the same net gain of units as putting housing where there was none before, the densification of existing housing stock will be required, if any population increase is to be added west of the ECR corridor.  This wider and more equitable geographic spread of development is necessary for both fairness and to keep all districts within Belmont vibrant and desirable places to live, while still achieving our RHNA-6 targets.  Specifically, the city could:

·       Re-zone the Service Commercial district at 1111-1205 Alameda de las Pulgas to Mixed Use and designate it as a Housing Opportunity Site, thus treating this area equitably with the Mixed Use districts in the eastern part of the city

·       Identify R-4 districts that could be appropriately re-zoned as High Density Residential, and encourage future redevelopment with increased density

·       Identify R-3 districts that could be up-zoned to R-4 to allow for increased density in future redevelopment projects

·       Update zoning ordinances to allow and encourage ADUs and duplexes in areas of single family homes, where lot sizes allow

·       Identify Planned Unit Development (PD) areas throughout the western part of the city with low Assessed Value (AV) ratios that can be designated as Housing Opportunity Sites, and work with the plan owners to develop appropriate High Density Residential or Mixed Use development plans for their lots, and/or change the zoning designation of these lots to encourage development

3. Invest planning and resources towards new parks, new school capacity, and road and intersection upgrades in the eastern district of Belmont

·       16 acres of new park land needs to be identified, preserved from development, and then turned into fun and safe public recreational space for residents in eastern Belmont

·       The City should work with the BRSSD now to develop new enrollment projections and identify solutions for our schools that do not unfairly burden Nesbit, Central, and Ralston MS with hundreds of new students, nor force the addition of new buildings to these campuses.

·       Traffic studies need to be conducted and plans put in place for mitigating congestion at Hiller/Masonic/Ralston, and OCR/Laurie Meadows / 42nd St.

In Conclusion

I understand that the majority of new development will occur in the eastern part of the city and that this development will include multistory residential and commercial/residential mixed use buildings.  Indeed, I welcome this development, as appropriate infill densification is by far the most environmentally friendly approach we can take.  But this development must be done with proper zoning controls in place; with maintaining incentives that encourage public benefits such as Affordable Housing; with forward-looking planning and investments that mitigate the impacts to traffic, pollution, and increased demand on parks and schools; and with more equitable distribution of development across the city.

The current Draft Housing Element is not acceptable to my husband and me, nor to many of our neighbors in Sterling Downs and Homeview.  We hope the Planning Commission, City Council, and staff will take these concerns seriously and make appropriate changes to the Draft Housing Element.

Thank you for your consideration.