Primer:
Understanding Menlo Park’s Housing Element

During the current 8-year cycle (2023–2031), Menlo Park must issue permits for an additional ~3,000 housing units, segmented by income level, in order to meet its state-mandated Regional Housing Needs Allocation (RHNA).

The Housing Element is a state-required part of Menlo Park’s General Plan that explains how the city will accommodate its share of the region’s housing need. While the document is hundreds of pages long, at its core it’s a plan built around:

  • 8 Pipeline Projects – developments already in progress

  • 72 Opportunity Sites – parcels the city believes are suitable for residential development, if incentivized by zoning changes that increase density

Together, these sites provide enough capacity to meet Menlo Park’s RHNA targets, plus a 30% buffer to ensure it remains viable even if some sites do not develop as expected.

Menlo Park’s most recent Annual Progress Report (March 2025) showed strong early progress toward meeting its RHNA goals. In fact, Menlo Park was one of only 47 municipalities (out of 482 statewide) that were not subjected to SB 423’s streamlined ministerial approval process — a sign of above-average performance to date.

But the city still faces a long road ahead, especially in meeting RHNA’s most challenging requirement: 740 units for very low-income households (those earning less than 50% of the Area Median Income). To meet that target, the City intends to use both private and city-owned land.

🏢 1. On Private Land

Menlo Park’s inclusionary zoning ordinance requires most large-scale housing developments to provide:

  • At least 15% of total units as Below Market Rate (BMR)

  • Of those BMR units, at least 40% must be for very low-income households

Through this policy, private developments can contribute a significant number of very low-income units.

🏛️ 2. On Public (City-Owned) Land

Menlo Park also plans to contribute city-owned land for affordable housing. Under state law, a city can declare its land to be “surplus” and lease it to a nonprofit affordable housing developer — often at $1/year — to build deeply affordable housing.

In its Housing Element, Menlo Park included eight downtown parking lots as Opportunity Sites to help meet very low-income RHNA targets.

🧩 What Happens If Those Parking Lots Are Removed?

If the city removes the downtown parking lots from the Housing Element, it must demonstrate to HCD that it can still meet its RHNA obligations. With the plan’s 30% buffer, it may be possible to re-prioritize or up-zone other sites already in the plan. However, if that is not sufficient, the city will need to add new Opportunity Sites to replace the lost capacity.

That’s where alternative sites come in. We’ve prepared a list of realistic alternatives that could be used in place of the downtown parking lots — without sacrificing the city’s housing obligations or putting its Housing Element at risk.

👉 [See the proposed alternative sites here]