Menlo Park’s Housing Element Explained

What’s the Housing Element?

The Housing Element is part of Menlo Park’s General Plan. It explains how the city will accommodate its state-mandated Regional Housing Needs Allocation (RHNA).

During the current 8-year cycle (2023–2031), Menlo Park must issue building permits for roughly 3,000 new housing units by 2031, segmented by income level.

The Housing Element is hundreds of pages long, but 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, with rezoning to allow greater 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.

How’s Our Progress?

Menlo Park’s 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 that Menlo Park is ahead of most California cities so far.

But the city still has 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).

How Will Very Low-Income Housing Be Provided?

To meet the requirements for very low-income housing, the Housing Element calls for 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 will 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.

Specifically, Menlo Park included all eight downtown parking lots. None of the other 35 city-owned parcels were included.

Why the Downtown Parking Lots?

From the Housing Element itself:

This is an opportunity for Menlo Park to leverage the value of City-owned land in the downtown core, providing affordable housing as well as increasing the vibrancy of downtown. (p. 7-30)

Program H4.G describes the City-led process to promote housing development on underutilized City-owned parking lots in downtown … acknowledging that further study is required to get housing built while working around existing constraints. (p. 7-32)

The value of the land as a residential use and the opportunity for new affordable housing downtown provides a public benefit that exceeds the value as surface parking facilities. (p. 7-33)

(emphasis added)

Notably, city leaders framed the repurposing of the parking lots not as an obligation, but as an opportunity.

Watch Mayor Drew Combs - the only councilmember who voted against ratifying the Housing Element - explain what happened.

What Happens if the Parking Lot Plan is Removed?

Watch City Attorney Nira Doherty answer that question.

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 do it by re-prioritizing or up-zoning other sites already in the plan.

However, if that is not sufficient, the City could add new Opportunity Sites to replace the lost capacity.

That’s where alternative sites come in. Menlo Park has better options. We’ve prepared a list of realistic alternatives that would protect the downtown while still meeting the city’s housing obligations.

👉 [See the proposed alternative sites here]