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About this blog: I grew up in Los Angeles and moved to the area in 1963 when I started graduate school at Stanford. Nancy and I were married in 1977 and we lived for nearly 30 years in the Duveneck school area. Our children went to Paly. We moved ...  (More)

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Is the Office Cap a "Blunt Instrument"

Uploaded: Jun 16, 2015

Last night the city council took another step toward designing an interim office space metering plan. There was a spirited discussion in the public comments and council discussion as to whether the cap is a "blunt instrument".

I think the answer is mostly yes since growth will continue under the plan including exemptions to the annual cap and much external growth. More about this later.

But as Councilmember Burt argued, the answer is partly no mostly as a result of some pleasant cooperation among council members in remembering important concepts like making an impact on existing housing shortages and traffic and fairness to applicants who are already well down the path to project approval.

With unanimous support the council accepted staff's recommendation to exempt projects with very small increases in square footage. With leadership from Council members Scharff and Kniss, the council exempted medical office projects under 5,000 square feet.

After Council member Scharff stressed the importance of fairness to applicants who had put time and resources into applications that are already complete, the council reached a compromise to exempt some projects and give others some priority in deciding which new projects are accepted under the cap.

But it was Council member Wolbach who made the most innovative and most discussed proposals to focus the office cap design on what we want—more housing, better design and mitigation of traffic and parking impacts. And it is the progress on these issues that supports Council member Burt's reminder that the council was working to soften any bluntness in the cap.

Wolbach had two compelling (at least to me) suggestions.

The first was since it is impacts we are concerned about, that projects that address impacts such as the housing shortage and traffic/parking and successfully improve these situations should be applauded and exempt from any cap because they address and not increase the problems that residents are concerned with.

During this part of the discussion Council members Filseth and Schmid also made suggestions with regard to measuring progress on addressing housing and in the end Council member Burt was persuaded that Wolbach;s mitigation proposal would actually address impacts even beyond those caused by a new project and help offset the impacts of existing projects.

Wolbach's second proposal found a vigorous discussion, seemed close to approval many times and ultimately was referred to the Planning and Transportation Commission. This proposal was to encourage developer and community cooperation in design of specific area plans and to exempt from the cap projects that were developed as a result of these processes. The other potential benefit is that decisions would reflect the participation of people in the directly affected plan areas such as the Cal Ave area.

So my thanks to Wolbach and to the positive response his proposals are getting.

They focus us on what I heard at the summit and what the public comments were last night.

We have a housing shortage that affects many groups. We have traffic and parking challenges that can only be addressed by having more housing and having active plans to mitigate, manage and reduce future car traffic and related parking. Slowing future office growth can only be a very small part of addressing traffic and parking (does not address existing problems) and may actually hinder the options for more housing.

But we will have an interim cap and last night's discussion brings hope to me that our council recognizes that the real problems people want addressed are housing and the impacts of past and future growth.
What is it worth to you?


Posted by Dan, a resident of Midtown,
on Jun 16, 2015 at 2:59 pm

"This proposal was to encourage developer and community cooperation in design of specific area plans and to exempt from the cap projects that were developed as a result of these processes."

Isn't this just PC zoning under a new guise ? Sounds like a backdoor mechanism for developers to continue driving the bus... where the developer can re-arrange the deck chairs to get his band playing while the ship is sinking. We have seen how this works in practice already under PC zoning. The developers have no inherent interest in looking at the larger citywide infrastructure, quality of life, cost impacts. I agree that there is a need for some flexibility, but success of this would lie entirely at the feet of having a very skeptical planning commission and city council that is inclined to say "no" most of the time. It is a lot easier to say "yes" than to take the often correct but harder stance of saying "no".

As far as the first suggestion goes ... I doubt many projects that are focussed on developing office space are going to improve net housing relative to jobs. This would just seem to add incentive to take projects that are housing projects and stuff in some office space rather than taking office developments and having the developer decide to add housing greater than the office space density.

I'm shocked that Wolbach's ideas are appealing to Steve... sarcasm.

Posted by area plans, a resident of Greenmeadow,
on Jun 16, 2015 at 3:30 pm

Area plans have nothing to do with PC zoning.

Area plans/master plans/specific plans happen like this: the City Council decides that a certain area within the city could use special planning that focuses just on that area. The city then forms community groups or subcommittees that look at that area parcel by parcel and zone each appropriately in order to accomplish that community's vision for that area. This is a multi-meeting process that generally lasts longer than one year and is careful to include many different kinds of community stakeholders. Only after such area plan is completed do any developers come into the picture. They will likely only develop a specific parcel in that area, not the entire area since parcels come on the market whenever they come onto the market. So, it may take a long time for that entire area to be rebuilt into the community's vision. But the vision is what guides forward-looking development. The area south of Forest was planned this way. So was Sunnyvale's and Mountain View's downtown. It allows for communities to do exactly what Mayor Holman has advocated for repeatedly - zone for what you want.

PC zoning is limited to one specific parcel. A developer finds a parcel, makes a design for that parcel, and then submits that design for approval as a PC zone. It doesn't involve a community vision and doesn't involve community input prior to the creation of a design. The community input comes after the design is submitted for review.

To say that today's council can and should hamstring communities that come together to decide for themselves what they want to live next to today and many many years down the line...that strikes me as a poor use of Council's time and is saying that 9 random people should have more say than the people who actually live there. Isn't this community all about "Residents first"?

Posted by Downtown Worker, a resident of Menlo Park,
on Jun 16, 2015 at 4:42 pm

Area plans also look good when compared to PA's other planning tactic: the referendum. If all you have is an up or down vote, it's easy to reject a project because every project has flaws. If, on the other hand, you get to participate in crafting not just a project, but a whole plan for your own neighborhood, you can work through those flaws in conjunction with the rest of the community and come out with something you can live with.

If you believe in stopping all growth, Area Plans don't help. But many residentialists have argued instead for channeling growth and moderating impacts - exactly what Area Plans do.

I was very skeptical of the office cap when first proposed. But the form it's taking seems to be about moderating growth in _unplanned_ areas while focusing growth in areas with a strong community plan. I think that was Pat Burt's intent in exempting SRP. This actually seems like it is evolving into a reasonable policy that all sides should be able to live with. (Though it pains me to say it!)

Posted by It's Msgic , a resident of Downtown North,
on Jun 16, 2015 at 10:02 pm

Whenever I hear development advocates say
"We have traffic and parking challenges that can only be addressed by having more housing and having active plans to mitigate"
what comes to mind is a magician on stage making things disappear.
I guess if they keep repeating it, some people will believe it. Or pretend they do.

Posted by Norman Beamer, a resident of Crescent Park,
on Jun 17, 2015 at 7:59 am

Given that the jobs to housing ratio for the city is one of the highest in the state, if not the country, how is that an office cap is a blunt instrument? We don't need a single new office. We have enough offices to last our lifetimes. So any new office development under the "Wolbach" program had better be pretty stunningly generous to make any sense -- I doubt if any developer interested in making a profit could come up with something that generous.

Posted by Happy Palo Altan, a resident of Midtown,
on Jun 17, 2015 at 3:20 pm

@Norman: absolutely. It sounds like you and Wolbach are on the same page. Wolbach himself said it was a high bar, but appropriate, given our traffic and housing problems.

Posted by stephen levy, a resident of University South,
on Jun 18, 2015 at 10:58 am

stephen levy is a registered user.


The traffic and parking concerns of residents have three major causes. One, by far the largest contributor is the existing population, jobs and visitors. The office cap does nothing to address these impacts.

The much smaller but second largest contributor is the growth that will continue under any cap, the growth in residents, visitors, job growth allowed in the cap and the larger job growth at Stanford land uses and areas outside the cap. The office cap does nothing to address these impacts.

The tiniest contributor would have been the extra job growth (speculative) that the cap prohibits.

If the concerns are about traffic and parking, any policy that addresses less than 1% of the impacts is a blunt instrument compared to policies the reduce car use and manage parking better.

When I see residents and the council fully support and fund proposals to deal with the impacts of existing and future growth, I will know we have entered a period of serious deliberation in Palo Alto and not just spending time dealing with a tiny portion of the challenges.

I do foresee such a time and am optimistic that parking and traffic can be successfully addressed if we keep our eye on the big payoff policies.

In this regard self mitigating projects or those that mitigate and mitigate additional impacts are a good "high bar" policy and I thank Cory Wolbach and the council for adopting this as part of the office metering plan.

Posted by stephen levy, a resident of University South,
on Jun 18, 2015 at 11:04 am

stephen levy is a registered user.

@ its magic

Not at all.

first housing and office are two separate issues to me.

The region needs more housing and Palo Alto can, should and is required to play a part. Good location and design criteria can reduce car use from future housing. No magic, just good planning.

In terms of job and visitor growth, look at my previous comment.

If we do not address the heart of the concerns, those parts that come from the 99+% not covered by the office metering plan, we will not succeed. That 99+% deserves our full attention and funding.

Models developed under Wolbach's two proposals will be helpful in addressing broader traffic and parking concerns and we will also need successful programs from the RPP and TMA.

Posted by mauricio, a resident of Embarcadero Oaks/Leland,
on Jun 18, 2015 at 11:31 am

mauricio is a registered user.

(portion deleted) false statement by poster.

SL: The reason for allowing more housing is that we need more housing and it is the law.

Since Palo Alto, absolutely and positively, does not need even one new office, the enthusiasm of Mr. levy at Wolbach's ideas confirms what I knew all along. They want to create an avalanche of development that will knock down any attempt to slow down growth, resulting in a massive densifying and urbanization of Palo alto. (portion deleted) if you want to make a personal accusation on this blog you need to bring evidence, not the person you accuse.

Posted by david schrom, a resident of Evergreen Park,
on Jun 20, 2015 at 1:29 pm

Portion deleted. SL: David, I believe you know how to disagree in a respectful manner.

The following excerpt from his post is illustrative of how he ignores alternative ways of seeing our situation and fails to accurately assess costs and benefits. (Numbers in parentheses reference my comments below.)

"We have a housing shortage (1) that affects many groups. We have traffic and parking challenges that can only be addressed by having more housing (2) and having active plans to mitigate, manage and reduce future car traffic and related parking. Slowing future office growth can only be a very small part of addressing traffic and parking (does not address existing problems) and may actually hinder the options for more housing.(3)

"But we will have an interim cap and last night's discussion brings hope to me that our council recognizes that the real problems people want addressed are housing and the impacts of past and future growth."(4)

1. Instead of claiming a housing shortage, Steve might observe that we've a commercial surplus--more commercial facilities than are necessary to provide residents with wanted services and opportunities for employment. The so-called "shortage" is, after all, a figment of our imagination without any corresponding material referent. The surplus is here for all to see, real bricks and mortar. [We encourage commercial uses to fund public services, especially schools. Then we act surprised when the owners/builders/occupants of such uses "externalize" costs that dwarf what they contribute to fund public services, leaving the public poorer for the process. The "free lunch" of school funding is anything but free.]

portion deleted SL: David, I believe you know how to comment without put downs.

3. Are we to imagine that the next round of offices will bring housing benefits great enough to offset their other costs. portion deleted. False statement.

I question whether builders/owners/occupants of commercial land uses can remedy this even if all of them become charitable organizations eschewing profit for public service.

4. So if the "real problems" are "impacts of past and future growth," what am I missing in thinking that having zero future growth, and undoing past growth are obvious solutions? If your response is "political reality," I ask that you consider whether natural or human law trumps the other.

Finally, the title of Steve's blog, "Invest or Die," is again an example of failure to understand the cost side of human activity. Portion deleted. SL: David. why don't you read my explanation of the title and respond to what I wrote.

I am a little surprised at your post since the only topic the council did not have large agreement on was whether areas where the community develops their own plan shouklf be exempt from the temporary cap. Do you have a position on the development of area plans by neighbors in an area?

I will explain the housing shortage, which deals with people already here, later. I am at tahoe with my family.

Posted by faux environmentalism, a resident of College Terrace,
on Jun 20, 2015 at 5:51 pm

The #1 contributions of commercial properties is jobs and the paychecks they pay to all of us. That's their contribution to society. They don't make us poorer, they make us richer! Pointing to how much they pay in taxes or whatever is an utter distraction - without jobs this place would be a desolate waste-land of starving people. Without jobs, no one else would be paying any taxes either. Can't pay those property taxes if I don't have a job, now can I? Can't pay any sales taxes or support local retailers if I don't have a job, either. Jobs are the reason why anyone's house in Palo Alto is worth over a $1 M. It's the reason anyone looking to buy a house today chooses to buy one here - don't see anyone wanting to live in Detroit, do you? Don?t see people paying 20-40% over asking price in Gilroy, either. It's the reason our government has the money to deliver the services that it does. Every other place on the entire planet desperately wants a jobs engine like the one that we have because it's the key to a well-managed government, a well-off populace, and healthier, longer living people. It's how you ensure that you will weather the next economic downturn: you have the economic infrastructure in place to make sure you'll be able to keep making jobs for your citizens and then you won't have to worry so much about poverty and crime.

And you can't say "we'll still have jobs- they'll just be in SF" - that's not legitimate because people in SF ALSO say that they don't want more jobs. So you can't be advocating something for yourself that you wouldn't want all the neighboring cities to do, too. Places without jobs are not Atherton (Atherton relies on us having jobs) - they're Detroit. And everyone can't be Atherton. Someone somewhere has to have jobs. And in our case, it?s us.

Everyone else is trying to recreate what we already have and investing billions in their own infrastructure, universities, and small businesses to do it. It's only the self-centered super-wealthy who would even suggest that we should be taking money out of other people's pockets and leave other people without paychecks so that they aren't inconvenienced by the people who actually have to work for a living. This notion that there can even be such a thing as a job surplus is the notion of only those idle rich millionaires and billionaires who don't have to worry about paying the mortgage and apparently have enough money that their kids and grandkids will never have to worry about it either. Parents everywhere should be downright aghast about the notion of taking job opportunities away from the next generation. Most of us want BETTER for our kids, not worse.

The rest of us, we're thrilled to be in a place with lots of jobs. We're thrilled to have many choices so we can pick what suits. We're thrilled to not be stuck in a three company town where real career progression is almost impossible because there's nowhere to go. We're thrilled to be surrounded by other smart ambitious people. We love meeting them, learning from them, going to maker and hacker spaces with them, collaborating with them, sharing new ideas, and building new companies with them. All of that can only happen in a place where there are a large number of talented people who have lots of opportunities to rub shoulders together. It can only happen in a place that is a hub for such things. There's a reason why the beautiful thing that is Silicon Valley can't easily be recreated - because you need a large swell of talented people in one area for something like this to thrive. Jobs that don't get added here don't just get added somewhere else - for the most part they just don't exist. Large companies like Google can create an outpost in North Carolina, but most start-ups start here because if it doesn't work out, it's easy to get another job and it's easy to get bought out by another tech company and it's easy to meet people who might invest in you. That's not going to happen in the middle of nowhere and frankly even large cities like Chicago can't even remotely come close to our levels of job growth. And when we have this amazing thing here which has provided jobs, opportunity, and upward mobility for millions of people from around the world (including YOU) - if CA were a country we'd have the 5th highest GDP in the world - and you're now saying that no one else can come and have access to the amazing opportunities here, well, sir, I call that downright unAmerican. Everything about this country is built around the notion of us opening our doors to immigrants who seek a better life and we all, in turn, benefit from their innovations.

Right now, you have written your response on a laptop invented here, on the internet, posted it to a website, and probably read the website on your phone. Very little of that would have existed if people like you had succeeded in killing off Silicon Valley. And if you proceed and throttle companies like Google that are creating self-driving cars (and also, that have made the entire world's information available at your fingertips!!), Theranos, which is re-inventing medical testing, Tesla which is creating an awesome electric car AND innovating space travel, and god knows how many other amazing companies all working on sustainable technologies, curing diseases, and making our quality of lives better because you don't like not being able to find a parking space as easily as you did 50 years ago....I have to ask, really?? The rest of the world benefits from what we do here in very real ways and even you take for granted all the amazing things that have been created here. Don't like Silicon Valley being a tech hub? Lead the way and drop all your electronic gadgets in the toilet! Every single one of them is wholly or partially patented here. Next time you need a cutting-edge medical treatment at Stanford, be sure to refuse it because certainly half the people that invented it represent "surplus jobs."

And now for your "impacts" argument. Just because something looks green, doesn't actually make it green. In reality, of all the people in this country who have the smallest carbon footprints - those are New Yorkers! Why? Because the greatest source of carbon emissions is cars and almost everyone in NY travels by public transportation. Additionally, they don't have huge lawns to water and their buildings are far more energy efficient because heating and air conditioning don't just escape outside- they heat or cool neighboring apartments. In reality, urban dwellers are the most green dwellers that there are. When people live densely, it means that their infrastructure is smaller. You don't need extra long water pipes and huge road networks to connect everyone. You actually use LESS concrete and asphalt when everyone is close together. And to top it off, when people live densely they leave more land open and untouched. A small but very dense city is WAY better for the environment than a huge swath of low-density land that has been covered over with houses and paved with roads. Any land inhabited by humans at suburban scale means the utter destruction of the wildlife and natural ecosystems in those areas. Suburbs may look green, but you've decimated the natural ecosystem and destroyed the diversity of life that used to be there.

As for your claims that the housing shortage is somehow unreal.... are the homeless encampments all over the valley not real? Are all the families packing in 8 people in a one bedroom not real? Are all 30+ year olds who still live with roommates not real? what about all the college grads who have no choice but to move back in with their parents? Are all the people driving for an hour or more to get to their jobs every day not real? How about all the people that have left CA because they just can't afford the rent here? The housing shortage is very real and stopping office growth doesn't actually alleviate the existing housing shortage.

Every time we say no to housing here in Palo Alto, people don't just go away. Everyone needs a job. They come here for the jobs - many of which don't even exist in significant quantities outside of silicon valley. Try finding a job as a search engine optimizer, a graphic designer, a computational biologist, or a virtualization expert in Kentucky. And if we don't have housing here, they get housing far away and they pollute all the way here on their commutes and it's much more likely that they end up living in a water-guzzling, energy-leaking single family home in Gilroy than a green apartment here in Palo Alto. That's no environmentalism.

Posted by Stephen Levy, a resident of University South,
on Jun 21, 2015 at 9:37 am

Hi David,

The more I thought about your post, the more it puzzled me. You of all people know that events like climate change, sea level,rise and population growth are global phenomena.

So, as the previous poster points out, moving people and jobs around does nothing to mitigate these impacts. And as the previous poster clarifies, the Bay Area and other California urban communities are great places for people and jobs in terms of emission reduction. We have the strongest environmental laws, a strong emission reduction program and great opportunities for reducing car use compared to say Texas or Tracy or most any other place.

I know some posters count a victory if activity moves from Palo Alto to elsewhere but you are smart enough to know that would be a negative for attacking climate change.

If you are arguing that we should throw people out of jobs to reduce emissions, we disagree but somehow I doubt that is what you meant.

There is a large housing shortage. In the Bay Area, we have built 85,000 units less than needed to meet recent population growth. I am not sure what you are proposing to help the people already here with housing access and affordability.

Why would you ask companies and people to move to their second or third choice location if your real concern is global emissions? How does that help?

As far as Invest or Die, the investments I am talking about are in education, transportation, energy efficiency and the like. Are you really against those investments?

Posted by mauricio, a resident of Embarcadero Oaks/Leland,
on Jun 21, 2015 at 12:00 pm

mauricio is a registered user.

There is a large housing shortage in the Bay area because companies insist on hiring more people right here, instead of moving some of their operations to areas that crave jobs, have lots of available land and much lower housing costs. There are cities in the Bay area who welcome more population density and more urban lifestyle. We don't. We will not diminish our quality of life for corporations' sake. What's supposedly good for corporations is bad for us. The solution is no more growth and development and redoing some of the past overdevelopment, not more density and urbanization.

Posted by Stephen Levy, a resident of University South,
on Jun 21, 2015 at 12:14 pm

Hi David,

Look at the above post. Mauricio wants companies and people to move to their,second or third choice location for his personal benefit. He does not seem to care what they want or what is best for reducing global emissions.

Are you sure you still want to treat me as your enemy.

You do remember I think that professionally I support the finding that strict emission reduction measures do not harm the economy.

Looking forward to your continued discussion now that you have had time to look at the last few posts.


Posted by mauricio, a resident of Embarcadero Oaks/Leland,
on Jun 21, 2015 at 1:00 pm

mauricio is a registered user.

I could care less what a corporation's first, second or third choice is. We should not compromise our values and choices for the benefit of corporation portion deleted

If corporations insist on expanding operations in an area with great land scarcity and skyrocketing housing prices, it is their hubris, not my problem.

Portion deleted.

SL: Mauricio, do you not care where people want to live and work either? It seems reasonable to assume that,people want to live in the Bay Arra since they have lots of choices and pay high prices to live is easy to rant about corporations and developers, but the main choices we are dealing with is that of people who want to live here, meaning in the region. By the way Stanford and the accompanying activity and attractiveness was here long before we were.

Are you arguing that Stanford shows hubris to expand here?

Posted by mauricio, a resident of Embarcadero Oaks/Leland,
on Jun 22, 2015 at 9:35 am

mauricio is a registered user.

There are flight that have a 300 seat capacity but a few thousands people want to get on the plane. Would you let them all get on the plane just because they want to? Ever heard of saturation point, capacity? I'm all for people buying existing houses, replacing people the residents who moved out.-that's how I bought in, replacing a family that moved out of Palo Alto. I'm all for people remodeling old houses. However, we live in Palo Alto as a chosen way of life. The vision of people like you will destroy that way of life, and turn it into a very dense and urbanized place.

Portion deleted.

Posted by Gale Johnson, a resident of Adobe-Meadow,
on Jun 22, 2015 at 12:18 pm

Housing, traffic, and parking! By all means, I welcome more housing, (affordable housing) in fact enough to house all those workers who are commuting long distances. If it takes a few Channing House size buildings let's do it. They would have to be properly located tho. I don't have any particular sites in mind but I'm sure developers do. It's too bad the Registry isn't panning out because that would provide valuable information about the housing needs. But, key also, it has to be affordable. That could be the sticking point to my idea. If it won't be affordable for workers who are currently communicating long distances (talking mainly about cars) then what do we do?

But keep the cap in place. We have some catching up to do without building more offices.

Posted by Crescent Park Dad, a resident of Crescent Park,
on Jun 22, 2015 at 12:35 pm

The general consensus is that PA suffers from a office:housing imbalance. Housing on the short-end. And ABAG (I disagree with its existence) supports that POV and is mandating housing starts all over the SF Bay Area.

Yet, the pro-office crowd want to build more and more offices...which will further the imbalance.

The only real serious way to fix the imbalance in PA is to significantly slow down office expansion while allowing housing to catch up. This may take decades - but if you keep allowing office expansion in the most highly imbalanced areas, such as PA, you will never catch up.

Developers will always want to build office space ahead of housing. It's all about the profits and the office lease cash flow. I get that and I don't blame them for their business goals. But take away or significantly reduce those opportunities and the developers are either going to build elsewhere or they will look at the next great PA opportunity: housing.

And I say this...even though I'm quite skeptical of increasing housing capacity due to the often ignored issues of lack of infrastructure, school space, safety services, etc.

Posted by Gale Johnson, a resident of Adobe-Meadow,
on Jun 22, 2015 at 2:02 pm

@Crescent Park Dad

I think we are almost in violent agreement on this issue. lol. So, I'll give you a 'ditto' on it but I actually think I was the originator of these brilliant ideas we have. I've written about it on numerous occasions in previous posts. I understand your concern about infrastructure and schools, but my personal opinion is that those might not be a big issue if, and I'm guessing now, most of the renters/owners of the housing units would be singles (unwed) workers. Here again, information from the Registry would be so valuable.

And one more..and I want to take credit for this one. I've written numerous times on what owners/developers like to develop and build...offices, offices, offices! Of course they like office projects over housing and, as you pointed out, the reason is profit.

Portion deletrd

Posted by Michael, a resident of University South,
on Jun 22, 2015 at 2:54 pm

Area plans are PC zoning writ large. Phase 1 of the SOFA Plan, our only area plan to date, was written by developers and adopted whole by the city planning department right down to the developers' letter designations for the land parcels. Mayor Liz Kniss ably shepherded it through the approval process. Three years later, Mayor Dena Mossar ensured Phase 2 was structured around the infamous PC condo development at 800 High, which set Palo Alto's development pattern for the next decade. Both mayors then received substantial campaign donations from the developers they aided.

Lesson: avoid area plans.

Posted by Gale Johnson, a resident of Adobe-Meadow,
on Jun 22, 2015 at 4:18 pm

Still naive, but learning, maybe too late. Area Plans? Who initiates those? PAF, PASZ, or the real living breathing area folks they are targeting and promising to serve? I think I know.

Posted by Michael, a resident of University South,
on Jun 22, 2015 at 9:41 pm

"Area Plans? Who initiates those?"

The PA planning dept, with PACC confirmation.

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