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Housing Element Draft 2 Site Capacity Adendum

Executive Summary

On July 14th, 2022, Mountain View YIMBY provided the City with a data-driven analysis of site capacity assumptions in Draft 1. The letter in front of you replicates our previous methodology to update our findings for Draft 2, which likewise fails to justify its capacity assumptions. Our main results are presented in Table 1, and the key takeaways are:

  1. Despite HCD’s review letter1 reminding the City that it “must demonstrate [pending] units are expected to be constructed during the planning period,” Draft 2 shares Draft 1’s unjustified assumption that 100% of pipeline projects will be built by 2031, when data shows a third of pending units fail to be built in 8 years.

  2. Draft 2 now asserts the City’s pipeline alone exceeds Mountain View’s total unit requirement for RHNA6. This makes Mountain View an outlier across the entire state, surpassing even Alhambra.

  3. After correcting for the City’s inflated pipeline claims, the City accommodates most low income housing on non-vacant sites, triggering AB 1397’s threshold for substantial evidence that existing uses pose no impediment to redevelopment.

  4. The City assumes, without evidence, that development rates will triple in East Whisman and double across North Bayshore and El Camino.

  5. To maintain its No Net Loss buffer, the City should rezone for 6,299 additional units.

The City’s pipeline claims unequivocally violate housing element law. Our prior analysis showed that the City’s pipeline claims were inflated. HCD’s review letter called out the same issue. Nevertheless, the City retains these far-fetched assertions. This is not an accident but rather an attempt by the City to “reduc[e its] responsibility… to identify, by income category, the total number of sites for residential development as required,” flouting §65583.1(a). It’s furthermore an attempt by the City to excuse itself from complying with AB 1397’s substantial evidence threshold, which would otherwise constrain the City from listing highly-trafficked big box stores in its site inventory. And it’s finally an attempt by the City to excuse itself from complying with Least Cost Zoning Law, which mandates zoning for enough “land for residential use with appropriate standards… to meet housing needs for all income categories,” per §65913.1(a). Every fake unit of pipeline capacity is exactly one unit of its RHNA that the City, by unlawful fiat, writes out of existence.

Main Results

Table 1. Site Capacity Analysis Breakdown

This table presents our main results comparing Draft 2 claims with our data-driven analysis.

Draft 2 Claims MV YIMBY Analysis Difference
Approved Projects LI Units 509 423 -86
All Units 3,942 3,251 -691
Pending Projects LI Units 1,992 1,324 -668
All Units 7,476 4,969 -2,507
Developable Sites LI Units 3,127 1,606 -1,521
All Units 6,265 3,201 -3,064
ADUs LI Units 48 30 -18
All Units 96 59 -37
Total LI Units 5,676 3,383 -2,293
All Units 17,779 11,480 -6,299

Our methodology is explained at length in the Appendix of our July letter (see here). As a refresher, our downward adjustment for pending projects is, as HCD suggested in its September review letter, the “City’s past completion rates on pipeline projects” within eight years. Our analysis for ADUs is simply HCD’s safe harbor formula. Our analysis for developable sites is based on HCD’s Site Inventory Guidebook’s recommendation of looking at “past production trends” that are “based on the rate at which similar parcels were developed during the previous planning period.”2


Additional Notes on the Pipeline

Approved Projects

The following projects are on record as being stalled or abandoned:

  1. 1919 Gamel Way
  2. 870 E. El Camino Real
  3. 400 Logue Avenue

Accordingly, our analysis for approved projects does not credit the City for these projects.

North Bayshore Master Plan

Many of the City’s errors regarding North Bayshore have not been corrected since Draft 1:

  1. Per Table 60 of Draft 2,3 Phase 2 BMR land dedication will occur in 2029. City staff also say BMR housing takes two years to get built - that is, 2031. Even absent delay, Phase 2 BMR housing almost surely won’t be built in RHNA6.

  2. Delays are foreseeable. In our July 13th letter to HCD, we identified seven major potential sources of delay or derailment for the North Bayshore Master Plan, and the City has not added programs to curtail these concerns.

  3. The City fails to adequately respond to HCD’s review letter.

    1. HCD’s review letter said** the North Bayshore Master Plan parcels must be listed as sites, not pending projects,** if the estimated capacity is merely “anticipated capacity from yet to be proposed projects that will require subsequent approvals.” The City’s response on page 304 of Draft 2 was simply to call the master plan a project. This is beyond non-responsive. We remind HCD of the facts:

      1. There is no approved Development Agreement. The City’s position is that Google has pending projects under a DA that does not exist. This is nonsensical.

      2. Google is on record saying they are not designing or planning housing projects until after office is decanted and demolished.4

      3. There are no permit applications for the parcels in the North Bayshore Master Plan, and there is no question that future planned community permits will require “subsequent approvals,” as HCD puts it. City staff has explicitly said the Zoning Administrator’s approval for future permits will be required.

      4. **A pending land dedication is not a pending project. **There are no RFPs or plans for Phase 1 (2026) or Phase 2 (2029) land dedications. The City does not know who will build these projects, what the projects will look like, or where the funding will come from.

      5. The City’s submission for Table A cannot even allot units to parcels in the North Bayshore Master Plan - this is for the glaringly obvious reason_ _that there aren’t projects proposed for each parcel.

      For the above five reasons, the City must designate the North Bayshore Master Plan sites as opportunity sites, not as pending projects, per HCD’s review letter.

    2. HCD’s review letter stated, “given the element’s reliance on pipeline projects, the element must include programs with actions that commit to facilitating development and monitoring approvals of the projects.” 6. The suggested programs have not been added, and the North Bayshore Master Plan still faces foreseeable delays. We encourage HCD to review our public comment from July, as it further explains the complexities and foreseeable delays facing the North Bayshore Master Plan that remain unanalyzed in Draft 2.

Opportunity Sites Analysis

Table 2. Historical Record vs City’s RHNA6 Assumptions, Broken Down by Precise Plan.
Projects per Year (Historical) Projects per Year

(City Claims for RHNA6)

East Whisman 0.67 1.88 181%
El Camino 3.13 6.50 108%
North Bayshore 0.40 0.88 119%
San Antonio 0.88 1.13 29%

To create Table 2, Mountain View YIMBY analyzed all relevant annual progress reports to calculate how many projects have been built per year in each precise plan since each precise plan was implemented. We compare these to the City’s projections and note that, on average, the City assumes, without evidence, that development rates will double.

Table 3. Developable Sites, by Precise Plan.

City Claims, Draft 2 MV YIMBY Analysis Difference
Downtown LI Units 0 0 0
All Units 6 6 0
East Whisman LI Units 997 354 -643
All Units 1,312 466 -846
El Camino LI Units 1,127 542 -585
All Units 1,905 916 -989
Grant - Phyllis LI Units 201 201 0
All Units 322 322 0
North Bayshore LI Units 463 212 -251
All Units 2,137 977 -1160
San Antonio LI Units 191 149 -42
All Units 310 241 -69
Not in Precise Plan LI Units 148 148 0
All Units 273 273 0
Total LI Units 3,127 1,606 -1,521
All Units 6,265 3,201 -3,064

As with Table 2, Mountain View YIMBY analyzed all relevant annual progress reports to calculate how many projects have been built per year in each precise plan since each precise plan was implemented. We then adjusted the City’s estimates to account for historical development trends and report the delta in the final column. This methodology is further explained at length in the Appendix of our July letter (see here).

Additional Notes on Opportunity Sites

Opportunity sites have been selected in bad faith:

  1. The City knowingly excludes sites with demonstrated interest in redevelopment and knowingly includes sites with demonstrated lack of interest in redevelopment.

    1. Despite demonstrated interest from builders, the City excludes 901 North Rengstorff (“Ambra project”) and Castro Commons from the inventory to retain the discretion to deny housing from being built.
    2. Despite demonstrated lack of interest from landowners, the City refuses to exclude 384 San Antonio, 2633 California, and 1288 El Camino Real from the inventory. This error has been identified repeatedly in prior public comments.5
  2. Since the initial inventory was released, the main improvements have come from members of the public reaching out to landowners of large parcels. This led to Target, Lozano Car Wash, U-Haul, CSA, and El Camino Hospital’s properties being removed from the inventory. That unpaid volunteers are the primary reason the inventory has improved since Draft 1 is evidence that the City’s effort to ameliorate the site inventory has been inattentive and perfunctory.

  3. The City claims 1,732 units from 1500 North Shoreline, even though no project of this size has ever been built before in Mountain View without multi-decade phasing or a DA. The City simply omits this analysis hoping that HCD will not notice.

  4. The City lists densities around or below 40 du/acre for religious institutions. Affordable housing does not get built at this density in Mountain View. The City should zone for at least 60 du/acre, which at least has historical precedent.


  1. https://siliconvalleyathome.org/wp-content/uploads/2022/10/SclMountainViewDraftOut092922.pdf ↩︎

  2. Page 20 of https://www.hcd.ca.gov/community-development/housing-element/docs/sites_inventory_memo_final06102020.pdf ↩︎

  3. See page 307 of Draft 2. ↩︎

  4. At the December 14th, 2021 city council meeting, Andrew Chapple with Google explained that their housing projects will only be proposed after office is decanted and demolished. When asked to explain the timeline to build housing in North Bayshore, Chapple explains, “The action required, of course, first of all is decanting existing Google office buildings where they have existing operations. That’s quite a process. Then, of course, after we manage to do that, we have to demolish that area and make way for housing. Then we embark on the housing process, the planning and designing process, and that can take a year plus.” See 4:35:45 of the council meeting here: https://www.youtube.com/watch?v=yWg_RrVOGWQ ↩︎

  5. See https://mvyimby.com/post/2022-07-13-site-capacity-addendum/ and page 6 of our March public comment here: https://mountainview.legistar.com/View.ashx?M=AO&ID=115391&GUID=cfb7c739-4b47-4253-a679-c87c85bb75ce&N=SXRlbSA2LjEgQ29ycmVzcG9uZGVuY2UgQmF0Y2ggMy5wZGY%3d ↩︎