Re: Agenda item 5.1
Dear Chair Gutierrez and Commissioners,
Mountain View YIMBY strongly supports efforts to update the R3 Zoning District. We appreciate Staff’s extensive work to transition toward objective, form-based standards. This update is a critical step in fulfilling the Housing Element’s commitment to ensuring multifamily projects are economically feasible and can achieve their allowed densities. To ensure these new standards successfully encourage diverse housing types—particularly on smaller parcels—we respectfully submit the following recommendations:
Rely on Standards Other than Density Limits
We recommend removing maximum density limits (dwelling units per acre), instead relying on use-neutral standards like FAR, height, and setbacks. The City has various Precise Plans (El Camino Real, San Antonio, etc.) using FAR rather than du/ac. This is clear precedent for this approach, and extending it to the R3 district would align with the goal of creating a form-based code, addressing the physical size of projects.
Increase FAR in R3-B
The most recent condo projects in R3 (1919-1933 Gamel, 918 Rich, 1057-1061 El Monte) all used the state density bonus to bring FAR up to ~1.5 (1.64, 1.41, 1.48 respectively). This indicates the R3-B FAR should be at least 1.5 in order to facilitate stacked flats rather than townhomes.
Replace the Lot Consolidation “Incentive”
We strongly oppose the proposal to “incentivize” lot consolidation by functionally demoting small lots in R3-D to R3-C. Small parcels already face the hardest path to financial feasibility. Artificially capping their density is not an incentive, instead adding unnecessary complexity.
Instead, the City should look to examples from Concord, Martinez, Brea, and Saratoga that facilitate consolidation through positive incentives. We recommend waiving fees and expediting the Lot Line Adjustment process, as well as qualifying projects for the draft exemptions in Section 36.10.80. This reduces the administrative burden of merging lots and provides a meaningful “carrot” rather than a punitive “stick.”
Reduce Front Setbacks
The proposed setbacks, particularly the 20-foot front setback for R3-A, are out of step with the walkable, urban neighborhoods Mountain View aims to create. Given that the new standards encourage parking to be located at the rear of the property, a deep front setback serves no functional purpose other than to push buildings away from the sidewalk and waste valuable land.
We recommend reducing front setbacks to 4-5 feet, aligning with pedestrian-friendly neighborhood design and providing greater flexibility. This should include reducing front setbacks to any required pedestrian/bicycle easements. Additionally, we support allowing upper-story architectural features like bay windows and balconies to project into these setbacks to create visual interest and break up massing naturally, rather than just exempting building entryways.
We also see an opportunity to encourage arcades to improve the pedestrian experience; they should either be exempt from setbacks or explicitly added to the “Building Entry Types” list.
Replace “Massing Breaks” with Better Design Tools
We are concerned that the prescriptive “massing break” requirements in the proposed Division 16 may result in more-expensive, less-attractive buildings. Mandating arbitrary separations often leads to convoluted floor plans, increased construction costs, and significant waterproofing risks, without necessarily improving aesthetics. This also seems to add greater work on staff to ensure compliance, at a time when review timelines are shrinking significantly.
We recommend replacing this requirement with standards that encourage ornamentation and articulation. Features such as bay windows, balconies, and porches naturally break up a building’s massing without reducing its functional floor area or creating structural complexity. It also better addresses what the community thinks of as building design.
If massing break requirements are maintained, they should be satisfiable by projections. The code should allow massing breaks to be achieved by elements that project into the setbacks rather than cutting into the building envelope, ensuring design requirements do not penalize the project’s feasibility or density.
Allow Retail Everywhere
The current draft restricts ground-floor retail to the R3-D subzone. We believe this restriction is unnecessary. Although mixed-use may not pencil out on every R3 site currently, the zoning code should not prohibit it outright.
We recognize staff’s concern that it may conflict with the goal of encouraging more housing. However, we believe that the city should be ensuring that future residents’ needs are met, which includes proximity to amenities. Otherwise, we risk perpetuating the transportation issues inherent in our current segmentation between residential and commercial areas.
Allow Height Exceptions
We believe that, given Council desires for heritage tree preservation and open space, projects are encouraged to use less of their lot. To compensate for this loss of development capacity, the exception list in Table 36.10.80.A should be updated to explicitly include height. Currently, height is excluded from the standards eligible for exceptions.
Grant Exceptions for Community Benefits
We support expanding exception applicability from just addressing physical compatibility to also cover projects that go over and beyond in providing significant community benefits, akin to Bonus FAR programs already included in various Precise Plans. This is intended not to replace the state density bonus law, as was previously framed for a past Council decision, but it is a nudge for developers who are willing to closely follow the city’s procedures and desires.
Thank you for your consideration.
David Watson on behalf of Mountain View YIMBY