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Menlo Park’s third version of its housing element shows improvement, but it’s not there yet, according to the latest rejection letter from the California Department of Housing and Community Development (HCD) dated Aug. 29.
The housing element update is a state-mandated process that occurs once every eight years — and this time, the state is strongly enforcing the regulations. California requires cities to plan for future development with an eye toward balancing jobs and housing. Menlo Park’s housing target, also known as the Regional Housing Needs Allocation (RHNA), says the city must plan for close to 3,800 net new housing units by 2031, and show how it will accomplish it in a document known as a housing element.
Menlo Park first submitted its housing element to the HCD over a year ago, in July 2022, but state housing officials didn’t accept it and sent it back for revisions. A second attempt was shot down by the state in April. The third and most recent iteration of the housing element was submitted in June.
Among the issues that the state took with Menlo Park’s latest housing element version was a lack of displacement protections for residents and unequal housing opportunities on the east and west sides of the city.
The Belle Haven neighborhood on the east side of Menlo Park has historically faced institutionalized injustice that still affects the city’s layout, including racist redlining in the 1930s and blockbusting in the 1950s and ’60s.
Council member Drew Combs was the one holdout in the 4-1 vote that approved submitting the second version of the housing element to the state in January. Combs said that he believed the city could do more to spread affordable housing projects throughout the city, rather than concentrating them in Belle Haven.
There is certainly a disparity in where council members know affordable housing will be built, Combs said. “I thought there was an ability for council to address that better than they did. Does that mean that I agree with the stance that HCD is taking? I would say I do not.”
Many of the HCD’s complaints center around a lack of analysis of development sites and programs. Combs said he was mystified by the generic language in the HCD’s letter, adding that the city had reached out to the department in the weeks prior to submitting the latest housing element to get guidance.
“I’m still left a little perplexed about what the city can actually do to receive the approval,” Combs said.



